c/EPA
        United States
        Environmental Protection
        Agency
          Office of Water
          (4503F)
          Washington, DC 20460
EPA-R-96-001
May 1996
TMDL Development Cost
Estimates: Case Studies
of 14TMDLS

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                               TABLE OF CONTENTS
PART T. STUDY OVERVIEW
  Purpose of the Study                                                                  1
  Study Approach                                                                      1
  Selection of TMDLs for Cost Estimation                                                 2
  Development of a Data and Information Collection System                                  2
  Information Collection, Case Study Development, and Follow-up                             5
  Presenting Cost Estimates in Full-time Equivalents and Dollars                               5

PART n.  COST ESTIMATION APPROACH	7
PARTm. COST SUMMARY	9

  Relationships Between Costs and TMDL Features                                          9
     Cost and In-House FTEs                                                            9
     Cost and Watershed Size                                                           12
     Cost and Model Complexity                                                        13
     Cost and Pollutants                                                               13
     Cost and Distribution of Point and Nonpoint Sources                                    13
     Cost and Public Participation                                                       14
  Examination of TMDL Costs by Component                                             14

PART TV. FINDINGS	20

  Decision Factors for Amounts Spent on TMDL Development                                20
  Relationship of TMDL to Other Water Quality Program Activities                            21
  Cost Minimization Strategies                                                          21
  Funding sources                                                                    22
  Benefits                                                                           22

PART V. FEDERAL TMDT. RESOURCES	   23

  Availability of Funding                                                              23
  TMDL Coordinators                                                                 23

PART VI.  TMPL CASE EXAMPLES	.	25

  Appoquinimink River                                                                26
  Lake Chelan                                                                        32

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

APPENDIX A	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 use 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;
   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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                      Figure 1.  TMDLs Selected for the Study
                                                                                             bbossee
                                                                                          Lake
                                                                                el. River Estuary
                                                                                ppoquinimink River
ielhn
4 S&mth Fork Salmon Rh
     V-~-
Lower Minnesbta'Tlive
                                                        \ A         J.	
                                                        I wSycXmoreJCreek
                                         Page 3

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

Level
of
Complexify
Simple
Mid-
Range
Complex
Pollutant
N
HTL
TRK

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

NH3
CHN

LMR
Metals


DEL
                                          KEY:
                  APQ = Appoquinimink River
                  CHE = Lake Chelan
                  CHN= ChenowethRun
                  COB = Cobbossee Lake
                  DEL = Delaware River Estuary
                  FLT = Flint Creek
                  HIL  = Hillsdale Lake
LDF = Little Deep Fork Creek
LMR = Lower Minnesota River
OIL  = Oil Branch Creek
SAM= South Fork Salmon River
SYC = Sycamore Creek
TRK = Truckee River
YNK= 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; USDA hydro logic 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, eliminating 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 II. 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
   Alternative
   Approach
          Obtain estimates of staff time
          necessary to complete each
       component of TMDL development
                    i
Obtain cost estimates
 including staff and
capital costs for each
component of TMDL
    development
              Obtain or estimate
            current average salary
             or hourly rate of staff
                    i
               Obtain estimate
               of staff benefits
   Use 1.25 as a
 benefits multiplier
            Obtain estimates of any
          capital or contracting costs
          and convert to 1995 dollars.
                    i
             Compute total costs
               in 1995 dollars
                                       Page?

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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-time
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.
Summing these costs yields total TMDL costs.  In the case of Lake  Chelan, level of effort was
estimated from cost estimates rather than vice versa.2
1 The 1995 figure is currently unavailable for the price index of state andjocal 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.

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


                                          PageS

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                           PART III. 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,

                                         Page 9

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Figure 4. Costs and Key Features of TMDLs
TMDL Area
Oil Branch
Creek
Yankee Hill
Lake
Cobbossee Lake
South Fork
Salmon River
Chenoweth Run
Hillsdale Lake
Appoquinimink
River
Truckee River
Sycamore Creek
Little Deep
Fork Creek
Delaware River
Estuary
Lower
Minnesota
River
Lake Chelan
Flint Creek
Cost
$4,039
$4,598
$6,057
$19,363
$19,625
$21,934
$145,527
$158,387
$202,000
$401,576
$675,426
$775,000
$993,337
$1,023,531
In-
House
FTEs
0.08
0.18
0.13
0.42
0.26
0.42
0.96
1.00
4.0
6.87
10.30
3.56
12.13
2.00
Watershed
Size (mi2)
5.0
9.4
14.9
370.0
17.0
134.5
47.0
2,300.0
37.0
240.0
>7,794.0
320.0
924.0
244.0
Model
Complexity
Simple
Simple
Simple
Mid-range
No model
Simple
Complex
Mid-range
Simple
Mid-range
Complex
Complex
Mid-range
Simple
Pollutants
Low DO
TSS, P, N
P
Sediment
P, or. phos., TDS,
TSS, BOD, NH3
P, N, chlorophyll
P, DO
N, P, TDS
Sediment
DO, TSS, P,
chlordane
Metals, toxics
CBOD, NH3
P, bacteria
Low DO
Point Sources
WWTP
None
None
None
WWTP, light
industry
WWTPs, res.
lagoons, quarry
WWTP
Wastewater
reclam. facility
N/A
WWTPs, storm
sewers
83 industrial or
municipal
facilities
WWTPs
Salmon pens
WWTPs
Nonpoint Sources
N/A
Agriculture, residential
Agriculture
Silviculture, logging
roads, erosion
Urban, pasture
Agriculture
Agriculture
Agriculture
Agriculture
Agriculture, surface
runoff, petroleum
activities
Runoff, agriculture,
CSOs, ground water
infiltration, atmospheric
deposition
Agriculture, residential,
commercial
Stormwater, forest, &
agricultural runoff;
ground water inflows,
tributaries, septic systems
Agriculture
Public
Partic.
none
none
none
<$5,000
<$5,000
<$5,000
<$5,000
>$5,000
none
>$5,000
>$5,000
none
>$5,000
<$5,000
Page
No.
89
113
44
93
39
67
26
105
98
74
50
84
32
60

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                                          Figure 5.  Total Cost for Each TMDL to Date
   $1,200,000  T
   $1,000,000  -
     $800,000  -
 8   $600,000  --
u
    $400,000  --
    $200,000  -
           $0
                                                                                                         $993,2
                $4,039   $4,598  $6,057  $19>363  $19>625 $21,934
 o



PQ
i—H

O
                         i i

                         a
                         CD
                                 
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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
O
U
o
60
e
h-1
75
I
es
            14.0 ' '

            13.0 • -
       JR   12.01
            ii.o--

            10.0 - -

             9.0"

             8.0"

             7.0"

             6.0 "

             5.0
                -t-
-t-
        0.0      1.0     2.0     3.0     4.0     5.0     6.0    7.0     8.0
                     Natural Log of Watershed Size (Square Miles)
                                                                                  9.0
3 The compression of scale caused by taking natural logs eliminates outlyer effects that distort the relationship
between actual values of cost and size. Other functional forms also can be used to express the relationship between
cost and size, but this nonlinear relationship appears appropriate as evidenced by the graph.
                                           Page 12

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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 Creek and Flint Creek.  Both of these
relatively expensive TMDL efforts used simple models.  They incurred higher costs for other
(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




>r>
o\
i— (
Average Cost (


$500,000 -
$450,000 -
$400,000 '
$350,000 -
$300,000 '
$250,000 '
$200,000 '
$150,000 '
$100,000 -
$50,000 -
(prv -








                                                           $468,260 (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.  Their
       categories were adjusted to fit the five standard categories as follows:

           Appoquinimink Categories                       Standard Categories
           Planning/Administration                  -»•     Administration
           Preliminary Assessment                   -»•     Analysis
           Data Collection                         -»•     Data Collection and Monitoring
           Modeling Strategy and Model Development  -*•     Modeling
           Public Participation                      -»•     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
      the Lower 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.
                                        Page 14

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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 Sb and 9. For example,
       in Figure Sb, 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 SO percent of
       the  total  cost  of  the TMDL.   In fact modeling and  data collection  constitute
       approximately SO percent of the total cost.
       Figures Sa and Sb 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 mat cost categories are not
directly comparable.  It  is likely that bom of these  factors  account for the wide s\\ings  in
expenditures among components. Figure 9 points out these variations more clearly than Figures
Sa and Sb.  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 man 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 tin's point more
clearly.
                                        Page 15

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                                 Figure 8a. Costs ofTMDLs Less Than $25,000, by Component
     $25,000
     $20,000
     $15,000
s
u
     $10,000
      $5,000
          $0
• Administration
D Outreach & Pub. Partic.
ID Analysis
D Modeling
• Data Coll. & Monitoring
                  Oil Branch
            Yankee
             Hill
Cobbossee
S. Fork
Salmon
Chenoweth
Hillsdale
  Lake
                                                              TMDLs

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                               Figure 8b,  Costs ofTMDLs Greater Than $25,000, by Component
    $1,200,000
    $1,000,000
      $800,000
8     $600,000
      $400,000
      $200,000
            $0
• Administration
D Outreach & Pub. Partic.
DD Analysis
D Modeling
• Data Coll. & Monitoring
                                                                                                 u
                                                                                                  
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Figure 9. Component Costs ofTMDLs, as a Percentage of Total Cost
3
o
CM
O
DJD
a
a
                                                                             • Administration
                                                                             D Outreach & Pub. Partic.
                                                                             O Analysis
                                                                             EJ Modeling
                                                                             • Data Coll. & Monitoring
       TMDLs (in order of least to most expensive)

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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%   Jllllllllllllllllllk  V^^^^^A Data Coll. &
                                                               Monitoring
                                                                 40%
                               Modeling
                                32%
                                          Page 19

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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.
                                        Page 20

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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 hi conducting certain
TMDL activities, resulting in less attention to and spending on those activities.
       Leveraging resources   both financial and in-kind sendees   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 \\iih 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.
                                        Page 21

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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.
                                        Page 22

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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 Voorhees
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 (3WM12)
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, EL  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
                                      Page 23

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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
                                     Page 24

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PART VI. TMDL CASE EXAMPLES
        APPOQUINIMINK RIVER



           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:
 Poantairt(s):
 Sources of Pollutants:
Model Use and Complexity:


Total Cost
Funding Sources:
Appoquinonink River-
New Castle County., northeastern. Delaware; USEPA Region JJL
5.2 mile tidal freshwater river segment; 47 square mile watershed.
Small; 
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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
0,0, 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
time 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
                                     Page 27

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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.
    •   Planmng/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.
                                     Page 28

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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.
            Planning/Administration for the Appoquinimink River TMDL
                                       Cost                   Funding Sourcefs)
           0.08                "       $6,875                       State
       Costs associated with planning and administration reflect staff time for various
meetings.  These meetings included:  (1) discussions with officials at the wastewater
treatment plant regarding options for attaining water quality standards; (2) meetings with
soil conservation districts and other agricultural support groups to discuss the benefits of
BMPs; and (3) internal planning sessions.  Additional costs were incurred for staff time to
conduct scheduling and other general administrative activities. Costs for these activities
are computed as the equivalent of one senior engineer working for one month over a two-
year period.  The state, through DNREC's  budget, paid all  of the planning and
administritive costs.  This staff time translates into a cost of $6,875.
            Preliminary Assessment far the Appoquinimink River TMDL
       fa-home FTE&                    Cost      .    .         Funding Source(s)
           0.33                       $25,000	•-       State
       All of the costs for preliminary assessment are associated with DNREC staff time.
DNREC dedicated the equivalent of one engineer working for four months to complete
the preliminary assessment.  This staff time translates into a cost of $25,000, which was
paid by the state.

       DNREC began its assessment of water quality by compiling all readily available
and existing information.  Spatial  and temporal trends in ambient water quality were
evaluated and descriptive statistics were produced. The data were then compared against
applicable water quality criteria to identify pollutants/stressors of concern and regions of
impact. Data gaps were also identified.
                                     Page 29

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J>ata C0Ue
In-house FTEs
0,26
ction far the App&qumimink River TMDt *
Cost Funding Sourcefs)
$49,381* State and ioca.1
       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 Appoquinimink River TMDL
       In-house FTEs                    Cost                   Bunding Someefe)
           0.02                      $43,9172                  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
 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.
                Model Testing for tfte Appoqumimink River TMJDL
       In-house FTEs                   Cost                 Funding Sourcefe)
           0.21	          ,     $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 far the Appoquinimink River TMDL
SlAouse FTEs Cost Funding Source(V)
0.06
$4327 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 the 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 Elings Highway
P.O. Box 1401
Dover, Delaware 19903
Phone (302) 739-4590
Fax (302) 739-6140
                                    Page 31

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                      LAKE CHELAN, WASHINGTON

 Key Features
 Title:                          LakeCfaelan.
 Location:                      Chelan County; Northern Cascades; north-central Washington;
                               USEPA Region X.                 - -
 Size/Scope:                    52 square mile lake; 924 square mile watershed.
 Comparative Size:              Medium, 
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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 $60,000 to assist with the
TMDL for Lake Chelan.
Table 2, Summary of TMDL Costs for Lake Chelan
Activity
Data Collection/Monitoring/Modeling
Analysis
Public Participation/Outreach
Administration
TOTAL
FTEs*
7.32
1.20
2.65
0.96
12.13
Cost ($)
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.  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.

       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 CQUectivn/MomtoringfMvaenngfor the Lake Chelan TMDL
        In-faouseFTEs    -                Cost                  Funding Sourcefst
	7.32  -	$813,245	State and 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 services 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  basin; 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.
In-hoase FTEs
1.20
Analysis for the Lake Chelan TMDL
Cost
$44,890
Funding Sourcefs)
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 Chelan TMDL
       In-house FTEs       .             Cogt           .        Funding goHrce(s)
           2.65	 	$99,222               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,  hi 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; stormwater  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.
                    Administration for the Lake Chelan TMDL
       In-hoitseFTEs                    Cost                   Funding Source(s)
           0.96                       $35,980                      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
Tide:                          Chenoweth Run.
Location:                      Jefferson County, north central Kentucky; USEPA Region IV.
Size/Scope:                     8.5 mile creek; 17 square mile watershed.
Comparative Size:              Small <100 mi2.
Pollotant(s):                    Phosphorus* orthophosphate, suspended-solids^ unionized
                               ammonia, and BOP.
Sources Of Pollutants :           Point sources—wastewater treatment plant, light industries,
                               Nonpoint sources—urban runoff, pasture lands.
Model Use and Complexity:      No model.
Total Cost                     $19,625 current; $35,000 anticipated cumulative.
Funding Sources:       "       EPA nonpoint source TMDL Mini-Grant; State general revenuesj
                               Funding from 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 Jeffersontbwn 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 g****
 *1 FTE (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 in 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:
    •  Monitoring/Data 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/Data Collection far the Chenoweth Run TMDL
       Jn-hQUS&FTBs     ,               Cost                  Funding Souraefs.)
           O.&g                       $12,500	Federal and 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 the 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.1
                     Modeling far the Chenvweth Run TMDL
        In-hoQseFTEs                    Cost                  Funding Sovnrcefa)
           0.00         '               $0                        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.
Anai
In-house FTEs
0.15
'ysisfor the Chenoweth Run
Cost
$6,000
TMDL
Funding Source(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 and Public Participation far the Chenoweth Run TM&L
In-house FTEs Cost Funding Sonrcefe)
0,01
$375 ' 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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                  Administratwn for the Chenoweth Run TMDL
       la-houseFTEs                   Cost "                 Funding
           0,02 "                      $750               '   FederalajidState.
       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:

Dave Leist
Department of Environmental Protection
Division of Water
Frankfort Office Park
14 Reilly Road
Frankfort, Kentucky 40601
Phone (502) 564-3410
Fax (502)  564-4245
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                        COBBOSSEE LAKE, MAINE

 Key Features
Title:                          Cobbossee Lake.
Location:                      Kennebec County, southern Maine; USEPA Region I.
Size/Scope:                     Affected watershed 14.86 mi2.
Comparative Size:              Small, <100 mi2.
Pollutant(s):                    Phosphorus,
Sources of Pollutants:           Nonpoint sources—numerous return Sows associated ^vith area
                               agricultural activities,
Model Use and Complexity:      Empirical models developed by Vollenweider (1969), and
                               modified by Dillon andRigler (1974) were used to run simple
                               simulations of the lake and to determine pollutant loading,
Total Cost                     $6,057.
Funding Sources:               Federal Clean Water Act TMDL 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 Jhe
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 hi 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  lihe
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 capital,  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 qf
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 propagation 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 $12,000 to  assist with its Cobbossee Lake TMDL activities.
This grant covered all TMDL development expenditures to date.
Table 4. Summary of Cobbossee Lake TMDL Costs
ACTIVITY
Monitoring/Data Collection
Modeling
Analysis
Outreach
Formal Public Participation
Administration
TOTAL
CWDFTEs
0.03
0.02
0.05
0.00
0.00
0.03
0.13
Cost ($)
1,369
938
2,344
0
0
1,406
6,057
Cost as % of Total
22.6
15.4
38.6
0.0
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.  In  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. With 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 evolving 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/D&te Collection Costs for the Cobbossee LaKe TMDL
       Iri-bouseFTEs                    Cost            '      Funding Scmrcefs)
                                      $1,36$ '                    .Federal
       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 time
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
       Jn-hoBse FTEs                    Cost                  Funding SoTirce(s)
           &.&2            -            $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 GPA 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 phosphonis 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.
In-housg FIEs
0,05
Analysis Costs for the Cobbossee Lake
Costs
$2,344
TMDL
Funding Sourcefs)
Federal
       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 Cobbossee Lake TMDL
       In-house FTEs                     Cost                   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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              Public Participation Costs far the Cobbossee lake TMDL
        In-hopseFTEs                    Cost              ,    Funding Sourcefs^
	0	$0	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.
                Administration Costs for the Cobbossee Lake TMDL
        In-house FTEs                    Cost                   Funding Sourcefe)
	Q.Q3	$1,406	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:

 Bill Monagle
 Cobbossee Watershed District
 P.O. Box 418
 Winthrop, 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:
PoUntant(s):
Sources of Pollutants:
Model Use and Complexity:
Total Cost
Funding Sources:
Delaware River Estuary,
Eastern Delaware; west and southeast New Jersey; southeastern.
Pennsylvania; within USEPA Regions II & HI.
Surface water segment £4 miles. Affected watershed drainage
area >7J94 mi2,
Large; > 1,000 mi2.
Metals, approximately ten toxics (bio-organics, PCBs, DDT),
Point sources—83 industrial or municipal facilities {110 outfalls).
The wasteload aHoeations (WLAs) developed for up to ten toxic
pollutants will be translated into effluent limitations for toxic  ,
pollutants for selected National Pollution Discharge Elimination
System (NPDES) dischargers to the estuary,
Nonpoint sources—stormwater runoff from urban, agricultural  ,
and industrial areas; groundwater infiltration and: runoff from
Superfund sites; atmospheric deposition; combined sewer
overflows (CSOs); groundwater infiltration and natural       '  .
background. Load allocations will be developed during Phase EL
of the TMDL development process.
EPA's WASP4 water quality model and the DYNHYD5
hydrodynamic submodel were used to run complex simulations of
river and pollution, processes and develop WLAs for human health
and chronic aquatic life criteria. Tidal CORMIX, a near-field
model which utilizes a modified version of an EPA-supplied
model, was used to develop WLAs for modeling acute criteria.
DELTOX, a far-field model, was also used to develop WLAs for
toxics.
$675,426.
Federal Clean Water Act Section 20S(j) and S&ction 106 grants;
State (DE,NJ, NY, PA) general revenues; Delaware National
Estuary 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; and 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 II 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 205(j) grants
NJDEP 205(j) 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
100.2****
*Includes lab-related costs
**Includes capital costs for computers
***Includes 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,  hi addition, whenever possible,
DRBC used available water quality data.  For 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 and 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 II.


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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       Monitoring/Data Collection Cmtsfvr the Delaware River Estuary TMDL
        In-house FTEs                     Cost                   Funding Sourcefe)
            2.5      -      .           S278J333         -      Federal, Stale, 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 Estnary TMDL
        In-faousg FTEs                    Cost                   Furtdmg Sourcefe)
            2.8      -                 $122,103"               Federal, State, and Local
       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 (DYNHYD5)  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
 Costs computed as 1 senior staff working 0.8 years x $60,000 average annual salary including indirect
costs = $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-supported DYNHYD5 and  WASP4 models for  the  tidal Delaware River.
Additionally, DRBC utilized consultants for sample collection 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 life 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 toxiciry,  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.
                Analysis Costs far the Delaware River Estuary TM1>L
        in-house FTEs                   Costs                  Funding Source(s)
            2.9	-     	SUT.OQQ5	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.
5 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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                Outreach Costs for the Delaware River Estuary TMJ>1<
        in-house FTEs                    Cost                   Funding Sourcefe)
            OJ                        $8,6'936                Federal, State, and Local
       To coordinate multi-agency interests, DRBC organized numerous committees and
 sub-committees 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 far the Delaware River Estuary TMDL
        in-house FTEs                -    Cost                   Funding Source(s)
            0.25                      $!5,0007               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.
6
 Costs computed as 1 senior staff working 0.1 years x $60,000 average annual salary including indirect
costs = $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 the Delaware River Estuary TM&L
        In-house FTEs                     Cost         ,          Funding Sourcefs)
            1,75	$105>OOQS               Federal, State, and 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
8 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®:
 Sources of Pollutants:
 Model Use and Complexity:


 Total Cost
 Funding Sources:
Flint Creek.
North central Alabama; USEPA Region IV.
Creek watershed 244 mi2,
Medium, <10QQrai2,
Dissolved oxygen.
Point sources—two Avastewater treatment plants ^WWTPs) one
each for the Cities of Hartselle and Falkville*
Nonpoint sources—numerous agricultural
Watershed Screening and Targeting Tool (WSTT); modified
Streeter-Phelps models; and QUAL2E were used to run simple
simulations of river and pollution processes.
$1,023,531.
Federal Clean Water Act Section 319 and nonpoint source TMDL
Mini-Grants, 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. In 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.  In 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  fully 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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               ,Dnta CoJlectwit/Mamtoringfor the Flint Creek TMDL
           PTEs                        Cost                  Funding Sourcefs)
           6,52  ,                 '   $500,662                Federal and State
       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,
 ADEM 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.

       In 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.
'
FTEs
too
Modeling for the Flint Creek TMDl
Cost '
$55,000

Funding Source(s)
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 Terra Tech for use in 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 the  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 for the Flint Creek TMDL
           FTEs                       £o§t                  Funding Source(s>
           7,00                     S415.207                 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, Tetra 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  information  will  be used  to estimate in-stream  DO
 concentrations at different locations along the creek.
                       Outreach for the Flint Creek TMDL

           FTEs                       Cost                  Funding Sourcefe)
           0.04                       $1,875                      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
0,02
Cost
$1,731
Funding Scmrcefs.)
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 TV A 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.
FTEs
1.14
Administration for the Flint Creek TMJXL
' . Cost
$49,056
Funding Sourcefe)
Federal and 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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                        fflLLSDALE LAKE, KANSAS
Key Features
Title:
Location:
Size/Scope:
Comparative Size:
Pollutant^):
Sources of Pollutants:
Model Use and Complexity:


Total Cost
Funding Sources:
Hfllsdale Lake.
Miami County, eastemKansas; USEPA Region VH.
134.5 square mile watershed.
Medium, <10QO mi2.
Phosphorus, nitrogen* and chlorophyll-a.
Point sources—Gardner wastewater treatment plant (WWTP);
Edgerton WWTP; Johnson County Air Industrial Park WWTP;
Connestoga Mobile Home Park Lagoon; Lone Elm Estates
Lagoon; and Edgerton Quarry Pond Discharge,
Nonpoint sources—widespread agricultural fields andanimal
holding areas,
EUTROM0D 2.50 developed specifically for use in lake
eutrophication management was used to run simple simulations of
the lake and pollution processes.
$21,934.
EPA Clean Water Act Section 104 (b) (3) nonpointsour^e.TMDL
mini-grant; and State general revenues.
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,  hi 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 $10,000 to develop the TMDL for Hillsdale Lake. State general revenues
supplied additional funds for salaries, monitoring,  data collection, nonpoint source load
assessments, model calibration, and other activities.
1
Table 7. Summary of TMDL Costs for Hillsdale Lake
Activity
Monitoring/Data Collection
Modeling
Analysis
Outreach/Public Participation
Administration* * *
TOTAL
KDHE FTEs*
0.08
0.30
0.04
0.00
0.00
0.42 -
Cost ($)
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 also  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 hi 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,   hi 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 Collection far the Hillsdale Lake TMDL
        in-house TTEs                    Cost                   Fundmg Sourcefs)
           0.08                       $6,642                      .State
       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.
                      Meddling for the HHlstfate Lake TMDL
       la-hoBseFTEs      '              Cost                  Funding SoTircefs)
          '  0,3               '    '"   $13,478                 Federal and State
       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,  hi 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
loading 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 in 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.                                                             .
ln»house FTEs
0.04
Analysis for the Hittsdale Lake TMDL
Cost
, $1,728
Funding Sourceffi
Slate
       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 Hillsdale Lake TMDL
       In-house FTEs                     Cost                   Funding Sonrcefe)
           0.002                        $86                        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 Hillsdale Lake TMDL
       la-hotts&FI'Es  ,                  Cost                   Funding Source(s)
          indirect                     indirect    ,              Federal aad. State
       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 other 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 20% 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                                                                             Co
Kansas Department of Health and Environment                                             £lj
Science and Standards Section                                                          ,O
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:
Little Deep Fork Creek
Central Oklahoma; City of Bristowand Town of Depew; USEPA
Region VI.
Affected watershed 240 mi2.
Medium, ^1000 mi2.
Low dissolved oxygen, suspended solids, phosphorus, chlordane,
and turbidity.
Point sources include: two WWTP$ one each for fhe City of
Bristowand Town of Depew andnumerous storm sewers.
Nonpoint sources include: surface runoff, pefroleum activities,
non-irrigated crop production* specialty crops, pasture land and
range land.
QUAL2EU a one-dimensional steady-state model was used to fun
mid-range <»rnplexity simulations of river and pollution processes.
$401,576.
Federal Section 319{a), Section 604(b), and Section 104
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       As illustrated in Table 8, INCOG and OCC's total in-house effort on the Little
Deep Fork Creek TMDL is estimated to  be 6.87  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 as 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 nonpoint 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,   hi  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 fully 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/OCC FTEs
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,   hi 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.
         Monitoring/Data Collection for the LMe Deep Fork Creek TMDL
           FTEs                       Cost                   Funding Sourcefs)
           2.26                      $204,720                 Federal and State
       In 1989, 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.
Modeling for the Little Deep Fork Creek TM&L
FTEs " Cost Funding Sourcefel
0.23
$40,758 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.
                                                                       i
       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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A&afysl
FTEs
0.11
t for the Little Deep Fork Creek TMDL
Cost Funding $otirce(Vy
$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 time 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 Fork
In-house FTEs Cost
2.6 $85,275
Creek TMDL
Funding Sourcefs)
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 (0.10 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 the Little Deep Fork Creek TMDL
           FTEs  -                      Cost                  Funding Sourcefs/t
            U6	       $36,124                 FederaUtid 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.
Administra
FTEs
0.51
tfion far the Little Deep Fork Creek TMDL
Cost Funding Sourcefs)
$26,705 Federal and State
       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
STORE!  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@compuserve.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:                          Lower Minnesota. Rivet.
 Location:                      Southern Minnesota; USEPA Region V.
 Size/Scope:            '         25 mile river segment; 320 square mile drainage; area.
 Comparative Size:              Medium, ^1000 mi2.'
 PoUutant(s):                    Carbonaceous biochemical oxygen demand {CBOD} and
                              , ammonia*
 Sources of Pollutants:           Point sources—Blue Lake WWTP and Seneca WWTP.
                               Nonpoint sources—agriculture and residential and commercial
                               development
 Model Use and Complexity;      The RMA-12 model was used to run complex simulations of river
                               and pollution processes.
 Total Cost                     $775,000.
 Funding Sources:               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 hi 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.
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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
their 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 Collection for the Lower Minnesota JRiver TMDL
       In-faouseFTEs                    Cost   -                Funding Source(s)
           0,40                      $621,000              State, Local, and Federal
       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 Council would have conducted this
monitoring in the absence of the TMDL.

       MPCA'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 TMJ>L
       Ih-faouse FTHs                   Cost                  Funding Soufcefs)
           2.83         "              $i3&,000               Stats, Local, and Federal
       In 1985, MPCA used RMA-12, a derivative of the Qual II model, to determine
waste load allocations for the lower Minnesota.  At the time 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 far the JLower Minnesota River TMD1*
      '  In-hoaseFTEs                    Cost                  Funding Source(s)
	0.35	-	$1^000	State, Local, and 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
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                   OIL BRANCH CREEK, OKLAHOMA
Key Features
Title:
Location:
Size/Scope:
Comparative Size:
Pollutantfs):
Sources of Pollutants:
Model Use and Complexity:

Total Cost
Funding Sources:
Oil Branch Creek.
City of Heavener, southeastern Oklahoma; USEPA Region VI-
                             *
5 square mile watershed,      :
Small, <;1QO mi2. -
                                               i
Low dissolved oxygen.
Point sources—City of Heayener •wastewater treatment plant
Nonpoint sources—Pasture tends (No TMDL activities were
conducted for nonpoint sourcesi).
Simple model developed on spreadsheet software for personal
computers.
$4,039.
State 106 revenues, which ODBQ receives from EPA, 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 process 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, and 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/Data Collection for the Oil Branch Creek TMDL
     In-house FTEs              Cost                     Ponding Source(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
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           SOUTH FORK OF THE SALMON RIVER, IDAHO

Key Features
Title:                          South Fork of the Salmon Rivet.
Location:                      Central Idaho- USBPA Region X.
Size/Scope:                     River fork; 370 square mile watershed.
Comparative Size:              Medium, <10GO mi2.
Poilutant(s):     '               Sedroenl
Sources of Pollutants:           point sources—None.
                               Nonpoint sources—Silviculture., logging road$> and natural
                               erosion.
Model Use and Complexity:      Rigorous, localized calculations, as well as the mid-tange BOISED
                               model were used to simulate river and sedimentation processes.
Total Cost                     $19,363.
Funding Sourcesi               The State operating budget provided funding for all of the costs,
                               although Federal agencies did support Ihe TMDL 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 in 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 in 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, TDEQ used available resources, data,
and the expertise of experienced staff to make decisions efficiently.
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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 for the South Fork Salmon River TMDL
In-house TTBs Cast Fundine SourcefV)
• '0.10
$4,062 Slate
       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.
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                 Modeling for the South Fork Salman River
       in-house FTEs                    Cost                   Funding Source(s)
           0.08        '               $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.
                 Analysts for the South Fork Salmon River TMDL
       Iri-noase FTEs                    Cost                  Funding Sourceffi
           0.06                       $2,818                       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.
          Work Group Negotiation for the South Fork Salmon River TMDL
                                      Cost                  Funding Soureefs;)
                                      $939                      State
       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 Pftrtwpatiimfor the Smith Fork Salmon River TMDL
        In-faoBse FTEs        ^            Cost                  Funding Source(s;>
            0.08	:	$3,412	'	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
        ln-hoa$fe FTEs    '                Cost                  Funding Soureefe)
	0.08	$3,732	    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
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                     SYCAMORE CREEK, MICHIGAN

 Key Features
 Title:                          Sycamore Creek.
 Location:           ,           Ingham County; southern Michigan; USEPA Region V.
 Size/Scope:                    Total affected watershed 106 mi2; subwatershed 3 7 ml2.
 Comparative Size:              Small; £100 mi2,
 PoUutant(s):                   Sediment.
 Sources of Pollutants:           Nonpoint sources—agricultural erosion, stream bank erosion, and
                               xirban runoff- Three load allocations (LAs) developed,
 Model tJse and Complexity:      A simple quasi steady state DO model (O'Conner and DiToro,
                               1970) was used to predict DO concentrations in the Creek Airing
                               drought conditions.
 Total Cast                     $202,000.
 Funding Sources:               State general revenues.
 Summary

       In 1992, the Michigan Department of Natural Resources (MDNR) initiated Phase
 I of a TMDL for Sycamore Creek to address high levels of oxygen demanding substances
 causing decreased dissolved oxygen (DO) levels in the Creek.  A primary objective of the
 TMDL was conducting an assessment of demand sources and their impact  on water
 quality, particularly sediment oxygen demand (SOD) under drought conditions. A 1989
 biological survey of the Sycamore Creek watershed indicated that the  creek was not
 meeting its designated uses, impairing fish and macroinvertebrate communities.

       Designated uses  of the TMDL segment of the creek include:  support  of warm-
 water  fish; support of other indigenous aquatic life and  wildlife;  total body contact
 recreation; navigation; and industrial and agricultural water supply. Sycamore Creek is a
 small,  warm-water stream and is a tributary of the Red Cedar River.  The Red Cedar
 River flows into the Grand River, which flows into Lake Michigan.  The topography of
 the stream is  varied,  ranging  from gently rolling  hills to primarily flat plains.  The
 Sycamore Creek watershed drains  approximately 106 square miles, but  TMDL related
 activities have focused on a 37 square mile subsection.

       Approximately 52 percent (35,453 acres) of the  67,738 acre watershed are used
for  agriculture,  including  croplands  and  pasturelands.    Residential/commercial
development,  business/industrial development, forestlands, wetlands,  idle  agricultural
lands, open land, transportation corridors, and gravel pits and wells are the other primary
features of the watershed.  Primary  sources of sediment loading are stream bank erosion,
agricultural erosion and urban runoff.   While  there  are no industrial point source
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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
oy
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
9 Due to the inseparability of public participation/outreach costs from other TMDL activities, the cost is
recorded as $0.
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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 III (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
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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 for the Sycamore Creek TMDL
In-house FTBs Cost Fundinfir Soimiefsl
12
$111,000 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 as 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
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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 for the Sycamore Creek TMDL
       In-house FTEs                     Cost       '            Funding Sourcefe)
            ft.9                       $46,000	:	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 Creek TMDL
in-faoaseFTEs
0,7
Costs
$34,000
Funding Sourcefs)
State
       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 Fnbttc Participation Costs for the Sycamore Creek TMDL
       In-hooseFTEs                    Cost                   Funding Source(s)
                                       $Q'°                   Federal and Local
       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 USDA; and the USEPA.
                Administration Costs for the Sycamore Creek TMDL
       In-house FTEs       .              Cost                  Funding Sourcefs)
            0.2    .                   $11,000                      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:
Sources of Pollutants:
Model Use and Complexity:

Total Cost
Funding Sources:
Truckee River,
East-central California/Western Nevada; USEPA Region IX.*
Affected watershed 2,300 rat2.
Large, > 1000 mi*
                                        /
Nitrogen, phosphorus, total dissolved solids.
Point sources—one discharger Trnckee Meadows Wastewater
Reclamation Facility* Three wasteload allocations (WLAs) were
developed.
Konpoint sources—jmmerous irrigation return flows associated
with area agricultural activities. Three load allocations (LAs) were
developed.
1>SSAM in was used to run mid-range simulations of river and
pollution processes,
$158,387.
Clean Water Act 
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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  the 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 205 (j)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)0) 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
90, 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) inter-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 sources 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;
    •  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 Trwkze River TMDL
       In-house FTEs                     Cost                  Funding Sotirce(sj
           0,55                       $25,200               Federal, State, and Local
       The  Truckee Meadows Wastewater Reclamation Facility (TMWRF) and  the
Desert Research Institute (DRI) conducted the majority of water quality monitoring for
TMDL development.   TMWRF,  the  sole major point source discharger, regularly
conducts monitoring as  a requirement of their NPDES permit.  DRI monitors the river
monthly as  part of Nevada's customary ambient water quality monitoring activities.
Beyond  such routine  monthly sampling, TMWRF,  NDEP,  and  Washoe  County
incorporated intensive sampling to support model development.  This sampling involved
following the same parcel of water downstream and collecting samples every four hours
for 24 hours at each site.

       A multi-agency  data collection team initially conducted intensive sampling in
1988, the year advanced (tertiary)  treatment processes were  installed at TMWRF, and
again in 1989, to collect data during different river  flow conditions. This effort involved
four staff from NDEP, and a similar number from Washoe County and the City of Reno.
Eight staff conducted monitoring and data collection activities, 12 hours per day for eight
days. Finally, the team conducted intensive sampling three times in 1993 to refine model
development.  In this case, eight staff conducted monitoring and data collection activities
on three separate occasions, working for four days, a total of eight hours each day.  NDEP
plans to continue monitoring the Truckee River.

       Only half  of the stated costs were incurred by NDEP; the city and  county
contributed half of the staff and incurred associated costs.  The staff time translates into a
cost of $25,200.  TMWRF provided laboratory analysis of the samples.
                    Modeling Costs far the Truckee River TMDL
       In-house FTEs                     Cost                   Funding Soufce(g)
             *	$109,778	Federal, State, and Local
* Because modeling activities were conducted by a consultant, total FTE costs are not calculated.

       Modeling efforts for TMDL development on the Truckee River have varied over
time to account for changes in the river as well as the region.  The Truckee is a managed
or "flow regulated" waterbody.  As a result, the model has been adjusted repeatedly to
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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 El (DSSAM ET) 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 m 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 m. 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."
                    Analysis Costs far the Twckee River TMDL
        In-house FTEs                    Costs                   Funding Sourcefs)
            0.17                        $7,576                       State
       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 of 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.
                    Outreach Costs for the Truckee River TMDL
        Tn-house FTEs                    Cost                   Funding Sourc6(s)
            0.19                       $10,707                       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 Costs for the Tmekee River TMDL
        In-faoBse FTEs                    Cost                   Funding Sourcefe)
           0.02                       $1,009                       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 public 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 Costs for the Truckee River TMDL
                                      .Cost             .     Funding Sourcefe)
           0,08  >                     $4,11?                       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 tune 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
Title:
Location:
Size/Scope:
Comparative Size:
Sources of Pollutants:
Model Use and Complexity:
Total Cost
Funding Sources:
Yankee Hill Lake,
Southeastern Nebraska; USEPA Region VDL
9A square mile watershed.
Small, ^100 mi*
Suspended solids, phosphorus, and nitrogen.
Point sources—none,
Honpoint sources—agriculturaHaads'and rural residential areas.
AGNPS is the noapoint source loading model andEUTROMOD is
flie receiving water quality model. These models are relatively
simple.   >
$4,598 to date, plus $5,402 to cover ongoing monitoiing and
analysis efforts.
EPA nonpoint source TMDL 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 obj ectives 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 Collection far the Yankee Hill lake TMDl
        In-tio-BS&FTEs t                   Cost                  Funding Source(s)
            •0<10	•_       $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 Hffl Lake TMDL
        In-house FTEs                    Cost                  Ponding Sonrcefe)
            0.02             .           $465                   EPA 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.
                     Analysis for the Yankee Hilt Lake TMDL
                                       Cost                  Funding Source(s)
            0.03                        $952               ,    EPA Mini-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 the Yankee Hill Lake TMDL
        In-fatmse FTEs                    Cost                  Funding Sourcefs)
	0.05	$952	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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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 Collection 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)

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

Total Time

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 FTEs 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
$»
$$,000







Fiscal
Year
1991
$10,000
$8,000







Fiscal
Year
1992
$15,000
$9,500







Fiscal
Year
1993
$c
$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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