EVALUATING OPTIONS FOR
      DOCUMENTING
INCREMENTAL IMPROVEMENT
   OF IMPAIRED WATERS
 UNDER THE TMDL PROGRAM
 ^.-. -
          I M' of ltl.i|.i»iciil InFormarlnn to
          I in I), -i-iiiilol AqUHllr I ifr I u-s in
          Statr *nil Trlhal \\atn
          Available August 2005
    -

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Documenting Incremental Improvement                         November 30, 2008
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                                        11

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Documenting Incremental Improvement                   November 30, 2008
      EVALUATING OPTIONS FOR DOCUMENTING
INCREMENTAL IMPROVEMENT OF IMPAIRED WATERS
              UNDER THE TMDL PROGRAM
                         November 30, 2008
                       Watershed Branch (4503T)
                 Office of Wetlands, Oceans, and Watersheds
                   U.S. Environmental Protection Agency
                       1200 Pennsylvania Ave. NW
                       Washington, D.C. 20460

              Document posted at: http://www.epa.gov/owow/tmdl/
                               in

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Documenting Incremental Improvement                           November 30, 2008
Acknowledgements:

This report was developed for the U.S. Environmental Protection Agency's Office of Wetlands,
Oceans, and Watersheds under EPA Contract No. 68-C-04-006, as a product of the TMDL
Program Results Analysis Project.

The authors are Chris O. Yoder,  Principal Investigator at the Midwest Biodiversity Institute,
Center for Applied Bioassessment and Biocriteria, and Edward T. Rankin, Senior Research
Associate from Ohio University, Voinovich School for Leadership and Public Affairs. Douglas J.
Norton served as the EPA Work Assignment Manager.
This publication should be cited as:

Yoder, C.O. and Rankin, E.T. 2008. Evaluating Options for Documenting Incremental
Improvement of Impaired Waters Under the TMDL Program. Prepared under Contract 68-C-
04-006 for the US Environmental Protection Agency, Office of Wetlands, Oceans and
Watersheds, Washington, DC.  28 pp.
                                           IV

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                                   INTRODUCTION

The Midwest Biodiversity Institute was tasked by EPA to develop and evaluate options for
identifying incremental improvement in impaired waters based on biological, chemical and
physical monitoring methods, and data interpretation methods currently in use among (or
available to) state and regional water programs. This report is the principal product of a detailed
work plan that was approved as work assignment 4-68 (WA 4-68) under HECD contract 68-C-04-
006 in December 2007.  The primary goal of this report is to document working examples of
detecting and quantifying incremental improvement and to summarize the key concepts and
methods into a consistent framework.

What is Incremental Improvement?
Incremental improvement is defined here to represent a measurable and technically defensible,
positive change in the condition of an impaired water body within which an improvement has
been measured, but which does not yet fully meet all applicable water quality standards (WQS).
The general principles of this investigation are defined as follows:

    • measurement of incremental improvement can be accomplished in different ways, provided
       the measurement method is scientifically sound, appropriately used, and sufficiently
       sensitive enough to generate data from which signal can be discerned from noise;

    • measurable parameters and indicators of incremental improvement may include biological,
       chemical, and physical properties or attributes of an aquatic ecosystem that can be used to
       reliably indicate a change in condition; and,

    • a positive change in condition means a  measurable improvement that is related to a
       reduction in a specific pollutant load,  a reduction in total number of impairment causes, a
       reduction in an accepted non-pollutant measure of degradation, or an increase in an
       accepted measure of waterbody condition relevant to designated use support.

EPA Program Issues
A protocol for the documentation of incremental improvements in impaired waters is a major
need of the TMDL program and other surface water protection programs.  The evaluation of
program success has almost exclusively focused on the full restoration of listed impairments.
While this seems a straightforward process based on the removal of all impairment causes and
meeting all WQS, it is presently difficult to account for improvements that have occurred as a
result of TMDL based restoration actions, but do not yet meet all WQS. This can result in the
perception that the program seems staked to an "all or nothing" end result with no recognition of
any positive movement towards full attainment of WQS. Furthermore, failing to recognize that
waters are improving and are on a positive trajectory can lead to erroneous conclusions about the
attainability of Clean Water Act (CWA) goals and the viability of certain management practices.
Hence, developing ways to measure and display incremental improvement would be beneficial to
all CWA programs in a number of different ways. While the TMDL program is the primary water

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Documenting Incremental Improvement                           November 30, 2008


program that is dedicated to the delineation and tracking of the status of impaired surface waters
and the progress of their restoration to meet CWA goals, other EPA water programs can also
benefit from the measurement of incremental change.

Evaluating incremental improvement short of fully meeting WQS (i.e., no causes of impairment
are removed, but evidence of improvement exists)  can be variable and subject to interpretation -
there are presently no widely accepted "benchmarks" for recognizing partial improvement, as
compared to the clear target represented by fully meeting specific WQS. Although a number of
TMDLs have produced such full restoration, many more if not most of the TMDL program's
currently undocumented successes are assumed to be incremental improvements and thus, their
reliable  documentation poses a challenge.  Because full recovery may take  several years to become
manifest and most TMDLs are comparatively recent, consistent protocols  to recognize partial
recoveries  are essential to demonstrate interim program success.  In addition to the TMDL
program, other CWA clientele will also have an interest in the accurate identification of
incremental improvements (Table  1).

EPA Program Needs
Although some EPA water program actions acknowledge the concept of incremental
improvement, performance measures and guidance for determining incremental improvements to
date have been limited. EPA and the states need program evaluation protocols that recognize and
give credit to the documentation of partial progress toward the full attainment of restoration goals.
EPAs 2006-2011 Strategic Plan (U.S. EPA 2008a) contains several targets  based on full restoration
to the point of meeting all WQS, but this Plan was EPA's first to begin addressing incremental
improvements.  Specifically, Goal 2 "Clean and Safe Water" includes demonstrating such
improvements on a watershed basis by 2012. Two programmatic targets directly linked to this goal
include  watershed improvement measure SP-12  (U.S. EPA 2008b) and partial restoration measure
SP-11 (U.S. EPA 2008c).  To meet measure SP-12, one or more impairment causes for water
bodies in the watershed must either be removed, or alternatively show watershed-wide
improvement based on "credible scientific data". The Agency is seeking to achieve these
improvements in 250 HUC-12 scale watersheds by 2012 nationwide.  To meet measure SP-11
nationally, a minimum of 5,600 water body specific impairment causes must be removed by 2012.
This measure recognizes incremental improvement in cases where restoring waters impaired by
multiple causes may eliminate some of those causes yet fall short of attaining all WQS by removing
all causes.

Both of these targets include incremental improvements that do not represent full restoration, and
thus, will require the demonstration of numerous  partial successes while full recovery progresses
along more extended time frames.  These will require sound, defensible reporting and accounting
protocols and decision rules,  and each requires sound and consistent guidance to ensure credible
and consistent reporting and counting. Whereas these measures are a start toward recognizing
partial progress in restoration, additional targets concerning incremental improvement may be
considered in upcoming EPA strategic planning. Even beyond strategic planning and EPA
programs,  formal and informal  evaluations of the variety of state and federal programs that are
oriented toward restoration should be capable of weighing partial as well as full restoration success.

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 Documenting Incremental Improvement
November 30, 2008
Table 1.  Clientele for a framework document on incremental improvement measurement
         concepts and methods.
Clientele
TMDL program managers
(primary clientele)
NFS program managers
Monitoring program managers
4b projects (controls other than
TMDL are in place)
EPA Surface Water Strategic
Planners and
Watershed Managers Forum
States
WQS program
Reason for Interest
Demonstrate partial recoveries as program results in
outcomes potentially earlier and in larger numbers than
full recovery (i.e., a recognition that all stressors cannot
be remediated in the same time frames).
Related to qualifying for NPS success stories recognition;
also demonstrate more 3 19 progress and results.
Once documented as partially recovered, help orient
limited monitoring funds to measuring waters more
likely to have completely recovered. Also documenting
incremental improvement is a primary component of
post- project effectiveness monitoring.
Demonstrate progress being made within a reasonable
time period so as not to revert from 4b to 5/4a process.
Clarify and help defensibility of counting rules on partial
restoration measures (W, Y). Also, aid the consideration
of possible new measures concerning incremental
improvement.
Additional consideration in performance partnership
agreements & reporting to EPA.
Related to determination of highest attainable use for the
purpose of designating aquatic life uses; essential in use
attainability analysis (UAA) considerations.
 Current Challenges and Issues
 The significant challenges  in addressing the need for a framework and protocol for measuring
 incremental change center on the inherently competing concepts of EPA desiring a readily
 available and tractable process for reporting and the fundamental need to have it based on sound
 data and information (i.e., "credible scientific data"). We are clearly taking the position here that
 the integrity and strength  of the underlying data and information upon which the incremental
 change indicators are founded is the starting point for devising and demonstrating a framework
 within which EPA can have such reliable measures of progress. One problem with the current
 situation is that a wide range of different approaches are essentially homogenized by existing
 measures of designated use attainment. This is commonplace within CWA program reporting and
 prior examples include state variability in 305[b] reporting from the previous 25-30 years and the
 litany of "lists" that have been produced from the same baseline data for a variety of purposes.
 A fundamental problem with these past approaches has been the homogenization of technically

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Documenting Incremental Improvement                           November 30, 2008


different baseline inputs in designated use status reporting.  Many states base their assessments of
status either wholly or partially on chemical/physical parameters and indicators while others
employ bioassessment results, yet each is distilled to a common terminology and "currency"
expressed as the proportion of a waterbody that partially or fully achieves designated aquatic life
use support. As has been shown in prior comparability studies (Rankin and Yoder 1990; Rankin
2003; Karr and Yoder 2004) such assessments based on chemical/physical indicators can be
substantially different than biologically based assessments, the differences being up to 50% in
some cases.  In such cases, biological assessment contributed to the avoidance of the type II
assessment errors that are inherently propagated in chemical/physical assessments, which results in
the significant under-reporting  of aquatic life use impairments. Current practice would in  effect
obliterate these important differences by effectively homogenizing the fundamentally different
assessment protocols.  There are additional differences in state programs  that also contribute to
the uncertainty about the reliability of status assessments and these include differences in spatial
sampling design and the level of rigor of state monitoring and assessment (M&A) programs.
These almost certainly contribute an as yet undocumented degree of variability and uncertainty in
consolidated measures of program effectiveness. A major focus of this report is about how to
relate baseline chemical, physical, and biological measures and indicators in an integrated
assessment process that results in improved accuracy and consistency in the type of reporting that
are to be accomplished by measures SP-11 and SP-12 (aka measures W and Y).  This is an
important prerequisite to assuring that "credible scientific data" are effectively used in the
measurement of incremental change within these measurement frameworks.
                                TECHNICAL APPROACH

The technical approach followed by this report is intended to address the following questions:

  1) What constitutes a bona fide incremental improvement in an impaired water body that is
     not yet meeting water quality standards?

  2) What scientifically valid methods are appropriate for detecting incremental improvement in
     a water body, and what types of data are required to use these methods?

  3) How are states presently documenting incremental improvement in their waters?

  4) What capacity do state programs need to document incremental improvements, and how
     does this generally match the current range of state capabilities?

To demonstrate the process and framework we reviewed a set of case examples from the state of
Ohio that encompass a range of spatial context from statewide to watershed level reporting and for
different types of water quality management program issues.  Five of these case studies are reported
in full detail in Appendix A and follow the principles and concepts of adequate watershed
monitoring and assessment (Yoder 1998; Yoder and Rankin  1998; Appendix B) that is envisioned
here as a framework to assure the use of "credible scientific data".  To answer the question about

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Documenting Incremental Improvement                           November 30, 2008


how states presently accomplish incremental assessment and if they have the technical and
logistical capacity to do so, we accessed the results of the recent evaluation of state WQS and
monitoring and assessment programs that have taken place in multiple states since 2002 (MBI
2004; Yoder and Barbour 2009).
  CASE STUDY: OPTIONS FOR DEMONSTRATING INCREMENTAL IMPROVEMENT

To illustrate what constitutes a bona fide incremental improvement in an impaired water body that is not yet
meeting water quality standards we chose a case study involving the assessment of designated aquatic
life use support from an eastern Ohio watershed. This is one of a collection of watershed case
studies from Ohio that deal with small watersheds of the size envisioned in SP-11 and SP-12 that
have been the subject of acid mine drainage abatement and treatment projects that are detailed in
Appendix A. This will demonstrate the utility of using chemical, physical, and biological
indicators both singly and collectively in a multiple lines of evidence approach and within a
framework of adequate monitoring and assessment (Appendix B) to demonstrate reasonably
available options for incremental assessment.  We focused on the sequence of stressor, exposure,
and response indicators (Figure 1) using each singly and in combination as multiple lines of
evidence to not only demonstrate incremental improvement, but to facilitate a complete
assessment of the degree of program success to date and what can be expected in the future.

Case Study: Mine Drainage Abatement in Small Watersheds
We utilized the results of watershed assessments performed by the Ohio University Voinovich
School for Leadership and Public Affairs, the Midwest Biodiversity Institute, and selected
watershed groups in support of Acid Mine Drainage Abatement and Treatment (AMDAT) projects
sponsored by the Ohio Department of Natural Resources Division of Mineral Resources
Management and 319  implementation projects sponsored by Ohio EPA. AMDAT projects in
Ohio can also qualify as TMDLs under a cooperative arrangement with Ohio EPA whereby these
studies utilize the same methods and indicators and address WQS issues as part of the watershed
assessment. Pollutant loading reductions needed to meet WQS are then developed and are
evaluated by an adequate monitoring and assessment approach (Yoder 1998; Yoder and Rankin
1998) to determine overall abatement project effectiveness.  As such the data and information are
well suited to determining incremental changes in chemical/physical and biological indicators
through space and time.

The five case studies are drawn from three watersheds in the coal bearing region of Ohio: Huff
Run, Monday Creek, and Raccoon Creek - these are fully detailed in Appendix A. These
watersheds have varying amounts of data to support the demonstration of incremental change, but
each has the essential indicators to demonstrate the sequence of actions from TMDL development
to pollution abatement to incremental recovery towards attainment of WQS.  There are varying
amounts of incremental change across these five restoration project examples each showing varying
degrees of biological and chemical/physical change. Three of the five examples are active lime
dosing treatment BMP projects (Jobs Hollow, Essex Doser, and Hewett Fork).  The other two are

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Documenting Incremental Improvement
                          November 30, 2008
examples of sub-watersheds containing numerous passive systems and varying amounts of change
in the receiving streams (Huff Run and Little Raccoon Creek) through time.

   The  Linkage From  Stressor Effects
             to Ecosystem  Response
S                                  Habitat
                                  tructure
                                   Flow
                                  Regime
       Stressor
       Agent(s)
                               Biological
                               Response
                           Water Quality
                            & Toxicity
                             (   Energy   ^
                             VSSource   /
                                                   Biological
                                                     Index or
                                                      metric
      Biotic
   Interactions
This model is an
explicit statement of
multiple causation
     STRESSORS
STRESS/EXPOSURE
                                                        Stressor Metric
                                                       RESPONSE
Figure I. The linkage of the effect of stressors through Karr's five factors to the resultant biological response. The
   indicator roles represented by each category (stressor, exposure, response) are identified in accordance with Yoder and
   Rankin (1998); after Karr and Yoder (2004).

HuffRun
The Huff Run subbasin is located in eastern Ohio within the Muskingum River basin.  Huff Run
is 9.9 miles long with a 13.9 square mile watershed. A substantial portion of the watershed has
been surface mined for coal, limestone, and clay. Because most of the mined lands were not
originally reclaimed (referred to as abandoned mined lands), the watershed has been impacted by
legacy acid mine drainage (AMD) and it is the principal stressor.

The Huff Run Watershed Restoration Partnership Inc. (HRWRP) has partnered with the Ohio
DNR, Division of Mineral Resources Management (MRM), Rural Action, Ohio EPA, Division of
Surface Water (319 program), Crossroads RC&D, and the U.S. Office of Surface Mining (OSM)
"to restore the Huff Run watershed by improving water quality and enhancing wildlife habitat,
through community support and involvement." As a result, seven reclamation projects have been

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Documenting Incremental Improvement
                                        November 30, 2008
completed in the Huff Run Watershed since 1998 with the intent of meeting specific water quality
based targets and the Ohio WQS. Each project is directly adjacent to Huff Run (Figure 2).
          Mineral Zoar          Harsh North
                       Acid Pit #1
                     Lyons                Thomas
              Farr AMI and ALD
                                                                 Lindentree

                                                   Linden Bioremediation
Figure 2. Funded and proposed mine drainage abatement projects in the Huff Run subbasin.
         Pre acid load
         condition
Post acid load
condition
              J52lbs/day
                         80
      Data derived using the Mean Annual Load
      Method (Stoertz 2004).

       Mouth of Huff Run used for these numbers
             Graph based on 2005 data
  (Ibs./day) estimated at the mouth of Huff Run.

this case study acidity is a targeted and management
watershed is -67 mg/1 hence the net reduction to <0
in at least one of the targeted parameters.
Exposure Indicators: Chemical Constituents
        Stressor Indicators:  Pollutant Loadings
        Using data derived from project
        monitoring and the mean annual load
        method (Stoertz and Green 2004) the
        total acid loading reduction at the
        mouth of Huff Run is estimated at 82
        Ibs/day (Figure 2). The pre-
        reclamation acid load condition was
        based on two samples (1985 and
        1996). Since 1999 the mouth of Huff
        Run has continued to be net alkaline
        (i.e. all net acidity has been reduced).
        Heavy metal loading reductions were
        also derived using the same method.
        There were no metal load reductions
        up to 2005, with minimal loading
        reductions indicated after 2007.  In
relevant parameter. The TMDL target for this
mg/1 represents an incremental improvement

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Documenting Incremental Improvement
                                             November 30, 2008
Eight locations along the mainstem of Huff Run have been monitored since 1985. The values for
pH were average during the pre-construction time period prior to 1997.  From 1998 through the
present, seven remedial projects were completed (Appendix A) and this is considered the "post-
construction" time period in the data analysis. However, water quality is technically in a
transitional construction phase until all remediation projects are complete. Water quality data
collected at the mouth of Huff Run (RM 0.4) demonstrate an increase in both pH and net acidity
through time (Figure 4).  Total iron concentrations were elevated at the mouth of Huff Run with
post construction values being similar to pre-construction values and exceeding the Ohio WQS of
            Huff Run mainstem
                                 O a\erage pre net acidityprior 1997
                                -0—a\erage implementation net acidity 1998-2007
                                   current condition 9/1S/2007
                 RM 7.70 RM6.70 RM 5.40 RM 4.80 RM4.10 RM 2.70
                                        TMDL Target)-67 mg/l)
                                 Water quality stations
            Huff Run mainstem
               7.5 -
                7 -

               6.5 -

                6-
               5.5 -
                5 -

               4.5 -
           -average pre pH prior to 1997
           -averageimplementation pH 1993-2007
            current condition 9/18C007
           -pH target
                   RM
                   7.70
RM
6.70
RM
5.40
f RM T RM T RM T RM T
I 4.80 |  4.10 I 2.70   1.40
I   I irrlpn  '    '     '
                           Undent ree
                            Fern Hill
          Mainstem rwermile stations
            Linden
            Thomas
            Belden
          Marsha North
            Acid Pit
              #1
       RM
      0.40
     I
Lyons  Farr
    Mineral
     Zcar
                                            Incremental
                                         change -shortof
                                            incremental
                                         change - needed
                                           to meet TMDL
                                                                   Incremental
                                                                 change- beyond
                                                                   TMDL targot
                                                                 Incremental
                                                                   change -
                                                                 meets WQS
                                         Incremental
                                           change -
                                          marginally
                                         meets WQS
Figure 4-  Spatial and temporal patterns in pH and net acidity (mg/l) at eight monitoring locations in Huff Run showing
    average pre-, during, and post-implementation results.

1.0 mg/l (Figure 5) with a negligible decrease in the post-remediation period. Total aluminum
concentrations declined more during the post construction time period, but remained in excess of
the U.S. EPA chronic maximum (CMC) and continuous aquatic criterion (CAC) of 0.087mg/l
(Figure 5; Ohio has no WQS for aluminum). Taken at face value all of these results indicate
incremental improvement that falls short of fully meeting WQS. Both pH and acidity show virtual
attainment  for those parameters, but the two heavy metal parameters indicate continuing
exceedences that remain to be resolved.
Exposure Indicators: Physical Indicators

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 Documenting Incremental Improvement
                             November 30, 2008
 An essential component of adequate monitoring and assessment for designated aquatic life use
 support is habitat assessment that is included here in the form of the Qualitative Habitat
 Evaluation Index (QHEI; Ohio EPA 1989; Rankin 1989). The results obtained since 1997
        Mouth of Huff Run at stream rrile 0.40
   I Fe_total_mgl
   -Fe criterion mg/l (Ohio WQS)
         10.00 -
         9.00 -
         8.00 -
         7.00 -
         6.00 -
         5.00 -
         4.00 -
         3.00 -
         2.00 -
         1.00 -
         0.00
       Mouth of Huff Run at stream mile 0.40
• Aluminum total mgl
-Aim ax. criterion mg/l (EPA CMC)
 Al chroniccriterion mgd (EPACCC)
                          ...elemental
                        change needed
                         to meet CCC
                          Incremental
                         improvement
                       towards meeting
                                                                 Incremental
                                                               change needed
                                                                 to meet CCC
                                                                 Incremental
                                                                 improvement
                                                                 wards meeting
                                                                    CCC
Figure 5. Temporal pattern in total iron (mg/l) and total aluminum, (mg/l) at the. mouth of Huff Run between 1985
    and 2007.

 indicate that while habitat in Huff Run is sufficient to support aquatic assemblages that meet the
 Ohio EPA biological criteria (Table 2), problems remain. The most significant mine drainage
 related impact is the moderate to heavy siltation and moderate to high degree of embeddedness of
 the substrates, which alone can impede full biological recovery. In terms of this indicator there is
 no evidence of incremental improvement, but the lack of data prior to 1997 may preclude a firm
 showing.  What we do know from the results of this indicator is that further remediation is needed
 to resolve specific habitat deficiencies.
 Response Indicator:  Macroinvertebrate Assemblage
 Biological assessment in Huff Run included both macroinvertebrates and fish in keeping with
 methods applicable as level 3 bioassessment under the Ohio Credible Data Law1 and the Ohio
 WQS. This means that these data can be used to directly determine designated aquatic life use
   The Ohio Credible Data Law specifies three levels of data; level 3 is the highest level of rigor and is required for all regulatory
   purposes, i.e., WQS and TMDL listing and de-listing.

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Documenting Incremental Improvement                           November 30, 2008


attainment status under the Ohio WQS for purposes such as TMDL listing and development and


   Table 2. QHEI scores and metric values for sites in Huff Run.
                       WWH Attributes           MWH Attributes
                   	O>	 	
                      W        1  S     High Influence    Moderate Influence
QHEI ^llsS-isf I
Components = ,5 ! = ,1 ~ .5 ™ = ^ I c -^ £
^t^fl^A- | |§ j^Sf
cScoS-aSbSfc S .5 w « ° £
^-^:gj^;-^-^-"~~ a*" £ -^ O 2 T?
Mile QHEI (ft/mile] ^ » 55 o i iS " ° S 3 3 cS zros
i i5"2rel|^|f
I ||||Q§8|
1 ill fill!
2 SfSf235i
No Fast Current
High/Mod. Overall Embeddedr
High/Mod. Rile Embeddedne
No Riffle
Total MlKMiHAtfrixiles
,s
a
i
i
(17101) Huff Run
Year:
-7 A
7.4
5.2
0.3
Year:
7.7
r "7
6.7
ET /I
D.4
/I O
4.8
3^v
.0
2.7
1.4
O yl
U.4
Year:
C -1
D.4
4.1
r>4
1997
T5 K("l
72,50
60.00
60,50
2005
59.50
f -3 ST/"!
63.50
'»"»'»"» f\r\
/ /.ou
x j] K/%
64.50
68.00
67.00
x o e*"i
68. OU
2006
•T/. /V1
/O.UU
34.50
AA RH

26.58 "«
16.48 •

24.39 "

1 K 0"in •
1D.UU •
1 iL A Q M
16. 4B "
15.00 •
15.00 «

15.00

• • • 5 ••
• • • • 5 •

• • • » 5



• • • • • 6
• • • • 5 •

• 1 ••• •
OK «
• •
2 • ••
1 • «•

0 «
1 •
OK
•
jj_ H Ml H H
o • •
i • ••
OH
•
Om
•
• • A
• 4
• « 5
• • • 6

« 2
• • 3
• 3
• o
tL
• 5
• • 4
«« 5
H 1 1 <4
• • "5
• O
A 1 15
O.lo
0.50
0.33

0.17
A OK
O.iD
0.10
A 1 3
U.I O
0.29
0.14
0.33
C™\ 1 ^
U.I O
A 1 A
U.1U
2.50
n?R
fi / ^
O.od
1.33
1.33

0.50
A L O
O.OO
0.10
OQQ
.00
1 .00
0.71
1.17
r\ L. ^
U.oo
A Af\
U.4U
5.50
nsfi
evaluating the appropriateness of the existing designated uses. The demonstration of incremental
improvement in the biological indicators was of particular importance to the latter process for
mine drainage impacted streams in Ohio.

Macroinvertebrate and fish assemblages were monitored in Huff Run in 1997 (fish only), 2005,
and 2006, most of which occurred during the post-remediation period. Both assemblages
demonstrated incremental improvement, each to a differing degree. The Invertebrate Community
Index (ICI; Ohio EPA 1987; DeShon 1995) shows a spatial pattern in Huff Run that closely
follows pH and is the opposite of acidity, a tacit confirmation that biological assemblages have
responded positively to reduced loadings of acidity and allied constituents (i.e., heavy metals).
However, the ICI remained well below the warmwater habitat (WWH) use designation
biocriterion at the two downstream most sites that are in the segment of greatest impact from mine
drainage (Figure 6).  The incremental improvement in the ICI (and other biological indices) can
                                            10

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Documenting Incremental Improvement
                                                           November 30, 2008
          Huff Run longitudinal ICI scores
      60
                                - ICI 2005
                                - ICI 2006
                                - ICI WWH wadeable target
  50 -

o> 40 -
o
O -3f
« Ol
- 20 -

  10 -

   0
                WWH Biocriterion
                               2006 ADV =
                               90/mi.
                                               change
                                              remaining to
                                              meetWQS
                                              ncremental
                                              change post-
                                              treatment
               5.4
                            4.1
                          river mile
                                          0.3
                                                          also be portrayed by the Area of
                                                          Degradation Value (ADV;
                                                          Yoder and Rankin 1995) which
                                                          combines the severity and
                                                          extent of the departure from a
                                                          biocriterion and the length of
                                                          stream over which it occurs.  In
                                                          this case the ADV decreased
                                                          from  HOmi. in 2005 to 90/mi.
                                                          in 2006, a positive change of
                                                          18%. The fish assemblage data
                                                          showed lesser improvements in
                                                          the Index of Biotic Integrity
                                                          (IBI) ranging from 16 in 1997
                                                          and 2005 to 18 in 2006, a non-
                                                          significant improvement; the
ADV/mile for the IBI declined by 10% between 1997 and 2006.  However, species richness
improved from 1 and 2 species in 1997 and 2005 to 7 in 2006. Fish frequently lag
macroinvertebrates in their recovery taking longer to respond especially where the spatial scale of
the impacts inhibits reinvasion and reproduction. One issue with these results is that the
biological data were collected mostly during the post-implementation phase of the Huff Run
abatement projects. However, knowing how the biota are impacted in general by severe acid mine
drainage in Ohio, these results represent a bonafide incremental improvement in response to the
aggregate of the abatement projects. In this case the biota improved from very poor quality to poor
and even fair quality at some sites.
Figure 6.  Invertebrate Community Index (ICI) results at three locations in
   Huff Run during 2005 and 2006.
  1. Management actions

  2. Response to management
                                  Administrative indicators
                                   [permits, enforcement, plans, grants]
                                   [technologies used, BMPs installed]
  3. Stressor abatement
  4. Ambient conditions
  5. Direct exposure to effects of
     pollution
  6. Biological response
                \
                                  Stressor indicators
                                    [changes in land-use practices, effluent
                                    reduction]

                                  Exposure indicators
                                    [pollutant cone., physical habitat or flow
                                    alteration]
                                    [assimilation and uptake of pollutants, reduced
                                    spawning success, nutrient dynamics
                                    changed, sedimentation effects]

                                  Response indicators
                                    [biological metrics, target species, multimetric
                                    indexes, other biological measures]
                Endpoint: "Ecological Health" or Biological Condition

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Documenting Incremental Improvement
                November 30, 2008
Level 1:
AMD caused impairment; TMDL
indicates need to reduce loadings of
AMD pollutants.
Level 2:
AMDAT  program provides funding
for AMD abatement; treatment
project by HRWRP.
                                                     Level 3:  Load reductions
                                                     via additional treatment
                                                       Pre acid load
                                                       condition
                     Post .i 1.1 load
                     condition
                                                       O^m


                                                       I
                   ...
                   .]:•
                   20
                                                      Data derntdusng the Mean Amjal load
                                                      Method lifoerti 2«M)
                                                       Moutfj of Hu# Run used for these numbers
                                                          Graph based on 2005 data
    Level 6:  Partial improvement in macro-
    invertebrate biocriterion (<50%)
Level 4&5:  Net improvement in pH
to minimally meet WQS
Huff Run longitudinal ICI scores
50-
o> 40-
U 20-
10-
-•-CI2006
-.-CI2003
	 C IWWH wadeable tsrgst
WWH Biocriterion fltPV
^^ ^

5.4 4.1
river mile


r pew
~~~~ r |
^^— IH
0.3

1
1


HuffRur
81
7.5-
7 -
6.5 -
Q. °
5.5 -
5-
4.5-
mainstem ^^average prepHpriorto 1997
—•-average implementation pH 1 993-2007
curentcorditicn 9/18/2007
	 pH target
~^V
RM RM RM T RM T RM T RM T RM T RM
7.70 6.70 5.40 4.80 | 4.10 2.70 1.40 0.40
Lindertree T^6" Acid Pit Lyons Farr
Fetn HII Belden ffl Mine-al
Manstem river mile stations Marsha North ZoEr



evaluated by the environmental outcomes that are produced and within the conceptual framework
of adequate monitoring and assessment. This is portrayed specifically for Huff Run (Figure 8) in
which the response of the principal stressors (i.e., acidic loadings) to management are evaluated by
the changes in exposure (i.e., as indicated by pH, acidity, metals, habitat) and ultimately by the
biological response (i.e., as indicated by biological assemblage performance). In this case the
documented improvements are incremental because they fall short of fully meeting WQS, but the
expectation remains that WQS will eventually be met provided the sequence of indicators is
properly analyzed and interpreted in accordance with the causal sequences portrayed in the
indicators hierarchy (Figure 7). The degree to which the applied management efforts fall short of
meeting restoration targets depends on which indicator is used as a basis for making that
judgment. Individually, the different chemical, physical, and biological indicators each portray
differing degrees of improvement, some of which indicate the virtual attainment of the WQS or
TMDL goals for each (e.g., acid loadings, pH, aluminum) while others indicate comparatively less
improvement  (e.g., iron, habitat, biological assemblages). The easy way to deal with what would
otherwise be viewed as discrepancies among the indicators would be to follow an independent
applicability approach by which success is contingent on the most impacted of the indicators, in
this case iron, habitat, and the biota. An alternative is to employ a multiple lines of evidence
approach and in keeping with the most appropriate role of each indicator where the response
indicators bear the most weight for what constitutes bonafide success. In the case of Huff Run,
the Ohio WQS are explicit in defining how the attainment of the designated is determined, i.e., it
                                           12

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Figure 8. Hierarchy of indicators as applied to the abatement of mine drainage impacts in the Huff Run watershed and
   the causal linkages between stressor, exposure, and response indicators.
 is based on attainment of the numerical biological criteria.  Hence the principal measures for
 incremental improvement in this case are the biological assemblage data and indices. The role of
 the other indicators is to serve as the explanatory data for how the biota responds through space
 and time.  In this case the complex mosaic of mine drainage and its array of chemical and physical
 impacts and parameters comprise the principal causative stressors and serve as the appropriate
 targets for TMDL development and resulting abatement actions.  However, the stressor and
 exposure indicators can also serve as important signals of incremental improvement that provide
 more immediate feedback about the efficacy of the abatement practices. Following this approach,
 an indicators hierarchy for Huff Run was developed and serves as a watershed specific template for
 relating and evaluating incremental changes in the various indicators through time (Figure 8).

 M<§?A Program Design Implications
 The accuracy and comprehensiveness of incremental assessment is entirely dependent on adequate
 M&A that is designed and conducted to support the assessment of water quality management
 outcomes at the same scale at which the management is being applied.  This provides the spatial
 connections that are essential to diagnosing causal associations and relating the extent and severity
 of their effects as expressed by stressor and exposure indicators. This was evident in the Huff Run
 example in the spatial differences in the chemical and physical indicators along the mainstem.
 Simply relying on the results at the  mouth (i.e., the watershed "pour point") would have been
 much less  informative about the severity and magnitude of the impact of mine drainage
 constituents along the mainstem. While incremental improvement was evident in some of the
 indicators measured at the mouth sampling site (RM 0.4), these data alone could not capture the
 extent of impairments along the stream and in the spatial context of individual sources  and
 abatement projects.

 The data collected at multiple sites  along Huff Run documented the spatial "pollution profile"
 that is inherent to the action of pollutants and stressors in any flowing waterbody. A spatial
 sampling design that adequately captures this spatial context is essential to gaining the additional
 dimensions of incremental change within a watershed.  In Huff Run, the change in pH and acidity
 demonstrate the documentation of the  longitudinal pollution profile for these two parameters (see
 Figure 4).  The importance of knowing  this information is in relating the impact of remediation at
 each specific AMDAT project of which  there are at least 7 along the stream. While these
 collectively contribute to the overall TMDL targets, they are in some cases funded and operated
 independently. This type of detail in the spatial M&A design not only allows for more  detailed
 tracking of incremental improvements within the watershed, but it provides the opportunity to
 apply the most successful management approaches to other watersheds with similar sets of
 stressors.

 The casting of chemical, physical, and biological indicators in their most appropriate role as
 indicators of stress, exposure, or response is a pivotal concept within the adequate M&A
 framework and that affects how to evaluate incremental improvements.  Given that the Huff Run
 case example is focused on designated aquatic life  use status, the principal arbiter of success are the
 biological assemblage indices in their role as response indicators.  While this is defined  by the
 Ohio WQS in this case, adequate M&A would cast biological indicators in that role in  the absence
                                              13

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Documenting Incremental Improvement
November 30, 2008
of a formal biocriterion. However, a strict adherence to this disciplinary framework is not always
practiced. Depending on which indicator is used as the arbiter of "success" a different assessment
could be reached. For example, if loadings alone were used the outcome would be viewed as
having achieved full recovery (see Figure 3) where acid loads at the mouth were reduced to 0. It
also represents conditions only at the pour point of the watershed and the necessary assumption
that it represents conditions throughout the entire watershed. The same is true for the two heavy
metals aluminum and iron (see Figure 5).  Acidity and pH were available at multiple locations
                        Pollution (specific
                        human activities)
       Point and nonpoint
     pollutant loadings for all
     sources (source specific)
       Ambient pollutant
      levels in water body
       (pollutant specific)
         Human health
       (health outcomes
       including disease)
                   \
/
„ — '
Land use
effects
s
*^-


Channel/Flow
alterations


In-channel &
Riparian effects



Ecological health
(cumulative effects on
biological condition)


  Indicator Role
 ^  Stressor
       Exposure
      (landscape)
       Exposure
      (in-stream)
       Response
                      Designated use
                   (water body specific)
       Endpoint
Figure 9. Position of the criterion (stressor, exposure, or response) illustrating the relationships between human activities,
    specific types of criteria, and designated uses that define the endpoint of interest to society (modified from NRC
    2001). Their parallel roles as environmental indicators for each category is listed on the right.  Arrows indicate
    directions and interrelationships along the causal sequence of stress, exposure, and response (after Karr and Yoder

    2004).
                                             14

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Documenting Incremental Improvement                            November 30, 2008
Taken together, the closer that an indicator is to the summation of a designated use, the more it
indicates that the incremental improvement observed thus far in Huff Run is just that, partial
success. This illustrates the "Position of the Standard" concept that was  articulated by the National
Academy of Sciences Committee on Science in the TMDL Process (Figure 9; NRC 2001; Karr and
Yoder 2004). This concept relates the "position" of a parameter or indicator as a "standard" to the
designated use in the same sequence as the stressor/exposure/response roles of surface water
indicators (Figure 9). The closer a parameter or indicator is to representing the direct attributes of
the designated use the more accurate it will be as an arbiter of that use.  In this case, the designated
use is aquatic life which is specifically described in the Ohio WQS for the appropriate tier (i.e.,
WWH) as follows:

       "Warmwater" - these are waters capable of supporting and maintaining a balanced,
       integrated, adaptive community of warmwater aquatic organisms having a species
       composition, diversity, and functional organization comparable to the twenty-fifth
       percentile of the identified reference sites within each of the following ecoregions: the
       interior plateau ecoregion, the Erie/Ontario lake plains ecoregion, the western Allegheny
       plateau ecoregion and the eastern corn belt plains ecoregion.  For the Huron/Erie lake
       plains ecoregion, the comparable species composition, diversity and functional
       organization are based upon the ninetieth percentile of all sites within the ecoregion.  For
       all ecoregions, the attributes of species composition, diversity and functional organization
       will be measured using the index of biotic integrity, the modified index of well-being and
       the invertebrate community index as defined in "Biological Criteria for the Protection of
       Aquatic Life: Volume II, Users Manual for Biological Field Assessment of Ohio Surface
       Waters,"  as cited in paragraph (B) of rule 3745-1-03 of the Administrative Code. In
       addition to those water body segments designated in rules 3745-1-08 to 3745-1-32 of the
       Administrative Code, all upground storage reservoirs are designated warmwater habitats.
       Attainment  of this use designation (except for upground storage reservoirs) is based on the
       criteria in table 7-15  of this rule. A temporary variance to the  criteria associated with this
       use designation may be granted as described in paragraph (F) of rule 3745-1-01 of the
       Administrative Code.

This follows the NRC (2001) Position of the Standard concept by defining attainment as being
directly measured by the biological indices, which in the case of Huff  Run are the WWH
biocriteria for the ICI (see Figure 6) and IBI. In other states where designated aquatic life uses are
not as specific and are instead characteristic of "general" uses, stressor and exposure indicators and
parameters are either employed as surrogates for response or elevated  to the same "position" in
applications of the WQS.  However, surrogate indicators can induce an  unquantifiable level of
uncertainty and error into the assessment process.  Comparability studies have shown that using
chemical sampling data on a parameter-by-parameter basis in a surrogate role can miss
impairments that are otherwise detected and/or otherwise quantified  by bioassessment (Rankin
and Yoder 1990; Rankin 2003; Karr and Yoder 2004).

The implications to the TMDL program can be profound, especially when chemical-based M&A
                                             15

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Documenting Incremental Improvement                           November 30, 2008


misses impairments altogether thus improperly obviating the need for a TMDL and/or missing the
opportunity for the right kind of remediation. In contrast, over-emphasizing chemical exceedences
that are not proportionate to observed biological impairments can result in misdirected
remediation efforts. Even when biological assessment is included as part of the assessment
process, its sophistication and level of rigor can affect its ability to detect and characterize
impairments and its utility as a diagnostic tool to further understand impairments (Barbour and
Yoder 2008).  Hence the rigor of all aspects of M&A is critical to the reliability and relevancy of
reporting incremental changes.

The Huff Run case example illustrates some of the important issues involved with substituting
stressor and exposure indicators as surrogates for determining designated use support.  In this case
loadings data used alone would have indicated more success than what had been realized
biologically. The selective use of chemical parameters, while complemented by a more robust
spatial M&A design, would have generated a similar finding.  It was the performance of the biota
that revealed the influence of multiple stressors and where a significant degree of restoration is yet
to be accomplished. Hence, knowing what role an indicator best fulfills is  important to applying
the results of incremental assessment as a management tool. In terms of tracking overall
management program success the reliability of an observed incremental improvement is enhanced
with a primary reliance on using and interpreting a stress/exposure/response indicator sequence.
Within this framework stressor and exposure indicators serve the vital role of providing the basis
for  explaining observed changes in the response indicators. In short, incremental improvement
and M&A and general are best accomplished following the principles of adequate monitoring and
assessment (Appendix B).

The importance of these observations to measures SP-11 and SP-12 lie in the reliability and
relevancy of the parameters and indicators that are being reported. In terms of SP-11 (partial
improvement) the incremental improvement based on a stressor or exposure indicator is
fundamentally different than the same based on a response indicator, yet under the current
guidelines these are not necessarily distinguished. While it could be argued that any showing of an
incremental improvement has value, we are concerned that the inherent error tendencies of each
will ultimately pose a problem for how the ultimate remediation practices are selected, developed,
and judged as to their effectiveness. Again, the more gaps that remain in the baseline M&A
framework in terms of parameters and indicators and spatial sampling design the greater the
eventual uncertainty about the final outcomes. We believe that an adherence to the adequate
M&A framework from the initial documentation of the extent and severity impairments through
the remediation process will assure that these uncertainties are reduced to manageable levels.

Important Policy Implications
The ability to accurately depict and quantify incremental improvements has some equally
important implications for the WQS program, specifically the assignment of attainable designated
uses to individual  streams and rivers.  This process has been of interest to EPA via the TALU
framework (U.S. EPA 2005) of which the Ohio WQS for Huff Run are a working example. The
demonstration of incremental improvement like  that shown for Huff Run across a number of
watersheds that are impacted by mine drainage has profoundly influenced  how tiered aquatic life
                                            16

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Documenting Incremental Improvement                           November 30, 2008


use decisions are now made for acid mine drainage impacted streams and rivers in Ohio.  Prior to
having an awareness of what mine drainage remediation could accomplish, many acid mine
drainage impacted streams and watersheds were assigned to the Limited Resource Waters (LRW)
use designation based on persistent and severe acidity and low pH values and the lack of any
impending remediation actions. The latter simply supported the belief that these were intractable
and irretrievable impacts that resulted from pre-reclamation law mining practices that produce a
high acreage of abandoned mine lands throughout eastern and southeastern Ohio. When
subjected to the well structured use attainability analysis (UAA) process that has been used in
Ohio since the early to mid 1980s, the result was the designation to LRW which protected against
nuisance conditions well below the expectations for baseline CWA goals. This was generally the
result of UAAs conducted in these types of streams in the late 1970s and early 1980s prior to the
current day AMDAT and 319  remediation programs. Watershed-based remediation efforts
emerged in the late 1990s with the advent of active watershed groups, the professional facilitation
by the Appalachian Watershed Research Group (within the Voinovich School at Ohio University),
abatement funding provided through AMDAT, 319, and U.S. Army Corps of Engineer sources,
and evidence that there was at  least a positive directional (i.e.,  incremental improvement) change
that could be expected as a result of these interventions. While the observed incremental
improvements all fell well short of fully meeting WQS, as is the case with the Huff Run and other
case studies in Appendix A, it  raised the issue of revisiting and ultimately changing the WQS goals
for similar mine drainage impacted streams in Ohio. Clearly, the observed improvements went
beyond the very minimal expectations for the LRW use designation, thus redesignation to the
CWA goal compatible WWH  use designation was made. This not only raised the expectations for
the ultimate success of these restoration actions, but provided an impetus for continuing these
restoration programs in a phased approach. The realistic expectation is that while some if not all
of these waters will take many  years or even decades to fully meet WQS, the trajectory of change is
positive with the expectation that redeemable attributes and benefits will be accrued along the way.
While the generation of public support and funding for these projects was critical, the role that a
showing of incremental improvement played in these changes was equally important and provided
the essential evidence of plausibility.
     ASSESSMENT OF CAPACITY TO MEASURE INCREMENTAL IMPROVEMENT

Background
In addition to documenting how incremental improvement can be performed and which
indicators are best suited to providing meaningful assessments, detailing the fundamental capacity
that is needed to accomplish such is an important objective of this project.  We have referenced
what is termed "adequate monitoring and assessment" as the framework within which this is best
accomplished. This framework was introduced in the late 1990s (Yoder 1998; Yoder and Rankin
1998) has been advocated for the TMDL program (NRC 2001; Karr and Yoder 2004) and for the
development and implementation of tiered aquatic life uses (TALU; U.S. EPA 2005;  Barbour and
Yoder 2008; Yoder and Barbour 2009).  States, interstate compacts, and tribes are the
fundamental custodians of all aspects of monitoring and assessment (M&A) under the CWA.
While the type of M&A needed to perform incremental assessment can be performed outside of
                                           17

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Documenting Incremental Improvement                            November 30, 2008


state programs, we feel that states are uniquely positioned to foster a more rigorous and consistent
process that not only benefits the measurement of incremental improvement, but other water
quality management objectives programs as well. States can accomplish this by detailing methods
and protocols in their WQS and monitoring strategy documentation.  In turn,  this provides
outside "users" with a consistent and scientifically defensible framework for the design and
conduct of data collection, data analysis, and management program targets and benchmarks.
Having knowledge about the various state and tribal approaches is then a good way to determine if
they are indeed up to the task of documenting incremental improvement such  that it is
"scientifically sound, appropriately used, and sufficiently sensitive enough to generate data from
which signal can be  discerned from noise".

Evaluating the Rigor of State Programs
The knowledge and generation of data and results about incremental improvement are
fundamentally linked to the better use of M&A to support all relevant water quality management
programs. As such,  assessing the present capacity of states and others to both carry out and foster
the use of incremental assessment tools and indicators is critical to the successful application of
this concept in CWA programs. State program adequacy in M&A also makes standardized and
robust environmental indicators, methods, QA/QC standards and best practices, assessment
methodologies, and assessment criteria readily available to external users. By providing a supporting
infrastructure of indicators and WQS, state programs can fulfill their custodial role for M&A and
WQS and in a more integrated fashion.  This not only makes the  data and information produced
by each state of sufficient quality and reliability2, but makes it comparable and  of a known quality.
External users consisting primarily of other government agencies, watershed groups, academic
institutions, the regulated community, and non-governmental organizations will have a consistent
and standardized framework to follow  in conducting their own assessments.  These latter efforts
can constitute an important and to date largely untapped supplement to the baseline M&A
provided by states and it would help better fulfill many other baseline M&A needs in general.
Presently, the lack of such a systematic framework in most states results in the production of
external data that is  of highly variable quality, quantity, comparability, and reliability. This can
make the use of such data in incremental assessment highly suspect.

Region V States Evaluation Process
While all U.S. states more or less operate an M&A program, the quality and make-up of each
varies widely in terms  of organization, design, indicator development and use, and the extent to
which they are used to directly support their water quality management programs.  The assessment
of status for 305b reporting and 303d listing purposes is a significant, and in some cases the de
facto driver of state M&A programs (MBI 2004). The need for data that can support the TMDL
program has only amplified this dependence. There is growing evidence that an over-emphasis on
the statewide status  assessment function of M&A can supplant and even deter  the ability of states
to address emerging issues such as refined uses, use attainability analyses, and improved integration
between and within water quality management programs  in general. All of these are dependent on
the capacity of an adequate M&A program to incrementally measure environmental quality over
  It meets the goal of "scientifically sound, appropriately used, and sufficiently sensitive enough to generate data
  from which signal can be discerned from noise".
                                            18

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Documenting Incremental Improvement                           November 30, 2008


space and through time and at the same scale at which management is being applied. Building and
maintaining state capacity to conduct integrated assessments that serve multiple water quality
management program needs was a major focus of this evaluation process.

Between 2002 and 2006 MBI  conducted reviews of each of the six Region V state monitoring and
assessment and WQS programs, specifically as each relates to the assessment of designated aquatic
life uses. A report was produced and it documented the methods, indicators, and infrastructure of
each state's M&A programs. One key finding was that some states designed and executed their
M&A programs with the single purpose goal of producing the biennial 305b report. The net
result is that these states were  left ill equipped to use M&A to support multiple water quality
management programs, of which the measurement of incremental change as envisioned by this
report is one consistent need.  The states that were found to execute M&A programs that served
multiple water quality management program needs are the types of programs that are most likely to
fulfill the use of incremental change as a routine management tool.

Critical Technical Elements Process
In 2003 EPA initiated the development of an evaluation framework for state bioassessment
programs termed the Critical Technical  Elements process. As an outcome of the Region V states
pilot evaluation process, this was done primarily to determine the comparative rigor of a state
program for  supporting the development and implementation of tiered aquatic life uses (TALU;
U.S. EPA 2005).  The TALU based approach includes tiered aquatic life uses (TALU) based on
numeric biological criteria and implementation via an adequate monitoring and assessment
program that includes biological,  chemical, and physical measures, parameters, indicators and a
process for stressor identification  (Yoder and Barbour 2009). In short, TALU relies on adequate
M&A and its integration with WQS  for the full benefits of each to be realized. The capacity to
detect and articulate increments of biological  change and relate that along a disturbance gradient
(which includes measuring incremental changes in stressor and exposure agents) is a fundamental
need and requirement to operate  such a program. Hence, the baseline capacity to execute TALU
is the same as that needed to determine and utilize incremental change.

The guiding principles of the critical  elements approach are intended to help state and tribal
monitoring and assessment programs achieve levels of standardization, rigor, reliability, and
reproducibility that are reasonably  attainable under current technology and reasonable levels of
funding. In  turn, this will produce an accurate, comparable, comprehensive, and cost-effective
monitoring and assessment program  that is capable of meeting the broad goal of supporting all
relevant water quality management programs. An important goal of this process is an adherence
to the following principles:

Accuracy - biological assessments should produce sufficiently accurate delineations of condition so
that type I and II assessment errors are minimized;

Comparability - bioassessment  programs  that utilize different technical approaches should produce
comparable assessments  in terms of biological condition ratings, detection of impairments, and
diagnostic properties;
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Documenting Incremental Improvement                            November 30, 2008
Comprehensiveness - biological assessments should be integrated with chemical, physical, and other
stressor and exposure indicators, each used in their respective indicator roles (Yoder and Rankin
1998) to demonstrate the relationship between human caused impacts and biological response;
and,

Cost-effectiveness - the term as used here means that the benefits of having a rigorous and reliable
biological assessment program to support making better management decisions outweighs the
intrinsic costs of program development and implementation.

In this process, the key technical elements of bioassessment programs are described and ranked
into one of four general levels of rigor supported by a sliding scale of resolution and development.
Level 4 is the most rigorous and most appropriate to address the myriad of management issues
regarding aquatic resources.  The remaining three levels of bioassessment rigor may be appropriate
to support some, but not all, water quality management program support needs. For the purposes
of this report, determining impairment and diagnosing categorical and parameter-specific stressors
provides the fundamental basis for supporting the  measurement of incremental change.

Table 3 depicts how the different levels of rigor for bioassessment support the key technical
questions that are the foundation for different aspects of water quality programs ranging from the
determination of condition to causal analysis.  The number of asterisks  denotes increasing
confidence in addressing the underpinnings of the baseline technical questions.  The capacity of
each bioassessment level to provide programmatic support is described as:

    •   Level 1  produces pass/fail assessments and is not amenable to supporting other functions
       such as expressions of severity and magnitude of effect or causal associations.

    •   Level 2 ranges from dichotomous (pass/fail) to multiple (3-4 categories) condition
       assessments; it is capable of only general cause and effect determinations.

    •   Level 3 is capable of providing programmatic support for incremental condition
       assessments along the BCG and for most causal associations, but is limited to a single
       assemblage.

    •   Level 4 achieves comprehensive fulfillment  of program support by providing the most
       robust and complete assessments including scientific certainty, accuracy, relevancy of
       condition assessment, and causal associations;  it includes two assemblages at a minimum.

Discussion
Since the methodology was developed in late 2003, a total of  18 states and one tribe have been
formally evaluated and the level of rigor determined.  Two (2) states achieved level 4, five (5) states
achieved level 3, ten (10) states and one tribe achieved level 2, and one state achieved level 1.
While this does not represent a random sample of the states, it is inclusive enough of different
areas and regions of the U.S. to be considered a fair representation of state capacities. Detailed
                                            20

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 Documenting Incremental Improvement
                                                            November 30, 2008
 analyses of these results (Yoder and Barbour 2009) indicate that the level 3 and 4 states have the
 essential technical capacity to accurately apply incremental assessment in keeping with the
 principles of adequate M&A. Ohio is one of the two level 4 states and this is exemplified by the
 case examples in Appendix A.  It also represents the value of the custodial role that is fulfilled by
 Ohio EPA in that these assessments were performed by external entities following their methods,
 protocols, and criteria.  This capacity greatly diminishes at level 2 to the point where incremental
 Table 3.  Relative degrees to which the four different levels of rigor for bioassessment defined by
          the Consolidated Assessment and Listing Method (CALM) process support the key
          technical questions that serve as a basis for water quality management programs.

Level
1
2
3
4
Condition Assessment
Impair/non-
impaired
*
**
**
***
Multiple
Condition
	
*
**
***
Causal Associations
General
	
*
**
***
Categorical
	
	
**
***
Parameter
Specific
	
	
*
**
***
**
*
Comprehensively fulfills program support role by providing robust and complete assessment including Best Available scientific certainty
in accuracy (i.e., minimizing Type 1 and 2 errors) of condition assessment, and categorical causal associations.

Condition assessments minimizes Type 1 error but doe not adequately address Type 2; general causal associations.

Condition assessments only address Type 1 error at extremes of condition and do not address Type 2 error; no causal association ability.
 assessment is rudimentary at best. While such states may be able to demonstrate incremental
 improvement in limited instances the inherent pass/fail attributes of their assessment frameworks
 technically limits incremental assessment.  The recent set of state evaluations shows that each state
 has developmental activities either planned or underway that will result in elevating the level of
 rigor with the next 5+ years.  Hence we should expect that the technical capacity to conduct
 incremental assessment should become more widespread provided that these efforts continue.

 The development of the technical capacity to accomplish incremental assessment is alone
 insufficient to make its practice a routine output of state programs.  The overarching impetus and
 incentive for conducting this type of reporting is also needed and it needs to become incrementally
 based in its own right.  Presently, the states are only required to report in a bivariate pass/fail
 framework with little recognition given to more detailed reporting of condition.  This needs to
 change if the states are to make the type of broad progress that is needed to make the desired
 measures such as SP-11  and SP-12 have wider application and acceptance. It would seem clear that
 the pursuit of TALU based programs in the states is presently a good way to make this outcome a
 reality while satisfying many other water program needs.
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Documenting Incremental Improvement                           November 30, 2008
                                      REFERNCES

Barbour, M.T., and C. O. Yoder.  2008. Critical Technical Elements of a Bioassessment Program.
   U.S. EPA, Office of Water, Washington, DC. (September 2008). 75 pp.
Karr, J. R., K. D. Fausch, P. L. Angermier, P. R. Yant, and I. J. Schlosser.  1986.  Assessing
   biological integrity in running waters: a method and its rationale. Illinois Natural History
   Survey Special Publication 5:  28 pp.
Midwest Biodiversity Institute (MBI). 2004.  Region V state bioassessment and ambient
   monitoring programs: initial evaluation and review. Midwest Biodiversity Institute Tech. Rept.
   MBI/01'03'1. 36 pp. + appendices.
   (http://www.epa.gov/region5/water/wqb/wqb  r5mon.htm)
National Research Council (NRC). 2001. Assessing the TMDL Approach to Water Quality
   Management. National Academy Press, Washington, DC., 109 pp.
Ohio Environmental Protection Agency (EPA).  1989. Biological criteria for the protection of
   aquatic life, volume III: standardized biological field sampling and laboratory methods for
   assessing fish and macroinvertebrate communities, Division of Water Quality Monitoring and
   Assessment, Columbus, Ohio.
Rankin, E.T.  2003.  Comparison of Biological-based and Water Chemistry-based Aquatic Life
   Attainment/Impairment Measures under a Tiered Aquatic Life Use System.  Center for
   Applied Bioassessment and Biocriteria Fact Sheet 3-CABB-03, Center for Applied
   Bioassessment and Biocriteria, Midwest Biodiversity Institute, Columbus, OH.  28 pp.
Rankin, E. T. 1989. The qualitative habitat evaluation index (QHEI),  rationale, methods, and
   application,  Ohio EPA, Division of Water Quality Planning and Assessment, Ecological
   Assessment Section, Columbus, Ohio.
Rankin, E. T. and Yoder, C. O. 1990.  A comparison of aquatic life use impairment detection and
   its causes between an integrated, biosurvey-based environmental assessment and its water
   column chemistry subcomponent.  Appendix I,  Ohio Water Resource Inventory (Volume 1),
   Ohio EPA, Div. Water Qual. Plan. Assess., Columbus, Ohio.
Stoertz, M.W. and D.H. Green. 2004. Mean Annual Acidity Load: A Performance Measure to
   Evaluate Acid Mine Drainage Remediation.  Ohio DMRM Applied Research Conference
   2004. Mineral Resource Extraction and Restoration Innovations. Ohio University, Russ
   College of Engineering and Technology, Athens, OH.
U.S. Environmental Protection Agency (EPA) 2008a. National Water Program: Strategic Plan and
   Guidance. URL: http://www.epa.gov/water/waterplan/index.htmltffinal Accessed
   11/24/08.
U.S. Environmental Protection Agency (EPA). 2008b.  Guidance on Reporting Watershed
   Improvement under Measure SP-12. URL:
   http://www.epa.gov/water/waterplan/documents/SP-12  Guidance  1-3 l-08.pdf Accessed
   11/24/08.
U.S. Environmental Protection Agency (EPA). 2008c.  Strategic Target SP-11. URL:
   http://www.epa.gov/water/waterplan/pamsfy08/def  wq08.html#spl 1 Accessed  11/24/08.
                                           22

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 )ocumenting Incremental Improvement                           November 30, 2008
U.S. EPA.  2005.  Use of biological information to better define designated aquatic life uses in
    state and tribal water quality standards.  Office of Water, Washington, DC. EPA 822-R-05-
    001.  188pp.
U.S. Environmental Protection Agency.  1995a. Environmental indicators of water quality in the
    United States. EPA 841-R-96-002. Office of Water, Washington, DC 20460. 25 pp.
U.S. Environmental Protection Agency. 1995b. A conceptual framework to support development
    and use of environmental information in decision-making. EPA 239-R-95-012. Office of
    Policy, Planning, and Evaluation, Washington, DC 20460. 43 pp.
Yoder, C.O. and M.T. Barbour. 2009.  Critical technical elements of state bioassessment
    programs: a process to evaluate program rigor and comparability. Environ. Mon. Assess.
    DOI10.1007/s 10661-008-0671-1 (accepted for publication).
Yoder, C.O. and E.T. Rankin.  1998. The role of biological indicators in a state water quality
    management process. J. Env. Mon. Assess. 51(1-2): 61-88.
Yoder, C.O. 1998. Important Concepts and elements of an adequate state watershed monitoring
    and assessment program, pp. 615-628. in Proceedings of the NWQMC National Conference
    Monitoring: Critical Foundations to Protecting Our Waters. U.S. EPA, Washington, DC, 663
    pp. + app.
Yoder, C. O., and Rankin, E. T. 1995. Biological criteria program development and
    implementation in Ohio, pp.  109-144. in W. Davis and T. Simon (eds.).  Biological
    Assessment and Criteria: Tools for Water Resource Planning and Decision Making.  Lewis
    Publishers, Boca Raton, FL.
                                           23

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MBI/CABB                     Documenting Incremental Change                November 30, 2008
                                   Appendix A
 Demonstrating Incremental Improvement: Case Studies in Biological and Water
 Quality Assessment of Acid Mine Drainage Abatement and Treatment (AMDAT)
                                     Projects
                                  Project Report to:
                             Midwest Biodiversity Institute
                                   P.O. Box 21561
                              Columbus, OH 43221-0561
                            Chris O. Yoder, Project Manager
                        U.S. EPA, HECD Contract 68-C-04-006
                                Work Assignment 4-68
                                        by:
                        Jennifer Bowman, Principal Investigator
                    Ben McCammet, Environmental Projects Manager
                      Edward T. Rankin, Senior Research Associate
                                   Ohio University
                    Voinovich School for Leadership and Public Affairs
                               The Ridges, Building 22
                                 Athens, OH 45701
                            http://www.watersheddata.com/

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MBI/CABB                      Documenting Incremental Change                November 30, 2008
                                      Appendix A

   Demonstrating Incremental Improvement: Case Studies in Biological and Water Quality
      Assessment of Acid Mine Drainage Abatement and Treatment (AMDAT) Projects

                                      Background

We utilized the results of watershed assessments performed by the Ohio University Voinovich
School for Leadership and Public Affairs1, the Midwest Biodiversity Institute, and selected
watershed groups in support of Acid Mine Drainage Abatement and Treatment (AMDAT) projects
sponsored by the Ohio Department of Natural Resources Division of Mineral Resources
Management and 319 implementation projects sponsored by Ohio EPA.  AMDAT projects in
Ohio can also qualify as TMDLs under a cooperative arrangement with Ohio EPA whereby these
studies utilize the same methods and indicators and address WQS issues as part of the watershed
assessment.  Pollutant loading reductions needed to meet WQS are then developed and are
evaluated by an adequate monitoring and assessment approach (Yoder  1998; Yoder and Rankin
1998) to determine overall abatement project effectiveness.  As such the data and information are
well suited to documenting incremental changes in chemical/physical and biological indicators
through space and time.

The five case studies are drawn from three watersheds in the coal bearing region of Ohio: Huff
Run, Monday Creek, and Raccoon Creek. These watersheds have varying amounts of data to
support the demonstration of incremental change, but each has the essential indicators to
demonstrate the sequence of actions from TMDL development to pollution abatement to
incremental recovery towards attainment of WQS. There are varying amounts of incremental
change across these five restoration project examples each showing varying degrees of biological
and chemical/physical change.  Three of the five examples are active lime dosing treatment BMP
projects (Jobs Hollow, Essex Doser, and Hewett Fork). The other two are examples of sub-
watersheds containing numerous passive systems and varying amounts of change in the receiving
streams (Huff Run and Little Raccoon Creek) through time.

                                       Huff Run

Huff Run flows from the Merges Community in Carroll County, into Tuscarawas County and has
its confluence in the Conotton Creek just South of Mineral City, Ohio. Huff Run is 9.9 miles
long with a 13.9 square mile watershed. Almost all land east of State Route 542 (about 2/3 of the
watershed) has been mined for coal, limestone, and clay. Because much of the mined lands were
not reclaimed, the watershed is impacted by acid mine drainage (AMD). Other pollution  issues in
the watershed include illegal dumping, riparian encroachment, raw sewage discharges, oil and gas
drilling impacts, and agricultural (row cropping) impacts.

The Huff Run Watershed Restoration Partnership Inc. (HRWRP) was founded in 1996 by a group
of concerned citizens. The HRWRP has partnered with ODNR/MRM, Rural Action, Ohio EPA,
1 see http://www.watersheddata.com/ for watershed projects data and reports.


                                           A-2

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Crossroads RC&D, OSM and others to fulfill their mission statement "to restore the Huff Run
watershed by improving water quality and enhancing wildlife habitat, through community support
and involvement."

There have been seven reclamation projects completed in the Huff Run Watershed since 1998.
All projects are located adjacent to the mainstem of Huff Run. Table 1 shows the name of each
project, a brief description, and the year completed.  Data derived using the Mean Annual Load
Method (Stoertz and Green, 2004) total acid loading reduction at the mouth of Huff Run is 82
Ibs/day (Figure 1).  The pre-reclamation acid load condition was based on two samples 1985 and
1996; since 1999 the mouth of Huff Run has continued to be net alkaline (i.e. all acidity has been
reduced).  Metal load reductions were derived using this same method.  There were no metal load
reductions up to 2005, however with the 2007 data,  minimal metal load reductions were
indicated, 103 Ibs/day, Figure 2.

Table 1.  Acid mine drainage treatment projects completed in the huff Run Watershed
AMD project name
Huff Run AML
reclamation (Mineral
City)
Farr AML and ALD
Linden
Bioremediation
Acid Pit #1
Lindentree
Lyons
Harsh North
Brief description of
treatment
Surface reclamation
Anoxic limestone
drain, limestone
channels, and a
wetland
Microbial inoculated
pyrolusite limestone
treatment bed
Reclaim 15 acre gob
pile and limestone
drains
Surface reclamation,
limestone and slag
channels
Gob pile reclamation
(15 acres), surface
reclamation (5 acres),
limestone and steel
slag channels
Surface reclamation
Year Completed
1998
2003
2003
2004
2005
2005
2006
Total Cost

$180,976
$321,619
$150,000
$270,240
$847,365
$793,095
Longitudinal stream quality for pH and net acidity
Eight stations along the mainstem of Huff Run have been monitored through time. The values
for pH were average during the pre-construction time period prior to 1997.  The first project was
completed in 1998.  From 1998 through the present seven projects were completed at various
                                           A-3

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MBI/CABB
         Documenting Incremental Change
November 30, 2008
times, see table 1. This time period from 1998 - 2008 is considered the "post-construction" time
period in the graphs below figures 3 and 4. However, technically this section of stream is in a
transitional construction phase until all projects are complete. There are two funded proposed
projects: Belden and Thomas and two proposed projects: Fern Hill and Mineral Zoar, see map.
Funded/proposed projects: Belden, Fern Hill, Mineral Zoar, and Thomas
                    Lyons

              Farr AMI and ALD
                Thomas
                                                             Lindentree

                                                Linden Bioremediation
    Pre acid load
    condition
   80
          82 Ibs/day
Post acid load
condition
                      60


                      40


                      20
                             0 Ibs/day
 Data derived using The Mean Annual Load
 Method (Stoertz, 2004).

   Mouth of Huff Run used for these numbers
         Graph based on 2005 data
Figure 1. Acid load reductions at the mouth of Huff Run under pre- and post-treatment.
                                              A-4

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MBI/CABB
Documenting Incremental Change
November 30, 2008
Log Acid Loading
(Ibs/day)
Huff Run -Acid Load Reduction
3 00

1 00 -0.0828X + 1.9124
0 00
-I go2-000 -1 -500 -1 -000 -0.500 O.C
0 00
3 00


v = 0
00 0.500 1 .C


Log Qnorm (cfs)
» P re-treatment 1985-1998 A Post-treatment 1 999-2007
— P re-treatment 1 985-1 998 	 Post-treatment 1 999-2007
00
Figure 2. Metal load reductions
Log Metal Loading
(Ibs/day)
13.00
11.00
9.00
7.00
5.00
3.00
1.00
-1.0,0,
-3.00
Huff Run - Metal Load Reduction





y = 1 .0243X + 2.823 _ , 	 	 * •-
— 1

1 1 1
DOO -1.500 -1.000 -0.500 O.C





y = 0.8189x+j
^^^^^F^^^^

'
00 0.500
Log Qnorm (cfs)
Pre-treatment 1985-1 998 A Post-treatment 1 999-2007
	 Pre-treatment 1 985-1 998 	 Post-treatment 1 999-2007
1.C

.7459
00
Water quality data collected at the mouth of Huff Run (RM 0.40) show an increase in both the
pH and net acidity through time, Figure 5 and 6.  Total iron concentrations continue to be
elevated at the mouth of Huff Run. Post construction values are similar to pre-construction values.
Iron exceeds the Ohio WQS of 1.0 mg/1, Figure 7. Total aluminum concentrations decreased
during the post construction time period.  However the levels of aluminum that remains at the
mouth of Huff exceeded the  EPA chronic aquatic criterion of 0.087mg/l, Figure 8.

How do these  documented water quality improvements translate into biological recovery?
ICI data for 2005 and 2006 indicate a small increase at three stations with the largest increase
noted at the mouth (two new taxa from 2005 to 2006), Figure 6. IBI scores between 1997 and
2006 indicate no significant changes at the mouth, but the number of fish species increased from
1 to 7, Table 2. Habitat is sufficient to support meeting the WWH biocriteria, but sedimentation
and substrate embeddedness remains a problem and are linked to the high instream iron
concentrations and general sediment in runoff, Table 3.
                                           A-5

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MBI/CABB
                             Documenting Incremental Change
                                                      November 30, 2008
Figure 3. Longitudinal pH values
    Huff Run mainstem
          8
        7.5
          7 -
        6.5
          6
        5.5
          5
        4.5
          4
Q.
               RM
              7.70
                                  average pre pH prior to 1997
                                 • average implementation pH 1998-2007
                                  current condition 9/18/2007
                                 -pH target
                 RM
                6.70
   RM
   5.40

Lindentree
 Fern Hill
 Mainstem river mile stations
 RM     RM
4.80  |   4.10
    Linden
   Thomas
   Belden
 Marsha North
 RM
2.70
RM
1.40
RM
0.40
                                                Acid Pit  Lyons  Farr
                                                   #1           Mineral
                                                                Zoar
Figure 4. Longitudinal net acidity values
     Huff Run mainstem
        60
        40
        20
                                   average pre net acidity prior 1997
                                  • average implementation netacidity 1998-2007
                                   current condition 9/18/2007
   ~  -20
   1  -40
   CD
   •ffi  -60
   5  -80
   2-100
   CD
   > -120
      -140
      -160
            RM7.70 RM6.70 RM5.40 RM4.80 RM4.10>RM2.70 RM-^40  RWQAO
                                                  2.70gM-rt
                                     Water quality stations
                                               A-e

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MBI/CABB
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Figure 5. Water quality values at the mouth of Huff Run through time
Mouth of Huff Run at stream mile 0.40
70.00 -
60.00 -
50.00 -
40.00 -
^ 30.00 -
o 20.00 -
| 10.00 -
0.00 -
-10.00 -
-20.00 -
-30.00 -

\
\
8/1/1985 n



\



V


/

8/15/1996


/
/





/



2/13/1997


^* 	 • 	 	 """


o> LO
0) °
Si oo
?5 C!
O>
date
L


**•



	 1 net acidity
-• — ph_lab

-+~~

	
g
O
CM
Si
Csi


	 .

1 1
°
o
oo
o5





r

- 7.00
- 6.00
- 5.00
- 4.00
I
a.
- 3.00
- 2.00
- 1.00
- 0.00
Figure 6. pH values at the mouth of Huff Run through time
Mouth of Huff

14 00
12.00 -
10.00 -
8.00 -
a.
6.00 -
4.00 -
2.00 -
Onn
























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oo
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^
oo



















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O>
O)

55
•<-
oo

Run at stream mile 0.40

















h-
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•<-
CN


















O
O
O

CNi
CO

date

















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o
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CD h-
O O
O O
CM CM
^ So
CM T-
CM O

                                           A-7

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MBI/CABB
Documenting Incremental Change
November 30, 2008
Figure 7. Mouth of Huff Run total iron concentrations
Mouth
10.00 n
9.00 -
8.00 -
B, 7-°°-
E 6.00 -
0 5.00 -
1 4°° "
| 3.00 -
2.00 -
1.00 -
0.00 -
i of Huff Run at stream mile 0.40













































i — • Fe_total_mg

g/l (USEPA ccc)






in co r^ CD
OO CD CD CD
CD CD CD CD
•? LT>  r\i
date






_\ L















§co r*~
o o
o o o
CM CM CM
OO T- OO
CM CM T-
55 ft 55

Figure 8. Mouth of Huff Run aluminum concentrations
   Mouth of Huff Run at stream mile 0.40
                     I Al_total_mgl
                     -Al criteria mg/l (USEPA cmc)
                      Al criteria mg/l (USEPA ccc)
                                                                CM
                                           date
Table 2. Fish assemblage changes at the mouth of Huff Run
RM 0.40
1997
2005
2006
IBI
16
16
18
Fish Species
1
2
7
                                           A-8

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MBI/CABB
Documenting Incremental Change
November 30, 2008
  Table 3. QHEI scores and metric values for sites in Huff Run.


Key
QHEI
Components
River Gradient
Mile QHEI (ft/mile;
(17101) Huff Run
Year: 1997
-7 a -7*5 Kf\ O A "3 O
1 A /i-.DU £4.oy
5.2 60.00 26.58
0.3 60.50 16.48
Year: 2005
7.7 59.50 24.39
* -7 >•••) Kr\ IK r\r\
o./ DO.DU ID.UU
K. A f I f\f\ O £ KO
5.4 77.00 26.58
4— •__ nn f r- fv^
.8 77.0O 15.00
3 A i yf K^"l 1 £^ A O
.0 64.SO 16.48
2.7 68.00 15.00
1.4 67.00 15.00
C\ A £.Q Kf\ 1 L. AO
U.4 DO.DU 16.4B
Year: 2006
K A -TS f\f\ *)t CO
0.4 fb.UU ILD.DO
41 ^A K/^ 1K ^^
.1 a4.DU lo.UU
04 66 RO 16 4R
WWH Attributes
~ 05

ifll
f^s-fOT^iw SS^
C^Si^m11- SSCC
« C5 ™ '(B 5 C ^ 0 .01 ,51 o

• • • •
• MM
• • • • •
• • • • • •

• •
• • •
• •

• •
Bill 1
• • • •
• • • • •
• • • •
• • •
M MM
• • • • •



,s
8 |
1 i
i i

4 A 1 "3
U.I o
5 0.50
6 0.33

2 0.17
3 A OR
U.iiD
0 0.10
2r\ 1 Q
O.lo
5 0.29
4 0.14
5 0.33
4/"l 1 "3
U.I 0
3 0,1 0
6O CA
£,00
R n?R



I
i

n £•3
U.DO
1.33
1.33

0.50
r\ £"3
U.DO
0.10
OOQ
.do
1.00
0.71
1.17
r\ L. Q
U.DO
A /I A
U.4U
c CA
O.OU
HRR
                                                A-9

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MBI/CABB
Documenting Incremental Change
            November 30, 2008
Figure 6. ICI values along the mainstem of Huff Run
    o
    O
       60

       50

       40
       20
       10
        0
             Huff Run longitudinal ICI scores
                     • ICI2005
                     -ICI 2006
                     - ICI WWH wadeable target

                    5.4
          4.1
      river mile
0.3
As levels of the metal concentration decrease as more projects are completed, it is expected the
biological communities will continue to respond positively. However, while metal concentrations
remain higher than the chronic criteria only small incremental changes can be expected.

                                      Monday Creek

Monday Creek, located in the Appalachian Region of southeastern Ohio, is a 27-mile long
tributary of the Hocking River, the latter which flows directly into the Ohio River. The Monday
Creek watershed drains a 116 square-mile area, with streams winding through portions of Athens,
Hocking, and Perry Counties.

The Monday Creek Restoration Project is a collaborative partnership of official and residents of
the Monday Creek watershed, along with more than 20 other organizations and state and federal
agencies. The goal of the project is to restore the watershed for the benefit of local communities.
Extensive portions of Monday Creek and its tributaries are dead due to acid mine drainage (AMD)
left behind from a century of coal mining.

For purposes of the collection of case studies, two reclamation projects have been selected for
review in Monday Creek: Jobs Doser and Essex Doser. Both of these BMPs  are active remediation
projects and require on-going maintenance for operation.
                                           A-10

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November 30, 2008
AMD project name
Jobs Hollow Doser
Essex Doser
Brief description of treatment
Install lime doser, decrease acid
load from headwaters by 54%
Install lime doser
Year completed
2004
2006
Capital
Costs
$ 385,983
$319,720
                                              Grimmett Hollow
                                              ^ Jobs Hollow Doser
      Maxville.

                                   Shawnee.
                                               Jf
                                     ^——- Rock Run Gob Pile
                                        ±	i^Rock Run 24
                  Gore,  New Straitsvtlle.
                                            •'   V    \   \
                                                          Essex Doser
           Lost R
                      Big Four Hollow


                          Snake Hollow
                                    All

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           Documenting Incremental Change
                                            November 30, 2008
Essex Doser
Essex Doser is located in Section 18 of Ward Township in Hocking County and lies within the 14
digit HUG unit #05030204060040. The site is located along Sycamore Hollow, State Route 216.
Sycamore Hollow is a tributary to Snow Fork. The design was completed by ATC Associates for a
cost of $32,320. The treatment was to install a lime doser. The goal of the design was to neutralize
acidity discharging from Essex Mine. The project goal, as indicated from initial post-construction
sampling, has been met 100 percent. Further evaluation of this site will be completed next year
after more data has been collected. A major consideration encountered during the design was the
close proximity of the doser to State Route 216. Construction was complete March 31, 2006, by
AWT Services Inc. for a cost of $287,400. The major responsibility of the construction company
was to install the doser. The funding sources for this project were ODNR-DMRM and EPA-319
for both the design and construction.

In the short amount of time since the Essex Doser was implemented,  an increase in both the
chemical and biological water quality has been documented.  Longitudinal chemical water quality
improvements were  documented from the mine discharge/doser site at river mile 9.77downstream
into Snow Fork for 7 miles. There were increases in pH initially that  remained above 6.5 until
Sycamore Hollow flows into the headwaters of Snow Fork at river miler 6.2. At this point the pH
remains higher than pre-doser conditions but is steadily dropping due to additional acidic-mine
drainage discharges flowing into Snow Fork, Figure 1.  This trend is mimicked in the longitudinal
net-acidity values recorded along the mainstem of Sycamore Hollow and its receiving stream Snow
Fork, figure 2.

Figure 1.  Longitudinal pH values pre and post implementation  of BMP
       Essex Doser
                   pre project pH
                   pre pH
                   pH target
                              I post project pH
                              •postpH
           RM 10.42
discharge
 input RM
  9.77
RM6.82    RM6.2
RM4.3
RM2.45
                                          Water quality stations
                                           A-12

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                        November 30, 2008
Figure 2. Longitudinal net-acidity concentrations pre and post implementation of BMP
        Essex Doser
          pre project net acidity
          pre net acidity
          alkalinity target
      I post project net acidity
      • post net acidity
                                                Water quality stations
From the Mean Annual Load Method (Stoertz and Green, 2004), the calculated acid and metal
load reductions were 724 Ibs/day and 200 Ibs/day respectively, figure 3 and 4.  Essentially all the
acidity has been neutralized and the load to the stream is net alkaline at the mine site. The metals
are precipitating and becoming part of the stream substrate at the site and downstream of the site.
          Pre acid load
          condition

       900

       700 ^B 724 Ibs/day

       500

       300

       100
   Pre metal load
   condition
250
200
150
100
        235 Ibs/day
      Data derived using the Mean Annual Load
      Method (Stoertz, 2004).
   Post acid load
   condition

900

700

500

300

100     0 Ibs/day
   Post metal load
   condition
200

150

100

 50
                                                                                    35 Ibs/day
                           Data derived using the Mean Annual Load
                           Method (Stoertz, 2004).
    The biological response to the chemical changes is small but do demonstrate positive
    change at this time, further monitoring continues. Three miles downstream of the Essex
    Doser before Sycamore Hollow enters into Snow Fork, IBI, ICI, and MAIS were calculated.
    Both IBI and ICI exhibit positive incremental change from 12 to 20 for IBI and 4 to 20 for
    ICI.  Fish count changed from 0 in 2001 and 2005 to 222 in 2006. The overall narrative
    changed from VP to F during this same time period.  The MAIS index didn't indicate a
                                             A-13

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MBI/CABB
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November 30, 2008
Figure 3. Acid load reductions at the Essex Doser site.
O)
_c
'•B
re
o •>;
-1 €
2 «
o £
< ~
O)
0
Essex Doser - Acid Load Reduction
4 00
y = 0.971 8x + 2.861 8
° nn
_-r— *-«r 	
° nn — — ^
1 nn

, n72.000 -1.500 -1.000 -0.500 O.C
° nn
i. nn



y = 0
00 0.500 1.000


Log Qnorm (cfs)
» Pre-treatment 2001 -2005 A Post -treatment 2006-2007
	 Pre-treatment 2001 -2005 	 Post-treatment 2006-2007
Figure 4. Metal load reductions at the Essex Doser site.
                        Essex Doser - Metal Load Reduction
                                                         y = 1.0786x + 1.5477
                                                                           1.000
                                      Log Qnorm (cfs)
              P re-treatm ent 2001 -2005
              Pre-treatment 2001-2005
                 Post -treatment 2006-2007
                 Post-treatment 2006-2007
positive change at this station but did directly downstream of the doser, Figure 5.
Macroinvertebrate family level index, MAIS, indicates in 2007 a MAIS score of 13 (a MAIS
score greater than 11 is equivalent to good quality) at the station directly downstream of
the Essex Doser, Figure 6.

Jobs Hollow Doser
Jobs Hollow Doser is located in Section 5 of Salt Lick Township in Perry County and lies
within the 14-digit HUC unit #05030204060010. The site is located in the headwaters of
Monday Creek Watershed downstream of Jobs Hollow at the bridge on Portie Flamingo
                                        A-14

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MBI/CABB
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November 30, 2008
Figure 5. Biological response three miles downstream of the doser.
3.0 mile
Si
60 n
50
O
— 4D
•0 4U
c
ra
•x 30
fO
i" 2°
<
S
10
n
(S dstr. Essex Doser
tation SY00050
— • — MAIS (3x)
— • — ICI
	 MAIS (3x) and ICI WWH target
— * — IBI
	 IBI WWH target




"\
	 	 r^-
pre (2001) pre (2005)
^
post (2006)
Date
— — •
60
54
48
42
36 m
30
24
18
19
post(2007)
Figure 6. Biological response directly downstream of the Essex Doser
Directly dstr. Essex Doser _^MAS 	 MAS WWH target
Station SY00706



w
o
0
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18 n
16
14
19
1 £.
10
8
6
4
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pre(2005) post(2006) post(2007)
Date
Road (CR 12). The design was completed by ATC Associates for $66,916.50. The
treatment approach for this site was to install a lime doser. The goal of the design was to
decrease acid load from the headwaters of Monday Creek by 54 percent. The project goal
was met 100 percent. Construction was complete July, 20, 2004 by Tuson Inc. for a cost of
319,066.50. Funding sources for this project were ODNR-MRM, OSM-ACSI and OEPA-
319 for design and ODNR-DMRM and OSM-ACSI for construction. Figure 3 and 4
(shown on page 3), approximately 692 Ibs/day of acid was reduced from entering into
                                       A-15

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MBI/CABB
Documenting Incremental Change
             November 30, 2008
Monday Creek as a result of this AMD reclamation project. In addition to the acid loading
reduction measured at this site, there are approximately 338 Ibs/day of alkaline addition to
the headwaters of Monday Creek. Dissolved metal load reduction occurring at this site was
approximately 97lbs/ day. The metals precipitate as a result of the high pH water and
become part of the substrate.

An increase in both the chemical and biological water quality has been documented
downstream of the Jobs Hollow Doser site in the headwaters of the Monday Creek
Watershed and downstream to river mile 16.0.  In addition to the doser,  along this flow
path two other projects have been completed and contribute to the overall changes
occurring.  The Rock Run gob pile was reclaimed in 2000 and enters Monday Creek near
river mile 23.5. The Lost Run subwatershed was completed in November 2006 for Phase I
and January 2008 for Phase II. Lost Run subwatershed discharges into the mainstem of
Monday Creek at river mile 16.1.
Chemical water quality improvements were documented for 10.5 miles downstream of the
doser (RM 26.5) to station MC00500 (RM 16.0).  The pH increases to greater than 6.5 and
remains above 6.5 along the flowpath, Figure 1. During pre-construction time period all
sites were on average net acidic, after implementation average concentrations of acidity
remain net-alkaline for 10.5 miles, Figure 2.

Figure 1. Longitudinal pH values pre and post implementation of BMP
     Jobs Hollow Doser
         pre project pH
         pre pH
        • pH target
I post project pH
• post pH
            upstream   project  downstream MC00800  MC00580   MC00500
            JH00530  discharge  MC00900   RM23.1    RM19.9   RM 16.00
                      JH00500   RM24.2
                       RM26.5
                                 Water quality stations
From the Mean Annual Load Method (Stoertz and Green, 2004), the calculated acid and
metal load reductions were 692 Ibs/day and 97 Ibs/day respectively, figure 3 and 4.
Essentially all the acidity has been neutralized and the load to the stream is net alkaline at
the mine site.  The
                                       A-16

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MBI/CABB
                     Documenting Incremental Change
                                                                           November 30, 2008
Figure 2. Longitudinal net-acidity concentrations pre and post implementation of BMP
     Jobs Hollow Doser
   140
i> 12°
,§ 100
>,  80
1  60
o
CD  40
1  20
     0
   -20 -]
   O)
   CD
       -60
                         pre project net acidity
                        -pre net acidity
                        • alkalinity target
                                                          I post project net acidity
                                                          • post net acidity
upstream
JH00530
                        project   downstream MC00800
                      discharge   MC00900   RM23.1
                       JH00500   RM24.2
                       RM26.5
                                                  MC00580
                                                   RM19.9
MC00500
RM16.00
                                    Water quality stations
metals are precipitating and becoming part of the stream substrate at the site and
downstream of the site.
       Pre acid load
       condition
            692 Ibs/day
              Pre metal load
              condition
                                99 Ibs/day
Post acid load
condition
700
600
400

300

200

100
0 Ibs/day
Post metal load
condition
100
80

60

40

20

3 lbs/da\
   Data derived using the Mean Annual Load
   Method (Stoertz, 2004).
                                      Data derived using the Mean Annual Load
                                      Method (Stoertz, 2004).
The biological response to the chemical changes is very small.  The IBI results show
positive incremental change during 2006 at the two downstream stations, Figure 5. The
ICI results show a positive increase during the post implementation time period of 2005
and 2006,  Figure 6.  Macroinvertebrate family level index, MAIS, display some mixed
results with a definite positive increase in 2006 and 2007 at most sites, Figure 7. In 2007
two sites scored greater than 11 for the MAIS index, the WWH equivalent score (Johnson,
2008), Figure 7. At station RM 19.9, 6.6 miles downstream of the doser both the MAIS
and ICI are in agreement of showing a positive biological response reaching target levels,
however the biological response for the fish community is lagging, Figures 5, 6, and 7.
                                         A-17

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MBI/CABB
Documenting Incremental Change
November 30, 2008
Figure 3. Acid load reductions at the Essex Doser site.
Log Acid Loading
(Ibs/day)
I I I
Jobs Hollow Doser -Acid Load Reduction
4 00 i
y = 0.4843X + 2.8425
3nn *
-nn 	 *
z.uu
1 nn

-inn-2 -1-5 ~1 -°-5 (
y = 0
2nn
.uu
3nn
. •
T^'A


D 0.5


.uu
Log Qnorm (cfs)
• P re-treatment 1997-2004 A Post-tr

eatment 2005-2007
satment 2005-2007

Figure 4. Metal load reductions at the Essex Doser site.
  o>
                   Jobs Hollow Doser- Metal Load Reduction
                                      Log Qnorm (cfs)
             »  Pre-treatment 1997-2004
             — Pre-treatment 1997-2004
                A  Post -treatment 2005-2007
               — Post-treatment 2005-2007

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MBI/CABB
Documenting Incremental Change
             November 30, 2008
Figure 5. Biological response three miles downstream of the doser
   Jobs Hollow Doser
     prelBI(2001)
    - post IBI (2006)
. post IBI (2005)
. IBI VWVH target
             project discharge  MC00900 RM 24.2 MC00800 RM 23.1 MC00580 RM 19.9
            JH00500RM26.5
                                     Water quality stations
Figure 6. Biological response directly downstream of the Essex Doser
      Jobs Hollow Doser
        prelCI/QUAL(2001)

       • post ICI/QUAL (2006)
. post ICI/QUAL (2005)

• ICI VWVH target
           project discharge  MC00900 RM24.2  MC00800 RM23.1  MC00580 RM 19.9
           JH00500RM26.5
                                     Water quality stations
                                            A-19

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MBI/CABB
        Documenting Incremental Change
                                      November 30, 2008
Figure 7. MAIS scores along mainstem Monday Creek
 Jobs Hollow Doser
      18 -,
      16 -
      14 -
   §  12-
   £  10-
   co  8 -
      6 -
      4 -
      2 -
      0
     pre MAIS (2001)
    -post MAIS (2005)
     VPO-7
    • VG>15
            pre MAIS (2002)
           -post MAIS (2006)
            P8-11
                   pre MAIS (2003)
                  -post MAIS (2007)
                   G 12-15
         project discharge
           JH00500 RM
              26.5
MC00900 RM
   24.2
MC00800 RM
   23.1
MC00580 RM
   19.9
MC00500 RM
   16.0
                                     Water quality stations
                                   Little Raccoon Creek

Description
Little Raccoon Creek is a 38.5 mile long tributary to Raccoon Creek in Southeastern Ohio.
Raccoon Creek flows to the Ohio River near the city of Gallipolis in Gallia County Ohio (Map 1).
The headwaters are in south central Vinton County and water flows southeast through eastern
Jackson County and enters Raccoon Creek in northwestern Gallia County.  Little Raccoon Creek,
draining 155 square miles, is a major tributary of Raccoon Creek and accounts for 22% of the
drainage area of Raccoon Creek (683 mi2). Little Raccoon Creek is located within the unglaciated
Western Allegheny Plateau Ecoregion and although the landscape topography is steep, the
gradient of Little Raccoon Creek is about 4.2 feet per mile.  Little Raccoon Creek discharges
approximately 400 cubic feet per second (cfs) into Raccoon Creek during high flow and less than
10 cfs during low flow.

Mining History
In the Little Raccoon Creek watershed, acid mine drainage (AMD) from abandoned underground
and surface coal mine spoils and coal refuse, has degraded stream water quality and damaged fish
and macroinvertebrate habitat.  Coal mining occurred in approximately 22% of the Little Raccoon
Creek basin. Coal has been mined underground in  the watershed since the  1840's. Surface mining
became the dominant type of mining starting in the 1930's and accounts for more than 90% of
the coal removed to date. Surface mining continues in the watershed.

Mines are found throughout the Little Raccoon Creek watershed, but those that most affect the
water quality are in Jackson County between tributaries Dickason Run (RM 12.57) and Mulga
Run (RM 24.45). Acid and metals reduce the number and diversity of aquatic organisms, increase
                                           A-20

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MBI/CABB
Documenting Incremental Change
November 30, 2008
the corrosiveness of the water, limit domestic use of the water, and impair the aesthetic qualities of
the water.

Watershed Restoration Efforts
The Raccoon Creek Partnership is a member based, nonprofit (501 (c) (3)) organization that was
formed to improve and protect water quality in the Raccoon Creek Watershed. The RCP has
partnered with ODNR-DMRM, ODNR-DOW, Soil and Water Conservation Districts, OEPA,
Ohio Valley RC&D, OSM and others to fulfill their mission statement: "to work toward
conservation, stewardship, and restoration of the watershed for a healthier stream and
community".

The Raccoon Creek Partnership has implemented 6 AMD treatment projects in the Little
Raccoon Creek Watershed since 1999. Table 1, shows the name of the project, brief treatment
description and year completed. Further project details such as BMP, costs, etc. are on the NPS
website at www.watersheddata.com under Reports/Raccoon Creek.

          Table 1. Completed AMD Projects in the Little Raccoon Creek Watershed
AMD Project Name
Buckeye Furnace
(Buffer Run
subwatershed)
SRI 24 Seeps project
Mulga Run
Middleton Run -
Salem Road
Flint Run East
Lake Milton
Brief Description of
Treatment
Reclamation,
Successive Alkaline
Producing System
(SAPS)
Reclamation, Open
Limestone Channels
(OLC)
2 Steel Slag Leach
Beds (SLB), wetland
enhancement
Reclamation, OLC,
steel slag channel,
Limestone Leach Bed
(LLB)
Reclamation, SLB,
LLB, SAPS, OLC,
wetland enhancement
SAPS, SLB
Year Completed
1999
2001
2004
2005
2006
2007
Total Cost
$1,090,530
315,490
440,783
687,913
1,456,106
961,536
Acid Load Reduction at Little Raccoon Creek Treatment Sites
Data derived using the Mean Annual Load Method (Stoertz and Green, 2004) shows that acid
loads were reduced following construction at all treatment sites. Figure 1 shows this reduction in
pounds per day as well as percent reduction, an important comparison as acid loads vary
                                           A-21

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MBI/CABB                       Documenting Incremental Change                November 30, 2008


considerably from site to site. Overall, acid loads into Little Raccoon Creek have been reduced by
a total of 4,700 Ibs/day since 1999. Total iron has been reduced by 291 Ibs/day, aluminum 286
Ibs/day, and manganese 48 Ibs/day.

Water Quality Changes in Little Raccoon Creek
Water quality in Little Raccoon Creek has  improved dramatically since the first survey by the
Division of Wildlife in the 1950's which showed an acidic stream with little to no aquatic life.
Water sampling in the 1980's in Little Raccoon Creek still showed acidic conditions with low pH
for the majority of the stream, especially downstream of river mile 24.5 where abandoned mines
are common.  However, since the 1990's water quality in the lower section of Little Raccoon
Creek has shown dramatic improvements.  At river mile 1.17, near its confluence with Raccoon
Creek, the pH of Little Raccoon Creek has increased from 3-4 in the 1980s to 7-8 in recent years
(Figure 2).  The change in pH correlates with acidity concentration decreases over time as alkalinity
increased providing buffering capacity (Figure 3). Total acidity of LRC at all Little Raccoon Creek
sites when compared to historical data. In fact, all Little Raccoon Creek long term monitoring
stations meet the 20 mg/1 net-alkalinity concentration target established by Ohio EPA in the
TMDL for the Upper Basin of Raccoon Creek (adjacent watershed within Raccoon Creek) since
2005  (Figure 4).  However, the impact of AMD is still noticeable on Little Raccoon Creek as
alkalinity levels drop  from upstream to downstream as acid from AMD sources enter the stream
and buffering capacity is lost. Net-alkalinity concentrations vary greatly with flow, with alkalinity
highest during low flow and lowest during  high flow.  This is mostly due to acidic runoff from
abandoned surface mine spoil present in the watershed during precipitation events  or seasonally
high groundwater levels.

Biological Changes in Little Raccoon Creek
The trend of improving water quality continues as the Raccoon Creek Partnership implements
AMD treatment projects, especially in the lower 18 miles of Little Raccoon Creek.  IBI data for
1995/1999 was only  collected at four sites  but all showed considerable improvement from 1984
data,  especially in the lower reaches of Little Raccoon Creek (Figure  5). Data collected in
2005/2007 indicates even more improvement from 1995/1999 data and significant improvement
from  1984 near the mouth of Little Raccoon Creek.  IBI scores are meeting the criteria for WWH
for the WAP Ecoregion from river mile 12.71 to the mouth. Mid portions of the watershed have
shown minimal improvement, as this area is the most severely impacted by AMD and where more
AMD treatment is  needed.

ICI data also suggests notable biological improvement in Little Raccoon Creek from 1984 to 1999
(Figure 6).  Macroinvertebrates (ICI) were collected in 2005 but because of extremely low water
levels  and lack of flow, the data could not be used for comparative purposes. In 1990 the upper
reaches of LRC showed significant improvement at both sample sites, with one attaining WWH
criteria. 1995 scores  decline slightly at river mile 28 but in general, show an improvement of
about 10 points further downstream. Five  sites were sampled in 1999 indicating significant
biological improvement with the lower sections of the watershed exceeding WWH criteria.  Again,
the middle section of the watershed shows  some incremental improvement but not complete
recovery, as this area  is still impacted by untreated AMD.

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MBI/CABB
Documenting Incremental Change
November 30, 2008
Macroinvertebrate Aggregated Index for Streams (MAIS) data has been collected since 2005 at all
long term monitoring sites.  MAIS data has shown direct correlation between upstream AMD
project completion and downstream biological improvement. In reaches where AMD treatment
projects have significantly reduced acid loads to Little Raccoon Creek, macroinvertebrate
communities have responded quickly with steadily increasing MAIS scores from 2005-2007. For
example, in Little Raccoon Creek downstream of the Mulga Run AMD treatment project MAIS
scores improved steadily over the years since the project was implemented (Figure 7).  At river mile
22.3 just downstream of Middleton Run where an abandoned mine land reclamation and
treatment project was completed in December of 2006, MAIS score improved two points in 2007
from 2005 & 2006 scores (Figure 8). And lastly at river mile 18.7, a noticeable improvement was
documented after the completion of two AMD treatment projects (Flint Run East and Lake
Milton) both located in the Flint Run tributary just a x/4 mile upstream (Figure 9).

        Figure 1. Little Raccoon Creek Acid Load Reductions at AMD Treatment Sites

2000 -
1800 -

1600 -

c 1400 -
£
u
"g 1200 -
-a
re
° 1000 -
2
u
• 8oo -
•S
^
S3
- 600-
400 -
200 -
o
















-

Little Raccoon Creek Acid Reduction



• Acid Load Reduction Ibs/day
• % Acid Load Reduction





I









T



































1





1 [] n
1


























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r 100
- 90

- 80
£•
- 70 S
£

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- 60 E
0
u.
- 50 §
—i
2
- 40 <
&
£
30 o
5?
- 20
- 10
n
Buffer Run Unnamed Trib - SR1 24 Mulga Run M ddleton Run Flint Run

AMD Project Tributary
                                           A-23

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MBI/CABB
Documenting Incremental Change
November 30, 2008
                  Figure 2. pH Trends in Little Raccoon Creek at RM 1.17
Little Raccoon Creek RM 1.17
14 nn T
19 nn
1 n nn
Q nn
R nn
A nn
9 nn
n nn


R2 = 0.6065
;*«;*** __^*i-~
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MBI/CABB
             Documenting Incremental Change
                                        November 30, 2008
            Figure 4. Little Raccoon Creek Net-Alkalinity Concentrations: 2005 - 2008
      140
      120
              24.55
                                     LRC Net-Alkalinity Mar 2005 - Jan 2008
-189cfs 3/7/2005
 300 cfs 2/6/2006
-9.2cfs 7/9/2007
-65 cfs 5/9/2005
-27 cfs 7/17/2006
-31 cfs 1/28/2008
8.4 cfs 10/3/2005
73 cfs 4/24/2007
OEPA Net-Alk Target 20 mg/l
                          24.3
                                      22.3
                                                  22.15
                                                               19.5
                                                                           18.5

                                                                                       12.71
                                                                                                   1.17
  Average acid loads Mu|ga Run    Middleton Run St Rt 124 Seep    Flint Run     Buffer Run     Goose Run
  at tnb mouths     -1321.45    1301.41 Ib/day   50.07 Ib/day    995.65 Ib/day   305.74 Ib/day   197.16 Ib/day
                    Ib/d
             Figure 5.  Index of Biologic Integrity (IBI) Scores in Little Raccoon Creek


40 -
0
0 30
v) Ja
m


Index of Biologic Integrity (IBI) Scores in Little Raccoon Creek

; B1984 B19950M999 B2005or2007


l.wWHCrit
_ VWVH Crit
;
;
;
ria for WAP Ecoregion - Wading Methc
ria for WAP Ecoregion - Boat Method
X


t
/


d ^ - •









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\
t
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*



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p






40 39 38 37 36 35 34 33 32 31 30 29 28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 1 1 10 9 8 7 6 5 4 3 2 1
River Mile - Sampling Location
?iver Mile 22 & 24 are "wading" method, all others are "boat
th d"
                                                    A-25

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MBI/CABB
Documenting Incremental Change
November 30, 2008
  Figure 6. Macroinvertebrate Community Improvement (ICI) Scores in Little Raccoon Creek
Little Raccoon Creek Macroinvertrebrate Community Improvement
ICI Scores 1984 to 1999
Source: USQS and OEPA Data


c Score
*J 4
D C
ly
£
O




• 1984 -ICI • 1990 -ICI • 1995 -ICI


• 1999- ICI

	 	 	 — — ~~ **"




/
/
/







--.

\
\
-
' — ..

/
/
-









-




40 39 38 37 36 35 34 33 32 31 30 29 28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1
River Mile
Note: RM 13 was sampled in 2 different locations in 1999 and 2005, higher score in 1999 could be explained by better
hahitat
                  Figure?. MAIS Analysis at Little Raccoon Creek RM 24.4

16


£
o
« 10
o
«
* 8
<
^



Little Raccoon Creek RM 24.4 MAIS Analysis



Mulga Run AMD Treatment project
completed in Spring of 2004 which reduced
acid loads by 17 Ibs/day and metal loads by
128 Ibs/day. Mulga Run enters LRC at RM
24.5
	 / 	 	

MAIS Target for VWVH
/
/
/
/








2005















2006 2007
Year Sampled
                                          A-26

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MBI/CABB
Documenting Incremental Change
November 30, 2008
                        Figure 8.  MAIS Analysis at Little Raccoon Creek RM 22.3
                                         Little Raccoon Creek RM 22.3 MAIS Analysis
           18
           16
           14
           12
         I 10
         _o
         •s
         I  8
                    MAIS Target for WWH
               Middleton Run - Salem Road AMD
              Treatment project was completed in
             December of 2006 which resulted in 764
             Ibs/day of acid load and 94 Ibs/day metal
             load reductions. Middleton Run enters
                      LRCatRM22.4
                             2005
                                                               2006
                                                           Year Sampled
                                                                                                 2007
                        Figure 9.  MAIS Analysis at Little Raccoon Creek RM 18.7
                                          Little Raccoon Creek RM 18.7 MAIS Analysis
             18
                   MAIS Target for WWH
             10
                 Lake Milton AMD Treatment project (in
                 Flint Run subwatershed) completed in
                  Fall of 2006 reduced acid loads by
                 another 1,200 Ibs/day and metal loads
                         by 103 Ibs/day.
                        Flint Run East AMD Treatment project
                        completed in Spring 2006 reduced acid
                        loads by 803 Ibs/day and metal loads
                          by 107 Ibs/day. Flint Run enters at
                                approx. RM 20.2
                              2005
                                                               2006
                                                           Year Sampled
                                                                                               2007
                                                           A-27

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MBI/CABB                       Documenting Incremental Change                November 30, 2008
                    Little Raccoon Creek Changing Biological Conditions

1952 - Ohio Department of Natural Resources Wildlife Council Study:
All sites in this survey were upstream of the current SR 32, which is upstream of the major AMD
loaders into LRC at present.  However, it does appear that AMD was more prevalent in the section
of LRC in the 1950's according to this report.  Test netting at SR 75, North of the village of
Hamden, caught a few fish in all four quarters  (Winter, Spring, Summer, & Fall) consisting of
primarily bullhead catfish and suckers. The greatest catch was 36 fish in the last quarter. Below
Lake Alma fish were caught only during the second quarter and were primarily suckers and
bullhead catfish with a total catch of 22 fish. East of Wellston, further downstream, fish were
taken every quarter except the first when free acidity was present. 8 to 11 fish were caught
consistently in the last three quarters at this site.  Test netting sampling consisted of using a hoop
net or a fyke net modified for stream fishing and sampling lasted for 7 2 hours per sampling
station.

1984 - Ohio EPA Biological Survey
Fish sampling was conducted at 6 stations along the  mainstem of Little Raccoon Creek. IBI scores
ranged from 12 near the mouth to 32 above Lake Rupert. Above Mulga Run, IBI scores were
above 30 at 3 out of the 4 sites with the exception of a 23 downstream of Lake Alma.  A site
downstream of Dickason Run at river mile 11.0 had an IBI of 12 and only two fish were captured
(1  Green sunfish and 1 Green X Longear hybrid sunfish).  Further downstream near the mouth at
river mile  1.8 (Koontz Sailor  Road) received the same IBI score of 12.  Only two fish were caught
at  this site and they were both Longear Sunfish.

1989 & 1990 - USGS and Ohio EPA Biological Surveys
3 sites combined were sampled and all were upstream of Mulga Run and downstream of Sandy
Run where the greatest problem with AMD is not encountered. IBI scores ranged from 26 - 34.

1995 Ohio EPA Biological Survey
Three sites were sampled: RM 11.0 at Keystone Road, dst. Sandy Run (RM 28.3), and upst. of
Mulga Run (RM 24.6).  Downstream of Sandy Run had an IBI of 38 and ICI of 36. SR 32 upst.
Mulga Run had an IBI of 36  and an ICI of 28. The  Keystone Road site showed the most dramatic
change with an IBI of 18 and an ICI of ??. This is a dramatic improvement from the 1984 data
with an IBI of 12 and ICI of  ??. Fish diversity increased at this site  from 2 fish (Green Sunfish and
Green X Longear Hybrid) to  17 species and 111 fish.

1999 USGS Biological Survey
USGS surveyed a total of six  sites in 1999 on the mainstem of LRC which is summarized in the
LRC AMDAT plan.  Macroinvertebrate data was collected at all six sites and fish were collected at
two sites only (RM 12.8 & 12.5).  If the RM 12.5 site (dst. of Dickason Run) is compared with the
RM 11.0/11.8 OEPA site, there is a dramatic increase in ICI values. The ICI goes from a ?? in
1984, an 18 in 1995, to a 34  in 1999. The IBI goes from a 12 in 1984, a 37 in 1995,  to a 40 at the
same site.  The 1999 data shows a stretch nearly meeting WWH criterion according to IBI and
ICI.
                                           A-28

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MBI/CABB                       Documenting Incremental Change                November 30, 2008


Conclusions
The 1952 DOW study showed low fish populations and diversity and documented AMD impacts
in the upper third of the watershed (upstream of SR 32). This is interesting because there is very
little evidence of AMD upstream of SR 32 currently and according to the 1999 AMDAT study
none of the major AMD loaders were in this part of the watershed.

Since Ohio EPA began collecting biological data in the watershed it is evident that biological
communities have improved drastically. Upstream of SR 3 2 and Mulga Run (the furthest
upstream major AMD loader) there is contradictorily data. IBI scores are 30, 31, 23, and 32 as you
move upstream from RM 25 to 37. The 23 IBI is due to point source impacts not AMD.  This
demonstrates relatively fair fish community performance, although not  meeting WWH status.
However, ICI scores show macroinvertebrates are more  impacted with ICI scores at RM 25 & 28
scoring 16 and 12 respectively. This section of the creek shows dramatic improvement in ICI
scores according to the 1990 and 1995  data with a high score of 28 in 1995 at RM 25 and both
dates scoring over 36 (WWH) at RM 28.  IBI scores show improvement also but not as drastic as
ICI at RM 25 and RM 28. 1995 data has an IBI of 36 and 38 at these two sites. Both the fish and
macroinvertebrate scores are relatively close to meeting WWH status in this upper section of the
creek according to the most recent data.

In 1984 from RM 12 downstream  to the mouth, 2 IBI scores of 12 were recorded with only 1 to 2
species present. ICI at RM 12 scored an 8, also exceptionally low. Basically, the creek was devoid
of much life in 1984 in this lower section, which is downstream of all the major AMD loaders.
However, more recent data show dramatic improvement. Sampling at approximately RM 11 in
1995 showed an IBI of 37 and at RM 12 an ICI of 18. Both sites showed improvement, but it's
much more profound in the fish population.  RM 13 was sampled in 1999 (still dst. of all major
AMD loaders) and showed even more improvement in both macro's and fish with an ICI of 34
and an IBI of 40. A site further downstream at RM 3 was only sampled for macroinvertebrates,
but scored an ICI of 44, which is meeting WWH habitat. Fish populations have not been sampled
below RM 11 since 1984 but with  macro's improving it would be likely for improving fish
populations as well. According to  the biological data it appears that the conditions  in Little
Raccoon Creek have been improving drastically over the past 20 to 50 years.  If decreases in AMD
are continued there is evidence to suggest LRC would recover to attain  WWH status.

                Little Raccoon Creek Water Quality Improvement Summary

Little Raccoon Creek (LRC) has been severely impacted by acid mine drainage from abandoned
coal mines in Jackson County. The majority of mining occurred between RM 24.5  and RM 13 in
LRC or subwatersheds.  Historical data from the 1970's and 1980's show acidic conditions from
RM 24.5 downstream and fish and macroinvertebrate populations severely impaired if existent.

Historical water quality data sets show a trend of improvement in the late 1980's or early 1990's as
mining decreased, reclamation laws were enforced, and  ODNR began reclaiming abandoned mine
lands.  The trend of improving water quality continues today as the  Raccoon Creek Partnership
implements AMD treatment projects, especially in the lower 18 miles of LRC.  Sampling locations
                                           A-29

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at RM 1.17 and 12.71 meet WWH criteria for fish and score in the "Good" range for the MAIS
metric in 2007. ICI data in 2005 still showed impaired conditions at these sites with scores of 26
& 24 respectively but have not been sampled since.

The Raccoon Creek Partnership has implemented 6 AMD treatment projects in the Little
Raccoon Creek Watershed since 1999.  Project details such as BMP, costs, etc... are on the NPS
website at www.watersheddata.com under Reports/Raccoon Creek.

              1999: Buckeye Furnace (Buffer Run subwatershed)
              2001: SRI24 Seeps project
              2004: Mulga Run
              2005: Middleton Run - Salem Road
              2006: Flint Run East
              2007: Lake Milton

Since 2005, 8 long term monitoring events in LRC show attainment of a 20 mg/1 net-alkalinity
target established in the RC Headwaters TMDL by Ohio EPA (2003). Alkalinity concentrations
vary greatly with flow in LRC, with alkalinity highest during low flow and lowest during high flow.
This is due to acidic runoff from surface mines during precipitation and high groundwater
interacting with coal refuse piles.  Iron and Aluminum have yet to be graphed for these same sites
and time period.

                     Hewett Fork Water Quality Improvement Summary

Hewett Fork is a 40.5 square mile, 15.4 mile long tributary to Raccoon Creek in Southeastern
Ohio (Map 1). Hewett Fork flows  from north to south/southwest in Hocking, Athens, and
Vinton Counties and contains a large amount of public property including Zaleski State Forest,
Waterloo Wildlife Area, and the Wayne National Forest.

Community driven watershed action has existed in Raccoon Creek since the early 1980's with an
active restoration partnership taking hold
in the late 1990's.  Currently, the
Raccoon Creek Partnership, a
membership based non-profit
organization coordinates water quality
restoration projects along with education
and outreach efforts in the watershed.
Since 1999, agencies and organizations
involved with the Raccoon Creek
Partnership have implemented 10  acid
mine drainage (AMD)
treatment/abatement projects to improve
water quality and restore aquatic life in
Raccoon Creek and its tributaries.
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One of those projects is the Carbondale Doser.  The Doser project was completed in the spring of
2004 at a cost of $389,637 with EPA and ODNR funding and was the second attempt at AMD
treatment at the abandoned underground coal mine near the village of Carbondale.  The first
attempt, an aerobic wetland installed by the Ohio Department of Natural Resources Division of
Mineral Resources Management in the early 1990's did not improve biological conditions in the
receiving stream, Hewett Fork.  A 75 ton silo dispenses calcium oxide pellets into the AMD water
via a water wheel and auger. The calcium oxide mixes with the acidic water in a concrete channel
with nine, six inch drops before entering Hewett Fork at river mile 11.0.

     Pre & Post Construction Pictures of the Carbondale Doser AMD Treatment System.
     Pre-construction                                Post-construction
                   'a^g^i.t: -:'  -

                    m*
The goal of the lime doser was to eliminate acid loads into Hewett Fork from the Carbondale
mine and to improve water quality and biota in Hewett Fork downstream of the doser. The
project was successful at neutralizing the entire acid load from the site. Based on 18 pre treatment
and 10 post treatment samples, a mean of 785 pounds per day were neutralized by the doser
(Figure 1). In addition, 631 pounds per day of additional alkalinity are discharged into Hewett
Fork post treatment.  Iron and aluminum loads increased to pre-wetland treatment system levels
because the eliminated wetland was capturing and storing between 25 - 50% of the aluminum and
iron load. Currently the mean iron loading from the site is 190 Ibs/day and aluminum is 105
Ibs/day.

Mean pH levels increased at all sampling sites downstream of the doser post treatment (Figures 2
& 3). Before dosing only the lower 3.9 river miles had a mean pH over  the USEPA high level of
protection of pH 6.0.  Since dosing, the entire 11 miles downstream of the doser have a mean pH
over 6.0 and 4 out of the 5 sites are above pH 6.5 (maximum level of protection). Alkalinity
concentrations also increased from pre to post treatment (Figures 4 & 5). The entire 11 river
miles downstream of Carbondale in Hewett Fork exhibited net-acidic conditions pre-treatment
(with limited data at some sites.  Post-treatment shows net-alkaline conditions  for the entire length
of Hewett Fork demonstrating water quality improvements.  On average, the lower 3.9 river miles
attain the 20  mg/1 net-alkalinity concentration established by Ohio EPA for the Upper Basin
Raccoon Creek TMDL in 2003. Limited data for iron and aluminum,  the dominant metals
associated with abandoned coal mines in the area, exists to compare pre & post conditions at most
Hewett Fork sampling sites. Post treatment concentrations of iron and aluminum remain high
close to the doser but decrease in concentration towards the mouth of Hewett Fork (Figures 6 &
7).  In summary, AMD treatment improved water quality conditions such that pH and net-
alkalinity have improved throughout Hewett Fork.  Total concentrations of aluminum and iron
                                          A-31

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                          Map 1: Hewett Fork Watershed
                                                   Hewett Fork
                                    A-32

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 Figure 1: Acid Loading at the Carbondale AMD Discharge (HF131) Pre and Post Lime Dosing
        3000
        2000 -
   ra   1000
   TJ

           0  -
       -1000 H
       -2000 -
       -3000
                               HF131 PreDoser
                        HF131 Post Doser
are incremental in most of Hewett Fork but are below EPA criteria in the lower 3.9 river miles.

Incremental changes in the Fish and Macroinvertebrate communities were documented from 2004
- 2007. Only one sample site pre-treatment existed on Hewett Fork, which was at river mile 8.3
(2.7 miles downstream of the Carbondale AMD discharge). Fish responded immediately at river
mile 8.3 with an increase from 0 species in 2000 pre-dosing to 8 species present in 2004, just
months after treatment at Carbondale (Figure 8). The number  of fish species at the site has
remained between 8-10 since 2004. Macroinvertebrate communities also showed improvement
from pre to post treatment at river mile 8.3 of Hewett Fork using the Macroinvertebrate
Aggregated Index for Streams (MAIS) metric (Family Level) (Figure 9). Overall the fish community
improved from 2004 - 2007 in the lower 8.3 river miles of Hewett Fork with the most productive
fish communities in the lower 3.9 river miles (Figure 10).  2007  data showed slight decreases in IBI
at most sites which is likely related to a low water levels as opposed to higher levels of AMD.
Macroinvertebrate data show a similar trend as fish data along Hewett Fork with improving
conditions moving downstream from the doser in 2006 and 2007 (Figure 11).

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            Figure 2: pH in Hewett Fork Pre AMD Treatment (Carbondale Doser)
          14
          12 -
          10 -
           8 -
           6 -
           4 -
           2 -
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                             IT



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                                          A-34

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           Figure 3: pH in Hewett Fork Post AMD Treatment (Carbondale Doser)
                      DL
                      CM

                      LL
                      T.
cc

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                                           A-35

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   Figure 4: Net-Alkalinity Concentrations in Hewett Fork Pre AMD Treatment (Carbondale
                                        Doser)
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                                         A-36

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  Figure 5: Net-Alkalinity Concentrations in Hewett Fork Post AMD Treatment (Carbondale
                                          Doser)
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            200
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                                           A-37

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 Figure 6: Total Iron Concentrations in Hewett Fork Post AMD Treatment (Carbondale Doser)




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                                         A-38

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 Figure 7: Total Aluminum Concentrations in Hewett Fork Post AMD Treatment (Carbondale

                                          Doser)
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  Figure 8: Fish Species Richness at Hewett Fork River Mile 8.3 Pre & Post AMD Treatment

                                     (Carbondale Doser)
    12
    10
     6
  •5
  *
     2
          Doser Operational

          in Spring of 2004
              2000
                               2004
                                                2005
                                                                 2006
                                                                                  2007
                                            A-40

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  Figure 9: Macroinvertebrate Aggregated Index for Streams (MAIS) Metric Scores for Hewett

                                     Fork River Mile 8.3

                      Pre & Post AMD Treatment (Carbondale Doser)
    7
    5
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    2
    1 -
       Doser Operational
       in Spring of 2004
          2000
                       2002
                                   2003
                                               2004

                                               TIME
                                                           2005
                                                                       2006
                                                                                   2007
                                            A-41

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     Figure 10: Index of Biological Integrity (IBI) Scores for Hewett Fork Pre & Post AMD
                                Treatment (Carbondale Doser)
        WWH Criteria for WAP Ecoreqion (wading sites)
                                                                                0.9

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  Figure 11: Macroinvertebrate Aggregated Index for Streams (MAIS) Metric Scores for Hewett
                                             Fork
                       Pre & Post AMD Treatment (Carbondale Doser)
         MAIS Target (WWH)
                   V
                                          2005
                                       -Q20I
                                              -2000

                                              -2002

                                               2003

                                               2004

                                              -2005

                                              -2006

                                              -2007
                                        8.3        6.4
                                          RIVER MILE
                                             A-43

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                                      REFERNCES

Stoertz, M.W. and D.H. Green. 2004. Mean Annual Acidity Load: A Performance Measure to
    Evaluate Acid Mine Drainage Remediation.  Ohio DMRM Applied Research Conference
    2004.  Mineral Resource Extraction and Restoration Innovations. Ohio University, Russ
    College of Engineering and Technology, Athens, OH.

Yoder, C.O. 1998. Important concepts and elements of an adequate state watershed monitoring
    and assessment program, pp. 615-628. in Proceedings of the NWQMC National Conference
    Monitoring: Critical Foundations to Protecting Our Waters. U.S. Environmental Protection
    Agency, Washington, DC.

Yoder, C.O. and E.T. Rankin. 1998.  The role of biological indicators in a state water quality
    management process. J. Env. Mon. Assess. 51(1-2): 61-88.
                                          A-44

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MBI/CABB             Documenting Incremental Improvement - Appendix B         November 30, 2008
                                    Appendix B
 Demonstrating Incremental Improvement:  Adequate Indicators and Monitoring
      and Assessment Are Essential to Accurate Watershed Characterization
                                    Prepared for:
                  U.S. EPA, Office of Wetlands, Oceans, and Watersheds
                      Assessment and Watershed Protection Division
                                   TMDL Program
                                Results Analysis Project
                                1200 Constitution Ave.
                               Washington, D.C. 20460
                       Douglas Norton, Work Assignment Manager
                         U.S. EPA, HECD Contract 68-C-04-006
                                Work Assignment 4-68
                                    Submitted by:
                     Center for Applied Bioassessment and Biocriteria
                             Midwest Biodiversity Institute
                                   P.O. Box 21561
                              Columbus, OH 43221-0561
                          Chris O. Yoder, Principal Investigator
                                  voder @rr ohio .com

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MBI/CABB               Documenting Incremental Improvement - Appendix B         November 30, 2008
                                      Appendix B

     Demonstrating Incremental Improvement:  Adequate Indicators and Monitoring and
              Assessment Are Essential to Accurate Watershed Characterization

                                       Background

As the need for adequate supplies of clean water increases, concerns about public health and the
environment escalate, and geographically targeted watershed-based approaches increase, the
demands on the water quality monitoring "infrastructure" will likewise increase. These demands
cannot be met effectively nor economically without fundamentally changing our attitudes towards
ambient monitoring (ITFM  1995). An adequate ambient monitoring and assessment framework is
needed to ensure not only a good science-based foundation for watershed-based approaches, but
water quality management in general. This paper attempts to describe the important elements,
processes, and frameworks that need to be included as part  of an adequate State monitoring and
assessment program and how this should be used to support the overall water quality management
process. Furthermore, it is a goal of this effort to highlight the need to revitalize monitoring,
assessment, and environmental indicators as an integral part of the overall water quality
management process.
Monitoring and assessment information, when based on a sufficiently comprehensive and rigorous
system of environmental indicators,  is integral to protecting human health, preserving and
restoring ecosystem integrity, and sustaining a viable economy. Such a strategy is intended to
achieve a better return on public and private investments in environmental protection and natural
resources management.  In short, more and better monitoring and assessment information is
needed to answer the fundamental questions that have been repeatedly asked about the condition
of our water resources and shape the strategies needed to deal with both existing and emerging
problems within the context of watershed-based management.

Watershed-based approaches are gaining widespread acceptance as a conceptual framework from
within which water quality management programs should function. However, overall reductions
and inequities in State ambient monitoring and assessment programs jeopardize the scientific
integrity of watershed-based approaches. This also has had the undesirable effect of failing to
properly equip the States and EPA to adequately meet the challenges posed by recently emerging
issues such as cumulative effects, nonpoint sources, habitat  degradation, and interdisciplinary
issues (e.g., TMDLs) in general. In response to these concerns a framework for adequate
watershed monitoring and assessment was developed in 1997.

A Framework for Adequate Monitoring and Assessment
Yoder (1998) detailed a framework for assuring that state monitoring and assessment programs are
adequate in terms of parameters, indicators, design, and assessment outputs.  Some of the
contemporary efforts to revitalize and better define the role of monitoring and assessment in state
and federal programs (ITFM 1992, 1995; U.S. EPA 1994) and the emergence of workable,
biological indicator concepts (Karr and Dudley 1981; Karr et al. 1986) offer detailed frameworks
that are the basis of what is termed here as "adequate" monitoring and assessment (Yoder 1998).
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The term "adequate" was deliberately chosen as a theme on which to base the template for
evaluating individual state programs. It is an attempt to avoid usage of the term "minimum"
which is what EPA has historically accepted. The term "comprehensive" was considered, although
it can imply doing more than is necessary to achieve the basic goals and objectives outlined by the
above referenced processes.

The baseline components of an adequate monitoring and assessment program were originally
described in Important Concepts and Elements of an Adequate State Watershed Monitoring and
Assessment Program (Yoder 1998). This document relied principally on the products and
recommendations of the ITFM process, EPA's environmental indicators initiatives of the 1990s,
and the experiences of selected states in operating consistent and adequately funded programs. In
turn, these efforts have given critical foundational support to EPA's CALM process and later the
TALU process (U.S. EPA 2005). What is different here is the greater level of detail and specificity
regarding specific roles and types of indicators and parameters and the tie-in to WQS, specifically
designated uses and criteria. It is a fundamental premise of adequate monitoring and assessment
that achieving a sufficient level of integration and detail is contingent on actually executing an
adequate approach to monitoring and assessment.  This includes the incorporation of essential,
underlying concepts in addition to the adequacy of what is measured and monitored and over what
spatial scales that it takes place.  It also includes "infrastructure" issues such as staffing (including
professional qualifications), facilities (e.g., laboratory, equipment, instrumentation), and support
(e.g., data management, fiscal and administrative support). It is important to recognize that
achieving adequacy is as much about framework and process as it is about data sufficiency.
Successfully addressing the process issues are key to resolving the current deficiencies and
inequities within and between state programs and still lingering questions about the reliability of
state and national 305[b] reports and, by extension, 303[d] listings, nonpoint source and watershed
management, and WQS. Certainly measuring incremental change is an important outcome of this
process.

An important prerequisite to achieving an adequate monitoring and assessment approach is the
incorporation of fundamental concepts in the development of the indicators and criteria that
operationally determine the status of aquatic resources,  designated uses, and the effectiveness of
water quality management. These include a comprehensive approach to developing indicators and
endpoints leading to the appropriately detailed and refined criteria and standards that guide
management programs and measure their effectiveness.  This approach addresses two of the
principal issues identified by the National Research Council (NRC 2001)  in their review of the
role of science in the TMDL process; 1) adequate monitoring and  assessment, and  2) appropriately
refined and detailed water quality standards (WQS). Adequate monitoring includes the following
key attributes and principles:

    •   Indicator development, position, and selection adhere to baseline theoretical concepts (i.e.,
       Karr's five factors; NRC position of the standard [NRC 2001]);
    •   Indicators are comprehensive, yet cost-effective;
    •   Indicators are used within their most appropriate roles (stress, exposure, or response);
    •   Indicators are directly tied to WQS via designated uses and numerical or narrative criteria;
                                            A-3

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       The Five Major Factors  Which  Determine  the
       Integrity of Aquatic Resources
            Solubilities
                            Alkalinity
                                                                      High/Low
                                                                      Extremes^
                                                                     Precipitation &
                                                                        Runoff
                                                   INTEGRITY OF THE
                                                  WATER RESOURCE
                                                                 Width/Depth
                                                                  Bank Stability
                                                                      Channel
                                                                     Morphology
                                                         Canopy
Figure 1.  The five factors which determine the integrity of aquatic ecosystems with selected attributes of each
         (modified from Karr et al. 1986).
     •  Measurement and data quality objectives (MQO/DQO) are defined in the WQS and are
       adequate to support accurate assessments and perform diagnostic functions;
     •  The program can adapt quickly to improved science and technology;
     •  The program is supported by adequate resources, facilities, and professionalism;
     •  The spatial design(s) matches the scale at which management is applied; and,
     •  The end product is an integrated assessment, not just the data.

 Theoretical Concepts - Karr's Five Factors
 One of the most important concepts developed over the past three decades is the recognition of
 how diverse human  activities  alter water resources and the extent to which those activities interact
 with topographical, geological, climatological, and biological differences among watersheds (Karr
 and Yoder 2004). Five features (or factors) of water resources that are altered by the cumulative
 effects of human activities (Figure 1; Karr et al. 1986; Karr 1991) are:

    Energy source: includes changes in the food web including nutrients, organic material
    inputs, seasonal  cycles, primary and secondary production, and sunlight.
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    Chemical variables: includes changes in chemical water quality including D.O., pH,
    turbidity, hardness, alkalinity, solubilities, adsorption, nutrients, organics, toxic substances,
    temperature, sediment, and their interactions.
    Flow Regime: includes modification of flows including precipitation, seasonal patterns, land
    use, runoff, velocity, ground water, daily and seasonal extremes.
    Habitat structure:  includes alteration of physical habitat including bank stability, current,
    gradient,  instream cover, vegetative canopy, substrate, current, sinuosity, width,  depth,
    pool/riffle ratios, riparian and wetland vegetation, shorelines, sedimentation, channel
    morphology.
    Biotic factors: includes changes in biotic interactions such as introductions of alien taxa,
    feeding, reproduction, predation, harvest practices and rates, diseases, parasitism,
    competition.

First, this model essentially defines the role and relevance of various chemical, physical, and
biological attributes, some of which can be measured and used as indicators.  It is the interaction
of the attributes of the five features that produces the state or quality of a water resource. A
measurable attribute of one of the five features by itself is seldom, if ever, a reliable indicator of the
whole system or its state. However, measures that approximate the condition of the system as a
whole are "positioned" closer to the endpoint of concern and hence function as more reliable
indicators of condition (NRC 2001). Second, it provides a conceptual basis for choosing and
using various chemical, physical, and biological indicators and measures within an adequate
monitoring and assessment framework. An understanding of these interactions is an important
guide to the selection of indicators for monitoring programs (Karr 1991; Yoder 1998). Third, it
places biological measures in the role of an integrative response indicator that represents the
synthesis of the interactions of the chemical, physical, and biotic attributes of a water resource.  It
provides a comprehensive signal to evaluate management actions that are inherently limited to
measuring  and controlling only some of the attributes. Lastly, it provides the basis for an allied
model by which the sequence of stress and exposure can be validated by the observation of
ecosystem response (Figure 2). Indicators of stress and exposure are routinely used in water quality
management as design criteria and as compliance thresholds.  Used alone, these may not achieve
the desired result (i.e., restoration of an impaired designated use) or they may have unintended
consequences, unless they are evaluated through the lens of biological response (Karr and Yoder
2004).  It is the accurate measurement of biological response that is key to making this process
work in actual practice, much more so than our ability to precisely measure stress or exposure.
Stress and exposure criteria are determined through indirect means and as such function as
surrogates for true biological response. This process offers a way to ground truth the application of
water quality and other criteria in relation to the totality of the interactions that result in a
biological response, but which cannot be accounted for on a parameter-by-parameter basis.
Sequencing the management of stress through how it affects key attributes  of the five factors
through to the eventual biological response provides a process by which adequate monitoring and
assessment can be used to validate the effectiveness of management actions to control stressors
(Figure 4).  The severity and degree of the biological response to these impacts is ultimately what is
important, not the mere presence of an impact.
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                                 November 30, 2008
   The  Linkage  From  Stressor  Effects
             to  Ecosystem  Response
       Stressor
    I  Agent(s)  J
    This model is an
    explicit statement of
    multiple causation
     STRESSORS
                                  Habitat
                                 Structure
                                   Flow
                                  Regime
                                       Biological
                                       Response
Water Quality
  & Toxic ity
                                 Energy
                                 Source
                               Biological
                                 Index or
                                  metric
   Biotic
Interactions
       STRESS/EXPOSURE
                              Stressor Metric
                         •*• RESPONSE
Cost'Effective Indicators
Cost-effective indicators are based on proven sampling methods and procedures that can be
executed in a reasonable time frame and with reasonable effort. A commonly used description are
measures that can be accomplished at a sampling site in a "few" hours, allowing several sites to be
sampled each day, tens of sites per week, and hundreds of sites per year by a single field crew1.
However, it includes indicators that are sufficiently developed, calibrated, and proven so as to
ensure accuracy and precision.  Accuracy includes the minimization of type I and II assessment
error, i.e., the under or over estimation of status. It also includes the ability to extract meaningful
diagnoses of observed responses using multiple chemical, physical, and biological parameters and
measures, each used in their most appropriate roles as Stressor, exposure, and response indicators.
Precision includes reliable estimates of chemical, physical, and ecological properties and that
produce statistical rigor. Frequently, statistical rigor implies attention to sampling frequency and
reducing variance estimates. However, it is also important to understand the assessment capacity
1 A field crew is a 2-4 person team dedicated to the collection of data for a specific indicator category (chemical,
 physical, biological).
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             November 30, 2008
 of each indicator and its position within the five factors that determine the integrity of a water
 resource. For aquatic life assessments, basing measures of condition on a biological indicator
 incurs the power of assessment inherent to the position of this indicator relative to the endpoint
 of concern, i.e., the health and well-being of the biota. Whereas attempting to estimate biological
 status using chemical or physical surrogates introduces the need to achieve statistically valid
 estimates for the parameter of concern, which may mean expending significant analytical and
 sampling resources. The use of the most direct measure of the endpoint of concern can in effect
 "leap frog" the statistical (i.e., sampling frequency) issues involved with surrogates and reduce the
 need for a higher degree statistical rigor for the surrogate indicator. In turn, the surrogates fulfill
 the role of stress and exposure indicators, which requires less statistical rigor and fewer samples.
 The trade-offs involved result in a more cost-effective monitoring and assessment program.

 Another aspect of a cost-effective approach to monitoring and assessment is determining which
 indicators and parameters are measured in a given situation. The ITFM  (1992) indicators process
 arranged indicators according to their role and value for first determining the state of the aquatic
                            CORE INDICATORS
           Fish Assemblage • Macroinvertebrates* Periphyton
                (Use Community Level Data From At Least Two)
        Physical Habitat Indicators
        • Channel morphology • Flow
        • Substrate Quality • Riparian
                    Chemical Quality Indicators
                    • pH  • Temperature
                    • Conductivity • Dissolved Q,
          For Specific Designated Uses Add  the Following:
  AQUATIC LIFE
  Base List
  • Ionic strength
  • Nutrients, sediment
  Supplemental List
  • Metals (water/sediment)
  • Organics (water/sed i men
      RECREATIONAL
      Base List
      • Fecal bacteria
      • Ionic strength
      Supplemental List
      • Other pathogens
      • Organics (water/sed.)
            HUMAN/WILDLIFE CONSUMPTION
            Base List
             Metals (in tissues)
             Organics (in tissues)
WATER SUP PLY
Base List
• Fecal bacteria
• Ionic strength
• Nutrients, sediment
Supplemental List
• Metals (water/sediment)
• Organics (water/sed.)
• Other pathogens
Figure 3.  Core indicators and parameters by designated use to support an adequate watershed monitoring and
   assessment approach (after ITFM 1992 and Yoder 1998).
                                        A-7

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MBI/CABB               Documenting Incremental Improvement - Appendix B         November 30, 2008


system and adding key parameters and indicators in accordance with specific designated uses and
the complexity of the setting.  The different types of measurements that comprise an adequate
watershed monitoring and assessment approach consist of core and supplemental indicators and
parameters (Figure 3). The core parameters are collected in all situations regardless of the
assessment, regulatory, and management issues of concern. These represent the key, essential
chemical, physical, and biological elements of water resource integrity (Karr et al. 1986) and reflect
the most basic components of all aquatic ecosystems (living biota, habitat, and primary water
quality).  These fulfill the need to first characterize the condition and status of the baseline
attributes. They are also measured directly in the field, thus providing rapid feedback to qualified
analysts.  Conventional approaches to monitoring  and assessment attempt to formulate the
assessment questions prior to deciding what to measure.  However, adequate monitoring generates
data and information about the core parameters in order to determine what the assessment
questions should be, some of which cannot be sufficiently formulated without such data and
information. Furthermore, they directly represent the fundamental attributes of aquatic
ecosystems and, as such, comprise the baseline of adequate information needs for fundamental
and recurrent assessment questions such as use attainment status, water quality standards
compliance, use attainability analyses, delineation of associated causes/sources of threat and
impairment, and basic reporting (305b report) and listing (303d listings).  The supplemental
parameters are added as the assessment needs (or questions) increase in diversity, quantity, and
complexity of the setting. For example, a comparatively simple setting with one or two principal
stressors  may be adequately addressed by the core parameters plus the base list for aquatic life and
recreation. As the complexity of a study area increases in terms of stressors and uses, the list will
increase to include more of the supplemental parameters, the frequency of their collection and
analysis,  and the spatial intensity of the sampling design.  This is a reasoned and stepwise selection
of additional measurements, most of which require laboratory analysis.  It can also include media
in addition to the water column such as bottom sediments and organism tissues. All of this is
dealt with in the initial planning of the watershed assessment and the development of a detailed
plan of sampling.

Another  dimension of cost-effectiveness is the capture of all relevant management objectives with
the chosen suites of indicators. Table 1 relates indicator categories to classes of common water
resource  management program objectives.  These may be addressed as part of the field sampling or
accessed  later in the analysis and reporting phases of the assessment process. These are critical
components of the sequential analysis of the monitoring data and information, which relates
designated use impairments to associated causes and sources.  This approach also economizes
sampling resources by scaling the intensity and complexity of the monitoring and assessment effort
in accordance with the management issues to be addressed. This type of approach also allows for
more flexible management responses that are attenuated by the  information revealed about the
environmental complexity of the setting, the quality of the aquatic resource, and the potential
pollution problems encountered.  Effective implementation of this process is improved through
the experience and knowledge gained by conducting monitoring and assessment for many years
and over a wide geographical area.
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November 30, 2008
Table 1. Summary matrix of recommended environmental indicators for meeting management objectives for
          status and trends of surface waters (a boldface  "X" indicates a recommended primary indicator
          after ITFM 1995; other recommended indicators are designated by a "v"). The corresponding EPA
          indicator hierarchy level (see Figure 6) is also listed for each suite of indicator groups.
Categories of Management Objectives
Human Health Ecological Economic Concerns
Health
Indicator Group
Consump- Public Recreation Aquatic/
tionoffish/ Water (swimming, Semi- Energy/
shellfish Supply fishing, aquatic Life Transportation
boating)
Agriculture/
Forestry/
Mining
Bioloqical Response Indicators (Level 6)
Macroinvertebrates
Fish
Semi-aquatic animals
Pathogens
Phytoplankton
Periphyton
Aquatic Plants
Zooplankton

X
X
X
X



X
X

X
X

X
X
X
X
X
X
X

X
X
X
X
X

X
X
X
X




X

X

X
X
X
X


X
X
Chemical Exposure Indicators (Levels 4&5)
Water chemistry
Odor/Taste
Sediment Chemistry
Tissue Chemistry
Biochemical Markers
Hydrological Measures
Temperature
Geomorphology
Riparian/Shoreline
Habitat Quality
X
X
X
X
V
Physical
X
X
X
X
X
X
X
X
V
X
X
X
V
X

X
X
V
X

X
X
X
X
X

Habitat/Hvdroloqical Indicators (Levels 3&4)
X
X
X
X
Watershed Scale Stressor
Land Use Patterns
Human Alterations
Watershed Impervious-
ness (% of watershed)
X
X

X
X

Pollutant Loadinqs
Point Source Loads
Nonpoint Loadings
Spills/Other Releases
V
V
V
V
V
V
X
X
X
V
Indicators
X
X
V
Indicators
V
V
V
X
X
X
X
V
(Levels 3,4,&5)
X
X
V
(Level 3)
V
V
V
X
X
X
X
V
X
X


V
V
X
X
X
X
V
X

V
V
V
V
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MBI/CABB               Documenting Incremental Improvement - Appendix B         November 30, 2008


Indicator Discipline - Adherence to Indicator Roles
An important factor in achieving the cost effective approach just described is using chemical,
physical, and biological indicators in their most appropriate roles as stressor, exposure, or response
indictors. The accurate portrayal of the condition of aquatic resources depends on wider
development and use of response indicators and  adequate spatial monitoring designs conducted at
the same scale of water quality management. Part of the solution to these challenges is to use
indicators within their most appropriate roles.  The EPA environmental Monitoring and
Assessment Program (EMAP; U.S.  EPA 1991) classified indicators as stressor, exposure, and
response. Yoder and Rankin (1998) further organized the concept defining the most appropriate
roles of parameters and measures when used in an adequate monitoring and assessment program.

Stressor indicators generally include activities and phenomena that impact, but which may or may
not degrade or appreciably alter key environmental processes and attributes. These include point
and nonpoint source pollutant loadings, land use changes, and other broad-scale influences that
most commonly result from anthropogenic activities. Stressor indicators provide the most direct
measure of the activities that water quality management attempts to regulate. Exposure indicators
include chemical-specific, whole effluent toxicity, tissue residues, and biomarkers, each of which
suggest or provide evidence of biological exposure to stressor agents.  Fecal bacteria also serve as
exposure indicators and are used as surrogates for response where direct human response
indicators are either lacking or their use would pose  an unacceptable risk.  These indicators are
based on specific measurements that are taken  either in the ambient environment or in discharges
and effluents, either point or nonpoint source  in origin are measures and parameters that reveal
the level or degree of an exposure to a potentially deleterious substance or effect that was produced
by a stressor event or activity.  Chemical water quality parameters and the concentrations at which
they occur in the water column fulfill this role. Water quality criteria for toxic substances  are
developed to indicate chronic, acute, and lethal exposures.  Exceedences of these thresholds, either
predicted or measured, provide design targets for planning and permitting  and assessment
thresholds for monitoring and assessment. Fecal bacteria fulfill  this role as well, indicating the
level of risk posed to humans and other animals by exposure to various levels and durations of
potentially harmful pathogens. Response indicators are  measures that most directly relate to an
endpoint of concern, i.e., ecological and human health.  They are most commonly biological
indicators,  e.g., aquatic assemblage measures for aquatic  life uses and human health for
recreational uses and are the most direct measures of the status of designated uses. For aquatic life
uses the assemblage and population response parameters that are represented by the biological
indices that comprise biological criteria are examples of response indicators. For other designated
uses such as recreation and drinking water, symptoms of deleterious  effects exhibited by humans
would serve as a response indicator, albeit these might prove more difficult to develop and
manage. Response indicators represent the synthesis of stress and exposure (re: Figure 4) and are
commonly used to represent overall condition or status.  The key to implementing a successful
indicators and watershed approach that serves as  a basis for developing a synthesized report card is
to ensure that indicators are used within the roles that are the most appropriate for each. The
inappropriate substitution of stressor and exposure indicators in the absence of response
indicators is at the root of the national problem of widely divergent 305(b) and 303(d) statistics
reported between the states (NRC 2001).
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Historically, states have used surrogate approaches to measuring and determining the status of
designates uses.  For aquatic life uses, chemical criteria have been cast in that role. For
recreational uses, fecal bacteria continue to fulfill that role. Yoder and Rankin (1998) define the
former practice as an inappropriate substitution of stress or exposure indicators for response.
Comparisons of biological and chemical assessments show that the latter leads to listing of water
bodies as impaired when they are not (type I error) or not listing when they are impaired (type II
error). Rankin and Yoder (1990) using data over a 10 year period in Ohio and the Oregon
Department of Environmental Quality (D. Drake, personal communication) using data from the
1990s, both showed that type II errors are the most prevalent, leaving up to 50% of the
impairments detected by biological assessments undetected and undiagnosed. In the case of
recreational uses, the reality of fecal bacteria exceedences and human health risks needs to be
better reconciled.

A process for assembling information from cost-effective indicators comprised of biological,
chemical, and physical measures used in their most appropriate roles can ensure that pollution
sources are judged objectively and on the basis of quantifiable environmental  results. Such an
approach simultaneously assures that indicators will be representative of the elements and
processes of the five factors that determine water resource integrity (Figure 1; Karr et al. 1986).  An
indicators hierarchy developed by U.S. EPA (1995a,b) provides a sequential process within which
indicators can be linked to support assessment and management responses (Figure 6). It offers a
structured approach to assure that management programs are, if necessary, adjusted based on
environmental feedback (see also Figure 2). A comprehensive ambient monitoring effort that
includes indicators representative of key variables within the five factors which determine the
integrity of the water resource  is essential to successfully implementing a true environmental
indicators approach. For this approach to be successful, ambient monitoring  must take place at
the same scale at which management actions are being applied.

This integrated framework relies on the hierarchical continuum of administrative and true
environmental indicators. This framework was initially developed by U.S. EPA (1995a).  The
original framework included six "levels"  of indicators as follows:

     Level 1 - actions taken by  regulatory agencies (e.g., permitting, enforcement, grants);
     Level 2 - responses by the  regulated community (e.g., construction of treatment works,
              pollution prevention);
     Level 3 - changes in discharged quantities (e.g., pollutant loadings);
     Level 4 - changes in ambient conditions (e.g., water quality, habitat);
     Level 5 - changes in uptake and/or assimilation (e.g., tissue contamination, biomarkers,
              assimilative capacity);  and,
     Level 6 - changes in health, ecology, or other effects (e.g., ecological condition, pathogenicity).

In this process the results of administrative activities (levels 1 and 2) are followed by  changes in
pollutant loadings and ambient water quality (levels 3, 4, and 5), all of which leads to measurable
environmental "results" (level  6).  The process is multi-directional with the level 6 indicators
                                            A-ll

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MBI/CABB             Documenting Incremental Improvement - Appendix B        November 30, 2008


        Measuring and  Managing Environmental
              Progress:  Hierarchy  of Indicators

          Indicator Levels
    1: Management actions
    2: Response to management
Administrative Indicators
[permits, plans, grants,
enforcement, abatements]
      - Strp«5«5or ahatpmpnt             Stressor Indicators [pollutant
      . siressor aoaiemem             loads land use practices]
    4: Ambient conditions
    5: Assimilation and uptake
Exposure Indicators [pollutant
levels, habitat quality, ecosystem
process, fate & transport]
^                                              Response Indicators [biological
                                              assemblage indices, other
                                              attributes]


                                      The "Health" End point

  Figure 4. Hierarchy of indicators for determining the effectiveness of water quality management and
         maintaining appropriate relationships and feedback loops between different classes of indicators
         (modified from US. EPA I995a).

providing overall feedback about the completeness and accuracy of the process through the
preceding levels. While the U.S. EPA (1995a) hierarchy employs point source terms, it is
adaptable to nonpoint sources and media other than surface waters.  Superimposed on this
hierarchy is the concept of stressor, exposure, and response indicators (Figure 6) similar to that
developed by the U.S. EPA Environmental Monitoring and Assessment Program (EMAP; U.S.
EPA 1991). Stressor indicators include activities that have the potential to degrade the aquatic
environment such as pollutant discharges, land use changes, and habitat modifications (level 3).
Exposure indicators are those which measure the apparent effects of stressors and include chemical
water quality criteria, whole effluent toxicity tests, tissue residues, bacterial levels, and biomarkers,
each of which provides evidence of biological exposure to a stressor or bioaccumulative agent
(levels 4 and 5). Response indicators include composite measures of the cumulative effects of
stress and exposure and include the more direct measures of biological community and population
response that are represented here by the biological indices which comprise the Ohio EPA
biological criteria (level 6). Other response indicators could include target assemblages (e.g., rare,
threatened, endangered, special status, and declining species). All of these indicators represent the
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essential technical elements for watershed-based management approaches. The key is to use the
different indicators within the roles that are most appropriate for each.

The processes for sequencing and synthesizing environmental data and indicators serves as a
foundation for reporting on status and trends at all levels (national, regional, statewide, or local).
The disciplinary process just described should minimize both type I and type II assessment errors.
Such errors are a concern in the integrated 305b/303d reporting and listing process, in which
both type I and II errors have been extensively propagated (Yoder and Rankin  1998; National
Resource Council 2001). The results of these errors are waters that are not impaired are identified
as needing corrective actions (type I error) or waters that are truly impaired are overlooked
altogether (type II error). While this may be the most "visible"  issue at present, the impact of such
assessment errors can adversely affect other water quality management program areas.  The process
by which the basic data and information on which indicators are developed and used must be
integrated at the outset, not as a "tack-on" at the end of the process. Bringing a more consistent
and scientifically robust approach to indicators development and usage should lead to the
correction of such errors and foster better policy and management outcomes as a result.

Key Indicators Are Tied to  WQS'- Designated Uses and Criteria
Water quality standards (WQS) establish the essential framework for developing measurable
endpoints and criteria for deriving restoration and protection benchmarks. They consist of two
parts - a designated use and criteria intended to protect and measure attainment of the designated
use. They are used as targets for developing management strategies to achieve restoration and
protection (e.g., wasteload allocations, TMDLs, BMPs, etc.) and for measuring the relative quality
of water and aquatic ecosystems.  Obviously, the more that WQS account for regional variability
and characteristics inherent to the aquatic ecosystems of a region, the more relevant and accurate
are  assessments of quality and management strategies designed to achieve restoration and
protection goals.  WQS are an absolutely fundamental issue of adequate monitoring and
assessment and the linkages between the two must be recognized (NRC 2001).  States widely
employ non-specific, general uses, which essentially represents a one-size-fits-all approach to
designating and assessing surface waters.  For example, states designate waters for the "protection
and propagation offish and aquatic life" of other general descriptions such as "cold water fishery".
Such uses are not specific enough to foster the development of the more detailed criteria and
indicators that are needed to address many of the deficiencies identified by the General
Accounting Office (GAO 2000, 2003b) and NRC (2001).  Furthermore, the use of direct
biological measures and criteria is viewed as essential to making refined uses work. A few states
(e.g., Maine, Ohio, Vermont) have developed refined use designation frameworks that are
supported by numeric biological criteria and these have been extensively described elsewhere
(Courtemanch 1995; Yoder and Rankin 1995a; Yoder 1995).  This has given rise to the biological
condition gradient framework, which has been under development and testing by U.S. EPA
(Figure  7) in support of the development of a national process for tiered aquatic life uses.

Water quality criteria are largely expressed as chemical pollutant concentrations and sometimes as
narrative descriptors. As such, they function as indirect surrogates for the endpoint described by a
designated use.  The designated use is  a description of a desired state or set of attributes for a
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            Documenting Incremental Improvement - Appendix B
                                                                         November 30, 2008
waterbody and the criterion is a measurable indicator that is a surrogate of use attainment. A
criterion occupies a position at any point along the sequence of stress, exposure, and response
(Figure 8). The NRC (2001) described this as the "position of the standard" and concluded that a
criterion that is positioned closer to the designated use is a more accurate indicator of that use.  In
addition, the more precisely the designated use is stated, the more accurate the criterion will be as
a result.  Karr and Yoder (2004) modified the original figure to show its consistency with the
previously described stress, exposure, and response roles of indicators.  It provides a way to relate
different types of criteria (chemical,  physical, biological) and how to sequence each along a causal
chain of events such as that portrayed by the hierarchy of indicators. Both the appropriate roles of
indicators and the hierarchy for sequencing them along a causal chain of events are embedded in
Figure 8.  Including adequate representatives of each indicator role and their development and
calibration in a state's WQS institutionalizes their usefulness to water quality management.
Data and Measurement Quality Objectives
Data (DQO) and measurement quality objectives (MQO) determine the level of detail and analysis
that is required in support of an indicator or parameter.  Frequently, these are defined by the
state's WQS, either directly or implicitly and these comprise an important determinant of the

 Tiered  Aquatic Life Use Conceptual Model: Draft Biological Tiers
                                                                          (10/22 draft)
 c
 3
 E
 E
 O  •£•
O  £
 o  *•*
"3  o
 O  uj
m  o
 O  O
   +-  o
   it-  0)
   O  Q.
   cffi,
   c
   o
   o
           1
     Natural structural, functional, and taxonomic integrity is preserved.


              Structure and function similar to natural community with some additional
              taxa & biomass; no or incidental anomalies; sensitive non-native taxa may
              be present; ecosystem level functions are fully maintained
                                   Evident changes in structure due to loss of some rare native
                                   taxa; shifts in relative abundance; ecosystem level functions fully
                                   maintained through redundant attributes of the system.
                                              Moderate changes in structure due to replacement
                                              of sensitive ubiquitous taxa by more tolerant taxa;
                                              overall balanced distribution of all expected taxa;
                                               zosystem functions largely maintained.
Sensitive taxa markedly diminished;
conspicuously unbalanced distribution of
major groups from that expected; organism
                                                   condition shows signs of physiological
                                                   stress; ecosystem function shows reduced
                                                   complexity and redundancy; increased
                                                   build up or export of unused materials.
Extreme changes in structure; wholesale changes in
taxonomic composition; extreme alterations from
normal densities; organism condition is often poor;
                                                               anomalies may be frequent;
                                                               ecosystem functions are
                                                                \xtremely altered.
           LOW
              Human Disturbance Gradient
                                                                              HIGH
Figure 5.  Refined aquatic life use conceptual model showing a biological condition axis and descriptive
    attributes of tiers along a gradient of quality and disturbance (U.S. EPA 2005).
                                           A-14

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MBI/CABB
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                           November 30, 2008
accuracy of assessments produced by a monitoring and assessment effort. For example, if a
pollutant criterion is set at a concentration of 10 M-g/1, then sampling and analytical methods that
ensure detection to at least that concentration will be required. As such, the 10 (o.g/1 criterion
serves as the data and measurement quality objective.  Furthermore,  for many parameters it will be
necessary to measure below the criterion threshold as there will be management issues of interest
at lower levels. An example is defining reference condition for individual pollutants, which will
require knowledge of the range of occurrence from minimum detection limit up to the criterion.
For biological assessments, the issue includes how samples are obtained (effort, gear selectivity),
how they are processed (subsampling, handling, preservation), how they are enumerated and
identified (level of taxonomy), and the attributes that are recorded (species, numbers, biomass,
anomalies).  This illustrates both the qualitative and quantitative aspects of this issue.  In biological
assessment, taxonomic resolution is a key quality objective, as this not only determines the power
of the assessment tool, but the diagnostic capabilities as well (Yoder and Rankin  1995b; Yoder and
DeShon 2003). DQO/MQO can be governed by methods and protocol documents, but are much
less ambiguous and debatable when they are codified in the state's WQS. Data and measurement
                        Pollution (specific
                        human activities)
       Point and nonpoint
     pollutant loadings for all
    sources (source specific)
       Ambient pollutant
      levels in water body
       (pollutant specific)
            Land use
             effects
Channel/Flow
  alterations
                   In-channel &
                 Riparian effects
                                           Indicator Role
                                                Stressor
 Exposure
(landscape)
                         Exposure
                        (in-stream)
         Human health
       (health outcomes
       including disease)
             Ecological health
          (cumulative effects on
           biological condition)
                   \             /
                         Response
                      Designated use
                   (water body specific)
                                                Endpoint
Figure 6.  Position of the criterion (stressor, exposure, or response) illustrating the relationships between human
   activities, specific types of criteria, and designated uses that define the endpoint of interest to society
   (modified from NRG 2001). Their parallel roles as environmental indicators for each category is listed on
   the right. Arrows indicate directions and interrelationships along the causal sequence of stress, exposure,
   and response.
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MBI/CABB
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              November 30, 2008
quality objectives inherently determine the overall capabilities of a monitoring and assessment
program to accurately detect, quantify, and diagnose environmental status.


Strategic Issues
Adequate monitoring and assessment is an inherently strategic process. To fully realize the
benefits of such requires an understanding of the multiple uses of the information in the
management of water resources. A fundamental tenet of adequate monitoring and assessment is
that the same set of core resources, methods, standards, data, and information should support
multiple program management needs (Figure 13).  It also requires a commitment to program
maintenance and upkeep (i.e., maintenance of adequate resources, facilities, and professionalism)
over the long term. Professionalism includes the qualifications of the monitoring and assessment
personnel and their ability to carry out all tasks, including data analysis and the sequencing and
interpretation of multiple indicators.  Several of the indicators require specialized expertise in
terms of data collection, field observations, laboratory methods, taxonomic practice, and data
analysis and interpretation skills. Thus the professional qualifications of the personnel who
execute and manage a statewide program is a pivotal issue.
   Adequate Monitoring & Assessment Supports
   All  Water Quality Management Programs
         Watersheds/
           TMDLs
         Nonpoint
          Source
       Assessment &
        Management
        Status/Trends
       Reporting (305b
           Report)
         NPDES Permits
        (WQBEL Support,
        Permits to Install)
           Comparative
              Risk
        Monitoring &
        Assessment
         Wet Weather
      Discharges (CSOs,
          Stormwater
  Hazardous Waste
Sites (NRDA/CERCLA)
           Habitat
        Modifications
      (401 Certification
                                     WQS/Criteria,
                                   Use Designations,
                                    Anitdegradation
   Source Water
     Protection
                                                Enforcement/Litigation
                                                       Support
Figure 13.  Adequate monitoring and assessment should be capable of supporting multiple program support

    needs with the same core base of indicators, parameters, and designs.
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MBI/CABB               Documenting Incremental Improvement - Appendix B         November 30, 2008


Two important functions of adequate monitoring and assessment include the functional support
provided to individual management programs.  The first includes tasks such as determinations of
status at multiple scales, use attainability analyses, supporting the management of specific sources,
and providing information to guide watershed planning and restoration processes (Figure  14;
upper tier). The second is that of providing "strategic support" via the systematic accumulation of
data, information, knowledge, and experience across various temporal and spatial scales (Figure 10;
lower tier). This includes resources devoted to such tasks as sampling and maintenance of
reference sites for determining regional reference condition and developing reference condition
and benchmarks for key biological, physical, and chemical indicators and parameters. Many
contemporary management needs are not well supported by conventional approaches to water
quality criteria and modeling, thus new ways of developing and applying benchmarks and criteria
are needed. Developing criteria for nutrients and clean and contaminated sediments are examples.
Other issues such as urbanization and habitat concerns will require landscape and riparian level
indicators and objectives. All require robust spatial and temporal datasets. Coupled with this is
the need to conduct ongoing applied research and exploratory data analysis with the monitoring
program datasets, including the aggregate experience of the program. The  ongoing accumulation
of data, information, and assessment across different spatial scales provides both the datasets and
the assessment experiences. This comprises the strategy for delivering the criteria and benchmarks
that will not be delivered by the conventional approach to developing national water quality
criteria.

Finally, the recognition that the most important product  of adequate monitoring and assessment is
the assessment, not just the data, is critical  to achieving success.  Data by itself has limited
usefulness to  environmental decision-making unless it is converted to useful information.  This
means having decision criteria and benchmarks fully integrated into the monitoring and
assessment program.  It also means adhering to the indicator sequencing and linkage processes
that were previously described and most importantly, using indicators within their most
appropriate roles. An integrated assessment should serve the needs of multiple programs by the
same set of assessments, without the need to generate new or different datasets for each and every
management  issue.
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                            November 30, 2008
           Functional Support Provided by Annual
           Rotating Basin Assessments	
             305b ReporT
              Statistics^
             303d List of
           Impaired/Threat-J
             ened Waters^
                                   Individual
                                     Basin
                                  Assessment
WQS/Use
Attainability
Analyses


                             Annual
                            WQS Rule
                            Revisions^
       Goals
      Tracking
    (GPRA, State]
      Specific)
NPDES
Permits


  Permit
 Defense/
Fact Sheets
                                     Watershed
                                   Specific Issues
                                   • TMDL develop-
                                   ment
                                   • Local water-
                                   shed groups
                                   •319 projects
                                   • 404/401 dredge
                                   &fill permits
                                   • Problem
                                   discovery
                                   • Special
                                   Investigations
          Strategic Support Provided Collectively
          by Rotating  Basin Assessments
                    The ongoing accumulation of information
                        across spatial and temporal scales
                 Policy
              Development
            TMDL Listing/De-listing
            Refined WQS Uses
            Antidegradation
            NPDES (WET, CSOs,
            Stormwater)
            404/401 dredge & fill
            Stream Protection
            Nutrient management
            1 Overall program/policy
            effectiveness
            1 Environmental audits
                                         \
                 Program
               Development
            > Environmental Indica-
            tors
            > Refined & Validated
            WQ Criteria
            • Reference WQ &
            Sediment benchmarks
            > Biological Criteria
            > Biological Response
            Signatures
            > Regional stratification
            (ecoregions, subreg.)
               Statewide/Regional
                 Applications
               TMDLs (303d)
               Status/Trends (305b)
               Local projects
               NPS/BMP effective-
               ness evaluations
               NAWQA/REMAP
               Watershed mgmt.
               SWAP
               UWA
               IWI "ground
               truthing"
Figure 14.  Examples of water quality management program support routinely provided by adequate
    monitoring and assessment at the watershed level (upper panel) and as a baseline support function
    delivered by routine monitoring over time (lower panel).
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MBI/CABB               Documenting Incremental Improvement - Appendix B         November 30, 2008
                                      REFERNCES

General Accounting Office (GAO). 2000.  Water quality - key EPA and state decisions are
    limited by inconsistent and incomplete data. GAO/RCED-00-54. Washington, DC: GAO.
General Accounting Office (GAO). 2003a.  Major Management Challenges and Program Risks:
    Environmental Protection Agency. GAO-03-112. Performance and Accountability Series. US
    General Accounting Office, Washington, DC.
General Accounting Office (GAO). 2003b. Water quality: improved EPA guidance and support
    can help states develop standards that better target cleanup efforts. GAO-03-308, U.S. General
    Accounting Office, Washington, D.C.
ITFM (Intergovernmental Task Force on Monitoring Water Quality). 1995. The strategy for
    improving water-quality monitoring in the United States.  Final report of the
    Intergovernmental Task Force on Monitoring Water Quality. Interagency Advisory Committee
    on Water Data, Washington, D.C. + Appendices.
ITFM (Intergovernmental Task Force on Monitoring Water Quality). 1993. Ambient water
    quality monitoring in the United States: second year review, evaluation, and
    recommendations. Interagency Advisory Committee on Water Data, Washington, D.C. +
    Appendices.
ITFM (Intergovernmental Task Force on Monitoring Water Quality). 1992. Ambient water
    quality monitoring in the United States: first year review, evaluation,  and recommendations.
    Interagency Advisory Committee on Water  Data, Washington, D.C.
Karr, J. R., K. D. Fausch, P. L. Angermier, P. R. Yant, and I. J. Schlosser. 1986.  Assessing
    biological integrity in running waters: a method and its rationale. Illinois Natural History
    Survey Special Publication 5: 28 pp.
Karr, J. R., and Dudley, D. R. 1981.  Ecological perspective on water quality goals. Environ.
    Management 5: 55-68.
Midwest Biodiversity Institute (MBI).  2004. Region V state bioassessment and ambient
    monitoring programs: initial evaluation and review. Midwest Biodiversity Institute Tech. Rept.
    MBI/01'03'1. 36 pp. + appendices.
    (http://www.epa.gov/region5/water/wqb/wqb r5mon.htm)
National Research Council (NRC). 2001. Assessing the TMDL Approach to Water Quality
    Management. National Academy Press, Washington, DC., 109 pp.
National Research Council (NRC) 2000. Ecological Indicators for the Nation. Washington, DC:
    National Academy Press, http://www.nap.edu/catalog/9720.html.
Rankin, E. T., and Yoder, C. O.  1990. A comparison of aquatic life use impairment detection
    and its causes between  an integrated,  biosurvey-based environmental assessment and its water
    column chemistry subcomponent.  Appendix I, Ohio Water Resource Inventory (Volume 1),
    Ohio EPA, Div. Water Qual. Plan. Assess., Columbus, Ohio.
U.S. Environmental Protection Agency.  2003.  Elements of a state monitoring and assessment
       program.  EPA 841-6-03-003.  Office of  Water, Washington, DC.  14pp.
U.S. Environmental Protection Agency.  1995a. Environmental indicators of water quality in the
       United States. EPA 841-R-96-002.  Office of Water, Washington, DC 20460. 25 pp.
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MBI/CABB               Documenting Incremental Improvement - Appendix B         November 30, 2008


U.S. Environmental Protection Agency. 1995b. A conceptual framework to support development
       and use of environmental information in decision-making.  EPA 239-R-95-012. Office of
       Policy, Planning, and Evaluation, Washington, DC 20460.  43 pp.
U.S. Environmental Protection Agency. 1994. Section 106 and 604[b] grant guidance - water
       monitoring. U.S. EPA, Office of Water, Assessment and Watershed Protection Division,
       Washington, DC. 9 pp. + app.
U.S. Environmental Protection Agency. 1990. Feasibility report on environmental indicators for
       surface water programs. U. S. EPA, Office of Water Regulations and Standards, Office of
       Policy, Planning, and Evaluation, Washington, D. C.
Yoder, C.O. and 9 others. 2005.  Changes in fish assemblage status in Ohio's nonwadeable rivers
    and streams over two decades, pp. 399-429. in R. Hughes and J. Rinne (eds.).  Historical
    changes in fish assemblages of large rivers in the America's.  American Fisheries Society
    Symposium Series.
Yoder, C.O. and J.E. DeShon.  2003. Using Biological Response Signatures Within a Framework
    of Multiple Indicators to Assess and Diagnose Causes and Sources of Impairments to Aquatic
    Assemblages in Selected Ohio Rivers and Streams, pp. 23-81. in T.P. Simon (ed.).
    BIOLOGICAL RESPONSE SIGNATURES: patterns in biological integrity for assessment of
    freshwater aquatic assemblages. Lewis Publishers, Boca Raton, FL.
Yoder, C.O. and E.T. Rankin.  1998. The role of biological indicators in a state water quality
    management process. J. Env.  Mon. Assess. 51(1-2): 61-88.
Yoder, C.O.  1998. Important Concepts and elements of an adequate state watershed monitoring
    and assessment program, pp. 615-628.  in Proceedings of the NWQMC National Conference
    Monitoring: Critical Foundations to Protecting Our Waters. U.S. EPA, Washington, DC, 663
    pp. + app.
Yoder, C.O. and E.T. Rankin.  1995a.  Biological criteria program development and
    implementation in Ohio, pp.  109-144. in W. Davis and T. Simon (eds.). Biological
    Assessment and Criteria: Tools for Water Resource Planning and Decision Making. Lewis
    Publishers, Boca Raton, FL.
Yoder, C. O., and Rankin, E. T. 1995b. Biological criteria program development and
    implementation in Ohio, pp.  109-144. in W. Davis and T. Simon (eds.). Biological
    Assessment and Criteria: Tools for Water Resource Planning and Decision Making. Lewis
    Publishers, Boca Raton, FL.
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