EPA 910-R-01-006
Total maximum daily load for dissolved
cadmium, dissolved lead, and dissolved zinc in
surface waters of the Coeur d'Alene River Basin
-------
, COEUR D'ALENE RIVER BASIN TMDL *
%S22/ AUGUST2000 °UAUTY
%PH0^
ENVIRONMENTAL
Final TMDL Issued for Metals in Coeur d'Alene River Basin
Significant Improvements Made As a Result of Public Input
The US. Environmental Protection Agency (EPA) and the Idaho Department of Environmental Quality
(DEQ) have now issued the final TMDL (Total Maximum Daily Load) for dissolved cadmium, lead, and zinc
in surface waters of the Coeur d'Alene basin. The TMDL establishes a "pollution budget" for sources that
discharge metals to the Coeur d'Alene River and tributaries, Coeur d'Alene Lake, and Spokane River.
TMDL Revised to Address Public Comments
Several hundred individuals and groups pro-
vided comments, suggestions, and new informa-
tion to the agencies during the comment period
last spring and summer. EPA and DEQ have
made several improvements to the TMDL as a
direct result of public input These changes
include the following:
1. River flows and water hardness: The
relationship between river flow and river
hardness (the amount of calcium and
magnesium in the water) is now built into
the TMDL loading capacities for the South
Fork Coeur d'Alene River and tributaries.
The available data indicates that river
hardness increases as river flow decreases
at these sites. Since hardness reduces the
toxicity of metals to aquatic life, the water
quality criteria are less restrictive during
low flow conditions. This results in higher
TMDL allocations during low flow
conditions.
2. Background levels of metals: The levels
we use to reflect natural background
conditions have been increased based on
significant new data received since the
release of the draft TMDL However, as in
the draft TMDL, the new levels are lower
than the Gold Book criteria levels.
3. Current Performance of Facilities: The
approach for determining performance-
(Contirtued on page 2)
Where to Review the Final TMDL Package
u
and Administrative Record
Copies of the final TMDL documents (which
indude a technical support document re-
sponse to comments document and informa-
tion fad sheet) are available at DEQ's Coeur
d'Alene field office, the North Idaho College
Library, and the Wallace Public Library. They
are also available on EPA's website at:
www.epa.gov/r10earth/water.htm
The Administrative Record for the TMDL
includes all of the Information (correspon-
dence, comment letters, draft documents,
technical reports, etc.) that forms the basis for
the final TMDL An index of the documents
contained in the Administrative Record is
currently available at the website noted
above. In the near future, copies of all the
Administrative Record documents will be
available for public review (by appointment)
at the DEQ office in Coeur d'Alene and the
EPA office in Seattle.
Interested parties may call the contact num-
bers below to request copies of the final
TMDL documents or make an appointment to
review the Administrative Record.
EPA's Seattle office Toll-free at
1-800-424-4372
(extension 1256)
DEQ's Coeur d'Alene office (208) 769-1422.
-------
Coeur cfAlene River Basin TMDL
August 2000
based wasteload allocations has been
revised. Rather than setting current
performance levels up-front in the TMDL,
facilities will be allowed to conduct their
own studies and determine current
performance levels on a permit-by-permit
basis during the NPDES permitting process.
This allows additional time for sampling
and analysis to establish accurate estimates
of current performance for each facility.
4. New or Expanding Facilities: Hie final
TMDL provides a process for new and
expanding facilities in the South Fork Coeur
d'Alene River watershed, allowing for future
development in these areas. Also, the final
TMDL accounts for municipal stormwater
sources for the Spokane River.
5. Discharges more closely tied to river
conditions. The final TMDL is still calculated
for four river flow conditions, but it now
allows NPDES permit writers to indude
additional flow conditions in the permit for
a particular facility.
In addition to the above changes, the TMDL has
been refined based on extensive new data
obtained in the Coeur d'Alene basin by the
United States Geological Survey in 1999.
The remainder of this fact sheet provides
general information about the final TMDL in a
question and answer format:
Question: is the TMDL Still Based on the
'Gold Book' Water Qualify Criteria?
Answer: Yes. The Gold Book' criteria are
adopted statewide by the State of Idaho as the
water quality standards for protection of aquatic
life. Site-specific criteria for lead and zinc in a
small segment of the South Fork Coeur d'Alene
River above Wallace are nearing completion.
These criteria will not affect the TMDL because
they only apply in the headwaters portion of the
basin, while statewide criteria still apply
downstream and drive the TMDL allocations.
Question; Can the Operating Mines Achieve the
TMDL Goals?
Answer We are very optimistic that mining
facilities can achieve the TMDL allocations. EPA
and DEQ's ongoing evaluations of the Bunker
Hill Central Treatment Plant (CTP) indicate that
the final TMDL allocations are achievable using
water management controls and conventional
treatment technologies.
Question: Can the Superfund Program Achieve
the TMDL Goals?
Answer: We don't know. The basin-wide
Remedial Investigation/Feasibility Study (RI/FS)
that is underway now will evaluate cleanup
alternatives for waste piles and tailings in the
floodplain. The success of Superfund cleanup
actions in this basin will depend on the level of
funding for cleanup and the effectiveness of the
selected cleanup actions. Due to the sole of
the contamination problem, the cleanup is
expected to take many years. EPA, DEQ, and
other governmental agencies will continue to
evaluate the effectiveness of cleanup projects in
light of the TMDL goals.
Question: Will the TMDL Cause
Unreasonable Increases in Sewer Rates in
the Silver Valley?
Answer The Idaho water quality standards
allow for relaxation of requirements when they
would result in widespread economic harm.
This relief mechanism is called a "variance'.
Based on a review of the comments and
information received from the wastewater
treatment plants in Page, Smelterville, and
Muilan, EPA and DEQ believe that these facilities
are candidates for variances due to the potential
costs to the community. Variances require an
analysis of alternatives and a public comment
period. EPA and DEQ plan to work with the
Silver Valley sewer utilities to develop variances
(Continued on page 3)
-------
3
Coeur d'Alene River Basin TMDL
that include reasonable further progress toward
achieving the TMDL allocations. The NFDES
permit renewal process for these facilities will be
coordinated with the variance process.
The agencies note that the TMDL has
highlighted known problems in the aging
infrastructure of the Silver Valley sewage
collection system, inflow and infiltration of
runoff and groundwater into the sewers causes
increased metals levels in treated sewage and
can also cause raw sewage overflows to streets
and nearby streams during high flow events.
EPA and DEQ believe that a long-term program
to upgrade and replace portions of collection
system is needed to eliminate these problems.
August 2000
Question: Is There an Immediate Effect on
Industries and Communities?
Answer: The TMDL is a plan. This plan is
implemented in separate regulatory actions by
EPA and DEQ. For example, operating facilities
are not required to meet the TMDL allocations
until their permits are updated and re-issued for
a new five-year term. Unless the facility is
granted a variance (see above), the updated
permit for a particular facility must contain
metals limits that are consistent with the final
TMDL The permit may include a schedule that
gives the facility time to design and construct
improvements to meet the new permit limits.
Question: Will the TMDL Restrict Growth
Along the Spokane River?
Answer: EPA and DEQ do not expect the TMDL
to result in any growth restrictions. The TMDL
requires municipalities along the Spokane River
to maintain current concentrations of metals in
their discharges to the river. The TMDL does
not restrict discharge flow rates, which are
expected to increase as the community grows.
Question: What Happens Next?
Answer: EPA and DEQ plan to continue working
on projects that will help to improve water
quality in the Coeur d'Alene basin. Toward the
end of this year, EPA's Superfund program will
release a draft, basin-wide RI/FS for public
comment Meanwhile, EPA and DEQ will be
developing updated NPDES permits for mining
and municipal facilities in the Silver Valley.
These permits will incorporate the TMDL
wasteload allocations and address non-TMDL
pollutants as well (e.g., ammonia in the
municipal discharges and copper In mining
discharges). The public will have the
opportunity to provide comments on each
proposed permit.
-------
United States
Environmental Protection
Agency - Office of Water
Region 10 (ECO-081)
1200 Sixth Avenue
Seattle WA 98101
PRE-SORTED STD
POSTAGE & FEES PAID
U.S. EPA
Permit No. G-35
FINAL COEUR D'ALENE RIVER BASIN TMDL ISSUED
-------
ST Ale OF IDAHO
| DEPARTMENT OF
'ENVIRONMENTAL
QUALITY
August 21, 2000
Dear Interested Party:
The Environmental Protection Agency (EPA) and Idaho Department of Environmental
Quality (DEQ) have issued a final Total Maximum Daily Load (TMDL) for dissolved cadmium,
lead, and zinc in surface waters of the Coeur d'Alene Basin. The TMDL contains individual
wasteload allocations for mining mid municipal wastewater facilities and gross allocations for
cleanup of contamination from historic mining activity. The scope of the proposed TMDL
includes waters of the South Fork Coeur d'Alene River and tributaries, mainstem Coeur d'Alene
River, Coeur d'Alene Lake, and Spokane River above the Idaho-Washington border.
EPA and DEQ have endeavored to collect, review, and respond to the comments and
information we received during the public comment period. The final TMDL package includes
copies of the final TMDL, a revised Technical Support Document, and a Response to Comments
document. In addition, we have enclosed a feet sheet that highlights information generated during
the public process that affected final decisions on the TMDL.
The Administrative Record for the final TMDL includes the complete information base
(correspondence, comment letters, draft documents, technical reports, etc.) for the final TMDL.
An index of the documents contained in the Administrative Record is currently available. In the
near future, copies of all the Administrative Record documents will be available for public review
(by appointment) at the DEQ Coeur d'Alene field office and the EPA regional office in Seattle.
We look forward to implementing the TMDL allocations to improve water quality in the
Coeur d'Alene basin. If you have any questions, please contact Bill Riley of EPA at
(206) 553-1412 or Gwen Fransen of DEQ at (208) 769-1422.
Sincerely,
Randall F. Smith,
Director, Office of Water
David Mabe,
Administrator, Water Quality Program
DEQ
EPA
/
Enclosures
Environmental Protoctioo Agaxry, 1200 Srxth Avenue, Seattle, Washington 9SI01
Idatw Depmtmm of Envirotifflc**a) Quality, 1410 North Hilton, Boise, Idaho S3706
-------
Total Maximum Daily Load for Dissolved Cadmium,
Dissolved Lead, and Dissolved Zinc in Surface Waters
of the Coeur d'Alene River Basin
Under authority of the Clean Water Act, 33 U.S.C. § 1251 et seq.. as amended by the
Water Quality Act of 1987, P.L. 100-4, the U.S. Environmental Protection Agency (EPA) and
Idaho Department of Environmental Quality (DEQ) are establishing a Total Maximum Daily Load
(TMDL) for dissolved cadmium, dissolved lead, and dissolved zinc in the surface waters in the
following sub-basins of Idaho:
The State of Idaho is establishing the TMDL for waters of the State. EPA is establishing
the TMDL for waters within the reservation boundaries of the Coeur d'Alene Tribe.
The legal and technical basis for this TMDL is described in the final Technical Support
Document. Tot^j Daily Ix^ad for Dissolved Cadrntiiir^ Dissolved I^ad. and Disyilvsri
document, and the Administrative Record for this TMDL.
This TMDL shall become effective immediately, and is incorporated into the water quality
management plans for the State of Idaho under Clean Water Act § 303(e).
South Fork Coeur d'Alene
Coeur d'Alene Lake
Upper Spokane
(HUC 17010302)
(HUC 17010303)
(HUC 17010305)
Zinc in Surface Waters of the Coeur d'Alene Basin
Randall F. Smith,
Director,
Office of Water
EPA
David Mabe,
Administrator,
Water Quality Program
DEQ
-------
Coeur d'Alene Basin TMDL
August 2000
Table of Contents
I. Scope of this TMDL 4
A. Pollutant Parameters 4
B. Idaho 303(d) List 4
C. Target sites 5
D. Source Identification 5
II. Water Quality Standards 6
III. TMDL Elements 7
A. TMDL Elements for Coeur d'Alene River and Tributaries .7
B. Allocations for Individual Sources . 11
1. Wasteload Allocations for Coeur d'Alene River and Tributaries 11
2. Load Allocations for Coeur d'Alene Lake Sediments 17
3. Wasteload Allocations for the Spokane River 17
Tables and Figures
Table 1. Coeur d'Alene Basin Waterbodies on the 1998 Idaho 303(d) List for Metals 4
Table 2. TMDL Target Sites 5
Table 3: Water Quality Criteria for Dissolved Cadmium, Lead, and Zinc 6
Table 4: TMDL Elements for Dissolved Cadmium 8
Table 5: TMDL Elements for Dissolved Lead 9
Table 6: TMDL Elements for Dissolved Zinc 10
Table 7: Wasteload Allocations for Individual Sources - South Fork at Wallace 12
Table 8: Wasteload Allocations for Individual Sources - Canyon Creek 13
Table 9: Wasteload Allocations for Individual Sources - Ninemile Creek 14
Table 10; Wasteload Allocations for Individual Sources - Pine Creek 15
Table 11; Wasteload Allocations for Individual Sources - South Fork above Pinehurst 16
Table 12 : Load Allocations for Coeur d'Alene Lake Sediments 17
Table 13 : Spokane River Wasteload Allocations 18
Appendix A : Map of Coeur d'Alene Basin 19
Appendix B : Source Location Maps for Coeur d'Alene River and Tributaries 20
3
-------
Coeur d'Alene Basin TMDL
August 2000
I. Scope of this TMDL
A. Pollutant Parameters
The TMDL is established for lead, cadmium, and zinc in the dissolved form in the water
column.
B, Idaho 303(d) List
As required under Section 303(d) of the Clean Water Act, the State of Idaho has
promulgated a listing of waters not currently meeting applicable water quality standards. Table 1
lists the waters in the Coeur d'Alene basin that are included on the 1998 Idaho 303(d) list as
impaired by metals.
Table 1. Coeur d'Alene Basin Waterbodies on the 1998 Idaho 303(d) List for Metals
HUC
SEG#
WATERBODY NAME
SEGMENT BOUNDARIES
LENGTH
17010302
3513
South Fork Coeur d'Alene R.
Big Creek to Pine Creek
8.99
17010302
3514
South Fork Coeur d'Alene R.
Pine Creek to Bear Creek
1.79
17010302
3515
South Fork Coeur d'Alene ft.
Bear Creek to Coeur d'Alene ftiver
0,44
17010302
3516
South Fork Coeur d'Alene R.
Canyon Creek to Ninemile Creek
0.55
17010302
3517
South Fork Coeur d'Alene R.
Ninemile Creek to Placer Creek
0.33
17010302
3518
South Fork Coeur d'Alene R.
Placer Creek to Big Creek
7.56
17010302
3519
Pine Creek
E Fk Pine Creek to S Fk CdA River
5.28
17010302
3520
East Fork Pine Creek
Headwaters to Hunter Creek
5.19
17010302
3521
East Fork Pine Creek
Hunter Creek to Pine Creek
1.57
17010302
3524
Ninemile Creek
Headwaters to S Fk Coeur d'Alene R
4.91
17010302
3525
Canyon Creek
Gorge Gulch to. South Fk CdA River
6.90
17010302
5084
Government Gulch
Headwaters to S Fk of CdA River
3.53
17010302
5127
Moon Creek
Headwaters to S Fk CdA River
4.07
17010302
5661
Milo Creek
Headwaters to mouth
2.56
17010303
2001
Coeur d'Alene Lake
NA
NA
17010303
3529
Coeur d'Alene River
Black Lake to Thompson Lake
4.21
17010303
4015
Coeur d'AJene River
Cave Lake to Black Lake
4.00
17010303
4016
Coeur d'Alene River
Fortier Creek to Robinson Creek
0.80
17010303
4017
Coeur d'Alene River
Fourth of July Creek to Fortier Cr
10.50
17010303
4018
Coeur d'Alene River
French Gulch to Skeei Gulch
4.21
17010303
4019
Coeur d'Alene River
Latour Creek to Fourth of July Cr
4.09
17010303
4020
Coeur d'Alene River
Robinson Creek to Cave Lake
1.57
17010303
4021
Coeur d'Alene friver
S £k
-------
Coeur d'Alene Basin TMDL
August 2000
C Target sites
The following table lists nine target sites in the Coeur d'Alene basin. The required
elements of a TMDL under Section 303(d) of the Clean Water Act are established at the seven
target sites below that are located on 303(d) listed waterbodies. A map of the basin is included in
Appendix A.
Table 2. TMDL Target Sites
Target Site Name
Description.
Spokane River @ State Line
Idaho-Washington Border
St. Joe River @ Calder1
USGS Station No. 12414500
Coeur d'Alene River @ Harrison
Near Mouth of Coeur d'Alene River
North Fork Coeur d'Alene River (4> Enaville'
USGS Station No. 12413000
South Fork Coeur d'Alene River (s> Pinehursi
USGS Station No. 12413470; URS Greiner Station No. 271
Pine Creek
Mouth of Pine Creek; URS Greiner Station No. 315
South Fork Coeur d'Alene River (s> Wallace
South Fork downstream from Ninemile Creek confluence,
URS Greiner Station No. 233
Ninemile Creek
Mouth of Ninemile Creek south of Depot RV park, URS
Greiner Statical No. 305
Canyon Creek
Mouth of Canyon Creek at Frontage Road Bridge north of I-
90; URS Greiner Station No. 288
'Target sites on the North Fork of the Coeur d'Alene River and St. Joe River are established for tracking purposes
and allocation of loading capacity through the river network. These two rivers currently meet water quality
standards based on available information.
D. Source Identification
The TMDL allocations apply to all sources contributing dissolved metals to surface
waters upgradient of a given target site. The TMDL assigns individual wasteload allocations to
discrete sources and gross allocations to non-discrete sources in the basin.
5
-------
Coeur d'Alene Basin TMDL
August 2000
II. Water Quality Standards
The TMDL elements are calculated to achieve the following metals concentrations in the
surface waters of the basin.
Table 3: Water Quality Criteria for Dissolved Cadmium, Lead, and Zinc
Target Site
Flow
Tier
Rrar
Budw$$
Dissolved
Dissolved
Pb
Dissolved
Zn >
(cfe>
(ug/l>
tugrt>
288
Canyon
7.1
56
0.67
1.33
64
11
56
0.67
1.33
64
25
45
0.57
1 05
53
149
25
0.37
0.54
32
305
Nine Mile
2.0
73
0.82
1.78
80
3.0
73
0.82
1.78
80
6.9
63
0.73
1.52
71
41
36
0.48
0.81
44
233
South Fork
Wallace
22
57
0.68
1.36
65
35
56
0.67
1.33
64
79
47
0.59
1.10
55
469
25
0.37
0.54
32
315
Pine
20
25
0.37
0.54
32
29
25
0 37
0.54
32
80
25
0 37
0.54
32
387
25
0.37
0.54
32
271
South Fork
Pinehurst
68
101
1.00
2.54
105
97
96
1.00
2.40
101
268
71
0.80
1.73
78
1.290
28
0.40
0.62
36
CDA River
Harrison
239
47
0.59
1.10
55
348
45
0.57
1.05
53
1,100
36
0.48
0.81
44
6,870
25
0.37
0.54
32
Spokane
River
NA
20
0.31
042
27
6
-------
Coeur d'Alene Basin TMDL
August 2000
III. TMDL Elements
A. TMDL Elements for Coeur d'Alene River and Tributaries
Tables 4 through 6 list the following TMDL elements for the target sites in the
Coeur d'Alene River and tributaries: total loading capacity, natural background loading, loading
allocated upstream, loading available for allocation, margin of safety, gross allocation to waste
piles and nonpoint sources, and gross wasteload allocations for discrete sources.
The gross wasteload allocation for each target site is allocated to individual discrete sources in
Part HI. B.l below.
7
-------
Table 4 : TMDL Elements for Dissolved Cadmium
Loading
Capacity Used
Loading Avail.
Margin of
Gross
Wasteload
Target Site
Flow Tier
Capacity
Background
Upstream
for Allocation
Safety (10%)
Allocation (65%)
Allocation (25%)
(cfs)
(lbs/day)
(lbs/day)
(lbs/day)
(lbs/day)
(lbs/day)
(lbs/day)
(lbs/day)
Canyon
Creek
CC288
7
2.57E-02
2.30E-03
NA
2.34E-02
2.34E-03
1.52E-02
5.85E-03
11
3.98E-02
3.56E-03
NA
3.63E-02
3.63E-03
2.36E-02
9.07E-03
25
7.70E-02
8.09E-03
NA
6.89E-02
6.89E-03
4.48E-02
1.72E-02
149
2.97E-01
4.82E-02
NA
2.49E-01
2.49E-02
1.62 E-01
6.21 E-02
Ninemile
Creek
NM305
2
8.81 E-03
6.47E-04
NA
8.17E-03
8.17E-04
5.31 E-03
2.04E-03
3
1.32E-02
9.71 E-04
NA
1.22E-02
1.22E-03
7.96E-03
3.06E-03
6.9
2.73E-02
2.23E-03
NA
2.50E-02
2.50E-03
1.63E-02
6.26E-03
41
1.07E-01
1.33E-02
NA
9.38E-02
9.38E-03
6.09E-02
2.34E-02
South Fork
at Wallace
SF233
22
8.11E-02
7.15E-03
3.16E-02
4.24E-02
4.24E-03
2.75E-02
1.06E-02
35
1.27E-01
1.13E-02
4.85E-02
6.69E-02
6.69E-03
4.35E-02
1.67E-02
79
2.51 E-01
2.55E-02
9.39 E-02
1.31 E-01
1.31 E-02
8.55E-02
3.29E-02
469
9.34E-01
1.52E-01
3.42E-01
4.40E-01
4.40E-02
2.86E-01
1.10E-01
Pine
Creek
PC315
20
3.98E-02
1.08E-02
NA
2.91 E-02
2.91 E-03
1.89E-02
7.26E-03
29
5.78E-02
1.56E-02
NA
4.21 E-02
4.21 E-03
2.74E-02
1.05E-02
80
1.59E-01
4.31 E-02
NA
1.16E-01
1.16E-02
7.55E-02
2.91 E-02
387
7.71 E-01
2.09E-01
NA
5.62E-01
5.62E-02
3.65E-01
1.41 E-01
South Fork
at Pinehurst
SF271
68
3.81 E-01
2.93E-02
7.14E-02
2.80E-01
2.80E-02
1.82E-01
7.00E-02
97
5.23E-01
4.19E-02
1.09E-01
3.73E-01
3.73E-02
2.42E-01
9.31 E-02
268
1.16E+00
1.16E-01
2.48E-01
7.94E-01
7.94E-02
5.16E-01
1.98E-01
1290
2.80E+00
5.57E-01
1.00E+00
1.24E+00
1.24E-01
8.03E-01
3.09E-01
North Fork
at Enaville
NF400
165
3.28E-01
7.12E-02
NA
NA
NA
NA
NA
253
5.04E-01
1.09E-01
NA
NA
NA
NA
NA
845
1.68E+00
3.65E-01
NA
NA
NA
NA
NA
1100
1.01E+01
2.20E+00
NA
NA
NA
NA
NA
CdA River
at Harrison
239
7.60E-01
1.03E-01
3.51 E-01
3.05E-01
3.05E-02
2.75E-01
NA
348
1.07E+00
1.50E-01
4.82E-01
4.40E-01
4.40E-02
3.96E-01
NA
1100
2.87E+00
4.75E-01
1.16E+00
1.24E+00
1.24E-01
1.11E+00
NA
.6870
1.37E+01
2.96E+00
3.43E+00
7.29E+00
7.29E-01
6.56E+00
NA
8
-------
Table 5 : TMDL Elements for Dissolved Lead
Target Site
Flow Tier
(cfs)
Loading
Capacity
(lbs/day)
Background
(lbs/day)
Capacity Used
Upstream
(lbs/day)
Loading Avail,
for Allocation
(lbs/day)
Margin of
Safety (10%)
(lbs/day)
Gross
Allocation (65%)
(lbs/day)
Wasteload
Allocation (25%)
(lbs/day)
Canyon
Creek
CC288
7
5.10E-02
6.51 E-03
NA
4.45E-02
4.45E-03
2.89E-02
1.11 E-02
11
7.90E-02
1.01E-02
NA
6.89E-02
6.89E-03
4.48E-02
1.72E-02
25
1.41E-01
2.29E-02
NA
1.18E-01
1.18E-02
7.67E-02
2.95E-02
149
4.35E-01
1.37E-01
NA
2.98E-01
2.98E-02
1.94E-01
7.45E-02
Ninemile
Creek
NM305
2
1.92E-02
1.83E-03
NA
1.74E-02
1.74E-03
1.13E-02
4.35E-03
3
2.89E-02
2.75E-03
NA
2.61 E-02
2.61 E-03
1.70E-02
6.53E-03
6.9
5.64E-02
6.33E-03
NA
5.01 E-02
5.01 E-03
3.26E-02
1.25E-02
41
1.80E-01
3.76E-02
NA
1.43E-01
1.43E-02
9.26E-02
3.56E-02
South Fork
at Wallace
SF233
22
1.62E-01
2.03E-02
6.19E-02
7.97E-02
7.97E-03
5.18E-02
1.99E-02
35
2.51 E-01
3.21 E-02
9.50E-02
1.24E-01
1.24E-02
8.08E-02
3.11 E-02
79
4.67E-01
7.23E-02
1.68E-01
2.26E-01
2.26E-02
1.47E-01
5.65E-02
469
1 37E+00
4.30E-01
4.41 E-01
4.98E-01
4.98E-02
3.24E-01
1.24E-01
Pine
Creek
PC315
20
5.84E-02
2.27E-02
NA
3.57E-02
3.57E-03
2.32E-02
8.93E-03
29
8.46E-02
3.28E-02
NA
5.18E-02
5.18E-03
3.36E-02
1.29E-02
80
2.33E-01
9.06E-02
NA
1.43E-01
1.43E-02
9.28E-02
3.57E-02
387
1.13E+00
4.38E-01
NA
6.91 E-01
6.91 E-02
4.49E-01
1 73E-01
South Fork
at Pinehurst
SF271
68
9.33E-01
7.70E-02
1.15E-01
7.41 E-01
7.41 E-02
4.81 E-01
1.85E-01
97
1.26E+00
1.10E-01
1.76E-01
9.74E-01
9.74E-02
6.33E-01
2.43E-01
268
2.50E+00
3.04E-01
3.69E-01
1.83E+00
1.83E-01
1.19E+00
4.57E-01
1290
4.28E+00
1.46E+00
1.19E+00
1.63E+00
1.63E-01
1.06E+00
4.07E-01
North Fork
at Enaville
NF400
165
4.81 E-01
1.87E-01
NA
NA
NA
NA
NA
253
7.38E-01
2.87E-01
NA
NA
NA
NA
NA
845
2.47E+00
9.57E-01
NA
NA
NA
NA
NA
1100
1.49E+01
5.77E+00
NA
NA
NA
NA
NA
CdA River
at Harrison
239
1.41E+00
2.70E-01
9.27E-01
2.14E-01
2.14E-02
1.93E-01
NA
348
1.96E+00
3.94E-01
1 26E+00
3.07E-01
3.07E-02
2.76E-01
NA
1100
4.83E+00
1 25E+00
2.79E+00
8.01 E-01
8.01 E-02
7.21 E-01
NA
6870
2.00E+01
7.78E+00
7.39E+00
4.87E+00
4.87E-01
4.39E+00
NA
9
-------
Table 6 : TMDL Elements for Dissolved Zinc
Loading
Capacity Used
Loading Avail.
Margin of
Gross
Wasteload
Target Site
Flow Tier
Capacity
Background
Upstream
for Allocation
Safety (10%)
Allocation (65%)
Allocation (25%)
(cfs)
(lbs/day)
(lbs/day)
(lbs/day)
(lbs/day)
(lbs/day)
(lbs/day)
(lbs/day)
Canyon
Creek ,
CC288
7
2.45E+00
2.34E-01
NA
2.22E+00
2.22E-01
1.44E+00
5.54E-01
11
3.79E+00
3.62E-01
NA
3.43E+00
3.43E-01
2.23E+00
8.58E-01
25
7.16E+00
8.23E-01
NA
6.34E+00
6.34E-01
4.12E+00
1.59E+00
149
2.59E+01
4.90E+00
NA
2.10E+01
2.10E+00
1.37E+01
5.26E+00
Ninemile
Creek
NM305
2
8.63E-01
6.58E-02
NA
7.98E-01
7.98E-02
5.18E-01
1.99E-01
3
1.30E+00
9.87E-02
NA
1.20E+00
1.20E-01
7.78E-01
2.99E-01
6.9
2.63E+00
2.27E-01
NA
2.40E+00
2.40E-01
1.56E+00
6.01 E-01
41
9.72E+00
1.35E+00
NA
8.38E+00
8.38E-01
5.44E+00
2.09E+00
South Fork
at Wallace
SF233
22
9.04E-03
9.03E-03
3.01 E+00
9.03E-03
0.00E+00
1.42E-02
1.00E+00
35
3.39E-03
3.39E-03
4.63E+00
3.39E-03
0.00E+00
5.33E-03
1.00E+00
79
4.67E-02
4.66E-02
8.74E+00
4.66E-02
0.00E+00
7.34E-02
1.00E+00
469
2.26E-01
2.26E-01
2.94E+01
2.26E-01
0.00E+00
3.55E-01
1.00E+00
Pine
Creek
PC315
20
3.48E+00
3.34E-01
NA
3.15E+00
3.15E-01
2.05E+00
7.87E-01
29
5.05E+00
4.85E-01
NA
4.57E+00
4.57E-01
2.97E+00
1.14E+00
80
1.39E+01
1.34E+00
NA
1.26E+01
1.26E+00
8.19E+00
3.15E+00
387
6.74E+01
6.47E+00
NA
6.09E+01
6.09E+00
3.96E+01
1.52E+01
South Fork
at Pinehurst
SF271
68
3.87E+01
2.24E+00
7.15E+00
2.93E+01
2.93E+00
1.90E+01
7.32E+00
97
5.28E+01
3.19E+00
1.09E+01
3.88E+01
3.88E+00
2.52E+01
9.69E+00
268
1.13E+02
8.82E+00
2.47E+01
7.95E+01
7.95E+00
5.17E+01
1.99E+01
1290
2.47E+02
4.24E+01
9.77E+01
1.07E+02
1.07E+01
6.96E+01
2.68E+01
North Fork
at Enaville
NF400
165
2.87E+01
4.45E+00
NA
NA
NA
NA
NA
253
4.41 E+01
6.82E+00
NA
NA
NA
NA
NA
845
1.47E+02
2.28E+01
NA
NA
NA
NA
NA
1100
8.86E+02
1.37E+02
NA
NA
NA
NA
NA
CdA River
at Harrison
239
7.10E+01
6.85E+00
3.37E+01
3.04E+01
3.04E+00
2.74E+01
NA
348
9.97E+01
9.99E+00
4.56E+01
4.41 E+01
4.41 E+00
3.97E+01
NA
1100
2.61 E+02
3.16E+01
1.02 E+02
1.27E+02
1.27E+01
1.14E+02
NA
6870
1.20E+03
1.97 E+02
2.44E+02
7.55E+02
7.55E+01
6.79E+02
NA
10
-------
Coeur d'Alene Basin TMDL
August 2000
B. Allocations for Individual Sources
1. Wasteload Allocations for Coeur d'Alene River and Tributaries
a. For a given metal and target site flow, the wasteload allocation for an individual
source in the Coeur d'Alene River and tributaries is:
(1) The calculated value listed in Tables 7 through 11; or,
(2) A reasonable estimate of the current monthly average performance at the
facility (established in the NPDES permit),
whichever is more stringent.
b. After issuance of a permit with cadmium, lead, and/or zinc limits based oo current
performance (see Part a(2) above), the loading equal to the difference between the
calculated value (in Tables 7 through 11) and the performance-based limit will be
reserved for future growth. Reserve allocations created by a permitting action
may be allocated to new or expanding facilities within the same target site or at a
target site downstream of permitted source. Allocation of the future growth
reserve will require formal modification of this TMDL.
c. In its discretion, the NPDES permitting authority may develop additional flow
tiers (and associated permit limits) to those listed below.
d. The listed wasteload allocation applies to tlie monthly average discharge to the
receiving water.
Maps showing the locations of discrete sources are included in Appendix B to the TMDL.
11
-------
Table 7 : Calculated Wasteload Allocations for Individual Sources - Canyon Creek (URSG Site CC288)
All values in lbs/day
Total Recoverable Cadmium
Total Recoverable Lead
Total Recoverable Zinc
Station ID
Flow
(cfs)
7Q10L
10,h
Percentile
50th
Percentile
90*
Percentile
7Q10L
10th
Percentile
50th
Percentile
90th
Percentile
7Q10L
10th
Percentile
50th
Percentile
90,n
Percentile
CC817
Hecla #3
0.0684
4.85E-05
7.51 E-05
1 43E-04
5.14E-04
1.01E-04
1.57E-04
2 68E-04
8.79E-04
4.58E-03
7.10E-03
1.31 E-02
4.36E-02
CC355
Gem
0.26
1.84E-04
2.85E-04
5.42E-04
1.96E-03
3.85E-04
5 96E-04
1.02E-03
2.58E-03
1.74E-02
2.70E-02
4.99E-02
1.66E-01
CC816
Star/Phoenix Tailings (001)
2.34
1.66E-03
2.57E-03
4.88E-03
1 76E-02
3.46E-03
5.37E-03
9.19E-03
2.32E-02
1.57E-01
2.43E-01
4.49E-01
1 49E+00
CC357
Woodland Park Seep
0.0038
2.69E-06
4.17E-06
7.92E-06
2.86E-05
5.63E-06
8.72E-06
1.49E-05
3.77E-05
2.55E-04
3.95E-04
7 29E-04
2.42E-03
CC372
Tamarack #7
1.59
1.13E-03
1 75E-03
3.32E-03
1.20E-02
2.35E-03
3.65E-03
6.24E-03
1 58E-02
1 07E-01
1.85E-01
3 05E-01
1.01E+00
CC353
Hercules #5
1.707
1.21E-03
1.87E-03
3.56E-03
1.28E-02
2.53E-03
3.92E-03
6.70E-03
1.89E-02
1.14E-01
1.77E-01
3.28E-01
1 09E+00
CC371
Blackbear Fraction
1.165
8.25E-04
1.28E-03
2.43E-03
8.76E-03
1.72E-03
2.67E-03
4.57E-03
1.16E-02
7.81 E-02
1.21E-01
2.24E-01
7.42E-01
CC373
Anchor
0.008
5.67E-06
8.78E-08
1.07E-O5
8.02E-05
1.18E-05
1.83E-05
3.14E-05
7.94E-05
5.36E-04
8.31 E-04
1.53E-03
5.09E-03
CC354
Hidden Treasure
0.72
5.10E-04
7.90E-04
1 50E-03
5.42E-03
1.07E-03
1 65E-03
2.83E-03
7.14E-03
4.83E-02
7.48E-02
1 38E-01
4 58E-01
Tiger/Poo rman
0.4
2 83E-04
4.39E-04
8.34E-04
3.01 E-03
5.92E-04
9.17E-04
1.57E-03
3.97E-03
2.88E-02
4.15E-02
7.67E-02
2 55E-01
12
-------
Table 8 : Calculated Wasteload Allocations for Individual Sources - Ninemile Creek (URSG Site NM305)
All values In lbs/day
Total Recoverable Cadmium
Total Recoverable Lead
Total Recoverable Zinc
Station ID
Flow
(eft)
7Q10L
10th
Percentile
50th
Percentile
90,h
Percentile
7Q10L
10th
Percentile
60th
Percentile
90th
Percentile
7Q10L
10m
Percentile
50th
Percentile
90th
Percentile
NM360
Interstate-Callahan
(IC) #4
0.040
4.11 E-05
6.17E-05
1.26E-04
4.72E-04
9.65E-05
1 45E-04
2.78E-04
7.90E-04
4.02E-03
8.03E-03
1.21E-02
4 22E-02
NM362
IC Waste Rock
1.790
1 84E-03
2.70E-O3
5.64E-03
2.11E-02
4.32E-03
6.48E-03
1.24E-02
3.53E-02
1.80E-01
2.70E-01
5.42E-01
1.89E+00
NM363
IC Tailings Seep
0.004
4.11E-06
6.17E-08
1.26E-05
4.72E-05
9.85E-06
1 45E-05
2.78E-05
7.90E-05
4.02E-04
8.03E-04
1.21 E-03
4 22E-03
NM361
Rex #2
0.020
2.06E-05
3.09E-05
6.31 E-05
2.36E-04
4.82E-05
7.24E-05
1.39E-04
3.95E-04
2.01 E-03
3.01 E-03
8.05E-03
2 11 E-02
NM364
Tamarack 400
Level
0.040
4.11 E-05
6.17E-05
1.26E-04
4.72E-04.
9.65E-05
1.45E-04
2.78E-04
7.90E-04
4.02E-03
6.03E-03
1 21E-02
4.22E-02
NM366
Tamarack #5
0.030
3.09E-05
4.B3E-05
9.46E-05
3.54E-04
7.24E-05
109E-04
2.08E-04
5.92E-04
3.01 E-03
4.52E-03
9.08E-03
3.16E-02
NM368
Rex Tailings Seep
0020
2.06E-05
3.09E-05
6.31 E-05
2 36E-04
4.82E-05
7 24E-05
1 39E-04
3.95E-04
2.01 E-03
3.01 E-03
6.05E-03
2 11 E-02
NM359
Success #3
0.010
1 03E-05
1.54E-05
3.15E-05
1.18E-04
2.41 E-05
3.62E-05
6.94E-05
1.97E-04
1.00E-O3
1.51 E-03
3.03E-03
1.05E-02
NM367
Dayrock 100
0.007
6.99E-06
1.05E-05
2.14E-05
8.03E-05
1 64E-05
2.46E-05
4.72E-05
1.34E-04
6.83E-04
1.02E-03
2.06E-03
7 17E-03
NM369
Silver Star
0.0096
9.87E-06
1.48E-05
3.03E-05
1.13E-04
2.32E-05
3.47E-05
6.67E-05
1 90E-04
9.65E-04
1.45E-03
2.90E-03
1 01 E-02
NM370
Duluth
0.011
1.13E-05
1.70E-05
3.47E-05
1 30E-04
2.65E-05
3.98E-05
7.64E-05
2 17E-04
1.11 E-03
1.66E-03
3.33E-03
1.16E-02
NM374
Success Tailings
0.003
3.50E-06
5.25E-06
1 07E-05
4.02E-05
8.20E-06
1.23E-05
2.36E-05
6.71 E-05
3.42E-04
5.12E-04
1 03E-03
3.59E-03
13
-------
Table 9 : Calculated Wasteload Allocations for Individual Sources - South Fork at Wallace (URSG Site SF223)
All values In Iba/day
Total Recoverable Cadmium
Total Recoverable Lead
Total Recoverable Zinc
Station ID
Row
(cfs)
7Q10L
10*1
Percentile
50th
Percentile
90th
Percentile
7Q10L
10"
Percentile
so"1
Percentile
90*
Percentile
7Q10L
10*
Percentile
50*"
Percentile
901"
Percentile
SF607
Lucky Friday
Outfall 001
1 27
1 52E-03
2.40E-03
4.72E-03
1.58E-02
3.43E-03
5.35E-03
9.73E-03
2 14E-02
1 43E-01
2.26E-01
4 35E-01
1 32E+00
SF609
Lucky Friday
Outfall 003
085
1 02E-03
1.61 E-03
3 16E-03
1 06E-02
2.30E-03
3.58E-03
6.51 E-03
1 43E-02
9.59E-02
1.51E-01
2.91 E-01
8 84E-01
SF328
Star/Morning
Waste Rock
1.59
1.90E-03
3.00E-03
5.90E-03
1.98E-02
4.29E-03
6.69E-03
1.22E-02
2.68E-02
1.79E-01
2.82E-01
5.44E-01
1 65E+00
SF 396
Square Deal
0.08
9 57E-05
1.51 E-04
2.97E-04
9.94E-04
2.16E-04
3.37E-04
6.13E-04
1.35E-03
9.03E-03
1.42E-02
2.74E-02
8.32E-02
SF395
Golconda
003
3.59E-05
5.67E-05
1.11 E-04
3.73E-04
8.10E-05
1.26E-04
2.30E-04
5.06E-04
3.39E-03
5.33E-03
1 03E-02
3.12E-02
SF627 ' '
Mullan STP
0.413
4.94E-04
7.80E-04
1.53E-03
5.13E-03
1.12E-03
1.74E-03
3.17E-03
6.97E-03
4.66E-02
7.34E-02
1.41 E-01
4.29E-01
SF338
Snowstorm #3
2
2.39E-03
3.78E-03
7 43E-03
2.49E-02
5.40E-03
8.42E-03
1.53E-02
3.37E-02
2.26E-01
3.55E-01
6.84E-01
2.08E+00
SF339
Copper Kinq
0.0564
6.75E-05
1.07E-04
2.09E-04
7.01 E-04
1.52E-04
2.37E-04
4.32E-04
9.51 E-04
6.37E-03
1.00E-02
1.93E-02
5.86E-02
SF345
Morning #4
0.0152
1.82E-05
2.87E-05
5.64E-05
1.89E-04
4.11E-05
6.40E-05
1.16E-04
2.56E-04
1.72E-03
2.70E-03
5.20E-03
1 58E-02
SF346
Morninq #5
0.0111
1.33E-05
2.10E-05
4.12E-05
1.38E-04
3.00E-05
4.67E-05
8.51 E-OS
1.87E-04
1.25E-03
1.97E-03
3.80E-03
1.15E-02
SF347
Star 1200 Level
0.695
8.31 E-04
1.31 E-03
2.58E-03
8.64E-03
1.88E-03
2.93E-03
5.33E-03
1.17E-02
7.84E-02
1 23E-01
2.38E-01
7.23E-01
SF349
Grouse
1 82
2.18E-03
3.44E-03
6.76E-03
2.26E-02
4.92E-03
7.66E-03
1.39E-02
3.07E-02
2.05E-01
3.23E-01
6.23E-01
1 89E+00
SF386
Adit in Beacon
Light Area
0.0003
3 59E-07
5.67E-07
1.11E-06
3.73E-06
8.10E-07
1.26E-06
2.30E-06
5.06E-06
3.39E-05
5.33E-05
1.03E-04
3.12E-04
SF389
Unnamed Adit
Deadman Gulch
0.011
1.32E-05
2.08E-05
4.08E-05
1.37E-04
2.97E-05
4.63E-05
8.43E-05
1 86E-04
1.24E-03
1.95E-03
3 76E-03
1.14E-02
SF390
Reindeer Queen
0.011
1.32E-05
2.08E-05
4.08E-05
1.37E-04
2.97E-05
4.63E-05
8.43E-05
1.86E-04
1.24E-03
1.95E-03
3.76E-03
1.14E-02
14
-------
Table 10 : Calculated Wasteload Allocations for Individual Sources - Pine Creek (URSG Site PC315)
All values In lbs/day
Total Recoverable Cadmium
Total Recoverable Lead
Total Recoverable Zinc
Station ID
Flow
(cfs)
7Q10L
10th
Percentile
50th
Percentile
90th
Percentile
7Q10L
10m
Percentile
50,h
Percentile
90th
Percentile
7Q10L
10th
Percentile
50th
Percentile
90th
Percentile
PC329 North Amy
0.322
3.48E-03
5.04E-03
1.39E-02
6.73E-02
4.27E-03
6.20E-03
1.71E-02
8.27E-02
3.77E-01
5.47E-01
1 51E+00
7.29E+00
PC330 Amy
0 005
5.40E-05
7.83E-05
2.16E-04
1.05E-03
6.64E-05
9.62E-05
2.65E-04
1.28E-03
5.85E-03
8.49E-03
2 34E-02
1.13E-01
PC331
Liberal Kinq
0.005
5 40E-05
7.83E-05
2.16E-04
1.05E-03
6.64E-05
9.62E-05
2.65E-04
1 28E-03
5.85E-03
8.49E-03
2.34E-02
1.13E-01
PC332 Lookout
0.027
2.92E-04
4.23E-04
1.17E-03
5 64E-03
3.58E-04
5.20E-04
1.43E-03
6.94E-03
3.16E-02
4.58E-02
1 26E-01
6.12E-01
PC333
Upper Lynch
0.001
1 08E-05
1.57E-05
4.32E-05
2.09E-04
1.33E-05
1.92E-05
5.31 E-05
2.57E-04
1.17E-03
1.70E-03
4.68E-03
2.27E-02
PC334
Lynch/Nabob
0.0006
6.48E-06
9.40E-06
2.59E-05
1.25E-04
7.96E-06
1.15E-05
3.19E-05
1.54E-04
7.02E-04
1.02E-03
2.81 E-03
1.36 E-02
PC335
Nevada-Stewart
0.091
9.83E-04
1.43E-03
3.93E-03
1.90E-02
1.21 E-03
1.75E-03
4.83E-03
2.34E-02
1.07E-01
1.54E-01
4.26E-01
2.06E+00
PC336
Highland Surprise
0.038
4.10E-04
5.95E-04
1.64E-03
7.94E-03
5.04E-04
7.31 E-04
2.02E-03
9.76E-03
4.45E-02
6.45E-02
1 78E-01
8 61E-01
PC375
Highland Surprise
Waste Rock
0.0106
1.15E-04
1 66E-04
4.58E-04
2.22E-03
1.41E-04
2.04E-04
5.63E-04
2.72E-03
1.24E-02
1.80E-02
4.96E-02
2 40E-01
PC337
Sidney (Red Cloud
Creek Adit)
0,006
6.48E-05
9.40E-05
2.59E-04
1.25E-03
7.96E-05
1.15E-04
3.19E-04
1.54E-03
7.02E-03
1.02E-02
2.81 E-02
1.36E-01
PC340
Upper Little Pittsburg
0.002
2.16E-05
3 13E-05
8.64E-05
4.18E-04
2.65E-05
3.85E-05
1.06 E-04
5.14E-04
2 34E-03
3.39E-03
9.37E-03
4.53E-02
PC341
Lower Little Pittsburg
0.006
6.48E-05
9 40E-05
2.59E-04
1 25E-03
7.96E-05
1.15E-04
3.19E-04
1 54E-03
7.02E-03
1.02E-02
2 81E-02
1.36E-01
PC343
Nabob 1300 Level
0.066
7.13E-04
1 03E-03
2.85E-03
1 38E-02
8.76E-04
1 27E-03
3.50E-03
1.70E-02
7.73E-02
1.12E-01
309E-01
1.50E+00
PC344 Big It
0 00106
1.15E-05
1.66E-05
4.58E-05
2.22E-04
1.41E-05
2.04E-05
5.63E-05
2.72E-04
1.24E-03
1 80E-03
4.96E-03
2.40E-02
PC348
Upper Constitution
0 079
8.53E-04
1 24E-03
3.41 E-03
1.65E-02
1.05E-03
1.52E-03
4.19E-03
2.03E-02
9.25E-02
1.34E-01
3.70E-01
1 79E+00
PC351
Marmion Tunnel
0 0089
9 61E-05
1 39E-04
3.85E-04
1 86E-03
1.18E-04
1.71 E-04
4.73E-04
2.29E-03
1 04E-02
1.51E-02
4.17E-02
2.02E-01
PC352 Seep
Below Nevada
Stewart
0 0028
3.02E-05
4.39E-05
1.21 E-04
5 85E-04
3.72E-05
5.39E-05
1 49E-04
7.19E-04
3.28E-03
4.75E-03
1.31 E-02
6 34E-02
PC 400 Adit
Upstream of Little
Pittsburg
0.000422
4.56E-06
6.61 E-06
1 82E-05
8.82E-05
5.60E-06
8.12E-06
2.24E-05
1 08E-04
4 94E-04
7.16E-04
1 98E-03
9 56E-03
15
-------
Table 11 : Calculated Wasteload Allocations for Individual Sources - South Fork above Pinehurst (URSG Site SF271)
All values In lbs/day
Total Recoverable Cadmium
Total Recoverable Lead
Total Recoverable Zinc
Station ID
Flow
(cfs)
7Q10L
lO*"
Percentile
50,h
Percentile
90th
Percentile
7Q10L
10th
Percentile
50th
Percentile
90th
Percentile
7Q10L
10th
Percentile
S0,h
Percentile
90th
Percentile
SF382
Silver Dollar
0.015
7 OOE-05
9.30E-05
1 98E-04
3 09E-04
4.07E-04
5.35E-04
1.00E-03
8.93E-04
7.31 E-03
9.68E-03
1.99E-02
2 67E-02
SF393
Western Union (Lower
Adit)
0.001
4.67E-06
6.20E-06
1 32E-05
2.06E-05
2.71 E-05
3.57E-05
6.70E-05
5.96E-05
4.87E-04
6.46E-04
1 32E-03
1 78 E-03
SF3
Central Tmt Plant
4.990
2.33E-02
3.10E-02
6 59E-02
1 03E-01
1.35E-01
1.78E-01
3.34E-01
2.97E-01
2.43E+00
3.22E+00
6.60E+00
8 90E+00
SF620
Page STP
3.870
1.81 E-02
2.40E-02
5.11E-02
7.97E-02
1.05E-01
1 38E-01
2.59E-01
2.31 E-01
1 89E+00
2 50E+00
5.12E+00
6 90E+00
SF383
St Joe
0.007
3.27E-05
4 34E-05
9 25E-05
1 44E-04
1 90E-04
2.50E-04
4.69E-04
4.17E-04
3.41 E-03
4.52E-03
9.26E-03
1 25E-02
SF384
Coeur d'Alene
(Mineral Point)
0 005
2 33E-05
3.10E-05
6 61E-05
1 03E-04
1.36E-04
1.78E-04
3.35E-04
2.98E-04
2.44E-03
3.23E-03
6.62E-03
8 92E-03
SF385
Unnamed Adit
0 001
3.27E-06
4.34E-06
9.25E-06
1 44E-05
1.90E-05
2.50E-05
4.69E-05
4.17E-05
3.41 E-04
4.52E-04
9.26E-04
1 25E-03
SF600
Caladay
0210
9.80E-04
1.30E-03
2.77E-03
4.32E-03
5.70E-03
7.49E-03
1.41E-02
1.25E-02
1.02E-01
1.36E-01
2.78E-01
3 74E-01
SF602
Galena
1.300
6.06E-03
8.06E-03
1 72E-02
2.68E-02
3.53E-02
4.64E-02
8.71 E-02
7.74E-02
6.34E-01
8.39E-01
1.72E+00
2.32E+00
SF623
Smelterville STP
0 421
1 96E-03
2.61 E-03
5.56E-03
8.66E-03
1.14E-02
1.50E-02
2 82E-02
2.51 E-02
2.05E-01
2.72E-01
5.57E-01
7 51 E-01
SF624
Sunshine d01
3.120
1.40E-O2
1.94E-02
4.12E-02
6.42E-02
8.46E-02
1.11E-01
2.09E-01
1.88E-01
1 52E+00
2.01 E+OO
4.13E+00
5.56E+00
Coeur/Galena 002
0.775
3.62E-03
4.81 E-03
1.02E-02
1 60E-02
2.10E-O2
2 76E-02
5.19E-02
4.62E-02
3.78E-01
5.00E-01
1.03E+00
1 38E+00
Consolidated Silver
0 300
1.40E-03
1.86E-03
3.97E-03
6.18E-03
8.14E-03
1.07E-02
2.01 E-02
1.79E-02
1 46E-01
1.94E-01
3.97E-01
5.35E-01
16
-------
Coeur d'Alene Basin TMDL
August 2000
2. Load Allocations for Coeur d'Alene Lake Sediments
The following allocations apply to net loadings of dissolved metals occurring within
Coeur d'Alene Lake. Net loadings in this case are defined as the loadings in the Spokane River
at the lake outlet minus the loadings at the mouth of the Coeur d'Alene River.
Table 12 : Load Allocations for Coeur d'Alene Lake Sediments
Flow in St.
Joe River at
Calder (cfs)
Load Allocation for Net Loading from Lake Sediments (lbs/day)
Dissolved Cadmium
(lbs/day)
Dissolved Lead
(lbs/day)
Dissolved Zinc
(lbs/day)
241
0.46
0.38
36
374
0.71
0.59
56
1,000
1.9
1.6
150
6,470
12
10
970
3. Wastcload Allocations for the Spokane River
a. For a given metal, the wasteioad allocation for an individual source in the
Spokane River is:
(1) The value listed in Table 13; or,
(2) A reasonable estimate of the current monthly average performance at the
facility (established in the NPDES permit fact sheet),
whichever is more stringent.
b. After a permit is issued with any cadmium, lead, and/or zinc limits based on
current performance, the loading equal to the difference between the value in
Table 13 and the performance-based limit will be reserved for municipal
stormwater sources. Allocation of the future stormwater reserve will require
formal modification of tliis TMDL.
17
-------
Coeur d'Alene Basin TMDL August 2000
c. The listed waste load allocation applies to the monthly average discharge to the
receiving water.
Table 13 : Spokane River Wasteload Allocations
Facility
Total
Recoverable
Cadmium (ug/1)
Total
Recoverable
Lead (ug/1)
Total
Recoverable
Zinc (ug/1)
City of Coeur d'Alene
1.3
3.3
132
City of Post Falls
1.0
2.4
101
City of Hayden Lake
1.0
2.3
97
18
-------
Coeur d'Alene Basin TMDL
August 2000
Appendix A : Map of Coeur d'Alene Basin
19
-------
WASHINGTON
-------
Coeur d'Alene Basin TMDL
August 2000
Appendix B : Source Location Maps for Coeur d'Alene River and Tributaries
20
-------
107
857
332
341
375
377
351
X"
Bunker Hill/
Coeur cf Alone River Basin
Sampling Locations
-DRAFT-
?
LEGEND
Com
^373
Si#*
S»••••
369
;v
r
Vj
.T
, -V,.
"C
T>»» ir«p vaa*
-------
w
Bunker Hill/
Coeur rfAJene Rivef Basin
Sampling Locations
-DRAFT-
LEGCND
*¦*
* «.**» y I '
£.W
vr .V
n«i imp «« cimm (o> (itnmiq
pupoM*fortn» Co+jt tf Mww
d«0«Y«d
3*\x if Ajar*
¦WKWdKiHW Can*
BMMi and ftoamtf Sourc* tocmto
wwv otMnad tan tfw Mk ct
i (BlM)
n*«lDlitlM«
W«9M flMCoardniM Mm to*
N»» fciwift O^yri HM
URS Greiner
Doc Control: 416250*2772.04 L
Generation: 1
wrsr,- -
isur-.'...
I
-------
TECHNICAL SUPPORT DOCUMENT
Total Maximum Daily Load for Dissolved Cadmium,
Dissolved Lead, and Dissolved Zinc in Surface Waters
of the Coeur d'Alene Basin
FINAL
August 2000
U.S. Environmental Protection Agency, Region 10
1200 Sixth Avenue
Seattle, WA 98101
Idaho Department of Environmental Quality
1410 North Hilton
Boise, Idaho 83706
-------
TABLE OF CONTENTS
SECTION PAGE
1.0 INTRODUCTION 1
2.0 LEGAL AUTHORITY AND BACKGROUND 2
2.1 Legal Authority ,2
2.2 Background 3
3.0 SCOPE OF THE TMDL 4
3.1 Pollutant Parameters 4
3.2 Geographic Scope 4
3.3 Idaho 303(d) List 4
3.4 Identification of Target sites 7
3.5 Identification of Sources 8
4.0 APPLICABLE WATER QUALITY STANDARDS 9
4.1 General 9
4.2 Designated Uses 9
4.3 Applicable Water Quality Criteria 10
4.4 Anti-degradation 12
5.0 AVAILABLE DATA 12
5.1 Data Sources 12
5.2 Data Limitations 15
5.3 Current Metals Concentrations in the Basin 15
6.0 DERIVATION OF TMDL ELEMENTS 17
6.1 Approach to Calculating Loading Capacities at Target Sites 17
6.1. a. Seasonal Variation 17
6. l.b. Flow Estimation 18
6.2 Total Loading Capacity 22
6.3 Loading Available for Allocation 22
6.3.a. Natural Background Conditions 23
6.3.b. Upstream Allocations 27
6.3.c. Margin of Safety 27
6.4 Proposed Allocation Method - CDA River and Tributaries 32
6.4.a. Source Categorization in Mining Areas 32
6.4.b. Gross Allocation at Each Target Site .33
6.4.c. Wasteload Allocations to Discrete Sources 34
6.5 Refinement of Wasteload Allocations for CDA River and Tributaries 36
6.5.a. Translators ' 36
i
-------
TABLE OF CONTENTS
(Continued)
6.5.b. Implementation of Flow-based Allocations in Permits 38
6.6 Proposed Allocation Method - Coeur d'Alene Lake and Spokane River ..... 44
6.6.a. Sources in Coeur d'Alene Lake and the Spokane River 44
6.6.b. Load Allocations for Net Loadings from Lake Sediments 44
6.6.c. Wasteload Allocations for Spokane River Treatment Plants 46
6.6.d. Wasteload Allocations for Urban Stormwater 48
7.0 TMDL IMPLEMENTATION ISSUES 48
7.1 General 48
7.2 FACA Report 48
7.3 Coordination of Clean Water Act and Superfund Authorities 49
7.4 Preliminary Assessment of Feasibility 53
7.5 Other TMDL Issues 54
7.6 Development of Site-Specific Criteria 57
8.0 DATA MANAGEMENT AND SOFTWARE APPLICATIONS 57
9.0 REFERENCES 58
LIST OF TABLES
Figure 3-1 Map of Coeur d'Alene Basin 5
Table 3-1. Coeur d'Alene Basin Waterbodies on the 1998 Idaho 303(d) List for Metals 6
Table 3-2. Metals Concentrations in Non-Listed South Fork Tributaries 7
Table 3-3. TMDL Target Sites 8
Table 4-1. Range of Applicable Criteria in the Coeur d'Alene Basin 11
Table 5-1. Analytical Water Quality Data Available for CD A basin .12
Table 5-2. Current Conditions at TMDL Target Sites (in ug/1) 15
Table 6-1. Flow Tiers for USGS Stations in the CDA basin 19
Table 6-2. Flow Relationships between Short-Term and Long-Term Sites 19
Table 6-3. TMDL Flow Tiers 21
Table 6-4. Water Quality Criteria for Metals in the Coeur d'Alene Basin TMDL .......... 23
Table 6-5. Background Dissolved Metal Concentrations at Station 205 24
Table 6-6. Median Background Metals Concentrations in the South Fork Subbasin 26
Table 6-7. Available Loading Capacity for Dissolved Cadmium 29
Table 6-8. Available Loading Capacity for Dissolved Lead 30
Table 6-9. Available Loading Capacity for Dissolved Zinc 31
Table 6-10. Translators from Dissolved to Total Recoverable Metal 37
Table 6-11. Wasteload Allocations for Individual Sources - Canyon Creek 39
Table 6-12. Wasteload Allocations for Individual Sources - Ninemile Creek . ., 40
Table 6-13. Wasteload Allocations for Individual Sources - South Fork at Wallace ......... 41
n
-------
TABLE OF CONTENTS
(Continued)
Table 6-14, Wasteload Allocations for Individual Sources - Pine Creek 42
Table 6-15. Wasteload Allocations for Individual Sources - South Fork at Pinehurst 43
Table 6-16. St. Joe River Loading Capacity and Background 45
Table 6-17. Load Allocations for Net Loadings from Coeur d'Alene Lake Sediments 45
Table 6-18. Effluent-based Criteria Equations 47
Table 6-19. Effluent-Based Criteria for Spokane River Facilities 47
LIST OF FIGURES
Figure 6-1 Flow Diagram for CD A River and Tributary Allocations 25
Figure 7-1 Coordinating Clean Water Act and CERCLA Activities 51
Figure 7-2 Solubility of Metal Hydroxides and Sulfides 55
iii
-------
1.0 INTRODUCTION
Lead and silver nulling began in the South Fork Coeur d'Alene River (South Fork) in 1885, when
lead-bearrng rock was discovered in the drainage. In the early mining operation, ore was sorted
from waste rock by hand and shipped out to smelters. In later years, concentrators were
established within the mining district and tailings were produced. In most cases, tailings were
disposed directly in the stream channels. Originally, the zinc in the ore was not commercially
valuable and was discarded with the tailings. As zinc became commercially marketable, it joined
silver and lead as the primary metals being mined in tlie valley. Initially, all mining operations in
the area disposed of tailings by deposition in the streams. The Mine Owner's Association, which
had been formed to control the threat of organized labor, constructed plank dams in Osburn and
the Pinehurst Narrows in 1901 and 1902. These dams were constructed to control the tailings in
the river which were causing flooding and resulting in law suits and damage claims.
In the 1920's, the first tailings impoundments were constructed. In the 1950s, mines started to
use tailings to fill open mine areas. By the 196Q's, tailings deposition directly into the waterways
had ceased. In the mid-1960's, action was taken to stop mines and mills from discharging into the
river as well as to stop towns from pumping raw sewage into the waterways. In addition to
concentrators, metals recovery facilities were constructed in the Silver Valley. These included a
smelter, an electrolytic zinc plant built in 1928, and a phosphoric acid/fertilizer plant in 1960.
All of these operations had ceased by 1981.
Beginning in the 1970 s, EPA issued wastewater discharge permits to mines and sewage
treatment plants operating along the South Fork. In 1983, the Bunker Hill Mining and
Metallurgical Complex was placed on the National Priorities List (NPL). EPA and the State of
Idaho continue to fund and implement clean-up activities in the 21-square mile study area. In
late 1997, EPA decided to conduct a basin-wide Remedial Investigation and Feasibility Study
(RI/FS) to identify other sources of contamination, risks, and clean-up alternatives.
In September 1996, the United States District Court for the Western District of Washington
ordered EPA, in concurrence with the State of Idaho, to develop a schedule for completion of
total maximum daily loads (TMDLs) for all streams identified by the State of Idaho in its 1994
Section 303(d) list. In response to concerns over delays in submittal of TMDLs for the Coeur
d'Alene (CDA) basin, and concerns about intergovernmental coordination between tlie States of
Idaho and Washington and the Coeur d'Alene Tribe, EPA initiated development of a basin-wide
TMDL in 1998. In a letter dated February 26, 1999, the State of Idaho proposed that EPA and
the State jointly issue a TMDL for the basin. EPA and the State of Idaho released a proposed
TMDL for public comment on April 15, 1999. The agencies held public hearings on the
proposed TMDL in Wallace, Coeur d'Alene, and Qsbum during a 120-day comr»nt period.
EPA and the State of Idaho are jointly issuing the final TMDL. The State of Idaho is issuing
(and EPA is simultaneously approving), the final TMDL for those waters within the jurisdiction
1
-------
of the State of Idaho. EPA is issuing the final TMDL for waterbodies witliin the Coeur d'Alene
Reservation boundaries (see below lor discussion of legal authority).
This document, which has been revised in response to public comments and new information,
describes the information assembled and analyzed to develop the TMDL, including: applicable
water quality standards, available water quality and flow data, calculation methods, legal and
policy considerations, and implementation mechanisms. The proposed TMDL establishes
loading capacities, wasteload allocations, load allocations, background conditions, and a margin
of safety in accordance with federal regulations (40 CFR 130).
2.0 LEGAL AUTHORITY AND BACKGROUND
2.1 Legal Authority
EPA has the authority under section 303(d) of the Clean Water Act to approve the final TMDLs
submitted by the State. EPA also has the legal authority to develop these TMDLs for the CDA
basin in Idaho if the State is unable or unwilling to submit a TMDL. When Congress directed
EPA to approve or disapprove State § 303(d) lists and TMDL submissions and to establish its
own lists or TMDLs in the event EPA disapproves the State submission, Congress imposed very
specific duties on EPA under section 303(d). However, EPA does not believe that its role under
section 303(d) is limited to those narrow, although important, duties. It would be anomalous and
contrary to Congress' intent in enacting this section if States could obstruct the implementation
of section 303(d) simply by refusing to submit TMDLs in a timely fashion. Rather, EPA believes
that the most reasonable interpretation of section 303(d) vests in EPA more general authority to
ensure timely and meaningful implementation of section 303(d). Tliis includes tlie discretionary
authority to develop TMDLs in the absence of a State submission.
This interpretation of section 303(d) is also the basis for EPA's issuance of TMDLs for waters
within reservation boundaries for tribes which have not been authorized under section 518(e).
Under the authority of CWA section 518(e), EPA may approve eligible tribes to carry out the
responsibilities of CWA section 303. While, at this time, the Coeur d'Alene Tribe has not yet
been approved to exercise this authority, the Tribe has submitted its application for EPA
approval of its water quality standards program. To the extent that waterbodies lie within
reservation boundaries, it is EPA's position that EPA, rather than the State of Idaho, has the
authority to develop TMDLs for those waters. It is acknowledged that ownership and
jurisdiction over portions of the submerged lands underlying waters covered by this basin-wide
TMDL are contested between the State of Idaho, United States and/or Coeur d*Alene Tribe. This
TMDL is not intended as a waiver or admission of ownership or jurisdiction regarding the
contested submerged lands by any of those parties.
In developing this basin-wide TMDL, EPA has utilized federally recommended "Gold Book"
water quality criteria for those waters within Indian Country. EPA also considered the water
2
-------
quality standards of the downstream jurisdiction (Idaho) at the border. Those water quality
standards are identical to EP.Vs Gold Book water quality criteria guidance. This approach
ensures consistency within the basin and assures that the standards of the downstream state
waters of Idaho and Washington will be met.
2.2 Background
The Idaho Department of Environmental Quality (DEQ) is authorized to issue and submit to EPA
for approval this TMDL pursuant to section 303(d) of the Clean Water Act, Idaho Code
§§ 39-101 through 39-130 and 39-3601 through 39-3624. Within the time frames established in
the Idaho TMDL Schedule developed as a result of Idaho Sportsmen's Coalition v. Browner.
W.D. Wash., C93-943-WD, the State originally developed draft TMDLs for the Coeur d'Alene
River system based upon site-specific criteria. Idaho did not finalize and submit the TMDLs to
EPA for approval, however, for a number of reasons, including the fact that the State could not
use site-specific criteria while Idaho was still subject to the federally promulgated National
Toxics Rule. In October 1998, the State changed the TMDL Schedule so that it could submit
TMDLs after EPA removal of the State from the National Toxics Rule. The Plaintiffs in the
Idaho Sportsmen's Coalition v Browner case raised concerns about the legality of this delay in
TMDL development, while EPA raised concerns about its appropriateness.
The State has determined to proceed at this time with a final TMDL. EPA removed Idaho from
the National Toxics Rule on April 12, 2000 (FR19659). Since Idaho had previously adopted
EPA "Gold Book" criteria into its water quality standards, which are now the applicable
standards for the Coeur d'Alene River basin, the NTR removal has no effect on the dissolved
metals goals of the final TMDL. However, the removal from the National Toxics Rule does give
the State the flexibility to employ water quality standards mechanisms such as site-specific
criteria (SSC) and variances.
In tlie Coeur d'Alene basin, SSC have been under development for some time for the South Fork
Coeur d'Alene River .segment above Wallace (upstream of the Canyon Creek confluence). This
effort has included extensive toxicity testing with a representative suite of resident species to
determine the metals levels that will fully support aquatic biota in this segment. This work has
been funded by the state of Idaho and Hecla Mining Company.
EPA and DEQ have evaluated the impact of a potential SSC on the TMDL. The draft SSC for
the Wallace segment would not have any effect on the TMDL allocations, because Idaho water
quality criteria would still be applied in the impaired segments downstream of the Wallace
segment. Meeting these downstream criteria would require the same calculations and wasteload
allocations in the TMDL. On the other hand, an SSC for the entire South Fork mainstem (from
Pinehurst to the Montana border) could affect the TMDL allocations. This is because statewide
criteria could be achieved in the mainstem Coeur d'Alene River after dilution of metals (in
excess of the statewide criteria) in the South Fork by the relatively clean North Fork.
3
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The Statu continues to be committed to tlie development of appropriate site-specific criteria and
intends to complete its work with respect to such criteria. II site-specific criteria that impact the
TMDL are developed and adopted by the State and approved by EPA, the State intends to modify
the TMDL applicable to waters within its jurisdiction to reflect the site-specific criteria. Any
substantive modification to the State's TMDL would be submitted to EPA for approval.
3.0 SCOPE OF THE TMDL
3.1 Pollutant Parameters
The TMDL is established for lead, cadmium, and zinc in the dissolved form m the water column.
These metals parameters are considered the highest priority for TMDL development, because
large portions of the CDA basin exceed the water quality standards for these metals. As a result
of these exceedances, these metals are also important parameters in the NPDES permits and
Ri/FS analysis in the basin.
3.2 Geographic Scope
The geographic scope of the TMDL includes the entire CDA basin, from the headwaters to the
Idaho-Washington border. Figure 3-1 presents a map of tlie drainages in the CDA basin. These
drainages include tlie Idaho portion of tlie Spokane River, Coeur d'Alene Lake, St. Joe River,
main stem Coeur d'Alene River, and tlie North and South Forks of the Coeur d'Alene River.
Each of these streams has many named and unnamed tributaries.
Because the majority of sources are located in the South Fork portion of the basin, the TMDL
components are established at a finer scale in this area. More detailed maps of the drainages and
sources in the South Fork are included in Appendix A. A location key is provided in Appendix
B.
3.3 Idaho 303(d) List
As required under Section 303(d) of the Clean Water Act, the State of Idaho has promulgated a
listing of waters not currently meeting applicable water quality standards. A number of
waterbodies in the CDA basin are included on the 303(d) list as impaired by metals.
4
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r
——„
/
i
LEGEND
Cities or Towns
Target Srte Locations
Rivars and Streams
Watershed Boundary
Coeur tfAlane
Tribal Retervatlon
Sttviunt Hirer
Cataid
Location of Watersheds
K«k>M
—wasc*
^ ^ *L
rmoo
SaMJa
IPS
5 10 Miles
Figure 3-1 Map of Coeur d'Alene Basin
5
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Table 3-1. Coeur d'AIene Basin Waterbodies 011 the 1998 Idaho 303(d) List for Metals
HUC
SEG#
WATERBODY NAME
SEGMENT BOUNDARIES
LENGTH
fMU
17010302
3513
South Fork Coeur d'AIene R.
Big Creek to Pine Creek
8.99
17010302
3514
South Fork Coeur d'AIene R.
Pine Creek to Bear Creek
1.79
17010302
3515
South fork Coeur d'AIene R.
Bear Creek to Coeur d'AIene River
0.44
17010302
3516
South Fork Coeur d'AIene R.
Canyon Creek to Ninemile Creek
0.55
17010302
3517
South Fork Coeur d'AIene R.
Ninemile Creek to Placer Creek
0.33
17010302
3518
South Fork Coeur d'AIene ft.
3lacer Creek to Big Creek
7.56
17010302
3519
Pine Creek
|E Fk Pine Creek to S Fk CDA River
5.28
17010302
3520
East Fork Pine Creek
Headwaters to Hunter Creek
5.19
17010302
3521
East Fork Pine Creek
Hunter Creek to Pine Creek
1.57
17010302
3524
Ninemile Creek
Headwaters to S Fk Coeur d'AIene R
4.91
17010302
3525
Canyon Creek
Gorge Gulch to South Fk CDATRiver
6.90
17010302
5084
Government Gulch
Headwaters to S.Fk of CDA River
3.53
17010302
5127
Moon Creek
Headwaters to S Fk CDA River
4.07
17010302
5661
Milo Creek
Headwaters to mouth
2.56
17010303
2001
Coeur dAlene Lake
NA
NA
17010303
3529
Coeur d'AIene River
3lack Lake to Thompson Lake
4.21
17010303
4015
Coeur d'AIene River
Dave Lake to Black Lake
4.00
17010303
4016
Coeur d'AIene River
Fortier Creek to Robinson Creek
0.80
17010303
4017
Coeur d'AIene River
Fourth of July Creek to Fortier Cr
10.50
17010303
4018
Coeur d'AIene River
French Gulch to Skeel Gulch
4.21
17010303
4019
Coeur d'AIene River
.atour Creek to Fourth of July Cr
4.09
17010303
4020
Coeur dAlene River
Robinson Creek to Cave Lake
1.57
17010303
4021
Coeur d'AIene River
S Fk CDA River to French Gulch
2.13
17010303
4022
Coeur d'AIene ftiver
Skeel Gulch to Latour Creek
1.16
17010303
4023
Coeur d'AIene River
Thompson Lake to CDA Lake
4.19
17010305
3552
Spokane River
CbA Lake to Huetter
3.45
17010305
3553
Spokane River
buetter to Post Falls Bridge
4.S9
17010305
3554
Spokane River
3ost Falls Bridge to WA border
6.18
In the process of developing this TMDL, additional data and analysis indicate that metals criteria
are exceeded in a number of additional tributaries to the South Fork Coeur d'AIene River. EPA
has evaluated the available metals data and screened for stations that exceed water quality criteria
at an assumed hardness of 100 rag/1 (see "WQC" values in table below). Based on this analysis,
the following tributaries exceed one or more of the metals criteria.
6
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Table 3-2. Metals Concentrations in Non-Listed South Fork Tributaries
Waterbody
Static®
Maximum Reported Concentrations in ug/L
Dissolved Cd
{WQC=J,0>
Dissolved Pb
(WQC=2,5)
Dissolved Zn
(WQC=105)
SF CDA River above Canyon Cr.
SF228
3.1
8.0
475
Gorge Gulch
CC392
1.9
27
172
East Fork Ninemile
NM291
2 9
4.0
397
Wilson Creek
NM292
1.4
2.5
354
Highland Creek
PC307
3.5
5.0
1370
Denver Creek
PC308
18
14
7410
Nabob Creek
PC310
4.8
16
3430
Bunker Creek
SF100
152
20
9910
Portal Creek
SF104
6.0
26
1300
Groase Creek along Govt Gulch
SF110
306
21
10500
Slaughterhouse Gulch
SF218
1.0
3.4
190
Grouse Gulch near Wallace
SF223
17
19
2400
McFarren Gulch
SF250
2.5
<2.5
272
Prospect Gulch
SF261
13
11
1720
Source: URS GreinerRl/FS Database, April 2000
This list is provided for informational purposes and does not account for site-specific differences
in hardness levels.
3.4 Identification of Target sites
Due to resource constraints, it is not feasible to specifically develop loading capacities and
allocations for each individual 303(d)-listed waterbody in the basin (including South Fork
tributaries likely to be added in future listings) in this TMDL. The extent of this pollution
problem and the attempt to address it at the basin scale necessitates the selection of a limited
number of points-of-compliance or "target sites" that span the basin. Target sites are locations in
the river network where the loading capacities for dissolved metals are calculated and allocated
to upgradient sources contributing metals to the target site.
7
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EPA selected nine target sites that would result a TMDL that is fair, equitable, and appropriate to
the scale of the pollution problem Target sites are located at the mouths of major tributaries or
on mainstem junctions. EPA considered the location and number of contributing point and
nonpoint sources in establishing the target sites. Also, each target site is located at a sampling
station that has been used for synoptic sampling for water quality and discharge in the South Fork
or has been historically monitored for discharge by the United States Geological Survey (USGS).
Of the nine target sites, five sites are located in the South Fork, because of the large number of
point source and nonpoint source discharges in this drainage. A list of the target sites is provided
in the table below, and locations are depicted in Figure 3-1.
Table 3-3. TMDL Target Sites
Target Site Name
Description
Spokane River @ State Line
Idaho-Washington Border
St. Joe River (s> Calder
USGS Station No. 12414500
Coeur d'Alene River @ Harrison
Near Mouth of Coeur d'Alene River
North Fork Coeur d'Alene River @ Enaville
USGS Station No. 12413000
South Fork Coeur d'Alene River @ Pinehurst
USGS Station No 12413470; URS Greiner Station No. 271
Pine Creek
Mouth of Pine Creek, URS Greiner Station No. 315
South Fork Coeur d'Alene River @ Wallace
South Fork downstream from Ninemile Creek confluence;
URS Greiner Station No. 233
Ninemile Creek
Mouth of Ninemile Creek south of Depot RV park, URS
Greiner Station No. 305
Canyon Creek
Mouth of Canyon Creek at Frontage Road Bridge north of I-
90, URS Greiner Station No. 288
With the exception of two target sites, each target site is located on a segment listed on the
current Idaho 303(d) list. Target sites on the North Fork of the Coeur d'Alene River and St. Joe
River are established for tracking purposes and allocation of loading capacity through the river
network. These two rivers currently meet metals criteria based on available information.
3.5 Identification of Sources
To achieve water quality standards at the target sites, the TMDL must address all sources of
dissolved metals to waters at a given target site. In the Coeur d'Alene River and tributaries, the
loading capacity at each target site is allocated to all identified sources of dissolved metals that
8
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are upgradient from the target site. Thus, while the TMDL addresses impairment on 303(d)-
lisled waters, the allocations may include sources located along upstream watersheds that are
tributary to the listed waterbody. Some of these smaller, upstream watersheds are not on the
303(d) list. Nevertheless, sources in these watersheds discharge metals to the upstream
watershed, and the stream network then transports the metals downstream to the waters at the
target site location. Therefore, inclusion of these sources in the TMDL is essential to ensure that
water quality standards will be achieved, because metals discharged from these upstream
watershed sources are contributing to water quality standards exceedances in both listed and
unlisted waters. For example, the Star 1200 adit discharges dissolved metals to Grouse Creek, a
tributary to the South Fork above Wallace, which is not included on the 1998 Idaho 303(d) list.
Grouse Creek flows into the South Fork upstream from the Wallace target site. Since the metals
from the Star adit ultimately reach the Wallace target site, this adit is included in the wasteload
allocations for that target site, even though the creek immediately adjacent to the adit portal is not
included on the current 303(d) list.
4.0 APPLICABLE WATER QUALITY STANDARDS
4.1 General
Water quality standards are adopted by states and tribes to maintain and restore the nation's
waters for "beneficial uses" such as drinking, swimming, and fishing. The standards for a
particular waterbody consist of a set of protected uses ("designated" uses), the water quality
criteria necessary to protect these uses, and an "anti-degradation" requirement (see below). The
water quality criteria can be expressed as numeric criteria (e.g., contaminant concentrations) or
narrative criteria (e.g., "No toxics in toxic amounts"). The following discussions describe the
water quality standards applicable to CDA basin waters.
4.2 Designated Uses
Title 1, Chapter 2 of the State of Idaho Department of Environmental Quality rules presents the
State's water quality standards. Sections 100 and 110 present the Use Designations for Surface
Waters in the Panhandle Basin of Idaho, including the South Fork Coeur d'Alene Subbasin,
Coeur d'Alene Lake Subbasin, and Upper Spokane Subbasin (IDAPA 58.01.02.110'). The uses
designated for the Spokane River, Coeur d'Alene Lake, main stem Coeur d'Alene River, and the
North Fork of the Coeur d'Alene River include the following;
• Domestic water supply
• Industrial and agricultural water supply
• Cold water biota
• Salmonid spawning
'Effective July 1,2000, the citation to Idaho standards changed from IDAPA 16.01.02 to 58.01,02.
9
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• Primary contact recreation
• Secondary contact recreation.
In addition, Coenr d'Alcne Lake and the North Fork of the Coeur d'Alene River sire designated
as Special Resource Waters. Sections 56 and 400.01 (b) describe specific requirements related to
Special Resource Waters in Idaho.
The South Fork below Daisy Gulch and Canyon Creek below Gorge Gulch have been heavily
impacted by historic and ongoing mining activities. Above these segment boundaries (Daisy
Gulch and Gorge Gulch, respectively), the South Fork and Canyon Creek are designated for cold
water biota, salinonid spawning, primary contact recreation, agricultural water supply, industrial
water supply and domestic water supply. Below these boundaries, the South Fork and Canyon
Creek are classified for:
• Industrial and agricultural water supply
• Secondary contact recreation
• Cold water biota
The cold water biota use designations for the South Fork below Daisy Creek, Canyon Creek and
Shields Gulch, were promulgated by EPA on July 31, 1997 in accordance with section 303(c) of
the Clean Water Act, 33 U.S.C. Sec. 313(c) (see 62 Fed. Reg. 41162, July 31, 1997). EPA's
promulgation of water quality standards for Idaho was subsequently challenged in federal court.
On March 15, 2000, the United States District Court for District of Idaho issued a decision
largely upholding EPA's promulgation but vacating the cold water biota designation for Shields
Gulch. The District Court ruling results in two sets of use designations applicable to Shields
Gulch. Above the mining impacted area (P-8a), Shields Gulch is protected for cold water biota,
salmonid spawning, primary contact recreation, agricultural water supply, industrial water supply
and drinking water supply. Below the mining impact (P-8b), it is protected for secondary contact
recreation, agricultural water supply and industrial water supply.
The CDA basin includes hundreds of tributaries not specifically addressed in the Idaho water
quality standards. The standards include a default provision that designates these unspecified
waters for cold water biota, primary or secondary contact recreation, agricultural water supply,
and industrial water supply (IDAPA 58.01.02.101).
In summary, with the exception of Shields Gulch below the mining impact, the cold water biota
use applies to all streams in the CDA basin.
4 J Applicable Water Quality Criteria
For cadmium, lead, and zinc in the dissolved form in the water column, the water quality criteria
designed to protect aquatic life from chronic exposure effects are the most stringent criteria that
10
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apply to waters in the CDA basin. The applicable criteria for the TMDL are established in the
approved State of Idaho water quality standards (IDAPA 58, Title 01, Chapter 02). The criteria
for dissolved cadmium, lead, and zinc in the Washington and Idaho standards are identical except
for assumptions about hardness.
The toxicity of dissolved inetals to aquatic life is dependent on the hardness of the river or lake
waters. For this reason, the chronic criteria for dissolved cadmium, lead, and zinc are calculated
from hardness-based equations. The following equations are established in both Idaho and
Washington water quality standards:
Dissolved Cadmium Criteria - (1.101672-[ln(hardness)(0.041838)])*(exp[0.7852(ln(hardness)) - 3.490])
Dissolved Lead Criteria = (1.46203-[ln(hardness)(0.145712)])*(exp[l-273(ln(hardness)) - 4.705])
Dissolved Zinc Criteria = 0.986exp[.8473(ln(hardness)) + 0.7614]
CDA basin waters exliibit a range of hardness levels, and river hardness in the basin is strongly
related to the flowrate of the rivers. This relationship between river flow and hardness at various
locations in the river network is evaluated in more detail under "Derivation of TMDL Elements"
below. Hardness levels in the basin generally fall between 10 and 100 mg/1. However, the Idaho
water quality standards set a minimum hardness to be used in calculating the criteria at 25 ing/1.
Washington has applied the criteria equations at a hardness value of 20 mg/1 in its approved
TMDL for the cadmium, lead, and zinc in the Spokane River. Based on these considerations, the
range of applicable dissolved metals criteria is depicted in Table 4-1.
Table 4-1. Range of Applicable Criteria in the Coeur d'AIene Basin
Metal
Criterion
©hardness
of 20 mg/1
Criterion
©bareness
of 25 mg/1
Criterion
©hardness
of 100 mg/1
Dissolved Cadmium
0.31 ug/1
0.37 ug/1
1.03 ug/1
Dissolved Lead
0.42 ug/1
0.54 ug/1
2.52 ug/1
Dissolved Zinc
27 ug/1
32 ug/1
105 ug/1
11
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4.4 Anti-degradation
The Idaho anti-degradation requirements (IDAPA 58.01.02.051) are pertinent to the CDA basin
TMDL. If a waterbody has better water quality than that necessary to support designated uses,
the anti-degradation requirements dictate that the existing quality shall be maintained and
protected, unless the state finds that a lowering of water quality (i.e., degradation) is necessary to
accommodate important economic or social development.
While large portions of the CDA basin surface water network contain metals concentrations well
above the applicable water quality criteria, a cursory review of the available data indicates that
there are also a number of waters within the CDA basin with metals concentrations well below
the water quality criteria. Anti-degradation requirements apply to any proposed activities that
would lower water quality in these areas.
5.0 AVAILABLE DATA
5.1 Data Sources
A significant amount of monitoring information is available for the waterbodies in the CDA
basin. The data can be classified as one-time studies and longer term, programmatic monitoring.
Table 5-1 lists data sources and features of each data set that are pertinent to this TMDL. EPA
evaluated these data as part of the development of the TMDL elements described in Chapter 6.
Table 5-1. Analytical Water Quality Data Available for CDA basin
Data set
Period of
Record
Geographic Scope
Measured
Feature
Measured.
Parameters
Mfiasnber.ef
Samples
EPA
9/22/87-
5/19/88
S. Fork (& major
Tributaries)
Surface Water
Hardness
Cadmium (dis)
Lead (dis)
Zinc (dis)
29 sites
101 samples
USGS
Nov. 20,
1989- Nov.
14, 1990
S. Fork
Surface Water
Cadmium (dis)
Lead (dis)
Zinc (dis)
1 site
5 samples
USGS
1991-1992
Coeur d'Alene
Lake
Surface Water
Cadmium (tot rec)
Lead (tot rec.)
Zinc (tot rec.)
6 sites
146 samples
Idaho Dept.
Env. Quality
Dec. 4, 1989-
Jan. 23, 1990
S. Fork
Surface Water
Effluent
Hardness
Cadmium (dis)
Lead (dis)
Zinc (dis)
7 sites
36 samples
12
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Table 5-1. Analytical Water Quality Data Available for CDA basin
(Continued)
Data set
Period of
.Record
Ideographic Scope
Measured
Features
Measured
Parameters
Number of
Samples
Idaho Dept.
Env. Quality
Jan.-Aug
1993
Pine Creek
Surface Water
Hardness
Cadmium (lot)
Lead (tot)
Zinc (tot)
18 sites
90 samples
Idaho Dept.
Env. Quality
Apr. 23-
Sept 28,
1993
Canyon Creek
Ninemile Creek
Surface Water
Hardness
Cadmium (dis)
Lead (dis)
Zinc (dis)
10 sites
36 samples
Idaho Dept.
Env. Quality
Oct 26, 1993
- Sept. 14,
1995
S. Fork and
tributaries
Surface Water
Hardness
Cadmium (dis+tot)
Ixad (dis+tot)
Zinc (dis+tot)
14 sites
451 samples
CH2MHiil
(fur EPA)
Oct. 16-28,
1996 (once
each site)
Bunker Hill site
Ground Water
Cadmium (dis)
Lead (dis)
Zinc (dis)
72 sites
72 samples
CH2MHU1
(for EPA)
Feb. 6-12,
1997 (once
each site)
Bunker Hill site
Ground Water
Surface Water
Cadmium (dis)
Lead (dis)
Zinc (dis)
Flow (7 sites)
89 sites
89 samples
CH2MHill
(for EPA)
Apr. 21-29,
1997 (once
each site
Bunker Hill site
Ground Water
Surface Water
Cadmium (dis)
Lead (dis)
Zinc (dis)
Flow (12 sites)
92 sites
92 samples
CH2MHU1
(for EPA)
Sept. 1997-
Jan,1998
Bunker Hill site
Ground Water
Cadmium (dis)
Lead (dis)
Zinc (dis)
1 1 sites
41 samples
CH2MHill
(for EPA)
Oct. 1997
Feb. 1998
Bunker Hill site
Ground Water
Cadmium (dis)
Lead (dis)
Zinc (dis)
68 sites
136 samples
CHlMHill
(for EPA)
Oct. 9, 1997
Feb. 9, 1998
Bunker Hill site
S. Fork (few)
Surface Water
Cadmium (dis+tot)
Lead (dis+tot)
Zinc (dis+tot)
Flow (4 sites)
17 sites
34 samples
McCulley,
Frick, and
Gilman
(MFG)
May 14-18,
1991
S. Fork (& major
Tributaries)
Surface Water
Cadmium (dis+tot)
Lead (dis+tot)
Zinc (dis+tot)
Row
57 sites
57 samples
MFG
Oct. 1-5,
1991
S. Fork (& major
Tributaries)
Surface Water
Cadmium (dis+tot)
Lead (dis+tot)
Zinc (dis+tot)
Flow
70 sites
70 samples
13
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Table 5-1. Analytical Water Quality Data Available for CDA basin
(Continued)
Data set
Period of
{geographic Scope
Measured
Measurtti
Number of
Samples
Record
Features
Parameters
EPA PCS and
Facility/
Discharge
Monitoring
Rqxirts
1996-1998
Discharges in the
S. Fork (& major
Tributaries) and
Spokane River
Effluent
Cadmium (tot+tot
rec)
Lead (tot+tot rec)
Zinc (tot+tot rec)
(Also dissolved
metals for Lucky
Friday Mine)
Flow
15 sites
(monthly
summaries) on
South Fork, 3
sites on
Spokane River
EPA
Inspection
Reports
Apr. 96 and
Mar. 98
S. Fork (& major
Tributaries)
Surface Water
Effluent
Cadmium (tot)
Lead (tot)
Zinc (tot)
(Also dissolved
metals for Lucky
Friday Mine)
Hardness
Flow
24 sites
42 samples
URS Greiner
(for EPA)
Nov. 1997
and May
1998
S. Fork (& all
Tributaries)
N. Fork
Mainstem
St. Joe River
Spokane River
Surface Water
Effluent
Cadmium (dis+tot)
Lead (dis+tot)
Zinc (dis+tot)
Hardness
How
184 sites
380 samples
USGS
Oct. 1998 to
Sept. 1999
S. Fork (& select
Tributaries)
N. Fork
Mainstem
St. Joe River
Spokane River
CDA Lake
Surface Water
Cadmium (dis+tot)
Lead (dis+tot)
Zinc (dis+tot)
Hardness
Mow
42 sites
Note: (dis) = dissolved
(tot) = total
(tot ret) = total recoverable
The State of Idaho sampling has produced the largest data sets over time at several key locations
in the Coeur d'Alene river network, while USGS has collected the most recent data across the
river network. The November 1997 and May 1998 URSG sampling, wliich was performed under
EPA's Superfund program, was conducted at the finest geographic scale of all the sampling to
date, witli stations established at all tributary mouths to the South Fork outside of the Bunker Hill
Superfund site. Also, the URSG efforts are the only synoptic field studies (i.e., studies that
present data over a large area in a single period of time) that include parallel sampling of
abandoned adit discharges. Appendix C provides a more detailed description of the studies
completed by URSG in 1997 and 1998, MFG in 1991, IDEQ in 1993-1995, and CH2MHill in
1996-1998, and USGS in 1999. The URSG sampling locations are described in Appendix B.
14
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5.2
Data Limitations
While a significant amount of data is available for the TMDL analysis, a number of
inconsistencies in the data require EPA to make interpretative judgments and assumptions. The
limitations or inconsistencies in the data include:
Lack of data for certain sources that presented access difficulties (e.g., snowpack) for
field crews during a given sampling episode
Limited hardness data at some sites
Limited flow data at some sites
Non-uniform sampling locations from one sampling period to the next
Some data sets are summary information only (e.g., monthly averages, maxima)
Varied NPDES permit monitoring requirements
NPDES discharges are better characterized than unpermitted discharges
Metals analyses vary between dissolved, total recoverable, and total form
Some data sets have detection levels above the water quality criteria
These issues are not unusual in water quality analysis and regulation, because water quality and
flow data are often collected using a variety of methods and for different purposes. Collectively,
the above sources provide for the development of a sound and reasonable TMDL. In the
descriptions below of the methods used to develop the TMDL, EPA explains its approach
integrating and interpreting the varied data sources, including simplifying assumptions.
5.3 Current Metals Concentrations in the Basin
Table 5-2 summarizes current water quality in the basin based on available information in
April 1999.
Table 5-2. Current Conditions at TMDL Target Sites (in ug/1)
Dissolved Cadmium
Target Site
-------
Table 5-2. Current Conditions at TMDL Target Sites (continued)
Dissolved Lead
Target Site (URSG Station fl»
¦ ¦ ¦
Min
Max
SldDev
SF at Wallace (SF233)
20
8.8
31
19
5.4
Canyon Creek (CC287)
49
20
223
43
31
Ninemile Creek (NM305)
51
40
91
48
19
Pine Creek (PC305)
49
1.0
11
2.4
1.8
SF at Pinehurst (S271)
46
08
12
4.7
3.4
NF at Enaville (NF400)
9
< 1.0
< 1.0
< 1.0
NA
CDA River at Cataldo (USGS)
12
1.5
8.0
4.0
2.0
St. Joe R (SJ004)1
2
<0.5
10
NA
NA
Coeur d'Alene Lake3
146
<1.0
41
3.3"
NA
Spokane R (state line)
15
0.06
3 9
0.7
1.0
Dissolved Zinc
Target Site (URSG Stathm ID)
B
Min
SidDer ,
SF at Wallace (SF233)
21
319
2280
1250
540
Canyon Creek (CC287)
49
688
6730
2770
1510
Ninemile Creek (NM305)
52
1787
9710
3730
1500
Pine Creek (PC305)
49
20
402
122
63
SF at Pinehurst (S271)
46
345
2920
1420
767
NF at Enaville (NF400)
9
3.0
20
7.4
5.7
CDA River at Cataldo (USGS)
12
169
797
403
206
St. Joe R (SJ004)1
2
4.2
<5.0
NA
NA
Coeur d'Alene Lake2
146
<10
390
993
NA
Spokane R (state line)
15
22
105
73
25
'Only 2 sample results available for St. Joe River (URSG 1997-98), no averages or standard deviations calculated,
^ata are total recoverable concentrations from lake-wide samples obtained from the euphotic and lower
hypolimnion zones. No dissolved data available for lake.
'Median concentration.
4AI1 values in ug/1
16
-------
Data Sources: South Fork (and tributaries) data collected by 1DBQ, stored in URS Gremer Rl/FS database (Dec.
1998)
North Fork data collected by IJSCJS, stored m IJRS Grciner RI/FS database (Dec. 1998)
Cataldo data collected by LDEQ WY1996 monitoring in "Coeur d'Alene River Water Quality
Assessment and Total Maximum Daily Load to Address Trace (Heavy) Metals Criteria
Exceedences" (January 1998)
St. Joe River data collected by URS Gremer, stored in RI/FS database (Dec. 1998)
Coeur d'Alene Lake data collected by USGS, reported in "Nutrient and Trace-element Enrichment
of Coeur d'Alene Lake, Idaho" (U.S. Geological Water-Supply Paper 2485. 1997)
Spokane R. data collected by Washington Department of Ecology in "Cadmium, Lead, and Zinc
in the Spokane River" (Pub. 98-329, September 1998)
6.0 DERIVATION OF TMDL ELEMENTS
This chapter describes the derivation of the required "TMDL Elements", which include the water
quality standards, loading capacity, natural background loads, gross allocations, wasteload
allocations, load allocations, and margin of safety. These elements are consistent with the
requirements of the TMDL regulations (40 CFR 130.7).
6.1 Approach to Calculating Loading Capacities at Target Sites
6.1.a. Seasonal Variation
Two approaches were considered to account for variability in river flows and hardness levels,
which directly affect the loading capacity of CDA waters for dissolved metals. The first
approach is to develop calendar-based, seasonal loading capacities. Critical flows and hardness
levels over each particular season are derived, and one loading capacity and set of allocations for
each metal would apply during that season.
The second approach, and the approach chosen for development of this TMDL, is to develop
flow-based loading capacities. In this approach, the continuous range of river flow that occurs at
each target site is broken down into ranges or tiers. The loading capacity for each breakpoint in
the flow tiers is established. The applicable allocation for a given source does not depend on the
time of year, but rather on the actual river flow at the time of discharge and a conservative
estimate of the river hardness at that river flow. This approach was chosen because, unlike the
calendar-based approach, this flow-based approach allows for allocations based on actual river
discharge conditions and provides more flexibility in establishing and implementing allocations.
The technical information and analyses used to establish the appropriate flow tiers and hardness
levels is provided below.
17
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6.l.b. Flow Estimation
liSGS has collected long-term flow records from several stations across the CD A basin, with
some monitoring records dating back to the early 1900's. In addition, numerous field studies
have been conducted in the CDA basin, focusing on a wide variety of assessment questions.
Because studies were conducted for a variety of purposes, flow monitoring has not been
conducted in a standardized fashion. A handful of one-time studies have included flow
monitoring at numerous sites within the same time frame. These studies have been conducted by
MFG (1991), MFG (1992), EDEQ (1994), and URSG (1998). Measurement locations, sampling
techniques, analystical methods, and sample time frames have varied from one study to the next.
In 1999, USGS conducted a major monitoring program of the river network, wliieh included
daily flow monitoring at key locations in the basin. Prior to 1999, flow data was very limited for
tributaries to the South Fork CDA River, including TMDL target site tributaries (Canyon Creek,
Ninemile Creek, and Pine Creek). The USGS monitoring program significantly increased the
body of flow data for these target sites. EPA has used this new information to develop flow tiers
for the previously ungauged tributaries. For the purpose of establishing consistent and
reasonably accurate flow tiers, EPA has calculated linear regressions between tributary flows and
flows at USGS stations with long term records. Using these relationships, EPA can estimate
design flows at the less-monitored tributaries from the extensive record at the long term stations.
Flows Tiers
In order to represent the full range of river flows in a consistent manner, EPA calculates the
TMDL elements for four flow conditions at each target site: 7Q10 low flow (see below) and the
10th, 50ffi, and 904 percentile average daily flow. These design flows are used as breakpoints for
four flow tiers in the TMDL: 7Q10 to 10th percentile, 10th percentile to 50th percentile, 50th
percentile to 90* percentile, and greater than 90th percentile.
The characteristic flow used for water quality compliance programs in concert with chronic
aquatic life criteria is the lowest 7-day average daily river flow that occurs with a 10-year return
period (7Q10) (i.e., there is a 10 percent chance that this 7-day average river flow could occur in
any given year). The 7Q10 is used in development of this TMDL because it is the threshold
defined for use in the Idaho water quality standards.
For target sites with statistically sufficient long-term gauging of average daily river flow, the
7Q10 is calculated directly from the flow record. Table 6-1 shows 7Q10 and percentile river
flows calculated for these stations using the Log Pearson Type III distribution.
18
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Table 6-1. Flow Tiers for USGS Stations in the CDA basin
Station Name
USGS
Station
Number
Available
Period of
Record1
: Discharge Percentiles
7QW
(efs)
10th
90th
Spokane River @ Post Falls
12419000
1913-1997
211
906
2,980
17,400
St. Joe River @ Calder
12414500
1912-1997
241
374
1,000
6,470
CDA River @ Cataldo
12413500
1912-1997
239
348
1,100
6,870
North Fork CDA River @ Enaville
12413000
1911-1997
165
253
845
5,090
South Fork CDA River (s>
Pinehurst
12413470
1988-1997
68
97
268
1,290
South Fork CDA River Silverton
12413150
1967-1986
31
48
109
649
Placer Creek
12413140
1967-1997
1.0
3.6
15
97
Source: USGS WATSTORE database
For target sites without a long-term flow record, EPA used the 1999 USGS data to examine the
relationship between flows at a particular target site and two USGS stations with long term
records. First, regressions were calculated for each site and the long-term Placer Creek station,
because Placer Creek is closest in size to the target site creeks. Second, regressions were
calculated between each target site and the nearest long-term station on the South Fork. The
target site and selected long term stations are shown in Table 6-2. The flow data used for the
estimations and graphs of the regressions are included in Appendix L.
The gauging station for Placer Creek is situated below a water intake structure operated by the
East Shoshone Water District. Since past water withdrawals may have effected measured low
flows at tliis gauge, EPA selected the South Fork gauges for use in estimating flows. As
indicated in Table 6-3, the R2 values for the South Fork regressions were either similar or higher
than those for the Placer Creek regressions.
Table 6-2. Flow Relationships between Short-Term and Ixtng-Term Sites
Target Site
Long-Term USGS Station
R-Sqiiared Value
Regression Equation1
Canyon Creek
Placer Creek
0 81
NA
South Fork at Silverton
0.96
y = 0.23(x)
Ninemile Creek
Placer Creek
0.84
NA
South Fork at Silverton
0.79
y= 063(x)
Pine Creek
Placer Creek
0 82
NA
South Fork at Pinehurst
090
y =0.30(x)
1 y = flow at target site
x = flow at long term gauge
y-intcrcept for each regression is fixed ;il zero.
19
-------
South Fork at Wallace
The target site on the South Fork at Wallace is not included in the table, because USGS did not
monitor this location in 1999. The flow at this site is estimated as the combined flows from
Canyon Geek, Ninemile Creek, and the South Fork above the confluence with Canyon Creek.
Flows at Canyon Creek and Ninemile Creek are calculated above. The remaining contribution
requires an estimate of flows in the South Fork above Canyon Creek.
Two methods were considered to estimate 7Q10 river flows in the South Fork above Canyon
Creek. The first method considered would be to determine runoff coefficients. Runoff
coefficients are the unit runoff per unit drainage area for the watershed of interest. Runoff
coefficients can be developed and applied to an ungauged target site using downstream gauged
data. River flow and 7Q10 characteristic flows from the ungauged tributary can be estimated by
multiplying the calculated runoff coefficient by the drainage area associated with the ungauged
target site.
The other method considered was to utilize measured river flow data from synoptic sampling
studies. Since several of the long-term gauged stations were also sampled during these studies,
or automatically recorded, a ratio of river flow measured at a gauged station to river flow
measured at an ungauged station can be calculated for that sampling event. The calculated ratio
is then used to estimate design flows at ungauged locations using the design flows for gauged
stations. The assumption used in this method is that the ratio calculated between one-time
measured river flows and the ratio between the design flows are similar. EPA chose this method
for the Wallace site, because it provides estimates using actual measured tributary flows rather
than watershed area ratios.
Measured river flows reported by MFG (1992) for the fall 1991 and URSG (1998) for the fall
1997 at Wallace were used to the calculate river flow ratio. Three USGS gauges within the CDA
basin with sufficient long term records to determine the 7Q10 were evaluated using the synoptic
data. The stations compared were the Coeur d'Alene River@Cataldo, the South Fork@Silverton
(USGS No. 12413150), and Placer Creek (USGS No. 12413140).
EPA's examination of the available flow information led to the selection of the MFG fall 1991
data and the South Fork@Silverton gauge. The gauged flows recorded at SUverton showed low
variability during the period of the MFG synoptic sampling in 1991. Also, the sum of flows
measured by MFG in 1991 at the upstream ungauged tributaries is in greater agreement with the
recorded river flow at Silverton than the sum of similar flows in the URSG 1997 river flow data.
EPA has performed a check on the ratio calculated for the South Fork using the 1999 monitoring
data. EPA calculated the difference between the mean flow at the Silverton station and the sum
of mean flows at Canyon, Ninemile, and Placer Creeks in 1999. This difference represents a
rough estimate of the combined contributions of surface flow in the South Fork above Wallace,
groundwater recharge flows between Wallace and Silverton, and unmonitored flows in Lake
Creek and Daly Gulch. The ratio of this difference to the mean flow at Silverton (0.54) is
somewhat higher than the ratio of directly-measured Wallace/Silverton flows (0.43) calculated
using the MFG 1991 data. This difference in ratios is to be expected given the additional inputs
to flow at Silverton not captured in the 1999 monitoring, and the results of this check suggest that
the estimates for the South Fork above Wallace are reasonably accurate and conservative.
20
-------
Using the estimated ratio of Wallace/Silverton flows and the design flows at the Silverton gauge,
the 7Q10, 10th, 50th, and 90th percentile flows for the South Fork above Canyon Creek are 13,
21, 47, and 279 cfs. Tliese values are added to the Ninemile Creek and Canyon Creek flows to
estimate the Hows in the South Fork target site.
Harrison
River flow in the mainstem of the Coeur d'Alene River below Cataldo and above Harrison is
characterized by unsteady flows for the majority of the year. Flow through this reach is affected
by backwater conditions caused by the stage (height) of Coeur d'Alene Lake. The 1999 USGS
flow data collected at Harrison and Cataldo indicate that the flows at the two locations are nearly
identical, with a regression coefficient (i.e., the predicted ratio between the sites) of
approximately 0.99. Based on these data, the 7Q10 and the 10th, 50th, and 90th percentile flows
for the Cataldo gauge are directly applied in the TMDL as the estimated Harrison target site
flows.
TMDL Flow Tiers
Based on the above analysis, the flow values used to calculate the TMDL elements are shown in
Table 6-3.
Table 6-3. TMDL Flow Tiers
Target Site
URSG
Station
IB No.
Discharge Percentiles
7Q10
(cfs)
10%
(cfs)
50%
-------
6.I.e. Hardness and Water Quality Criteria
The chronic cold water biota criteria for dissolved cadmium, lead, and zinc arc hardness-
dependent. Toxicity of metals to aquatic life increases as hardness decreases. For this reason,
hardness-based water quality criteria are most stringent at low hardness levels. The available
data indicate that hardness levels vary from approximately 20 mg/1 to 100 mg/I in waters of the
Couer d'Alene River basin. Based on this variability in hardness levels, a range of water quality
criteria apply to basin waters.
In some rivers, hardness levels vary depending on river flowrate. The available data indicate a
strong flow/hardness relationship at most of the Coeur d'Alene River and tributary target sites.
At these sites, hardness increases as flow decreases. This means that a higher water quality
criterion is applicable to these waters under low flow conditions.
Since the TMDL elements are How-based for the Coeur d'Alene River and tributaries, EPA has
incorporated the flow/hardness relationship into the TMDL. At each target site showing a
flow/hardness relationship, a linear regression between ln(flow) and hardness was performed
using the available data for the target site. The resulting regression equation is used to predict
hardness values at the flow tiers. The lower bound of a 90th percentile confidence interval for the
regression equation is used in the prediction. Hardness values were not estimated outside the
range of available data, which did not include flows at or below tlie 7Q10 flows. Table 6-4 lists
the flows, hardness values, and resulting criteria applied in the TMDL. The data and regression
calculations for tliose sites that show a flow/hardness relationship is included in Appendix 1.
6.2 Total Loading Capacity
The total loading capacity is calculated by multiplying the river flow rate by the water quality
criterion concentration and a conversion factor (for "pounds per day" units) for each of the target
sites. The values calculated for Coeur d'Alene River target sites are shown in Tables 6-5 through
6-7. The total loading capacity is not calculated in Coeur d'Alene Lake and Spokane River,
because it is not needed for allocation of pollutant loads (see discussion in Section 6.7).
6.3 Loading Available for Allocation
Once the loading capacity is established, a series of calculations are performed, culminating in an
allocation of a portion of the loading capacity to sources upstream of each target site. This series
of calculations is depicted in Figure 6-1.
The portion of the loading capacity in the Coeur d'Alene River and tributaries that is available
for allocation is equal to the total loading capacity minus the natural background load, upstream
allocated load, and margin of safety. Each of these factors is described in detail in this section.
22
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Table 6-4. Water Quality Criteria for Metals in the Coeur d'Alene Basin TMDL
Target Site
Flow
'iter1
River
HaFrtmss*
Dissolved
Dissolved
Dissolved
Zn
(cfc)
¦
{Ufifl)
<«srt)
288
Canyon
7.1
56
0.67
1.33
64
11
56
0.67
1.33
64
25
45
0.57
1.05
53
149
25
0.37
0.54
32
305
Nine Mile
2.0
73
0.82
I 78
80
3.0
73
0.82
1.78
80
6.9
63
0.73
1.52
71
41
36
0.48
081
44
233
South Fork
Wallace
22
57
0.68
1.36
65
35
56
0.67
1.33
64
79
47
0 59
1.10
55
469
25
0.37
0.54
32
315
Pine
20
25
0.37
0.54
32
29
25
0.37
0.54
32
80
25
0.37
0.54
32
387
25
0.37
0.54
32
271
South Fork
Pinchurst
68
101
1.00
2.54
105
97
96
1.00
2.40
101
268
71
0.80
1.73
78
1.290
28
0.40
0.62
36
CDA River
Harrison
239
47
0.59
1 10
55
348
45
0.57
1.05
53
1,100
36
0.48
0.81
44
6,870
25
0.37
0.54
32
Spokane
River
NA
203
0.31
0.42
27
Notes
(1) These flows are estimates of the 7Q10, 10th, 50th, and 90th percentiles for each target site.
(2) Idaho water quality standards establish a 25 mg/1 minimum for criteria calculation, while the Washington
water quality standards contain no minimum.
(3) The applicable hardness value for the Spokane River at the Idaho-Washington border is 20 mg/1 based on
the approved Spokane River TMDL.
6.3.a. Natural Background Conditions
The TMDL takes into account estimates of the natural background loadings of metals in the
Coeur d'Alene River. These loadings are subtracted from the loading capacity to determine the
loading capacity available for allocation to point and nonpoint sources in the basin.
23
-------
South Fork and Tributaries
Evaluation of natural background conditions in historic mining areas such as the Silver Valley is
very difficult, because naturally mineralized areas are also disturbed throughout by mining
activities. In these areas, actual natural background conditions may only occur in non-
inineralized watersheds or high in the headwaters of mineralized watersheds. Under these
constraints, EPA reviewed data from locations above mining influences in the South Fork and
tributaries. Overall, the concentrations at the few available stations are very low, with cadmium
and lead generally not detected and zinc detected at levels below 10 ug/1 (which is below the
Idaho water quality criterion). For example, EPA evaluated URSG Station 205 in the South Fork
above Larson. Table 6-5 presents metals data collected by URSG for Station 205 and MFG for
corresponding location SF-1.
Table 6-5. Background Dissolved Metal Concentrations at Station 205 (in ug/1)
Source
Lead
Cadmium
23ne
MFG
5/16/91
<3
<0.2
<20
MFG
10/4/91
<1
<0.2
<12
URS Greiner
11/10/97
<0.1
<0.04
6.78
URS Greiner
5/8/98
<0.2
<0.2
<10
There is a concern with the assumption that the water quality at this station reflects natural
conditions throughout the basin. This site does not reflect the geology of the many mineralized
areas of the basin, which could have historically delivered higher metals concentrations to the
river network.
A group of experts involved in the ongoing Natural Resource Damage Assessment for this basin
has recently produced a more comprehensive analysis of the river network in a report entitled
"Release, Transport, and Environmental Fate of Hazardous Substances in the Coeur d'Alene
River Basin, Idaho" (Maest et al., 1999). This assessment is a comprehensive evaluation of
background conditions in over 40 watersheds of the South Fork, including conditions in
mineralized areas of historic mining activity. Additional discussion is found in a rebuttal to the
report (Runnels, 1999) and a response to the rebuttal (Maest et al, 2000). CH2M Hill has further
evaluated and updated the estimates from the Maest report based on additional sampling data
(CH2M Hill, 2000).
-------
m
Loading
Capacity
START
END
Reserve
I
m
Natural
Background
Load
E
WLA = Current
Performance
yes
Upstream Trib
Allocation (if any)
Individual Sou roe
Flowrate
Total Effluent
Flowrate
Current Discharges
less than Calculatedy
WLA?
W LA = Calculated
WLA
no
m
65% of Remaining Load
to W aste Piles &
Nonpoint, 10% to MPS
I
25% Available to
Discrete Sou rces
Flow 1
Flow 2
Flow 3
Flow x
T otal
Total
Total
T otal
Calculated Wasteload Allocaitons
m
Allocation 1
Allocation 2
Allocation 3
Allocation x
Figure 6-1 Flow Diagram for CDA River and Tributary Allocations
25
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Table 6-6. Median Background Metals Concentrations in the South Fork Subbasin
Area
Dissolved Cadmium
(ug/1)
Dissolved I>ead
(ug/1)
Dissolved Zinc
(ug/1)
Upper South Fork
.06
.17
6.1
Page-Galena Mineral Belt
.16
.40
7.5
Pine Creek Drainage
.10
.21
3.1
Entire South Fork CDA Basin
.08
.21
6.1
Source: CH2M Hill, July 2000
While drainages with large producing mines and/or mill sites were excluded from the dataset
underlying these estimates, the authors report that limited mining disturbances (e.g., small adits,
waste rock piles) are observed in some of the waterslieds included in the analysis. The inclusion
of these watersheds by tfie authors provides better representativeness of the dataset with respect
to mineralized watersheds. EPA has incorporated the baseline estimates from CH2M Hill (July
2000) into the TMDL, recognizing that they are conservative estimates with respect to natural
background conditions. This conservative approach provides one element of the margin of safety
for the TMDL (See Margin of Safety). Recognizing that the baseline estimates include some
mining-influenced areas, EPA has used the median estimates in the final TMDL calculations
rather than upper-percentile estimates.
The "Upper South Fork" estimates above are used at the Canyon Creek, Ninemile Creek, and
South Fork at Wallace target sites. The "Entire South Fork CDA Basin" estimates are used at the
Pinehurst target site. '"Pine Creek Drainage" estimates are used at the Pine Creek target site.
North Fork and Mainstem Coeur d'Alene River
Metals concentrations in the North Fork are needed in order to calculate the TMDL elements in
the mainstem Coeur d' Alene River at Harrison. Since the TMDL does not call for any reductions
in metals in the North Fork, the current metals concentrations are used in the TMDL calculations
rather than an estimate of natural background. EPA has made estimates for the North Fork at
Enaville using the most recent monitoring information from the USGS (October 1998 to
September 1999). The North Fork was below the detection limits for dissolved cadmium (1
ug/1) and dissolved lead (1 ug/1). Using an assumption that the North and South Fork have
similar natural background characteristics, EPA has set the North Fork background values equal
to the South Fork natural background estimates for cadmium (.08 ug/1) and lead (.21 ug/1). For
zinc, the background value was set at the maximum detected value in the North Fork (5 ug/1).
The background concentrations for the Harrison target site are estimated by combining the
natural background conditions in the South Fork and the background conditions in the North
Fork. As described above, cadmium and lead estimates are identical for the South and North
Forks, and are therefore the same for Harrison. For zinc, background concentrations and average
26
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river flows for the two forks are used in a mass balance to estimate the background zinc
concentration in the mainstem at Harrison (5.3 ug/I),
6.3.b. Upstream Allocations
Some Coeur d'Alene River target sites are located downstream from other target sites. Because
loading capacity builds with increased river flow, the allocation calculations (described below)
begin at the target sites at the headwaters of the basin and step tlirough each target site in the
downstream direction. Before allocating loads at a target site, EPA subtracts the loading capacity
allocated (i.e., already used) at any upstream target sites. For example, the loads allocated at the
two headwater target sites (Canyon Creek and Ninemile Creek) are subtracted from tlie loading
capacity downstream at Wallace; the remainder is allocated to sources contributing metals loads
to the South Fork above the Canyon Creek confluence. Similarly, loads allocated at the Wallace
site are subtracted from the loading capacity downstream at Pinehurst before allocating the
remainder to sources contributing metals between Wallace and Pinehurst. For the mainstem
Coeur d'Alene River site (at Harrison), the loading capacity allocated upstream at Pinehurst and
background loading in tlie North Fork arc subtracted from tlie loading capacity at Harrison prior
to allocation.
The subtraction of all upstream loadings from the loading capacity at downstream target sites is
based on an assumption that there is no in-stream attenuation of dissolved metals releases to the
river network. This is one of the conservative assumptions that compri.se the margin of safety for
the TMDL. EPA provides additional information about fate and transport of metals in the Coeur
d'Alene basin in Appendix G.
6.3.C. Margin of Safety
Section 303(d) of tlie Clean Water Act requires that TMDLs be established with a margin of
safety to account for these uncertainties and insure the TMDL will achieve water quality
standards. Each element of the TMDL is developed with some degree of uncertainty. While
some uncertainties can be addressed using conservative analyses and assumptions, others cannot
be addressed in that faslrion. For this reason, the margin of safety for this TMDL consists of a
combination of conservative assumptions used in building the TMDL elements and an explicit
margin of safety equal to 10% of the loading capacity The following is a discussion of tlie
uncertainties considered in establishing this dual margin of safety.
Conservative Assumptions
Tlie following conservative assumptions were employed in the development of the TMDL:
- Conservative estimates of natural background concentrations
- Lower bound of 90th percentile confidence interval for hardness estimates
- Restriction of hardness predictions to the range of available flow data
- Exclusion of flow contributions from St. Maries River in load allocations for lake -
- 5th percentile translators for total recoverable wasteload allocations
- Conservative lead translator during peak runoff
27
-------
Explicit Margin of Safety
There arc other uncertainties in the TMDL not addressed by the above assumptions. In
particular, there are uncertainties related to the flow and hardness predictions used to calculate
the loading capacities and uncertainties in the identification and characterization of discrete
sources.
With regard to flow and hardness values, there are uncertainties in the flow regression estimates
for ungauged tributaries. This is particularly an issue for critical low flow conditions, which
were extrapolated outside the range of the data (i.e., critical low flow conditions are not
represented in the dataset). There are also uncertainties in the hardness predictions, because the
datasets used to perform the regressions are modest in size and the strength of the correlations
varies. To minimize the potential for over-predicting hardness levels, EPA has not extrapolated
hardness values outside the range of available flow data and has used the lower bound of a
confidence interval. Nevertheless, because the loading capacities are sensitive to flow and
hardness predictions, EPA believes that an explicit margin of safety to address uncertainties in
the predictions is prudent.
EPA has also identified two areas of uncertainty in the assignment of wasteload allocations for
individual discrete sources (see discussion of the allocation process below). First is the potential
that some discrete sources are omitted from the wasteload allocations. A margin of safety is
appropriate to ensure that the sum of wasteload allocations, load allocations, and omitted source
contributions does not exceed the loading capacity available for allocation. EPA has attempted
to identify and sample all discrete sources in the South Fork and tributaries, and the TMDL
establishes wasteload allocations for all sources with measurable discharges from the URSG
database. EPA believes that any omissions from the discrete source inventory will be minor
loadings.
A second source of uncertainty is associated with effluent variability. Available data is not
sufficient to support an evaluation of individual versus aggregate variability in discrete loadings.
The TMDL establishes wasteload allocations on a monthly average basis (see description of
allocation process below). While EPA believes that individual source variability will not result
in criteria exceedances at the target sites under most conditions, it is appropriate to apply a
margin of safety for this uncertainty.
To account for the above uncertainties, EPA has established an explicit 10% margin of safety in
the TMDL. EPA believes 10% is a reasonable value that will account for the specific
uncertainties identified. After subtraction of the natural background load from the total loading
capacity, 10% of the remaining loading capacity is subtracted for the margin of safety. The
remainder is the loading available for allocation.
28
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Table 6-7: Available Loading Capacity for Dissolved Cadmium
Loading
Capacity Used
Loading Avail.
Margin of
Gross
Wasteload
Target Site
Flow Tier
Capacity
Background
Upstream
for Allocation
Safety (10%)
Allocation (65%)
Allocation (25%)
(cfs)
(lbs/day)
(lbs/day)
(lbs/day)
(lbs/day)
(lbs/day)
(lbs/day)
(lbs/day)
Canyon
Creek
CC288
7
2.57E-02
2.30E-03
NA
2.34E-02
2.34E-03
1.52E-02
5.85E-03
11
3.98E-02
3.56E-03
NA
3.63E-02
3.63E-03
2.36E-02
9.07E-03
25
7.70E-02
8.09E-03
NA
6.89E-02
6.89E-03
4.48E-02
1.72E-02
149
2.97E-01
4.82E-02
NA
2.49E-01
2.49E-02
1.62E-01
6.21 E-02
Ninemile
Creek
NM305
2
8.81 E-03
6.47E-04
NA
8.17E-03
8.17E-04
5.31 E-03
2.04E-03
3
1.32E-02
9.71 E-04
NA
1.22E-02
1.22E-03
7.96E-03
3.06E-03
6.9
2.73E-02
2.23E-03
NA
2.50E-02
2.50E-03
1.63E-02
6.26E-03
41
1.07E-01
1.33E-02
NA
9.38E-02
9.38E-03
6.09E-02
2.34E-02
South Fork
at Wallace
SF233
22
8.11E-02
7.15E-03
3.16E-02
4.24E-02
4.24E-03
2.75E-02
1.06E-02
35
1.27E-01
1.13E-02
4.85E-02
6.69E-02
6.69E-03
4.35E-02
1 67E-02
79
2.51 E-01
2.55E-02
9.39E-02
1.31 E-01
1.31 E-02
8.55E-02
3.29E-02
469
9.34E-01
1.52E-01
3.42E-01
4.40E-01
4.40E-02
2.86E-01
1.10E-01
Pine
Creek
PC315
20
3.98E-02
1.08E-02
NA
2.91 E-02
2.91 E-03
1.89E-02
7.26E-03
29
5.78E-02
1.56E-02
NA
4.21 E-02
4.21 E-03
2.74E-02
1.05E-02
80
1.59E-01
4.31 E-02
NA
1.16E-01
1.16E-02
7.55E-02
2.91 E-02
387
7.71 E-01
2.09E-01
NA
5.62E-01
5.62E-02
3.65E-01
1.41 E-01
South Fork
at Pinehurst
SF271
68
3.81 E-01
2.93E-02
7.14E-02
2.80E-01
2.80E-02
1.82E-01
7.00E-02
97
5.23E-01
4.19E-02
1.09E-01
3.73E-01
3.73E-02
2.42E-01
9.31 E-02
268
1.16E+00
1.16E-01
2.48E-01
7.94E-01
7.94E-02
5.16E-01
1.98E-01
1290
2.80E+00
5.57E-01
1.00E+00
1.24E+00
1.24E-01
8.03E-01
3.09E-01
North Fork
at Enaville
NF400
165
3.28E-01
7.12E-02
NA
NA
NA
NA
NA
253
5.04E-01
1.09E-01
NA
NA
NA
NA
NA
845
1.68E+00
3.65E-01
NA
NA
NA
NA
NA
5090
1.01E+01
2.20E+00
NA
NA
NA
NA
NA
CdA River
at Harrison
239
7.60E-01
1.03E-01
3.51 E-01
3.05E-01
3.05E-02
2.75E-01
NA
348
1.07E+00
1.50E-01
4.82E-01
4.40E-01
4.40E-02
3.96E-01
NA
1100
2.87E+00
4.75E-01
1.16E+00
1.24E+00
1.24E-01
1.11E+00
NA
6870
1.37E+01
2.96E+00
3.43E+00
7.29E+00
7.29E-01
6.56E+00
NA
29
-------
Table 6-8: Available Loading Capacity for Dissolved Lead
Loading
Capacity Used
Loading Avail.
Margin of
Gross
Wasteload
Target Site
Flow Tier
Capacity
Background
Upstream
for Allocation
Safety (10%)
Allocation (65%)
Allocation (25%)
(cfs)
(lbs/day)
(lbs/day)
(lbs/day)
(lbs/day)
(lbs/day)
(lbs/day)
(lbs/day)
Canyon
Creek
CC288
7
5.10E-02
6.51 E-03
NA
4.45E-02
4.45E-03
2.89E-02
1.11 E-02
11
7.90E-02
1.01E-02
NA
6.89E-02
6.89E-03
4.48E-02
1.72E-02 •
25
1.41E-01
2.29E-02
NA
1.18E-01
1.18E-02
7.67E-02
2.95E-02
149
4.35E-01
1.37E-01
NA
2.98E-01
2.98E-02
1.94E-01
7.45E-02
Ninemile
Creek
NM305
2
1.92E-02
1.83E-03
NA
1.74E-02
1 74E-03
1.13E-02
4.35E-03
3
2.89E-02
2.75E-03
NA
2.61 E-02
2.61 E-03
1.70E-02
6.53E-03
6.9
5.64E-02
6.33E-03
NA
5.01 E-02
5.01 E-03
3.26E-02
1.25E-02
41
1.80E-01
3.76E-02
NA
1.43E-01
1.43E-02
9.26E-02
3.56E-02
South Fork
at Wallace
SF233
22
1.62E-01
2.03E-02
6.19E-02
7.97E-02
7.97E-03
5.18E-02
1.99E-02
35
2.51 E-01
3.21 E-02
9.50E-02
1.24E-01
1.24E-02
8.08E-02
3.11 E-02
79
4.67E-01
7.23E-02
1.68E-01
2.26E-01
2.26E-02
1.47E-01
5.65E-02
469
1.37E+00
4.30E-01
4.41 E-01
4.98E-01
4.98E-02
3.24E-01
1.24E-01
Pine
Creek
PC315
20
5.84E-02
2.27E-02
NA
3.57E-02
3.57E-03
2.32 E-02
8.93E-03
29
8.46E-02
3.28E-02
NA
5.18E-02
5.18E-03
3.36E-02
1.29E-02
80
2.33E-01
9.06E-02
NA
1.43E-01
1.43E-02
9.28E-02
3.57E-02
387
1.13E+00
4.38E-01
NA
6.91 E-01
6.91 E-02
4.49E-01
1.73E-01
South Fork
at Pinehurst
SF271
68
9.33E-01
7.70E-02
1.15E-01
7.41 E-01
7.41 E-02
4.81 E-01
1.85E-01
97
1.26E+00
1.10E-01
1.76E-01
9.74E-01
9.74E-02
6.33E-01
2.43E-01
268
2.50E+00
3.04E-01
3.69E-01
1.83E+00
1.83E-01
1.19E+00
4.57E-01
1290
4.28E+00
1.46E+00
1.19E+00
1.63E+00
1.63E-01
1.06E+00
4.07E-01
North Fork
at Enaville
NF400
165
4.81 E-01
1.87E-01
NA
NA
NA
NA
NA
253
7.38E-01
2.87E-01
NA
NA
NA
NA
NA
845
2.47E+00
9.57E-01
NA
NA
NA
NA
NA
5090
1.49E+01
5.77E+00
NA
NA
NA
NA
NA
CdA River
at Harrison
239
1.41E+00
2.70E-01
9.27E-01
2.14E-01
2.14E-02
1.93E-01
NA
348
1.96E+00
3.94E-01
1.26E+00
3.07E-01
3.07E-02
2.76E-01
NA
1100
4.83E+00
1.25E+00
2.79E+00
8.01 E-01
8.01 E-02
7.21 E-01
NA
.6870
2.00E+01
7.78E+00
7.39E+00
4.87E+00
4.87E-01
4.39E+00
NA
30
-------
Table 6-9: Available Loading Capacity for Dissolved Zinc
Target Site
Flow Tier
(cfs)
Loading
Capacity
(lbs/day)
Background
(lbs/day)
Capacity Used
Upstream
(lbs/day)
Loading Avail,
for Allocation
(lbs/day)
Margin of
Safety (10%)
(lbs/day)
Gross
Allocation (65%)
(lbs/day)
Wasteload
Allocation (25%)
(lbs/day)
Canyon
Creek
CC288
7
2.45E+00
2.34E-01
NA
2.22E+00
2.22E-01
1.44E+00
5.54E-01
11
3.79E+00
3.62E-01
NA
3.43E+00
3.43E-01
2.23E+00
8.58E-01
25
7.16E+00
8.23E-01
NA
6.34E+00
6.34E-01
4.12E+00
1.59E+00
149
2.59E+01
4.90E+00
NA
2.10E+01
2.10E+00
1.37E+01
5.26E+00
Ninemile
Creek
NM3051
2
8.63E-01
6.58E-02
NA
7.98E-01
7.98E-02
5.18E-01
1.99E-01
3
1.30E+00
9.87E-02
NA
1.20E+00
1.20E-01
7.78E-01
2.99E-01
6.9
2.63E+00
2.27E-01
NA
2.40E+00
2.40E-01
1.56E+00
6.01 E-01
41
9.72E+00
1.35E+00
NA
8.38E+00
8.38E-01
5.44E+00
2.09E+00
South Fork
at Wallace
SF233
22
7.74E+00
7.27E-01
3.01 E+00
4.00E+00
4.00E-01
2.60E+00
9.99E-01
35
1.21E+01
1.15E+00
4.63E+00
6.29E+00
6.29E-01
4.09E+00
1.57E+00
79
2.35E+01
2.60E+00
8.74E+00
1.21 E+01
1.21 E+00
7.88E+00
3.03E+00
469
8.17E+01
1.54E+01
2.94E+01
3.68E+01
3.68E+00
2.39E+01
9.21 E+00
Pine
Creek
PC315
20
3.48E+00
3.34E-01
NA
3.15E+00
3.15E-01
2.05E+00
7.87E-01
29
5.05E+00
4.85E-01
NA
4.57E+00
4.57E-01
2.97E+00
1.14E+00
80
1.39E+01
1.34E+00
NA
1.26E+01
1.26E+00
8.19E+00
3.15E+00
387
6.74E+01
6.47E+00
NA
6.09E+01
6.09E+00
3.96E+01
1.52E+01
South Fork
at Pinehurst
SF271
68
3.87E+01
2.24E+00
7.15E+00
2.93E+01
2.93E+00
1.90E+01
7.32E+00
97
5.28E+01
3.19E+00
1.09E+01
3.88E+01
3.88E+00
2.52E+01
9.69E+00
268
1.13E+02
8.82E+00
2.47E+01
7.95E+01
7.95E+00
5.17E+01
1.99E+01
1290
2.47E+02
4.24E+01
9.77E+01
1.07E+02
1.07E+01
6.96E+01
2.68E+01
North Fork
at Enaville
NF400
165
2.87E+01
4.45E+00
NA
NA
NA
NA
NA
253
4.41 E+01
6.82E+00
NA
NA
NA
NA
NA
845
1.47E+02
2.28E+01
NA
NA
NA
NA
NA
5090
8.86E+02
1.37E+02
NA
NA
NA
NA
NA
CdA River
at Harrison
239
7.10E+01
6.85E+00
3.37E+01
3.04E+01
3.04E+00
2.74E+01
NA
348
9.97E+01
9.99E+00
4.56E+01
4.41 E+01
4.41 E+00
3.97E+01
NA
1100
2.61 E+02
3.16E+01
1.02E+02
1.27E+02
1.27E+01
1.14E+02
NA
6870
1.20E+03
1.97E+02
2.44E+02
7.55E+02
7.55E+01
6.79E+02
NA
31
-------
6.4 Proposed Allocation Method - CDA River and Tributaries
A range of opticus are available to allocate the loading capacity to sources of dissolved metals.
A full list of options considered by EPA is summarized ill Appendix D. ITie method adopted by
EPA for the Coeur d'Alene River and tributaries is outlined in Figure 6-1, with explanations for
each step provided below.
6.4.a. Source Categorization in Mining Areas
Mining sources in the Coeur d'Alene River and tributaries have been classified into three general
categories: adits and impoundments, waste piles, and nonpoint sources. Adits and
impoundments that discharge are point sources subject to technology-based and water quality-
based requirements in NPDES permitting regulations. The term "point source" also includes
waste piles. These "waste pile" point sources may discharge to receiving waters via surface
water runoff and/or seepage, reaching the receiving water via overland flow, through a pipe, or
tlirough a groundwater hydraulic connection. Waste pile discharges are also subject to NPDES
permitting regulations.
Based on the above, the only nonpoint sources of metals in the CDA basin are those mining
wastes that were disposed directly into the receiving water in the past. These wastes are no
longer confined to waste piles; rather, they are eroded and deposited in the bed and banks of the
river or lakes downstream from tlie original disposal site.
While most of the pollutant loads from waste pile and nonpoint source areas have not been
characterized in detail, EPA has identified and characterized over 70 individual "discrete" point
source discharges to CDA basin waters. These "discrete" sources are those individually
identified point sources with discharges that are readily observed and sampled. The TMDL
establishes individual wasteload allocations for each of the discrete sources observed to date in
the basin. These sources include adits, impoundments, visible waste pile seeps, and municipal
wastewater treatment plants. The TMDL establishes gross allocations to the remainder of
uncharacterized point sources (waste piles, urban stormwater) and nonpoint sources above each
target site. Allocation between tlie large number of non-discrete source areas will require
significantly more data and technical analyses than are currently available for this TMDL.
Analysis of these non-discrete sources is a component of the ongoing RI/FS for the basin.
Some of the sampled adits are located high in the watersheds of the upper portion of the basin,
and some are located some distance from the nearest gulch or creek. Investigation and
monitoring efforts to date identified adit locations, adit discharge flow rates, and the chemical
make-up of adit discharges. The discharge pathways to receiving waters have not been
documented for some adits. For the purposes of tliis TMDL, EPA has made a conservative
assumption that some fraction of dissolved metals from adit discharges enter the nearest gulch or
creek down-gradient from the adit location. Based on this assumption, all adits are assigned a
32
-------
wasteload allocation. EPA also assumes that all significant adit discharges are identified and
assigned waste load allocations, and that any unidentified adits are accounted for in the margin of
safety (see section 6.4.c ).
The allocation applies to the loading of the source to the receiving water. EPA and DEQ
anticipate that an adit with a subsurface or otherwise difficult-to-access discharge to a receiving
water will be regulated (based on the TMDL wasteload allocations) and monitored at the adit
portal. If it is demonstrated during permitting that an adit portal discharge is attenuated prior to
reaching the receiving water, the limits that apply to the adit portal can he adjusted upward while
remaining consistent with the TMDL wasteload allocations. For NPDES permits, the permittee
will bear the burden of demonstrating any attenuation of the source between the monitoring
location and the receiving water.
6.4.b. Gross Allocation at Each Target Site
In this TMDL, a gross allocation is made as the first division of available loading capacity among
the general categories of sources. The TMDL allocates 25% of the loading available to
individually identified discrete sources above each target site. The 25% allocation to discrete
point sources is consistent with the mixing zone guidelines in the Idaho state water quality
standards (IDAPA 58.02.01.060.01.e.iv.), A mixing zone is a portion of a river that is allowed to
exceed chronic water quality criteria. Mixing zones for rivers are commonly expressed as a
portion of the river flow that can be used for dilution of a point source discharge (assuming the
discharge is above water quality criteria to some degree) to levels below the water quality
criteria. The state of Idaho guidelines state that a mixing zone should not exceed more than 25%
of the stream flow. The TMDL allocates the same proportion of the loading capacity (25%) to
the group of individually identified discrete sources in tlie CDA basin. The remaining 75% of
the loading capacity is allocated to a margin of safety (10%, see discussion below) and waste
piles and nonpoint sources (65%).
EPA and DEQ are not directly applying the mixing zone regulation in this TMDL, and the
agencies do not take the position that the state's 25% mixing zone guideline dictates the
percentage of the loading capacity to be allocated to point sources. Rather, this guideline reflects
state policy on the use of river flow for assimilation of point source discharges, allowing up to
25% of the flow for this purpose. Because loading capacity is directly proportional to the river
flow, there is a nexus between mixing zones and TMDL allocations. Therefore, it is reasonable
to analogize to this guideline and allow the use of the guideline maximum of 25% of the loading
capacity for point source discharges. This analogy provides a reasonable, objective policy basis
for distributing the river's loading capacity between discrete point sources and non discrete
sources.
In selecting the above gross allocation breakdown, EPA considered several alternatives. EPA
considered the simplistic approach of citing that "background" (as opposed to "natural
33
-------
background") metals exceed the Idaho water quality criteria and allocating zero to the individual
discrete sources, with the remainder of the load capacity allocated to waste piles and nonpoint
sources. EPA does not believe this is a reasonable option, because it does not allow continued
operations at municipal treatment plants and operating mines. Another option would be to
establish end-of-pipe water quality criteria concentrations as the wasteload allocations for
individual discrete sources (based on a conservative hardness estimate). However, to quantify
non-discrete allocations by subtracting from the loading capacity, EPA would need to assign not
only a concentration but also a flow to each discrete source at each flow tier. The available
information for the majority of discrete sources is not sufficient to assign source flowrates that
correspond to each target site flow tier.
EPA also considered different percentage breakdowns in the gross allocation. One option was to
allocate according to estimates of the current contribution of point sources to the instream nretals
loadings. Because calculations indicate that the percentage contribution varies substantially
between target sites and between metals, EPA chose not to employ this allocation scheme. For
all metals and sites, EPA's gross estimates of" the contribution of discrete sources ranged from
7% (cadmium in Pine Creek) to 100% (zinc above Wallace) of the total current loadings. At the
Pinehurst target site, the discrete source contributions were estimated at 28% for cadmium and
12% for zinc (lead estimates were highly variable).
Given the above examination, EPA concludes that a 25% gross allocation to individual discrete
sources at each target site is both straightforward and reasonable. EPA believes it is reasonable
to set aside a majority of the loading capacity for waste piles and nonpoint sources, given the
magnitude of metals contributions from these sources in this basin. EPA also believes that the
25% allocation to point sources will enable active facilities to continue operations while also
resulting in improvements to current wastewater management in the basin.
Consistent with the requirements of the TMDL regulations at 40 CFR 130.2(i), the sum of
wasteload allocations (including individual allocations to discrete sources and gross allocations
for waste piles), load allocations (including allocations to nonpoint sources and natural
background loadings), and the margin of safety is equal to the loading capacity at each target site.
Over the long term, EPA plans to refine the gross allocations for waste piles and nonpoint
sources into individual allocations, as data collection and analysis proceeds for the RI/FS in the
basin. The RI/FS analysis may also lead to adjustments in some of the individual allocations to
discrete sources, particularly those for abandoned mine adits.
6.4.C. Wasteload Allocations to Discrete Sources
The 25% gross allocation to discrete sources is further allocated to individual sources based on
the average flowrates of the discrete sources within the target site watershed. Discharge flow
data were obtained from EPA's Permit Compliance System and Discharge Monitoring Reports,
EPA Inspection Reports, the URSG 1997-1998 and MFG 1991 sampling events, and other
34
-------
sources Appendix E describes EPA s specific sources for and methodologies used in calculating
average flows from each discrete source.
EPA recognizes that the use of the average flowrates to calculate allocations for all flow tiers
does not take into seasonal variation in flows between individual sources. In an attempt to
correlate individual source types to stream flow, EPA compared data from NPDES-permitted
sources with long-term flow measurements to tlie corresponding stream flow data for the USGS
Station at Elizabeth Park. While EPA observed some increased source flow under liigh stream
flow conditions, these relationships were not consistent and varied significantly by source.
Similarly, EPA found that flows in the Bunker Hill Kellogg Tunnel and the South Fork Coeur
d'Alene River are poorly correlated (CH2M Hill, 2000). Since source flows do not necessarily
correlate to river flows, EPA has allocated loadings among discrete sources using a single flow
ratio (based on average flow rates) for all river flow tiers.
Steps 1 tlirough 5 on Figure 6-1 are explained in earlier sections. The remaining steps in the
development of wasteload allocations for individually identified discrete sources are as follows:
Step 6 For each flow scenario (7Q10, 10th, 50th, and 90th percentile), the gross
allocation for discrete point sources (25%) is divided by the total average flowrate
of all the discrete discharges (i.e., the sum of the individual average flowrates).
The resulting ratio, in pounds of metal per unit flow, is used in Step 7 to derive
flow-proportioned wasteload allocations. An illustration of the practical effect of
flow-proportioning is as follows; if Source A discharges at twice the ilowrate of
Source B on average, its calculated wasteload allocation is twice that of Source B.
Step 7 The ratio derived in Step 6 is multiplied by each individual average discharge
flow to establish the calculated wasteload allocation to that source. This is
repeated for each design flow. The calculated allocations by target site,
parameter, and source are shown in Appendix H.
Step 8 The last step in the allocation involves a comparison between current discharge
levels and the calculated wasteload allocation for a given source. If the current
discharge concentrations are below the concentration associated with the
wasteload allocation, the assigned allocation is set at the current discharge level.
This adjustment ensures that sources already meeting their allocation do not
increase loadings above current levels. EPA believes this allocation step is
consistent with anti-degradation requirements and appropriate in the context of
basin-wide cleanup activities. The evaluation of current discharge levels
necessary to complete tliis step will be performed as part of the development of
individual NPDES permits.
35
-------
Step 9 When a pen ml containing performance-based limits (Step 8) is issued, the loading
equal to the difference between the calculated wasteload allocations in the TMDI.
and the performance based limits for that facility will be reserved to allow for
future growth (new or expanding facility). The reserve allocation created by a
permitting action can only be used by new or expanding facilities within the same
target site or at a target site downstream of permitted source. This limitation on
the use of the reserve is necessaiy to insure that use of the future growth reserve
does not result in exceedances of the gross allocation for discrete sources at
upstream target sites. EPA also notes that allocation of the future growth reserve
to individual sources will require formal modification of the TMDL.
6.5 Refinement of Wasteload Allocations for CDA River and Tributaries
6.5.a. Translators
In order to express wasteload allocations in a manner consistent with NPDES permitting
regulations (40 CFR 122.45), the dissolved wasteload allocations are translated into total
recoverable wasteload allocations in the TMDL. 'Total recoverable metal" is a measure of the
aiiiount of metal in both the dissolved and particulate phase in a water sample. Its use in
permitting reduces the potential impacts on downstream biota from effluent metals shifting from
the particulate phase to the (more bio available) dissolved phase upon discharge.
EPA has evaluated the ratio of total recoverable metal to dissolved metal in the Coeur d'Alene
River and tributaries (this ratio is also called a "translator"). Cadmium and zinc in the river are
almost entirely in the dissolved form at all of the target sites (i.e., the translator is approximately
1). For lead, the particulate fraction is a significant portion of the total lead concentration at a
number of target sites. Appendix G includes more discussion of physical/chemical processes that
affect the total-to-dissolved ratios for metals in the water column.
EPA also reviewed the available data for the South Fork Pinehurst station to determine whether
the total-to-dissolved ratio varies with respect to river flow. Over the range of flow tiers
established in the TMDL (68 cfs to 1290 cfs), there was no discernible relationship between river
flow and the total-to-dissolved ratios for cadmium, lead, and zinc.
Recent data collected by the USGS indicates that during peak runoff events, the total-to-
dissolved ratio for lead increases significantly in basin waters. The flows at which this
phenomenon occurs are higher than the top flow tier in the TMDL (greater than 1290 cfs). Since
the total-to-dissolved ratio at the top flow tier is more stringent than the actual ratio during peak
runoff events, the lead translators in the TMDL provide a margin of safety during peak runoff
events.
36
-------
Table 6-10. Translators from Dissolved to Total Recoverable Metal
' Target Site
Met*!
N«^ of Samples*
'Translator
; (Tatal/Dissolved),: -
Canyon Creek
Cadmium
49
1.0
Ninemile Creek
Cadmium
39
1.0
South Fork @ Wallace
Cadmium
17
1.0
Pine Creek
Cadmium
38
l.l2
South Fork @ Pinehurst
Cadmium
50
1.0
Spokane River @ state line1
Cadmium
29
1.0
iinif&ten
MpglMMl
WMSMmigmSSk
Canyon Creek
Lead
66
i.i
Ninemile Creek
Lead
61
i.i
South Fork @ Wallace
Lead
20
1.2
Pine Creek
Lead
47
1.0
South Fork @ Pinehurst
Lead
59
2.3
Spokane River @ state line1
Lead
26
3.2
MplpiiiiMi
r?'T" - ' V
Canyon Creek
Zinc
28
1.0
Ninemile Creek
Zinc
24
1.0
South Fork @ Wallace
Zinc
9
1.0
Pine Creek
Zinc
30
1.0
South Fork (s> Pinehurst
Zinc
36
1.0
Spokane River @ state line1
Zinc
30
1.0
1 Some Spokane River data (8 samples) used in this calculation (Oct 1997 to Aug 1998) are provisional data from
the Department of Ecology (lab QC only).
2 This is a case where the upstream translator is higher than a downstream translator. In this case, metal discharged
in particulate form could change to the dissolved form downstream. Therefore, the translator applied to Pine Creek
for cadmium is adjusted to 1.0, the translator calculated downstream at Pinehurst.
3 Sample results reporting a higher dissolved than total value were eliminated from the data set for this analysis.
This artifact is primarily found in the cadmium and zinc data.
37
-------
EPA has calculated the translator for each sample taken at or near a target site. From this group
of values, EPA has calculated a S"1 percentile value in order to assure compliance with water
quality standards. This translator is tlien multiplied by the dissolved wastcload allocation to
derive the total recoverable wasteload allocation Table 6-10 lists the calculated translators and
Appendix J includes the data used in the calculations.
6.5.b. Implementation of Flow-based Allocations in Permits
Flow-based allocations in a TMDL can be incorporated into NPDES permits as monthly average
effluent limitations (note that additional limitations may also be included as required by the
NPDES regulations). Rather than a single monthly average limit, a set of limits with associated
river discharge rates can be included in the permit. The applicable permit limit is dependent on
the discharge measured at the gauging station on the day (or over the month) of sampling. Using
this approach, however, the Permittee will be required to report the corresponding river flow at
the target site along with effluent monitoring information. The NPDES permit will set forth the
specific reporting requirements necessary to insure compliance with the flow-based allocations.
The TMDL establishes wasteload allocations at four flow tiers. The TMDL includes language
allowing for flexibility to interpolate between these flow tiers to establish additional flow tiers
and associated permit limits in an NPDES permit. EPA's permits program will balance the need
for flexibility with the additional compliance-tracking burden when considering any requests
from permittees for additional flow tiers in their individual NPDES permits.
The calculated wasteload allocations for sources in the CD A River and tributaries are listed in
Tables 6-11 through 6-15 below.
38
-------
Table 6-11 : Calculated Wasteload Allocations for Individual Sources - Canyon Creek (URSG Site CC288)
All values In lbs/day
r 1
Total Recoverable Cadmium
Total Recoverable Lead
Total Recoverable Zinc
Station ID
Flow
(cfs)
7Q10L
10th
Percentile
50th
Percentile
90th
Percentile
7Q10L
10th
Percentile
50th
Percentile
90th
Percentile
7Q10L
10th
Percentile
50th
Percentile
90th
Percentile
CC817
Heda #3
0.0684
4.85E-05
7.51 E-05
1.43E-04
5 14E-04
1.01 E-04
1 57E-04
2.68E-04
6.79E-04
4.58E-03
7.10E-03
1.31 E-02
4.36E-02
CC355
Gem
0.26
1.84E-04
2.85E-04
5.42E-04
1.96E-03
3.85E-04
5.96E-04
1.02E-03
2.58 E-03
1.74E-02
2.70E-02
4.99E-02
1.66E-01
CC816
Star/Phoenix Tailings (001)
2.34
1.66E-03
2.57E-03
4.88E-03
1.76E-02
3.46E-03
5.37E-03
9.19E-03
2.32E-02
1.57E-01
2.43E-01
4.49E-01
1.49E+00
CC357
Woodland Park Seep
0.0038
2.69E-06
4.17E-06
7.92E-06
2.86E-05
5.63E-06
8.72E-06
1.49E-05
3.77E-05
2.55E-04
3.95E-04
7.29E-04
2.42E-03
CC372
Tamarack #7
1.59
1.13E-03
1.75E-03
3.32E-03
1.20E-02
2.35E-03
3.65E-03
6.24E-03
1.58E-02
1.07E-01
1 65E-01
3.05E-01
1.01E+00
CC353
Hercules #5
1.707
1.21E-03
1.87E-03
3.56E-03
1.28E-02
2.53E-03
3.92E-03
6.70E-03
1.69E-02
1.14E-01
1.77E-01
3.28E-01
1.09E+00
CC371
Blackbear Fraction
1.165
8.25E-04
1.28E-03
2.43E-03
8.76E-03
1.72E-03
2.67E-03
4.57E-03
1.16E-02
7.81 E-02
1.21E-01
2.24E-01
7.42E-01
CC373
Anchor
0.008
5.67E-06
8.78E-06
1.67E-05
6.02E-05
1.18E-05
1.83E-05
3.14E-05
7.94E-05
5.36E-04
8.31 E-04
1.53E-03
5.09 E-03
CC354
Hidden Treasure
0.72
5.10E-04
7.90E-04
1.50E-03
5.42 E-03
1.07E-03
1 65E-03
2.83E-03
7.14E-03
4.83E-02
7.48 E-02
1.38E-01
4.58E-01
Tiger/Poo rman
0.4
2.83E-04
4.39E-04
8.34E-04
3.01 E-03
5.92E-04
9.17E-04
1.57E-03
3.97E-03
2.68E-02
4.15E-02
7.67E-02
2.55E-01
39
-------
Table 6-12 : Calculated Wasteload Allocations for Individual Sources - Ninemile Creek (URSG Site NM305)
All values in lbs/day
Total Recoverable Cadmium
Total Recoverable Lead
Total Recoverable Zinc
Station ID
Flow
(cfa)
7Q10L
lO*
Percentile
SO*
Percentile
90th
Percentile
7Q10L
10th
Percentile
50th
Percentile
90,h
Percentile
7Q10L
10w
Percentile
50th
Percentile
90th
Percentile
NM360
Interstate-Callahan
(IC) #4
0.040
4.11 E-05
6.17E-05
1.26E-04
4.72E-04
9.65E-05
1.45E-04
2.78E-04
7.90E-04
4.02E-03
6.03E-03
1.21E-02
4.22E-02
NM362
IC Waste Rock
1.790
1.84E-03
2.78E-03
5.64E-03
2.11 E-02
4.32E-03
6.48E-03
1.24E-02
3.53E-02
1.80E-01
2.70E-01
5.42E-01
1.89E+00
NM363
IC Tailings Seep
0.004
4.11E-06
6.17E-06
1 26E-05
4.72E-05
9.65E-06
1.45E-05
2.78E-05
7.90E-05
4.02E-04
6.03E-04
1.21 E-03
4.22E-03
NM361
Rex #2
0.020
2.06E-05
3.09E-05
6.31 E-05
2.36E-04
4.82E-05
7.24E-05
1.39E-04
3.95E-04
2.01 E-03
3.01 E-03
6.05E-03
2.11 E-02
NM364
Tamarack 400
Level
0.040
4.11E-05
6.17E-05
1 26E-04
4.72E-04
9.65E-05
1 45E-04
2.78E-04
7.90E-04
4.02E-03
6.03E-03
1.21E-02
4.22E-02
NM366
Tamarack #5
0.030
3.09E-05
4.63E-05
9.46E-05
3 54E-04
7.24E-05
1.09E-04
2.08E-04
5.92E-04
3.01 E-03
4.52E-03
9.08 E-03
3 16E-02
NM368
Rex Tailings Seep
0.020
2.06E-05
3.09E-05
6.31 E-05
2.36E-04
4.82E-05
7.24E-05
1.39E-04
3.95E-04
2.01 E-03
3.01 E-03
6.05E-03
2.11 E-02
NM359
Success #3
0.010
1.03E-05
1.54E-05
3.15E-05
1.18E-04
2.41 E-05
3.62E-05
6.94E-05
1.97E-04
1.00E-03
1.51 E-03
3.03E-03
1.05E-02
NM367
Dayrock 100
0.007
6.99E-06
1.05E-05
2.14E-05
8.03E-05
1.64 E-05
2.46E-05
4.72E-05
1 34E-04
6.83E-04
1.02E-03
2.06E-03
7.17E-03
NM369 -
Silver Star
0.0096
9.87E-O0
1.48E-05
3.03E-05
1.13E-04
2.32E-05
3.47E-05
6.67E-05
1 90E-04
9.65E-04
1 45E-03
2.90E-03
1.01 E-02
NM370
Duluth
0.011
1.13E-05
1.70E-05
3.47E-05
1.30E-04
2.65E-05
3.98E-05
7.64E-05
2.17E-04
1.11 E-03
1.66E-03
3.33E-03
1.16E-02
NM374
Success Tailings
0.003
3.50E-06
5.25E-06
1.07E-05
4.02E-05
8.20E-06
1.23 E-05
2.36E-05
6.71 E-05
3.42E-04
5.12E-04
1.03E-03
3.59E-03
40
-------
Table 6-13 : Calculated Wasteload Allocations for Individual Sources - South Fork at Wallace (URSG Site SF223)
All values In Iba/day
Total Recoverable Cadmium
Total Recoverable Lead
Total Recoverable Zinc
Station ID
Flow
(cfs)
7Q10L
10th
Percentile
50th
Percentile
90th
Percentile
7Q10L
10th
Percentile
50th
Percentile
90th
Percentile
7Q10L
10th
Percentile
50*
Percentile
90th
Percentile
SF607
Lucky Friday
Outfall 001
1.27
1.52E-03
2.40E-03
4.72E-03
1 58E-02
3.43E-03
5.35E-03
9.73E-03
2.14E-02
1.43E-01
2.26E-01
4.35E-01
1.32E+00
SF609
Lucky Friday
Outfall 003
0.85
1.02E-03
1.61E-03
3.16E-03
1.06E-02
2.30E-03
3.58E-03
6.51 E-03
1.43E-02
9.59E-02
1.51E-01
2.91 E-01
8.84E-01
SF328
Star/Morning
Waste Rock
1.59
1.90E-03
3.00E-03
5.90E-03
1.98E-02
4.29E-03
6.69E-03
1.22E-02
2.68E-02
1.79E-01
2.82E-01
5.44E-01
1 65E+00
SF 396
Square Deal
0.08
9.57E-05
1.51 E-04
2.97E-04
9 94E-04
2.16E-04
3.37E-04
6.13E-04
1.35E-03
9.03E-03
1.42E-02
2.74E-02
8.32E-02
SF395
Golconda
0.03
3.59E-05
5.67E-05
1.11 E-04
3.73E-04
8.10E-05
1.26E-04
2.30E-04
5.06E-04
3.39E-03
5.33E-03
1 03E-02
3 12E-02
SF627
Mullan STP
0.413
4.94E-04
7.80E-04
1.53E-03
5.13E-03
1.12E-03
1.74E-03
3.17E-03
6.97E-03
4.66E-02
7.34E-02
1.41 E-01
4.29E-01
SF338
Snowstorm #3
2
2.39E-03
3.78E-03
7.43E-03
2.49E-02
5.40E-03
8.42E-03
1.53E-02
3.37E-02
2.26E-01
3.55E-01
6.84E-01
2.08E+00
SF339
Copper King
0.0564
6.75E-05
1.07E-04
2.09E-04
7.01 E-04
1.52E-04
2.37E-04
4.32E-04
9.51 E-04
6.37E-03
1.00E-02
1 93E-02
5.86E-02
SF345
Morninq #4
0.0152
1.82E-05
2.87E-05
5.64E-05
1.89E-04
4.11E-05
6.40E-05
1.16E-04
2.56E-04
1.72E-03
2.70E-03
5.20E-03
1.58E-02
SF346
Morninq #5
0.0111
1.33E-05
2.10E-05
4.12E-05
1.38E-04
3.00E-05
4.67E-05
8.51 E-05
1.87E-04
1.25E-03
1.97E-03
3.80E-03
1.15E-02
SF347
Star 1200 Level
0.695
8.31 E-04
1.31E-03
2.58E-03
8.64E-03
1.88E-03
2.93E-03
5.33E-03
1.17E-02
7.84E-02
1.23E-01
2.38E-01
7.23E-01
SF349
Grouse
1.82
2.18E-03
3.44E-03
6.76E-03
2.26E-02
4.92E-03
7.66E-03
1.39E-02
3.07E-02
2.05E-01
3.23E-01
6.23E-01
1.89E+00
SF386
Adit in Beacon'
Liqht Area
0.0003
3.59E-07
5.67E-07
1.11 E-06
3.73E-06
8.10E-07
1.26E-06
2.30E-06
5.06E-06
3.39E-05
5.33E-05
1.03E-04
3.12E-04
SF389
Unnamed Adit
Deadman Gulch
0.011
1.32E-05
2.08E-05
4.08E-05
1.37E-04
2.97E-05
4.63E-05
8.43E-05
1.86E-04
1.24E-03
1.95 E-03
3.76E-03
1.14E-02
SF390
Reindeer Queen
0.011
1.32E-05
2.08E-05
4.08E-05
1.37E-04
2.97E-05
4.63E-05
8.43E-05
1.86E-04
1.24E-03
1.95E-03
3.76E-03
1.14E-02
41
-------
* t
Table 6-14: Calculated Wasteload Allocations for Individual Sources - Pine Creek (URSG Site PC315)
All values In lbs/day
Total Recoverable Cadmium
Total Recoverable Lead
Total Recoverable Zinc
Station ID
Flow
(cfs)
7Q10L
10th
Percentile
50th
Percentile
90,h
Percentile
7Q10L
10,h
Percentile
50th
Percentile
90th
Percentile
7Q10L
10th
Percentile
50,h
Percentile
90th
Percentile
PC329 North Amy
0.322
3.48E-03
5.04E-03
1.39E-02
6.73E-02
4.27E-03
6.20E-03
1.71E-02
8.27E-02
3.77E-01
5.47E-01
1.51E+00
7.29E+00
PC330 Amy
0.005
5.40E-05
7.83E-05
2.16E-04
1.05 E-03
6.64E-05
9.62E-05
2.65E-04
1.28E-03
5.85E-03
8.49E-03
2.34E-02
1.13E-01
PC331
Liberal King
0.005
5.40E-05
7.83E-05
2.16E-04
1.05E-03
6.64E-05
9.62E-05
2.65E-04
1.28E-03
5.85E-03
8.49E-03
2.34E-02
1.13E-01
PC332 Lookout
0.027
2.92E-04
4.23E-04
1.17E-03
5.64E-03
3.58E-04
5.20E-04
1.43E-03
6.94E-03
3.16E-02
4.58E-02
1.26E-01
6.12E-01
PC333
Upper Lynch
0.001
1.08E-05
1.57E-05
4.32E-05
2.09E-04
1.33E-05
1.92E-05
5.31 E-05
2.57E-04
1.17E-03
1.70E-03
4.68E-03
2.27E-02
PC334
Lynch/Nabob
0.0006
6.48E-06
9.40E-06
2.59E-05
1.25E-04
7.96E-06
1.15E-05
3.19E-05
1.54E-04
7.02E-04
1.02E-03
2.81 E-03
1.36E-02
PC335
Nevada-Stewart
0.091
9.83E-04
1.43E-03
3.93E-03
1.90E-02
1.21 E-03
1.75E-03
4.83E-03
2.34E-02
1.07E-01
1.54E-01
4.26E-01
2.06E+00
PC336
Highland Surprise
0.038
4.10E-04
5.95E-04
1.64E-03
7.94E-03
5.04E-04
7.31 E-04
2.02E-03
9.76E-03
4.45E-02
6.45E-02
1.78E-01
8.61 E-01
PC375
Highland Surprise
Waste Rock
0.0106
1.15E-04
1.66E-04
4.58E-04
2.22E-03
1.41E-04
2.04E-04
5.63E-04
2.72E-03
1 24E-02
1.80E-02
4.96E-02
2.40E-01
PC337
Sidney (Red Cloud
Creek Adit)
0.006
6.48E-05
9.40E-05
2.59E-04
1 25E-03
7.96E-05
1.15E-04
3.19E-04
1.54E-03
7.02E-03
1 02E-02
2.81 E-02
1.36E-01
PC340
Upper Little Pittsburg
0.002
2.16E-05
3.13E-05
8.64E-05
4.18E-04
2.65E-05
3.85E-05
1.06E-04
5.14E-04
2.34E-03
3.39E-03
9.37E-03
4.53E-02
PC341
Lower Little Pittsburg
0.006
6.48E-05
9.40E-05
2.59E-04
1.25E-03
7.96E-05
1.15E-04
3.19E-04
1.54E-03
7.02E-03
1.02E-02
2.81 E-02
1.36E-01
PC343
Nabob 1300 Level
0.066
7.13E-04
1.03E-03
2.85E-03
1.38E-02
8.76E-04
1.27E-03
3.50E-03
1.70E-02
7.73E-02
1.12E-01
3.09E-01
1.50E+00
PC344 Big It
0.00106
1.15E-05
1.66 E-05
4.58E-05
2.22E-04
1.41 E-05
2.04E-05
5.63E-05
2.72E-04
1.24E-03
1.80E-03
4.96E-03
2.40E-02
PC348
Upper Constitution
0.079
8.53E-04
1.24E-03
3.41 E-03
1.65E-02
1.05E-03
1.52E-03
4.19E-03
2.03E-02
9.25E-02
1.34E-01
3.70E-01
1.79E+00
PC351
Marmion Tunnel
0.0089
9.61 E-05
1.39E-04
3.85E-04
1.86E-03
1.18E-04
1.71 E-04
4.73E-04
2.29E-03
1.04E-02
1.51E-02
4.17 E-02
2.02E-01
PC352 Seep
Below Nevada
Stewart
0.0028
3.02E-05
4.39E-05
1.21E-04
5.85E-04
3.72E-05
5.39E-05
1.49E-04
7.19E-04
3.28E-03
4.75E-03
1.31 E-02
6.34E-02
PC 400 Adit
Upstream of Uttle
Pittsburg
0.000422
4.56E-06
8.61 E-06
1.82E-05
8.82E-05
5.60E-06
8.12E-06
2.24E-05
1.08E-04
4.94E-04
7.16E-04
1.98 E-03
9.56E-03
42
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Table 6-15 : Calculated Wasteload Allocations for Individual Sources - South Fork above Pinehurst (URSG Site SF271)
All values in lbs/day
Total Recoverable Cadmium
Total Recoverable Lead
Total Recoverable Zinc
Station ID
Row
(cfa)
7Q10L
10th
Percentile
50th
Percentile
90th
Percentile
7Q10L
10th
Percentile
50th
Percentile
90th
Percentile
7Q10L
10th
Percentile
50th
Percentile
90th
Percentile
SF382
Silver Dollar
0.015
7.00E-05
9.30E-05
1.98E-04
3.09E-04
4.07E-04
5.35E-04
1.00E-03
8.93E-04
7 31 E-03
9.68E-03
1.99 E-02
2.67E-02
SF393
Western Union (Lower
Adit)
0.001
4.67E-06
6.20E-06
1.32E-05
2.06 E-05
2.71 E-05
3.57E-05
6.70E-05
5.96E-05
4.87E-04
6.46E-04
1.32 E-03
1.78E-03
SF3
Central Tmt Plant
4.990
2.33E-02
3.10E-02
8.59E-02
1.03E-01
1.35E-01
1 78E-01
3.34E-01
2.97E-01
2.43E+00
3.22E+00
6 60E+00
8 90E+00
SF620
Page STP
3.870
1.81E-02
2 40E-02
5.11 E-02
7 97E-02
1 05E-01
1 38E-01
2.59E-01
2 31E-01
1 89E+00
2 50E+00
5.12E+00
6 90E+00
SF383
St. Joe
0007
3 27E-05
4 34E-05
9 25E-05
1 .44 E-04
1 90E-04
2.50E-04
4.69E-04
4.17E-04
3.41 E-03
4 52E-03
9.26E-03
1 25E-02
SF384
Coeur d'Alene
(Mineral Point)
0.005
2.33E-05
3.10E-05
6.61 E-05
1 03E-04
1 36E-04
1 78E-04
3.35E-04
2.98E-04
2.44E-03
3 23E-03
6.62E-03
8 92E-03
SF385
Unnamed Adit
0.001
3.27E-06
4.34E-06
9.25E-06
1.44 E-05
1 90E-05
2.50E-05
4.69E-05
4.17E-05
3.41 E-04
4.52E-04
9 26E-04
1 25E-03
SF600
Caladay
0.210
9 80E-04
1 30E-03
2.77E-03
4.32E-03
5.70E-03
7.49E-03
1.41 E-02
1.25 E-02
1.02E-01
1.36E-01
2.78E-01
3.74E-01
SF602
Galena
1.300
6 06E-03
8.06E-03
1 72E-02
2.68E-02
3.53E-02
4.64E-02
8.71 E-02
7.74E-02
6.34E-01
8.39E-01
1 72E+00
2.32E+00
SF623
Smelterville STP
0421
1 96 E-03
2.61 E-03
5.56E-03
8.66E-03
1.14E-02
1.50E-02
2.82E-02
2.51 E-02
2.05E-01
2.72E-01
5 57E-01
7 51E-01
SF624
Sunshine 001
3.120
1 46E-02
1 94E-02
4.12E-02
6.42E-02
8.46E-02
1.11E-01
2.09E-01
1 86E-01
1 52E+00
2.01 E+00
413E+00
5 56E+00
Coeur/Galena 002
0.775
3 62E-03
4.81 E-03
1.02E-02
1 60E-02
2.10E-02
2.76E-02
5.19E-02
4.62E-02
3.78E-01
5 0OE-01
1 03E+00
1 38E+00
Consolidated Silver
0.300
1 40E-03
1.86E-03
3.97 E-03
6.18E-03
8 14E-03
1.07E-02
2.01 E-02
1 79E-02
1.46E-01
1 94E-01
3.97E-01
5 35E-01
43
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6.6 Proposed Allocation Method - Coeur d'AIene Lake and Spokane River
The allocation approach for Coeur d'AIene Lake and the Spokane River is significantly different
than the approach used for the Coeur d'AIene River and tributaries. The differences stem from
the significant differences in the number, types, and proximity of metals sources in the Coeur
d'AIene Lake/Spokane River area. If the Coeur d'AIene River allocations were achieved and the
lake continues to act as a sink for dissolved metals (see discussion below), the Spokane River
would likely meet water quality standards if current metals concentrations were maintained by
discrete sources along the Spokane River. This contrasts with the need for significant reductions
from both discrete and non-discrete sources upstream in the Coeur d'AIene River to meet water
quality standards.
6.6.a. Sources in Coeur d'AIene Lake and the Spokane River
Aside from the dissolved metals in the Coeur d'AIene River, the only other potentially significant
source of metals to the lake is the release (or "flux") of dissolved metals from the contaminated
sediments on the lake bottom to the overlying water column. Results of studies to ascertain the
magnitude and direction of metals fluxes from the lake sediments are summarized in Appedix F.
The most direct measurements of metals fluxes at tlie lake bottom indicate that the sediments
deliver a dissolved metals loading to the water column. Furthermore, tlie magnitude of measured
fluxes were significant in relation to Coeur d'AIene River loadings.
At the same time, the available flow/concentration data at the lake boundaries indicate that
dissolved metals loadings in the Spokane River (at the Post Falls dam) are lower than loadings
delivered by the Coeur d'AIene River. This suggests that other physical, chemical, and/or
biological processes are occurring in Coeur d'AIene Lake that result in a net loss of dissolved
metals from tlie water column. These processes are not fully understood, and study of the lake is
ongoing. It is also recognized that cleanup actions over the long term could affect both the
sediment fluxes and other lake processes. Based on the magnitude of the measured fluxes from
the sediments and the uncertainty about long term changes in lake dynamics, EPA believes it is
prudent to establish a load allocation for net loadings from lake sediments to the water column.
Net loadings in this case are defined as the difference between loadings at the mouth of the Couer
d'AIene River and in the Spokane River at the lake outlet. The development of this allocation is
described below.
Along the Spokane River, between the lake and the state line, the only identified sources of
metals are three municipal treatment plants (Hayden Lake, Coeur d'AIene, and Post Falls) and
urban stormwater.
6.6.b. Load Allocations for Net Loadings from Lake Sediments
The load allocation for lake sediments is calculated in a straightforward manner based on an
idealized view of the lake as the confluence of two large rivers. The predominant inflows to
44
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Coeur d'Alene Lake are from the St. Joe River and Coeur d'Alene River. That portion of the
lake's loading capacity derived from the Coeur d'Alene River is already allocated to upstream
sources in the TMDL, However, the St. Joe River's loading capacity is not allocated. The
loading capacity delivered to the lake by the St. Joe River (i.e., the total loading capacity minus
the current background loading for a particular metal) can be allocated to the lake sediment
source.
Tlie load allocation is calculated for the same flow tier percentiles as those used for the Coeur
d'Alene River and tributaries (7Q10, 10th, 50th, and 90th percentiles). The available water
quality data for the St. Joe River (9 samples) indicates that hardness is generally below the 25
mg/1 lower bound in the Idaho water quality standards (the highest sample value was 27 mg/1).
EPA has applied the water quality criteria for a hardness of 25 mg/1 in calculating the loading
capacity at the four flow tiers. Background levels are below detection for dissolved cadmium
and lead, though detection levels vary within the dataset. EPA has estimated background in the
St. Joe by applying one-half the lowest detection level for cadmium (.02 ug/1) and lead (.25 ug/1),
and using the highest detected value for zinc (4,2 ug/1).
Table 6-16. St. Joe River Loading Capacity and Background
Flow
(cfs)
St. Joe Loading Capacity (lbs/day)
Background Loading (lbs/day)
Dissolved
Cadmium
Dissolved
Lead
Dissolved
Zinc
Dissolved
Cadmium
Dissolved
Lead
Dissolved
Zinc
241
0.48
0.70
41.6
0.02
0.33
5.5
374
0.74
1.09
64.6
0.04
0.50
8.5
1,000
2.00
2.92
173
0 11
1.4
23
6,470
12.9
18.9
1,120
0.70
8.7
147
Table 6-17. Load Allocations for Net Loadings from Coeur d'Alene Lake Sediments
Flow at
Calder (cfs)
Dissolved Cadmium
(lbs/day)
Dissolved Lead
(lbs/day)
Dissolved Zinc
(lbs/day)
241
0.46
0.38
36
374
0.71
0.59
56
1,000
1.9
1.6
150
6,470
12
10
970
45
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The above load allocation is establislied conservatively by using the flow measured at the USGS
station at Calder. Tlie actual flow into the lake includes contributions from the St. Maries River,
downstream from the Calder station.
6.6.c. Wasteload Allocations for Spokane River Treatment Plants
The State of Wellington has issued an EPA-approved TMDL for metals in the Spokane River
downstream of the state line (Wasliington Department of Ecology. 1999). Because tlie river and
source conditions are similar in the Spokane River segment upstream of the state line, EPA
allocates loading in a two-step method consistent with that used by the State of Washington in its
Spokane River TMDL. In the first step, an upper bound concentration is calculated for each
point source by applying the Idaho water quality criteria at the end-of-pipe using the effluent
hardness (in other words, applying an "effluent-based criterion")- The effluent-based criterion
accounts for differences between effluent and ambient hardness levels. The hardness levels of
the three municipal discharges to the Spokane River in Idaho are higher than that of the river,
because these cities pump groundwater for their water supplies, and this source water has a
significantly higher hardness than the Spokane River.
In simple terms, applying the effluent-based criterion is analogous to treating the effluent
discharge as if it were a tributary that has higher hardness levels than the mainstem river. As
discussed earlier, metals toxicity decreases with increased hardness. The tributary would be
allowed to achieve less stringent (i.e., higher) metals criteria by virtue of its elevated hardness
levels. It can be shown that the mixture of the tributary and mainstem waters would not result in
any local criteria exceedances. A detailed analysis of the relationship between the water quality
criteria equations and the mixing of two waters with different hardness levels is included in the
State of Washington TMDL.
In order to develop monthly average wasteload allocations for use in NPDES permits, it is
appropriate to translate dissolved metal allocations into total recoverable metal allocations. EPA
has calculated translators for the Spokane River (see Table 6-10). Since the translators from total
recoverable to dissolved metal are 1.0 for cadmium and zinc, the equations for these metals
provide both dissolved and total recoverable values. For lead, the characteristics of the criterion
curve necessitate a different approach to achieve a total recoverable allocation. Consistent with
the State of Washington TMDL, the dissolved criterion equation is converted to a total
recoverable equation using a default conversion factor. The tangent line is then used, at the river
hardness value, to calculate a total recoverable lead allocation. The effluent-based criteria for the
Spokane River dischargers are calculated using the equations in Table 6-18.
46
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Table 6-18. Efiluent-based Criteria Equations
Pollutant
Equation
Total Recoverable Cadmium
y - exp^78521^'-3-491)
Total Recoverable Lead
y = .0261(x) - .1119
Total Recoverable Zinc
_ (.8473[(bl(x)]+7614)
y — caF
Sfotes:
y = criterion (ug/1)
x = effluent hardness (mg/1)
Provided facilities maintain effluent metals concentrations below the effluent-based criteria,
effluent flow (and loading) can be increased without exceeding the loading capacity in the
Spokane River. In addition, the wasteload allocation concentration is not dependent on the river
flow. For this reason, the wasteload allocation is expressed as a concentration (ug/1) rather than a
load (lbs/day). A wasteload allocation expressed in tliis manner allows for future growth without
the need to revise wasteload allocations.
In the second step of the allocation process, the current discharge level (or current
"performance") is compared to the calculated effluent-based criterion during permit
development, and the more restrictive value is assigned as the wasteload allocation for the
facility. This step is similar to the final step (Step 8) of the allocation approach for the Coeur
d'Alene River and tributaries.
Based on the information in Table 6-19, all three municipalities on the Spokane River are
expected to liave final allocations based on current performance. The intent of this step in the
allocation process is to prevent significant increases in metals discharges from sources in tliis
basin, and this approach is consistent with anti-degradation requirements in the Idaho water
quality standards. In the Spokane River, this approach also allows for allocation of remaining
capacity to urban stormwater sources.
Table 6-19. Effluent-Based Criteria for Spokane River Facilities
Facility
Minimum
Httrttoess'.
CaCOj)
Tot*! Recoverable
Total Recoverable
Total Recoverable
zs»c<«g/i) ;;
Effinent
Criterion
Cwrrent
^Perform.
EfBwnt
Criterion
Current
Perform.
Effluent
Criterion
Cwrent
Perform.
Hayden
92
1.0
0.2
2.3
1.9
97
80
Coeur d'Alene
132
1.3
0.2
3.3
2.3
132
72
Post Falls
96
1.0
0.2
2.4
2.0
101 '
80
47
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Notes:
1. Tile wasteload allocation tor a facility will In: thu lower value of the current jierlbrmance and effluent-
based criterion. The above comparison is provided for informational purposes only. Final performance-
based permit limits will be developed in the individual NPDES permits.
2. Minimum hardness is used txscause the criteria increase with increased hardness.
3. Current jierlbrmance is the 90u' percentile of the available discharge data.
4. Effluent criteria are Idaho water quality criteria values associated with the minimum hardness of the
effluent,
6.6.d. Wasteload Allocations for Urban Stormwater
EPA has no information on the metals loadings entering Coeur d'Alene Lake and the Spokane
River from urban stormwater. Nevertheless, metals are commonly present in urban stormwater,
and therefore the TMDL must address these sources in the allocation process. The TMDL
stipulates that, upon issuance of a permit with performance-based limits in the Coeur d'Alene
Lake/Spokane River area, the reserve loadings associated with the differences between the
effluent criterion values and the performance-based values are reserved for municipal stormwater
sources in the area.
7.0 TMDL IMPLEMENTATION ISSUES
7.1 General
Under current regulations, an implementation plan is not a required element of a TMDL.
Nevertheless, EPA has considered implementation issues in the development of this TMDL.
This section of the document provides a preliminary discussion of several of these issues.
7.2 FACA Report
EPA believes the metals contamination in the CDA basin meets the description of "Impairments
Due to Extremely Difficult Problems" in the Report of the Federal Advisory Committee on the
TMDL Program (FACA Report, EPA, July 1998). The clean-up of abandoned mine wastes in
the Coeur d'Alene is certainly "technically and/or practically very difficult and extremely costly."
The report makes several recommendations for design and implementation of TMDLs for
"special challenge sources", notably the following:
"The Committee recommends that, where necessary, a TMDL implementation plan
involving special challenge sources allow a relatively longer timeframe for water quality
standards attainment. Different timeframes for implementation of (waste)load allocations
may be needed for special challenge vs. existing sources. For example, existing sources
may be required to achieve necessary load reductions quickly (i.e., witliin a compliance
48
-------
schedule in a 5-year NPDF.S permit), even if achieving prescribed load reductions for
these historic sources is anticipated to take longer. In such a situation, the state may
consider relying more on a phased (or iterative) TMDL approach, in which expected
loading reductions from special challenge sources over the long-term are factored in when
establishing short-term allocations for permit limits for point sources," (FACA Report,
page 42).
In the CDA basin TMDL, EPA believes that most of the waste piles and eroded tailings in the
bed and banks of the basin rivers can be viewed as "special challenge sources." EPA has begun
to address the contamination by establisliing specific allocations for discrete point sources in the
basin EPA does not currently possess the necessary information to establish specific allocations
for the waste piles and nonpomt (bed and banks) sources. However, these sources are currently
the subject of the Superfund RI/FS for the basin.
7,3 Coordination of Clean Water Act and Superfund Authorities
EPA has explored a conceptual framework to effectively use its authorities under the CWA and
CERCLA in the CDA basin, EPA proposes to issue NPDES permits that incorporate the TMDL
wasteload allocations to operating NPDES facilities in the basin, including mining facilities and
municipal sewage treatment plants. In the meantime, further study and identification of other
sources can proceed in the Rl/FS, culminating in a Record of Decision (ROD) that will identify
the plan for clean-up of waste piles, inactive adits, and tailings in the river bed and banks.
Figure 7-1 displays conceptually how EPA plans to coordinate CWA and CERCLA authorities
such that they essentially support one another as both processes unfold. The narrative below
corresponds to the 13 points in the chart and provides a brief explanation of important steps in
both processes.
1. Water Quality Standards
As described in this document, water quality standards form the basis of the TMDL and are goals
for CERCLA actions (see also discussion of "ARARs" under "Feasibility Study" below).
2. Remedial Investigation fRl )
Under CERCLA, an RI may be performed to determine the nature and extent of contamination in
a particular area. This normally entails a review of existing data and collection of additional
information to fill in data gaps. The RI will examine all environmental media (e.g., surface
water, soils, groundwater), evaluate risks to human health and ecosystems, and identify specific
sources of pollution. The TMDL Technical Support Document is anal ago us to the Rl, albeit with
a narrowed focus on surface water quality and no risk analysis. Some of the information
gathered to support the RI was used in the development of the TMDL.
49
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The RI will also generate 'risk-based' cleanup levels, and these cleanup levels may apply to
dissolved metals in the water column. The development of risk based cleanup levels may
employ laboratory and field methods that are similar to those used to develop site-specific criteria
under the CWA.
3, Total Maximum Daily Load (TMDL)
Described in this document .
4. Feasibility Study (FS)
The FS will develop remedial goals based on the risk assessments and will also identify
Applicable or Relevant and Appropriate Requirements (ARARs). ARARs are cleanup standards
or other requirements specified in state and federal laws. Actions taken under CERCLA must
comply with ARARs unless they are explicitly waived. As shown in the flowchart, the TMDL
provides information for consideration in the ARAR identification process. The FS will develop
a range of remedial action alternatives and then, for each alternative, evaluate the feasibility of
meeting remedial goals according to 7 criteria, including compliance with ARARs, protection of
human health and the environment, implementability and cost. Two additional criteria, state and
local acceptance, will be evaluated in the ROD, after comments on the RI/FS and proposed plan
have been received. Treatability studies may be conducted to support evaluation of remedial
alternatives.
5- NPDBS Permits
A number of sources of pollution in the CDA basin are sources with existing NPDES permits,
issued pursuant to the CWA. These sources include three operating mines (Lucky Friday,
Coeur/Galena and Sunshine), three inactive mines (Caladay, Consolidated Silver, and
Star/Morning) and several municipal wastewater treatment plants (Mullan, Page, SmelterviUe,
Hayden, Post Falis, and Coeur d'Alene). Once a TMDL has been established, EPA will begin
developing NPDES permits for the operating mines and municipalities along the South Fork.
The schedule for issuing the South Fork municipal permits will be coordinated with any variance
actions. The appropriate approach to address all inactive mine adits will be evaluated in the
RI/FS process. Decisions on next steps to implement the TMDL for these adits will be made in
the Superfund Record of Decision.
It is possible that final NPDES permits will include compliance schedules to allow operators a
specified time to install the necessary treatment or water management measures to meet the new
permit limits. Variances may be considered on a case-by-case basis.
50
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Integrating CWA and CERCLA in the Coeur D'Alene Basin
Clean Water Act - TMDL - NPDES Permits®
TMDL
I©
--
Operatlng
Source? J Vm
Public Notice
Draft NPDES
Permit
Final NPDES
Permits
with CompUanca Schedules
Modify
Permits?
Loading
Capacity
Roach 1
B. Ir Ravi
TMDL
nalysl
Loading
Capacity
Raach 2
Draft
Implemen-
tation
Plan
Final
Imolemen-
tlon
Plan
Other
NPDES
Permits?
Loading
nalyals
Reach
,\-'
<\S> V :
Flow +
Loadings!-!
(Zrt, Pb, Cd) X
ARARs
Development
a
Analysis of
Cleanup
Alternatives
Record
of
Decision
Surface Water
Remedial
Activities
Sediments
Remediation
Goals
Ecological
IK
Groundwater
Institutional
Controls
Remedial Investigation
Feasibility Study
Priority Removal Actions
:CERCLA - RI/FS
Figure 7-1 Coordinating Clean Water Act and CERCLA Activities
51
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6 & 7 CBRCLA Feasibility Study and TMDL Implementation Analysis
The FS and TMDL Implementation Analysis are focused on the same question: how, and on
what schedule, will source reductions and other control measures he achieved to meet
environmental goals? The TMDL plan is focused on surface water quality, while the FS is
broader in scope, addressing other media in addition to surface water (and potentially other
surface water pollutants, such as other metals, nutrients, etc.). Thus, the TMDL implementation
analysis draws upon the data and analysis in the RI/FS,
A consistent, informed understanding of the feasibility and scheduling of pollution controls will
require strong interagency coordination to ensure sharing of information between
state/federal/local agencies.
8. Possible TMDL Revisions
The TMDL can be revised in the future to reflect new information (such as information from the
RI/FS process) and/or changes to water quality standards. Any revisions to the TMDL would be
subject to public comment.
9. Record of Decision f ROD)/Final TMDL Implementation Plan
The outcome of coordinated CERCLA and CWA activities is a coordinated ROD and TMDL
Implementation Plan that are fully consistent and complementary. The TMDL Implementation
Plan may be one component of the broader ROD document. Both the TMDL Implementation
Plan and ROD are public documents that explain which cleanup alternative(s) will be used to
meet specific remediation goals. Both documents are based on a common information base and
teclmical analysis generated during the RI/FS study, taking into consideration public comments
and community concerns.
10. Remedial Actions
Following a Remedial Design stage (not shown), implementation of the remedial actions
specified in the ROD and TMDL Implementation Plan should begin.
11. Institutional Controls
In some cases, 'institutional controls' are necessary to help meet the remediation goals. An
example of an institutional control would be a local zoning ordinance prohibiting excavation in
potentially contaminated areas. Institutional controls must be evaluated as other remedial
alternatives prior to inclusion in a ROD and implementation following Remedial Design.
52
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12.
Other NPDES Permit Actions
Throughout the RI/FS and CWA processes, other previously unpermitted point sources of
pollution that need NPDES permits (e.g., unpermitted adit discharges, waste pile seeps) may be
identified. Also, if the TMDL wasteload allocations are revised, the corresponding NPDES
permit limitations may be modified during the five year permit term.
13. Priority Removal Actions
Throughout the RI/FS and CWA processes, it is envisioned that priority removal actions may be
conducted in the CDA basin, as deemed necessary to protect the public health or welfare or tlie
environment. To the extent practicable, such removal actions would contribute to the efficient
performance of any anticipated long-term remedial actions in the CDA basin.
7.4 Preliminary Assessment of Feasibility
EPA has explored the feasibility of whether individual sources that currently exceed the
wasteload allocations can achieve compliance with assigned loadings. EPA's Superfund
program has evaluated the feasibility of the TMDL allocations for the Bunker Hill Central
Treatment Plant (CTP) in Kellogg. On behalf of EPA, CH2M Hill has analyzed the hydraulic
characteristics of the Bunker Hill mine and a number of alternatives to reduce metals loadings to
the levels required in the draft TMDL, including: source control to reduce water entering the
mine workings, in-mine storage of untreated and/or treated wastewater when necessary to meet
TMDL allocations, and wastewater treatment using a variety of technologies. Based on the
analyses completed to date, EPA is optimistic that the CTP can achieve the TMDL allocations
using conventional pollution control technologies. While EPA requested comments on
feasibility from other sources in the basin, no information comparable to the Bunker Hill CTP
study has been received to date.
Many mining projects have historically used hydroxide precipitation to treat wastewaters for
metals removal prior to discharge. For example, hydroxide precipitation is currently employed at
the Bunker Hill CTP. Work to date at the CTP indicates that this technology, combined with
filtration and used in conjunction with mine water storage measures, may be sufficient to meet
the TMDL. Figure 7-2 shows theoretical lowest residual metal concentrations that can be
achieved by hydroxide precipitation.
Sulfide precipitation, which can be used in concert with hydroxide precipitation, offers
advantages due to the high reactivity of sulfides with heavy metal ions and the very low
solubilities of metal sulfides over a broad pH range. As shown in Figure 7-2, metal sulfides have
much lower solubilities than metal hydroxides. For example, at the Red Dog Mine in Alaska, a
sulfide precipitation and filtration system has been installed to treat effluent with high metals
levels to concentration ranges similar to levels specified in tliis TMDL. Laboratory treatability
53
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work tu date at the CTP indicates that sulfide precipitation is an effective add-on to the existing
hydroxide precipitation system By bringing effluent metals concentrations lower than can be
achieved by hydroxide precipitation alone, sulfide precipitation reduces the reliance oil mine
water storage measures to meet the effluent limits based on the TMDL.
For municipalities along the South Fork, information collected as part of the TMDL and NPDES
permit development process indicates that the primary source of metals to these systems is
infiltration of groundwater contaminated by tailings material to the collection systems. EPA
expects that, at a mimmuni, a long term effort to maintain or replace portions of the sewage
collection systems at these facilities will be needed to achieve the TMDL allocations. These
collection system improvements will also put the facilities in a better position to operate nutrient-
control technology in the future if needed. Because of the potential costs to local communities of
remedies to reduce metals in the municipal discharges, variances from state water quality
standards may be appropriate and necessary for these facilities (variances are discussed in further
detail in the Response to Comments document for the TMDL).
EPA recognizes that abandoned mine projects present significant challenges in designing and
implementing remedial/treatment measures. For many of these projects it may not be feasible or
practical to design and construct an active wastewater treatment facility, especially in remote
locations. In other cases, other source control measures (e.g., capping a waste pile or plugging an
adit) may be feasible.
7.5 Other TMDL Issues
Reasonable Assurance
When wasteload allocations are established under the assumption that nonpoint source
contributions will be reduced, a TMDL must provide "reasonable assurance" that nonpoint
source reductions will be implemented.
54
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T3
1
O
(A
OT
'S
"5
c
o
?
2
+*
c
0)
o
c
o
o
1 .00 E + 03
Pb OH 2
1.00E + 02
n(OHi)2
1 .00E + 01
AgO H
Cu(6H)2
N j (0 H )2
Cd (0 H)2
1 .00E + 00
1 .00E -01
1 .00 E -02
1 .00E-03
1 .00 E -04
1 .00E-05
1 .00E-06
1 .00E-07
1 .00E-08
1 .OOE -09
1 .00 E -1 0
1 .OOE -1 1
1 .OOE -1 2
1 OOE -1 3
7
pH
10 11
12 13
1 4
Figure 7-2 Solubility of Metal Hydroxides and Sulfides
55
-------
F.PA is currently conductinc a Remedial Investigation/Feasibility Study (RI/FS) for the Coeur
d'Alene River Basin pursuant to authorities under the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), 42 U.S.C. § 9601 et. seq. EPA has authority under
CERCLA to conduct an Rl/FS for an area regardless of whether releases of hazardous substances
in the area are included on the National Priorities List (NPL). If releases in an area are not
included on the NPL, EPA ordinarily has authority to spend up to $2 million from the Superfund
trust fund to conduct discrete removal actions in that area. If releases are included on the NPL,
EPA has broader authority to draw from the Superfund trust fund for financing remedial actions
in that area following completion of an RI/FS. However, EPA ordinarily seeks funds from the
Superfund trust fund only if potentially responsible parties are unable or unwilling to perform or
finance the response actions themselves. Through litigation filed in March 1996, tlie U.S.
Department of Justice, on behalf of EPA and other federal agencies, is seeking a declaration that
several mining company defendants are liable for past and future response costs caused by
releases of hazardous substances in the Coeur d'Alene Basin. EPA also retains administrative
authority under CERCLA to issue orders compelling parties to undertake response actions to
address releases that may present an imminent and substantial endangerment to public health,
welfare, or the environment. Tlirough removal and remedial actions funded by potentially
responsible parties and the Superfund trust fund, EPA's Superfund program has been actively
addressing releases of hazardous substances in the Coeur d'Alene Basin. These continuing and
anticipated activities may reasonably be expected to continue in the future, resulting in
substantial reduction of discharges from non-point sources into the Coeur d'Alene River and
tributaries, Coeur d'Alene Lake, and Spokane River.
Anti-degradation
Idaho's water quality regulation contains anti-degradation requirements pertinent to certain
waters in this basin. This regulation provides that where a waterbody exceeds the quality
necessary to support designated uses, the existing quality shall be maintained and protected
unless the State makes a formal finding that lowering of water quality is needed to accommodate
important economic or social development.
While large portions of the CDA basin surface water network contain metals concentrations well
in excess of the water quality criteria, there are also a number of waters within the CDA basin
with metals concentrations well below the water quality criteria. In particular, metals levels are
low within the North Fork sub-basin and numerous small tributaries to the South Fork and
mainstemCDA that are not influenced by mining activity. A State of Idaho anti-degradation
analysis and decision is required before activities that lower water quality (i.e., elevate metals
levels in the receiving water) can proceed in these areas.
56
-------
7.6 Development of Site-Specific Criteria
This TMDL is established to achieve the currently applicable water quality criteria for CDA
basin waters in the Idaho water quality standards. EPA and the state of Idaho recognize that site-
specific criteria (SSC) for lead, zinc and cadmium may be appropriate for the South Fork to
reflect the specific characteristics of the river and the sensitivity of the resident cold water biota.
In 1993, DEQ began efforts to develop SSC for the South Fork between Daisy Gulch and Canyon
Creek (8 mile study section upstream of Wallace). DEQ intends to complete tliis work and adopt
SSC for this section of the river. The SSC will be submitted to EPA for approval.
The spatial extent of an SSC is critical to its application in regulatory actions. For example, the
SSC for the Wallace segment would have no practical effect on the TMDL allocations, because
statewide water quality criteria would still apply in the impaired segments immediately
downstream of the Wallace segment. Meeting these downstream criteria would require the same
calculations and wasteload allocations in the TMDL. On the other hand, establishing an SSC for
the entire South Fork mainstem from Pinehurst to the headwaters (i.e., moving the point of
application of the statewide criteria to the mainstem Coeur d'Alene River) could have an effect
on the TMDL allocations. This is because statewide criteria could be achieved in the mainstem
Coeur d'Alene River after dilution of metals (in excess of the statewide criteria) in the South
Fork by the relatively clean North Fork.
Development of SSC for the entire South Fork would require an analysis based on differences in
biological community structure and water chemistry (hardness, etc) downstream of Wallace.
Tins work has not been funded by the state or mining companies to date. Even if the testing and
analyses indicate a substantially higher tolerance in resident species for dissolved metals, the
regulatory relief provided by such an SSC would be limited by the available dilution from the
North Fork.
The mining companies and State currently have no plans to establish SSC for cadmium. This is
because the SSC work to date indicates that resident species are sensitive to cadmium
concentrations in the range of the statewide criteria.
In the future, DEQ intends to adopt SSC based ou biological end points that reflect the existence
of a healthy, balanced biological community (full support of uses) in the South Fork. Water
quality, including levels of metals, that exists when the biological endpoints are met will be used
by DEQ to develop alternative SSC for lead and zinc.
8.0 DATA MANAGEMENT AND SOFTWARE APPLICATIONS
EPA directed its contractor, IJRSG, to incorporate the water quality and point source datasets
described in Table 5-1 into a relational database (Oracle®) for use in both TMDL and Rl/FS
analyses. For certain large data sets (e.g., PCS, USGS flows), a subset of the data was loaded
57
-------
into the database. Fur example, three years of data for the three metals of concern was
downloaded from PCS and incorporated into the database.
A number of Geographic Information System (GIS) coverages were used to generate the detailed
maps of the upper basin in this report. The relational database contains the necessary location
information to generate maps of station and source locations. The routines employ ARCVIEW®
coding.
TMDL allocations and other measures were calculated using EXCEL® spreadsheet applications
designed for the Coeur d'Alene TMDL. Copies of the spreadsheets used for the TMDL are
included on diskette in the Administrative Record for the TMDL.
9.0 REFERENCES
Barenbrock, C. 1998. Persona] Communication. United States Geological Survey, Spokane
Washington.
CH2M Hill. April 2000. Technical Memorandum: Draft Determination of Background
Concentrations (including updates/corrections in electronic message from Don Heinle
to EPA dated 07/28/00)
CH2M Hill. February 2000. Phase 1 Testing Results: Bunker Hill Mine Water Treatability
Study, Kellogg, Idaho.
CII2M Hill. February 2000. Final Report: Hydrologic Evaluation for Bunker Hill Mine TMDL
Compliance. Bunker Hill Mine Water Management, Kellogg, Idaho.
CH2M Hill. July 2000. Technical Memorandum: Bunker Hill Water Treatability Study;
Phase 2B Work Plan
CH2M Hill, February 2000. Technical Memorandum; Bunker Hill Water Treatability Study;
Phase 2A Work Plan.
CH2M Hill. January 2000. Technical Memorandum: Phase 2 Treatability Test Approach;
Bunker Hill Mine Water Management.
CH2M Hill. January 2000. Technical Memorandum: Bunker Hill Mine Water Treatability
Study; Phase 1 Follow-up Testing Results.
CH2M Hill. December 1999. Technical Memorandum: Bunker Hill Mine Water Treatability
Study; Summary of Phase 1 Results to Date.
58
-------
CH2M Hill. September 1999. Technical Memorandum: Addendum: Bunker Hill Mine Water
Treatability Study Work Plan.
CH2M Hill. July 1999. Bunker Hill Mine Water Treatability Study Work Plan.
Environmental Protection Agency. 1997. Idaho TMDL Development Schedule, EPA Review
and Evaluation.
Environmental Protection Agency. 1991. Guidance for Water Quality-based Decisions: The
TMDL Process. EPA 440/4-91 -001.
Environmental Protection Agency. 1996 The Metals Translator: Guidance for Calculating a
Total Recoverable Permit Limit from a Dissolved Criterion. EPA 823-B-96-OQ7.
Falter, CM. December 1999. Rebuttal to Expert Report of Thomas F. Pederson and Eddy C.
Carmack (U.S. vs. ASARCO, No. CV96-0122-N-EJL).
IDHW-DEQ. 1999. Letter of February 26, 1999, from DEQ Administrator C. Stephen Allred to
EPA Region 10 Administrator Chuck Clarke.
Maest, Heinle, Marcus, Ralston. 1999. Expert Report: Release, Transport, and Environmental
Fate of Hazardous Substances in the Coeur d'Alene River Basin, Idaho. Appendix C:
Determination of Baseline Concentrations of Hazardous Substances in Surface Water.
Maest, Lejeune, Cacela. January 2000. Rebuttal to Expert Report of Donald D. Runnells, PH.D.
(U.S. vs. ASARCO. No. CV96-0122-N-EJL).
Maest. December 1999. Rebuttal to Expert Report of Thomas F. Pedersen and Eddy C.
Carmack, PH.D. (U.S. vs. ASARCO. No. CV96-0122-N-EJL).
McCulley, Frick, and Gillman (MFG). 1992. Upstream Surface Water Sampling Program, Fall
1991 Low Flow Event, South Fork Coeur d'Alene River Basin above the Bunker Hill
Superfund Site.
McCulley, Frick, and Gillman (MFG), 1991. Upstream Surface Water Sampling Program,
Spring 1991 High Flow Event, South Fork Coeur d'Alene River Basin above the Bunker
Hill Superfund Site.
Pederson, T.F. and Carmack, E C. October 1999. Expert report: The physical and geochemical
status of the waters and sediments of Coeur d'Alene Lake, Idalio: A critical review
Runnells, D. November 1999. Expert Report of Donald D. Runnells, United States v. Asarco
Luc, et al (No. CV 96-0122-N-EJL)
59
-------
SAIC, 1998. Draft Review of liSGS Limnology Study of Coeur d'Alene Lake and Effects to the
TMDL for the Coeur d'Alene Basin.
SAIC, 1998. Technical Feasibility of Reducing Zinc, Lead, and Cadmium to Microgram per
Liter Levels in Mining Wastewaters.
United States Geological Survey (Woods and Beckwith). 1997. Trace-Element Concentrations
and Transport in the Coeur d'Alene River, Idaho, Water Years 1993-94.
United States Geological Survey. 1997. Nutrient and Trace-Element Enrichment of Coeur
d'Alene Lake, Idaho. Prepared in cooperation with the Idaho Department of Health and
Welfare, Division of Environmental Quality, and the Coeur d'Alene Tribe. U.S.
Geological Water-Supply Paper 2485.
United States Geological Survey (Balistrieri). 1998. Preliminary Estimates of Benthic Fluxes of
Dissolved Metals in Coeur d'Alene Lake, Idaho. Open-File Report 98-793.
United States Geological Survey. 1997. Nutrient and Trace-Element Enrichment of Coeur
d'Alene I^ake, Idaho. Prepared in cooperation with the Idaho Department of Health and
Welfare, Division of Environmental Quality, and the Coeur d'Alene Tribe. U.S.
Geological Water-Supply Paper 2485.
URS Greiner and CH2M Hill (URSG). 1998. Draft Field Sampling Plan and Quality Assurance
Project Plan Addenda for the Bunker Hill Facility/Coeur d'Alene Basin, Shoshone
County, Idaho; Addenda 04, Adit Drainage, Seep, and Creek Surface Water Sampling;
Spring 1998 High flow Event.
URS Greiner and CH2M Hill (URSG). 1998. Field Sampling Plan Alterations for Adit
Drainage, Seep, and Creek Surface Water Sampling; Spring 1998 High Flow Event;
Bunker Hill Facility/Coeur d'Alene Basin Project, Shoshone, County, Idaho.
URS Greiner and CH2M Hill (URSG). 1997. Field Sampling Plan and Quality Assurance
Project Plan Addenda for the Coeur d'Alene River Basin (Bunker Hill Facility) Project,
Shoshone County, Idaho; Addenda 02, Adit Drainage, Seep, and Creek Surface Water
Sampling.
Washington Department of Ecology. 1998. Cadmium, Lead, and Zinc in the Spokane River,
Recommendations for Total Maxium Daily Loads and Waste Load Allocations.
Publication No. 98-329.
Wasliington Department of Ecology. 1996. Total Maximum Daily Load Development
Guidelines. Pubication No. 97-315.
60
-------
Woods, P. 1999. Personal Communication. United States Geological Survey, Boise, Idaho,
Woods, P. 2000. Personal Communication. United States Geological Survey, Boise, Idaho,
61
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TECHNICAL SUPPORT DOCUMENT
APPENDICES
Total Maximum Daily Load for Dissolved Cadmium,
Dissolved Lead, and Dissolved Zinc in Surface Waters
of the Coeur d'Alene Basin
FINAL
August 2000
U.S. Environmental Protection Agency, Region 10
1200 Sixth Avenue
Seattle, WA 98101
Idaho Department of Environmental Quality
1410 North Hilton
Boise, Idaho 83706
-------
Table of Contents
APPENDIX A: SOUTH FORK COEUR DALENE RIVER MAPS
APPENDIX B: LOCATION KEY FOR COEUR D ALENE RIVER MAPS
APPENDED C: DESCRIPTION OF WATER QUALITY DATA
APPENDIX D: ALLOCATION ALTERNATIVES
APPENDIX E: DERIVATION OF AVERAGE SOURCE FLOWS
APPENDIX F : METALS FLUXES FROM COEUR DALENE LAKE SEDIMENTS
APPENDIX G : FATE AND TRANSPORT OF SURFACE WATER METALS
APPENDIX H : TMDL CALCULATION SPREADSHEETS
APPENDIX I: HARDNESS DATA
APPENDIX J : TRANSLATOR DATA
APPENDIX K : TMDL FEASIBILITY AT THE BUNKER HELL CIP
APPENDIX L : RIVER FLOW REGRESSIONS
-------
APPENDIX A: SOUTH FORK COEUR D'ALENE RIVER MAPS
-------
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-------
APPENDIX B: LOCATION KEY FOR COEUR D'ALENE RIVER MAPS
-------
Canyon Creek Station Locations
Location ID Location Type Location Description
1 RV Canyon Creek, just below outlet from domestic water supply
2 RV Canyon Creek above Gorge Gulch and downstream from Gertie Mine.
15 RV Canyon Creek, downstream from GEM, at wooden bridge.
17 RV Canyon Creek, near separation of Hecla upper tailings ponds
19 SP Star-Hecla tailings pile (seep at culvert)
20 SP Star-Hecla tailings pile seep that drains into open field.
23 RV Canyon Creek, near mouth, at Frontage Road bridge.
272 RV Canyon Creek, upstream of source areas and Humboldt Gulch.
273 RV Canyon Creek, bridge at 0,35 miles from dam
274 RV Canyon Creek, 0.5 miles upstream of Gorge Gulch.
276 RV Canyon Creek, above Hecla Portal, at walkway cross-over.
277 RV Canyon Creek, at bridge below Hecla Star Mine and Mil site.
278 RV Canyon Creek above Cornwall at Highway 4 bridge.
279 RV Canyon Creek, upstream of Tamarack No. 7.
280 RV Canyon Creek downstream of Tamarack No. 7.
281 RV Canyon Creek at Frisco Mine bridge.
282 RV Canyon Creek, at Whites Bridge
283 RV Canyon Creek, above Hecla-Star tailings ponds and Canyon Silver Formosa Adit
284 RV Canyon Creek, above Hecla-Star tailings ponds.
285 RV Canyon Creek at Grays Bridge.
286 RV Canyon Creek, below Hecla-Star tailings pond.
287 RV Lower Canyon Creek, below Woodland Park.
288 RV Canyon Creek, near mouth at Frontage Road bridge north of 190.
289 RV Canyon Creek upstream of sources and Military Gulch.
290 RV Canyon Creek, 0.2 miles upstream of Gorge Gulch.
291 RV Canyon Creek downstream of Tamarack No. 7.
353 AD Hercules #5 Mine
354 AD Hidden Treasure
355 RV Gem No. 3/GEM-1
356 AD Canyon Silver-Formosa
357 SP Woodland Park Area
371 AD Blackbear Fraction
372 AD
373 AD Anchor
392 RV Gorge Gulch, near confluence with Canyon Creek.
695 RV 2.75 river miles upstream of Canyon Creek confluence with South Fork.
699 RV 1.25 river miles upstream of Canyon Creek confluence with South Fork.
702 RV 4 river miles upstream of Canyon Creek confluence with South Fork.
705 RV 1.75 river miles upstream of Canyon Creek contfuence with South Fork.
800 OF Canyon Creek 200 yd above SF Coeur d AJene river
801 OF Canyon Creek above Gorge Gulch at Gertie Mine.
802 OF Canyon Creek at Burke Water Supply Dam (east of Burke).
811 OF Star Outfall 001A, 2 miles Northeast of Wallace.
812 OF Unknown supplemental monitoring point at Star Morning Mine.
814 OF Hecla-Star Morning 002B.
817 OF Hecla #3 0.5 miles southwest of Burke
-------
Ninemile Creek Station Locations
Location 10 Location Type Location Description
8
RV
East Nine Mile Creek, 200 yds above confluence with Ninemile Fork.
13
RV
Ninemile Creek, approximately 1.1 miles upstream of mouth.
289
RV
East Fork Ninemile Creek, upstream of Interstate at Callahan Mine/Rock Dumps.
290
RV
Tamarack tributary"
291
RV
East Fork Ninemile Creek upstream of Wilson Creek.
292
RV
Wilson Creek, near confluence with East Fork Ninemile Creek.
293
RV
East Fork Ninemile Creek, 02 miles downstream of Insterstate Mill site.
294
RV
Rex tributary"
295
RV
East Fork Ninemile Creek, 1/4 mile upstream of Success #3 Adit.
296
RV
East Ninemile Creek, 1/4 mile downsteam of Success Mine Rock Dump.
297
RV
East Ninemile Creek, downstream of Succes Mine Rock Dump.
298
RV
East Fork Ninemile Creek 0.3 miles upstream of confluence with West Fork.
299
RV
West Fork Ninemile Creek, 90 yards upstream of confluence with the East Fork.
300
RV
West Fork Nine Mile, at confluence with East Nine Mile
301
RV
Ninemile Creek, north side of culvert under road at Zannetville.
302
RV
Black Cloud Creek, before confluence with Nine Mile
303
RV
Ninemile Creek,Shepenfs Bridge above McCarthy.
304
RV
Nine Mile Creek between cemetary and Sierra Silver tours
305
RV
Ninemile Creek, below RV Park, 0.1 mile upstream of confluence with SF.
359
AD
Success No. 3
360
AD
Interstate-Callahan No. 4
361
AD
Rex No. 2/Goldback Co. Adit Drainage
362
SP
363
SP
Tamarack No. 5 Waste Flock Seep
364
AD
Tamarack 400 Level
365
AD
Sunset Tunnel
366
AD
Tamarack No. 5
367
AD
Day Rock 100
368
SP
Rex Tailings
369
AD
Duluth
370
AD
Silverstar
374
SP
Success Tailings
753
RV
1.25 river miles upstream of Ninemile Creek confluence with South Fork.
757
RV
2.25 river miles upstream of Ninemile Creek confluence with South Fork.
762
RV
3.25 river miles upstream of Ninemile Creek conlfuence with South Fork.
766
RV
4.25 river miles upstream of Ninemile Creek confluence with South Fork.
-------
Pine Creek Station Locations
Location ID Location Type Location Description
305
RV
Pine Creek @ Mouth
306
RV
East Fork Pine Creek -head waters
307
RV
Highland Creek near mouth.
308
RV
Denver Creek, near mouth.
309
RV
Trapper Creek, near mouth.
310
RV
Nabob Creek, near mouth.
311
RV
West Fork Pine Creek near confluence with East Fork.
312
RV
East Fork Pine Crsek upstream from Wast Fork
313
RV
Pine Creek at Main Street bridge, west of Pinehurst, South i
314
RV
Little Pine Creek
315
RV
Pine Creek approximately 1/2 mile upstream of mouth.
322
RV
Upstream Highland Creek 1; east tributary
323
RV
Upstream Highland Creek 2; Red Cloud Creek
324
RV
Upstream Denver Creek 1; above Little Pittsburg
325
RV
Upstream Denver Creek 2; above Sydney Mine
326
RV
Nabbob Creek, upstream of Nabob 1300 Level Adit
327
RV
East Fork Pine Creek Downstream of Nabob Creek
329
SP
North Amy
330
AD
Amy
331
AD
Liberal King
332
AD
Lookout
333
AD
Upper Lynch
334
AD
Lynch/Nabob
335
AD
Nevada-Stewart
336
AD
Highland Surprise
337
AD
Sidney (Red Cloud Ck. Adit)
338
RV
East Fork Pine Creek above Highland Creek
339
RV
Pine Creek between PC315 and PC312
340
AD
Upper Little Pittsburg
341
AD
Lower Little Pittsburg
343
AD
Nabob (1300 level)
344
AD
Big It
348
AD
Upper Constitution
351
AD
Marmion Tunnel
352
SP
Below Neveda- Steward
375
SP
Highland-Surprise Waste Rock Pile
400
AD
Upstream of Little Pittsburg
810
RV
1 river mile upstream of Main Street bridge.
812
RV
2 river miles downstream of Main Street bridge.
820
RV
3 river mites down stream of Main Street bridge.
823
RV
4 river miles downstream of Main Street bridge.
829
RV
5 river miles downstream of Main Street bridge.
834
RV
6 river miles downstream of Main Street bridge.
842
RV
7 river miles downstream of Main Street bridge.
845
RV
8 river miles downstream of Main Street bridge.
851
RV
8.75 river mites downstream of Main Street bridge.
857
RV
-------
South Fork Coeur d'Alene River Station Locations
Location ID Location Type Location Description
2
RV
At Smelterville bridge, east of airport
3
OF
{ID0000078 - Bunker Hill Mining Co.) Central Treatment Plant near Kellogg.
10
RV
South Fork CDR, east ol Wallace, above confluence with Canyon Creek.
11
RV
South Fork CDR, above confluence with Ninemile Creek,
12
RV
South Fork COR, at old railroad bridge in Wallace.
15
RV
South Fork COR, above Daly Gulch.
16
RV
South Fork CDR, at private bridge, 3/4 of a mile upstream of Silverlon.
20
RV
Revenue Gufch near mouth.
22
RV
South Fork CDR, near Osbum between Twomile Creek and Nuchols Gulch.
23
RV
Shield Gulch near mouth.
31
RV
South Fork CDR, at roadside stop 1-90,1 mile upstream of Big Creek.
33
AD
100
RV
Bunker Creek between Deadwood and Government Gulch/Gi
101
RV
Bunker Creek between Deadwood and Government Gulch/GI
102
RV
Bunker Creek near Deadwood Gulch
103
RV
Bunker Creek near Magnet Gulch
104
RV
Portal Creek between Deadwood and Government Gulch/GI
107
RV
Flats between Kellogg and Smelterville
108
RV
Grouse Creek along Government Gulch/GI
109
RV
Grouse Creek along Government Gulch/GI
110
RV
Grouse Creek along Government Gulch/GI
183
RV
Milo Creek near confluence to South Fork.
184
RV
Milo Creek upstream of MC*2.
185
RV
Milo Creek upstream of MC-2A and MC-2B.
186
RV
Milo Creek upstream of MC-3.
187
RV
Milo Creek
191
RV
South Fork North of Blue Star Ridge
195
RV
South Fork near Smelterville Rats.
196
RV
South Fork Coeur D'Alene
201
RV
Above Klondike Gulch on South Side of SFCDR
202
RV
Little North Fork
204
RV
Below OBiien Gufch on unnamed creek south side of SFCDR
205
RV
Above Mullan
206
RV
Daisy Gulch
o
CM
RV
Gentle Annie Gulch
208
RV
South Fork CDR at bridge, upstream of Deadman Gulch.
209
RV
Deadman Gulch near mouth.
210
RV
Willow Creek near mouth.
211
RV
Above Boulder Creek on unnamed creek south side of SFCDR
212
RV
Gold Hunter Gulch near mouth.
213
RV
Unnamed creeks between Mill Creek and Gold Hunter Gulch
214
RV
Boulder Creek
215
RV
216
RV
Mill Creek
218
RV
Slaughterhouse Gufch, below Morning No. 6
219
RV
Dry Creek
220
RV
South Fork CDR, below Mullan
221
RV
Gold Creek
222
RV
St. Joe Creek
223
RV
Grouse Gulch
224
RV
Ruddy Gulch
-------
225
RV
Rock Creek
226
RV
Trowbridge Gulch
227
RV
South Fork COR, upstream of Golconda Mine
228
RV
South Fork CDR, above Wallace, fifty yards downstream of railroad bridge.
229
RV
Dexter Gulch
230
RV
Watson Gulch
231
RV
In Weyer Gulch
232
RV
South Fork CDR, downtown Wallace above Nine Mile Creek
233
RV
South Fork CDR, at old railroad bridge in Wallace
234
RV
Placer Creek
235
RV
SF CDR Bridge next to gas station at visitor center west end of Wallace.
236
RV
Placer Creek near mouth.
237
RV
South Fork CDR, Bridge next to old railroad bridge West of Wallace.
238
RV
Lake Creek near mouth.
239
RV
South Fork CDR, Sifverton.
240
RV
Revenue Gulch 100 yards from 190 at Silverton off ramp
241
RV
South Fork CDR, downstream of Silverton and trailer park.
242
RV
Argentine Gulch
243
RV
South Fork CDR, at Galena tailing pile bridge.
244
RV
Shield Gulch before crossing under I 90
245
RV
Nuchols Gulch
246
RV
Meyer Gulch
247
RV
South Fork CDR, halfway between SF 170-and NG 1.
248
RV
Twomile Creek.
249
RV
South Fork CDR, Osbum.
250
RV
McFarren Gulch.
251
RV
Jewel Gulch
252
RV
Terror Gulch.
253
RV
South Fork CDR, below Terror Gulch near bridge.
254
RV
South Fork CDR, 100 feet upstream of Frontage Road, below Little Terror Gulch.
255
RV
Rosebud Gulch
256
RV
Spring Gulch
257
RV
Polaris Gulch
258
RV
South Fork CDR, at roadside stop on I 90 above Big Creek
259
RV
South Fork CDR, west side of I-90 bridge above Big Creek confluence.
260
RV
Big Creek south of Frintage Road bridge.
261
RV
Prospect Gulch
262
RV
Moon Creek at mouth.
263
RV
South Fork CDR, below Big Creek under golf course.
264
RV
South Fork CDR, above confluence with Gold Run Gulch.
265
RV
Gold Run Gulch
266
RV
Montgomery Creek,
267
RV
Elk Creek
268
RV
South Fork CDR, Elizabeth Park.
269
RV
Unnamed creek, downstream of Elk Creek on north side.
270
RV
South Fork CDR, Smeltervtlle.
271
RV
South Fork CDR, USGS Station at EnaviHe.
272
RV
South Fork CDR, at Galena Mine Tailings Pond bridge.
273
RV
South Fork CDR, below confluence with Canyon Creek above confluence Ninemile.
274
RV
South Fork CDR, below Daly Gulch.
275
RV
Kill Creek, 0.6 miles upstream of confluence with South Fork CDR.
316
RV
Upstream Slaughterhouse Gulch 1; above Morning No. 6
317
RV
Upstream Grouse Gulch 1 :east tributary in vicinity of houses
318
RV
Upstream Grouse Gulch 2; below Star Mine
-------
319
RV
Upstream Grouse Gulch 3:below West Star.east tributary
320
RV
Upstream Grouse Gulch 4: above West Star, east tributary
32!
RV
Upstream Grouse Gulch 5; above Star Mine, west tributary
328
SP
Morning No. 6 Waste Rock Pile
338
AD
Snowstorm No. 3
339
AD
Copper King
342
AD
Atlas
345
AD
Morning No. 4
346
AD
Morning No. 5
347
AD
Star 1200 level
349
AD
Grouse
350
AD
Alice
364
SP
382
AD
Silver Dollar
383
AD
St. Joe
384
AD
Coeur D alene {Mineral Point)
385
AD
Unnamed Location
386
AD
Pnnceton-Magna
389
AD
Unnamed Adit
390
AD
Reindeer Queen
392
AD
Rainbow
393
AD
Western Union {Lower Adit)
394
AD
395
AD
Golconda
396
AD
Square Deal
398
RV
Just Below Weyer Gulch Confluence
512
RV
14 river miles downstream of Deadman Gulch bridge.
518
RV
9.5 river miles downstream Deadman Gulch bridge.
536
RV
7.5 river miles downstream of Deadman Gulch bridge.
539
RV
1.75 river miles upstream of Deadman Gulch bridge.
543
RV
12 river miles downstream of Deadman Gulch bridge.
549
RV
17 river miles downstream of Deadman Gulch bridge.
600
OF
(ID0025429/Silver Valley Resources) Caladay Portal/001 A, 1/2 mi. NW of Wallace.
601
OF
(ID0025429/Silver Valley Resoures) Along facility boundary on Daly Gulch.
602
OF
(ID0000027A) Galena 001/001 A, 1 mi. NW of Wallace
603
OF
(ID0000027B) Stream monitoring location SE of Osbum at Osbum Tailings Pond.
605
OF
Adit 1/3 mile SW of Morning Star Mine Dump (ID0000167A/B)
606
OF
Creek in Gold Hunter Gulch various small mines north of Lucky Friday Mine.
607
OF
(ID0000175C) Lucky Friday outfall 001/001A - Tailings Pond #1 below Mullan.
608
OF
(ID0000175B) Lucky Friday Mine Tailings Pond, 1 mile east of Mullan.
609
OF
(ID0000175A) Lucky Friday 0Q3A- Tailings Pond #3 below Gentle Annie Creek.
610
OF
North of Lucky Friday 003A on Gentle Annie Creek near small mining claims.
611
OF
(ID00Q0167A) Morning Portal Raw (002)/Hecla-Star Morning G02A,
612
OF
(IDOOOQ167B) Morning Ditch Outfall 002/Hecla Star Morning Mine.
619
OF
SF Coeur d Alene River near Shoshone Park, east of Larson.
620
OF
(100021300) SFCDSD Page Plant Effluent/001 A-1, Smelterville.
622
OF
(ID0021300) Unknown supplemental monitoring point at Page Plant.
623
OF
(ID0020117) City of Smetterville STP § End of Pipe/Effluent 001 A-1.
624
OF
(ID0000060/ID0000159) Sunshine Mine/Consolidated Silver, effluent outall 001 A.
625
OF
(IDOO0OO6G/IDOOOG159) Sunshine Mine/Consolidated Silver effluent outfall G02A.
626
OF
(ID0000060/ID0000159) Sunshine Mine/Consolidated Silver effluent outfall G03A.
627
OF
(ID0021296) Mullan STP Effluent/001 A
630
OF
Central Impoundmenl Treatment Plant #6 near Bunker Hill CTP.
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APPENDIX C: DESCRIPTION OF WATER QUALITY DATA
WATER QUALITY STUDIES
URSG - Nov. 1997 to Jan. 1998 (Low Flow Sampling)
Low flow sampling was conducted throughout the CDA basin principally along Canyon Creek,
Nine Mile Creek, Pine Creek, and the South Fork of the Coeur d'Alene River. Approximately
120 river channel samples and 45 source discharge samples were collected. Field measurements
were recorded for stream flows, source discharges (adits and seeps), and water quality parameters
(pH, dissolved oxygen, and temperature). Surface water samples at these locations were
analyzed for total and dissolved inorganics, including cadmium, lead, and zinc. Hardness was
determined from calcium and magnesium concentrations. Descriptions were recorded for most
locations to provide information on location proximity to mapped features and landmarks.
Average daily flow rates at several USGS gauging stations were obtained that correspond to the
date range of the sampling events. With a few exceptions, chemical concentrations, flow
measurements, and hardness calculations are available for each location. A total of 12 samples
did not have corresponding flow rates measured due to field conditions.
I mo/""* !*»., 1 AAO /VI2.L i]n _ __
URbG - May 199H (High Mow Sampling)
High flow sampling was conducted at many of the same locations sampled during low flow data
collection. The purpose of this sampling design was to have a set of flows and chemical
concentrations for both low and high flow conditions. A total of 180 river channel samples and
45 source discharge samples were collected. Approximately 50 of the channel samples were
collected in the North Fork of the Coeur d'Alene River. Only one of these 50 samples
corresponded to a previous location sampled during the low flow sampling phase. Otherwise, the
same sampling and measurement pattern was used for this phase of work as previously described
for low flow sampling. A total of 17 samples did not have flow rates to correspond to the
analytical results because of high flows and other field conditions. Appendix B identifies URSG
sampling locations for both the November through January and May sampling events.
MFG - Spring 1991 (High Flow Sampling)
High flow sampling was conducted at many of the same locations sampled by URSG during
1997 and 1998. Approximately 60 river channel samples and 5 source discharge samples were
collected. Field measurements were recorded for stream flow and water quality parameters.
Samples at these locations were analyzed for both total and dissolved inorganics, total suspended
solids, and total dissolved solids. However, hardness was not determined and cannot be
calculated from the analytical results reported.
-------
MFG - Fall 1991 (Low Flow Sampling)
Low flow sampliag was predominantly conducted at tlie same sample locations as the high flow
sampling of May 1991. The sample quantities and sampling design were the same as those used
for the corresponding high flow sampling phase. Similarly, hardness was not determined for this
phase of work.
CH2M Hill - Oct 1996 to Feb. 1998 (Superfund Site Groundwater & Surface Water Data)
Groundwater and surface water sampling was conducted at the Bunker Hill Superfund site
surrounding Smelterville. The site covers a portion of the drainage basin of the South Fork of the
Coeur d'Alene River between Kellogg and Pinehurst Narrows. One river sampling location is on
Pine Creek near its confluence to the South Fork. The majority of the data is attributable to
groundwater sampling across 80 monitoring well locations and eight sampling events targeting
potential source areas. The remainder of the data is attributable to surface water consisting of 52
river channel samples collected primarily in to cations not sampled by URSG or MFG. The
surface water locations are associated with tributary streams near Government Gulch,
Smelterville Flats, and Kellogg. Corresponding field measurements of surface water flow rates
were recorded at only a portion of these sampling locations. Hardness was not measured nor
were calcium or magnesium concentrations for calculation of hardness. Chemical analyses
consisted of dissolved and total inorganics, including cadmium, lead and zinc. Supplemental
descriptions were developed for all new locations to provide information on location proximity
to mapped, features and landmarks. Average daily flow rates at several USGS gauging stations
were obtained that correspond to the date range of the sampling events.
IDEQ - Oct 1993 to Sept 1996 (Surface Water Quality)
Surface water sampling was conducted in the CDA basin, specifically along Canyon Creek, Nine
Mile Creek, Pine Creek, and the South Fork of the Coeur d'Alene River. The sampling intervals
for many locations vary considerably from biweekly to several times a year, but in general span
high and low flow conditions for all locations. Approximately 940 river channel samples were
collected. Field measurements of stream flow rates were recorded for approximately 85% of the
river channel samples. All samples were analyzed for total and dissolved cadmium, lead and
zinc. Hardness was measured for most of the samples. Average daily flow rates at several
USGS gauging stations were also obtained that correspond to the date range of the sampling
events.
USGS - Oct 1998 to Sept. 1999 (Surface Water Quality)
Surface water sampling in the CDA basin at 42 sites on a monthly basis. Field measurements
include flow; hardness; dissolved and total cadmium, lead, and zinc; and nutrients. Spring
sampling included liigh flow event sampling and sampling of a discharge event along climbing
and falling limb of event hydrograph.
2
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APPENDIX D; ALLOCATION ALTERNATIVES
Allocation Alternatives
EPA has evaluated a number of allocation methods for the Coeur d'Alene (CDA) basin. The
filial TMDL incorporates two allocation approaches. The following are some of the approaches
considered by EPA during the development of the TMDL.
Set Wasteload Allocations to Zero
By setting wasteload allocations at zero, the remainder of the loading capacity is set aside in load
allocations for nonpoint sources.
Set Wasteload Allocations to Water Quality Criteria at End-of-Pipe
One way to ensure that point sources do not cause exceedances of the water quality standard for a
toxic pollutant is to establish uniform wasteload allocations at the water quality criterion level.
Effluent-based Criterion
This option is a refinement of the above water quality criteria approach, applicable to the
regulation of metals. The metals criteria for protection of aquatic life are based on hardness,
because the toxicity of metals to aquatic life decreases as hardness increases. Thus, as a river
flows downstream, its loading capacity for metals may increase due to inflows of higher hardness
water, such as effluent discharges with elevated hardness. In determining whether a discharge is
above the criteria, one option is to consider the effect of the effluent hardness on the loading
capacity. Rather than evaluating whether a discharge exceeds the criteria for the receiving water,
the effluent-based criteria (defined as the water quality criteria associated with the effluent
hardness) can be calculated for each discharge to determine whether, on balance, a discharge
diminishes the loading capacity of the receiving water. This method was employed for point
sources along the Spokane River.
Uniform Reductions or Concentration
Another method to allocate the load among sources is to set a uniform pollutant concentration
target or a uniform percent reduction for all sources. The resulting allocations will be easily
developed and understood, but they may not account for variation between sources and spatial
variation in loading capacity.
Available Treatment Technologies
Discharges from many sources in the CDA basin receive no wastewater treatment beyond settling
1
-------
ponds. Cost-effective technologies to remove metals from mining wastewaters are in widespread
use in the industry, and the TMDL can consider treatment performance in setting allocations.
While not specifically used to calculate allocations, EPA considered information about treatment
options to evaluate the wasteload allocations in this TMDL
For waste pile sources, Best Management Practices (BMPs) can significantly reduce metals
discharges. Examples include collection/routing of runoff around metals-laden wastes,
removal/backfill of a waste pile into a nearby mine or into a confined storage area, and isolation
of wastes with capping material. Site-specific information is critical for developing allocations
to specific sources of this kind.
This TMDL does not have the benefit of a comprehensive feasibility study for the CDA basin.
Proposals for treatment of adit and impoundment wastewater can be founded upon site-specific
information and understandings from relevant literature. For the waste piles and nonpoint source
discharges, however, judgments on the feasibility of achieving loading reductions carry a Iiigh
uncertainty because of the difficulty in quantifying source characteristics and expected
reductions.
Gross Allocation and Within-Category Refinement
Because of the number of sources in the upper part of the basin, a multi-step allocation method
was considered appropriate for the CDA basin. For example, a "gross allocation" was
established for a general class of sources (e.g.f '"waste piles and nonpoint sources"). This gross
allocation can then be divided into individual allocations (e.g., 3 lbs/day lead allocated to "Blue
Mountain Mine Wasterock Pile 2 A") using an allocation scheme tailored to that source category.
Using a Characteristic Feature
Another option for allocation to a category of sources is to find a characteristic feature of the
source that directly affects its loading. The allocations can then be developed using a "use ratio"
based on this characteristic feature. For example, the loading capacity of a river for dioxin can
be allocated to pulp mills based on the relative production rate (tons/day of pulp) of each mill.
This achieves a reasonable and equitable allocation if sources are similar and there is a direct
relationship between the pollutant discharge and production rate. Another characteristic feature
that can be used to develop a use ratio is effluent flow. Dividing the available capacity by the
total effluent flow, a ratio (lbs/day of pollutant per unit flow) can be multiplied by each discharge
flow rate to establish individual allocations. This method was used for point sources along the
Coeur d'Alene River and tributaries.
Effluent Trading for Refinement of Allocations
"Effluent Trading" is an umbrella term to describe a number of new, innovative approaches to
allocate pollutant loads among sources. EPA has not issued final guidance or regulations on
2
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acceptable trading mechanisms. Nevertheless, public interest in trading is high and pilot projects
(many supported by EPA) are underway throughout the country. An attractive aspect of most
effluent trading approaches is the opportunity provided to dischargers and communities to
participate directly in developing cost-effective solutions to a water pollution problem.
3
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APPENDIX E: DERIVATION OF AVERAGE SOURCE FLOWS
The allocations for each discrete source were determined oil the basis of actual, average flow data
for the discharge. To the extent practicable, data was obtained over similar time frames. Flow
data were compiled from the following sources:
1. Facilities with NPDES permitted discharges are required to submit Discharge Monitoring
Reports (DMRs) which usually include monthly average and maximum flows. These data are
then entered into EPA's Permit Compliance System (PCS). PCS data used for the TMDL were
downloaded for the period from January 1994 to June 1998. For most locations, both average
and maximum flows were reported, and an average of the average monthly flows was used for
the TMDL allocations. For the sewage treatment plants at Mullan and Page and the Sunsliine
mine, only the maximum flows were reported. The averages of the maximum values were used
to calculate the allocations for these facilities.
2. McCully, Frick and Gillman, Inc. (MFG) conducted two sampling events during 1991,
intended to evaluate river contaminant levels during high flow and low flow periods.
3. URSG conducted similar, but more thorough, sampling events in November 1997 and May
1998. This study included adits and seeps which were known to discharge. Many sources were
sampled during only one event. Some of the sources were not included in the initial sampling
plan while others were sampled only once due to inaccessibility or inability to locate the source
during one of the events.
4. EPA inspection data from March 1998 that provides flow information for some of the NPDES
permitted sources.
The following sections describe source flow data compiled by target site.
Canyon Creek (Above Target Site CC288)
The discharge from the Star/Phoenix Tailings Ponds (CC816), also referred to as Star/Morning
and Star-Hecla tailings, is permitted as Outfall 001 under the same NPDES permit as
Star/Morning (Outfall 002 above). Flow data were taken from PCS and each of the two MFG
sampling events. The Woodland Park Area Seep (CC357) is an unpermitted seep from these
tailings wliich was sampled by MFG in 1991, but no flow was recorded. URSG reported a flow
iu May of 1998, which was used for tlie allocation.
The unpermitted discharge from the Gem #3 adit (CC355) was sampled in each of the MFG
events and the May 1998 URSG sampling. Because URSG found the site dry in November
1997, a value of zero flow was averaged with tlie other tliree flows for this site. One URSG and
two MFG flows were averaged for the Tamarack #7 Adit (CC372).
1
-------
The Hercules Mine Portal #5 (CC353) allocation was based on the average of four flows,
including one zero value because the adit was dry during the November 1997 URSG sampling
event.
The Hidden Treasure adit (CC354) was sampled by URSG in November 1997 and found dry in
1998. A zero value was used for the 1998 event to determine an average for the two sampling
events.
The Hecla #3 discharge at Burke (CC817) was not included in either URSG or MFG studies but
was sampled during EPA inspections in 1996 and 1998. Row was only recorded during the 1998
sampling (note also that this was a visual estimate rather than a direct measurement), so that
value was used for the allocation. Other adits on Canyon Creek were each sampled once by
URSG and those flows were used for the allocation.
The Tiger/Poorrnan adit was not included in either URSG or MFG studies but was sampled by
DEQ in July 2000. The single flow estimate obtained during this sampling was used for the
allocations.
Ninemile Creek (Target Site NM305)
Several unpermitted discharges occur at the Interstate Callahan mine and mill site. The waste
rock discharge (NM362) was sampled during both events by URSG and MFG and the flow was
averaged from the four values. The tailings seep (NM363) was sampled by URSG during both
sampling events, but flow during the 1997 event was reported as insignificant so the 1998 value
was used for the allocation. Two flows for the adit (NM360), obtained by URSG, were averaged
to obtain the value used for the allocation.
The Tamarack 400 Level (NM364) flow was reported as "insignificant" in November 1997 and
measured in May 1998, so a zero value was used for the 1997 sample to determine an average for
the two sampling events. Both the Success #3 (NM359) and Success Tailings (NM374) were dry
in 1997 so a zero value was averaged with the May 1998 values. The remainder of the flows on
Ninemile Creek were determined from URSG measurements, and were either the average of two
values, or a single sample value.
South Foiic (At Wallace, Target Site SF233)
There are two NPDES permitted facilities upstream from the Wallace target site on the South
Fork above the Canyon Creek confluence. The Lucky Friday Mine has three outfalls. No data are
available for Outfall 002 which has not recently discharged. Data for Outfall 001 (SF607) was
obtained from PCS Flow data tor Outfall 003 (SF609) was taken from DMRs for January 1996
to March 1998. Handwritten entries in a logbook, apparently belonging to the mine operator,
Hecla, were used for data from December 1994 through January 1995. Additional Outfall 003
flow data were obtained from IDEQ for July, 1990 and November, 1991.
2
-------
Heela holds an NPDES permit for the Star/Morning mine. Die permit authorizes discharges
from Outfall 001 into Canyon Creek (discussed in next section) and from Outfall 002 into the
South Fork (from a waste rock pile). The source of water from the waste rock pile includes flow
from the Morning No. 6 Portal. Flow data for the waste rock pile discharge (Outfall 002) was
taken from PCS monthly averages and both MFG and URSG sampling events.
The Golconda and Square Deal Adits (SF395, SF396) were sampled during both URSG
sampling events and the average of the two flows was used. The remaining adits in this stretch
were sampled once each during the URSG sampling events, and these flow values were used for
the allocations.
PCS data was used to determine the average flow for the Mullan Wastewater Treatment Plant.
Pine Creek (Target Site PC31S)
All locations on Pine Creek were sampled only by URSG and are either an average of two values
where available, or the actual flowrate where only one measurement was obtained.
South Fork (at Pinehurst, Target Site SF271)
The following information applies to facilities contributing metals to the South Fork between
Pinehurst and Wallace.
Sunshine Precious Metals holds NPDES permits for the Sunshine mine and Consolidated Silver
mine. The Sunshine mine permit includes three NPDES permitted discharges on the South Fork
or its tributary, Big Creek. Sunshine is conducting a Supplemental Environmental Project,
pursuant to a consent order, that includes elimination of Outfalls 002 and 003. Therefore, only
Outfall 001 is allocated a load. Flow data were obtained from PCS, with two additional values
from MFG, for the tailings pond discharge, Outfall 001 (SF624). Average monthly flows were
only reported for two months during the period from April 1997 to June 1998.
There has been no discharge from Sunshine's Consolidated Silver mine in the last five years.
However. Sunshine has indicated that the company is currently conducting further exploration of
the mine for potential re-opening in the future. In keeping with the use of actual flow data for
establishment of allocations, the allocation for Consolidated Silver is established based on the
most recently reported average flowrate of. 194 mgd (0.3 cfs) in the March 1993 NPDES permit
application for this facility.
Flows for the sewage treatment plant at Page (SF622) were taken from PCS; however, two
numbers were reported for each date in a single column. EPA determined that the lower flow
number for each date is an influent value so only the higher number for each date was included in
calculating the average flow. The PCS data for the Smelterville treatment plant (SF623) was
unusable, due to inconsistency of the units reported, so flows were compiled from available
3
-------
OMRs The Central Treatment Plant (SF3) flow average was determined from the average
monthly flows reported by EPA for the period from June 1996 through June 1998.
Silver Valley Resources holds NPDES permits for the Coeur/Galena (SF6G2) and Caladay
(SF600) mines. The flow data for these dischargers were averaged from PCS. The Caladay
average flow data included only one entry for the period from January 1994 to October 1997.
The Coeur/Galena pen nit includes two outfalls (Lake Creek tailings pond {001} and Osbura
tailings pond {002}). Because Outfall 002 commenced discharging in August 1998, it was
necessary to use more recent flow information (PCS data from August 1998 to March 2000) to
calculate the average flowrate. The average of the average monthly flows reported over this
period for Outfall 002 (0.775 cfs) was used in the allocation.
The remaining allocation flows for adits in this reach were taken from URSG sample events.
Where the flow was successfully measured during both events, the average value was used. A
"zero" value was used in calculating average flow for Coeur d'Alene Mineral Point (SF384)
since it was reported dry during one sampling event. Where only one flow was recorded, that
value was used for the allocation.
4
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APPENDIX F : METALS FLUXES FROM COEUR D'ALENE LAKE SEDIMENTS
The long-term risk of metal release from lakebed sediments was a major reason that a detailed
tamo logical study of Coeur d'Alene Lake was conducted in the early 1990's, the results of
which are described m Woods and Beckwith (1996). The justification for the study was based on
the following two key issues gleaned from previous studies of the lake: 1) the lake exhibited
classic symptoms of eutrophication; and 2) the lakebed sediments contained highly enriched
concentrations of metals such as arsenic, cadmium, lead, and zinc. The research question posed
for the study was therefore, "Has Coeur d'Alene Lake advanced far enough in the eutrophication
process to have a substantial risk to develop an anoxic hypolimnion, which would increase the
potential for release of nutrients and metals from the lakebed sediments into the overlying water
column?"
The linmological study addressed the eutrophication issue with water-quality data collected in the
lake and its watershed, as well as empirical modeling. The trophic state of the majority of the
lake was determined to be oligotrophic on the basis of concentrations of nitrogen, phosphorus,
and chlorophyll-a. Despite its oligotrophy, the deeper areas of the lake had a substantial
hypo limnetic dissolved-oxygen deficit, which is symptomatic of eutrophication. A nutrient
load/lake response model was used to determine the response of the hypolimnetic dissolved-
oxygen deficit to incremental increases or decreases in nutrient loads to the lake. Modeling
results indicated the lake has a large assimilative capacity for nutrients before anoxic conditions
were likely to develop in the hypolimnion. Limnological monitoring conducted between 1995
and 1999 indicate that oligotrophic conditions have continued and that the hypolimnetic
dissolved-oxygen deficit has lessened somewhat (written communication, G. Harvey, Idaho
Division of Environmental Quality, January 2000).
The limnological study also addressed the lakebed metals issue via collection and analysis of
about 150 surficial samples of the lakebed sediments followed by collection of 12 cores of
lakebed sediments (Horowitz and others, 1993, 1995). The goal of the analytical work was to
determine concentration, partitioning, and potential environmental availability of selected metals.
About 85 percent of the lakebed's surface area was found to be highly elevated in antimony,
arsenic, cadmium, copper, lead, mercury, silver, and zinc. The depth of elevated sediments
ranged from 17 to 119 centimeters. The chemical distribution of metals throughout the lake
clearly indicated that their source was the Coeur d'Alene River. Most of the metals in surficial
and core samples were associated with ferric oxides and thus would be subject to redissolution
under the reducing conditions that can occur within an anoxic hypolimnion. Previously, the
metals in the lakebed sediments were thought to be associated with sulfides and, under reducing
conditions, would remain immobile.
There is little doubt that the lakebed sediments in Coeur d'Alene Lake have elevated levels of
metals and that the source of thoss metals is the long-term mining and ore-processing activities
1
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within tiie Coeur d'Alene River Basin. The presence or absence of an oxidized micro zone in the
lakebed sediments and its effect on metal flux has been critically discussed in the expert reports
from Falter (1999), Maest (1999), and Pederson/Carmack (1999), Observations by Horowitz and
others (1993) during collection of surficial samples of lakebed sediments from Coeur d'Alene
Lake noted that many of the samples had a thin (few millimeters) veneer of fine-grained reddish
material overlying an oxidized layer between 1 and 5 centimeters thick. Maest (1999) reviewed
core-derived, pore-fluid concentration data for iron, manganese, and sulfate, as reported by
Balistrieri (1998), and concluded the profiles showed classic patterns for a transition from
oxygenated conditions near the sediment-water interface through suboxie and anoxic conditions
deeper in the sediment profile. The presence of an oxidized microzooe highly enriched in metals,
an oxic hypolimnion, and the metal-rich veneer at the lakebed surface all indicate remohilization
of metals within the upper sediment column accompanied by some unqualified degree of
sequestration at the sediment- water interface.
The first estimates of the flux of metals from the lakebed sediments of Coeur d'Alene Lake were
made by Balistrieri (1998) using porewater data collected in 1992 as part of the limnological
study. On the basis of porewater extracted from sectioned and centrifuged cores and diffusion-
controlled samplers. Balistrieri concluded the lakebed sediments were a source of dissolved zinc,
copper, manganese, and, possibly, lead. However, Balistrieri noted uncertainties in the original
data and recommended additional research to verify the direction and magnitude of fluxes.
Ongoing litigation (U.S. v. ASARCO) over the link between mining industry practices and the
presence of highly elevated levels of metals in Coeur d'Alene Lake have brought close scrutiny
of the limnological study in expert reports from the plaintiffs (Falter, 1999; Maest, 1999) and
defendents (Pederson and Carmack, 1999). A central issue is whether the metals in the lakebed
sediments are associated with ferric oxides or sulfides because that association bears directly on
the direction and magnitude of potential benthic fluxes of metals in the presence of an anoxic
hypolimnion. A litigated resolution of the metal-association issue may be in the future; however,
current information can be synthesized to answer the question about the long-term risk of metal
release from lakebed sediments.
Water-quality data collected in the 1990's indicate that the lake may receive a flux of metals
from its lakebed sediments. The early-1990's limnological study revealed a definite elevation of
whole-water recoverable concentrations of lead and zinc in the lower hypolimnion in comparison
to epilimnetic concentrations. Dissolved metals data collected in the summer of 1999 indicated
that cadmium, lead, and zinc concentrations in the lower hypolimnion were from between 1.5
and 3 times higher than those measured in the epilimnion (written communication, P. Woods,
U.S. Geological Survey, January 2000). Three processes, separately or in combination, could
explain these concentration differences. In the first, the inflow plume of the Coeur d'Alene River
and its associated metal load enters the lake as an interflow or underflow current into the lake's
hypolimnion on a seasonal basis (e.g., underflow tends to occur from October through December
because the river cools faster than the lake). Secondly, metals taken up by phytoplanktonic
production in the epilimnion may settle into the hypolimnion upon the demise of those
phytoplankton. The third process is remohilization of metals within the lakebed sedimsnts and
2
-------
subsequent release into the overlying hypolimnion
In the near future (Summer 2000), an improvement in the understanding of the role of
re mobilization and benthic flux will be available from a study conducted by the U.S. Geological
Survey. This study employed two independent research methods to measure benthic flux in
Coeur d'Alene Lake during August 1999. A benthic flux chamber (also called a "landef) was
placed on the lakebed to measure numerous variables associated with the geochemical interaction
of the lakebed sediments and overlying water column. Concurrently, a series of lakebed
sediment cores and overlying hypolimnetic water samples were collected with specialized
sampling equipment. The cores were incubated using dissolved-oxygen concentrations from
saturated to anoxic in order to measure the metal flux between lakebed sediments and the
overlying water column over a gradient of redox conditions.
Preliminary results from the August 1999 study indicate that the potential magnitude of metals
fluxes into and out of lake sediments is significant in relation to the metals loadings from the
Couer d'Alene River (Kuwabara, personal communication). The lander and core sample results
both indicate that dissolved lead fluxes are occurring from the sediments to the overlying water
column. The two methods, however, provided conflicting results with respect to the direction of
dissolved cadmium and zinc fluxes (lander indicates a positive flux, cores indicate a negative
flux). Analyses of water overlying the cores under anoxic conditions indicated smaller fluxes of
lead and a negative flux of both cadmium and zinc. This suggests that large fluxes would not
occur if the lake became anoxic at depth over the long term due to eutrophication. Questions
remain about the representativeness of the core sampling techniques, seasonal variability of
fluxes and potential changes to fluxes resulting from future cleanup actions along the Coeur
d'Alene River.
A review of water quality data collected by USGS upstream and downstream of the lake indicates
that, despite the positive fluxes from the sediments, the lake as a whole acts as a sink for
dissolved metals inputs from the Coeur d'Alene River. Dissolved metals loads exiting the lake
for lead at the Post Falls dam are significantly lower than the loadings entering the lake from the
Coeur d'Alene River; cadmium and zinc loads appear lower at the Post Falls dam as well, but to
a lesser degree (Woods, personal communication). This data suggests that fluxes from the
sediments measured in the lander study may be smaller in magnitude than dissolved metals
reductions due to planktonic uptake, chemical interactions, or other processes occurring in the
lake.
In conclusion, available data indicate that the chemical, physical, and biological processes
affecting dissolved metals concentrations in the lake currently result in a net reduction in the
metals loads introduced by the Coeur d'Alene River. EPA also believes the long-term risk for a
substantial release of metals from lakebed sediments is low because (1) Coeur d'Alene Lake's
large assimilative capacity for nutrients makes it very unlikely that an anoxic hypolimnion will
develop, and (2) core samples did not release larger metals loads under anoxic conditions (in fact,
cadmium and zinc fluxes were negative in the tests). The lake's susceptibility to eutrophication, a
prerequisite for an anoxic hypolimnion, can be managed if nutrient loads to the lake are not
3
-------
allowed to increase appreciably.
REFERENCES CITED
Balistrieri, L.S., 1998, Preliminary estimates of bentliic fluxes of dissolved metals in Coeur
d'Aiene Lake, Idaho: U.S. Geological Survey Open-File Report 98-793,40 p.
Falter, C.M., 1999, Rebuttal expert report: Rebuttal to expert report of Thomas F. Pederson and
Eddy C. Carmack, December 17.
Horowitz, A.J., Elrick, K.A., and Cook, R.B., 1993, Effect of mining and related activities on the
sediment trace element geochemistry of Lake Coeur d'Aiene, Idaho, USA. Part I: Surface
sediments: Hydrological Processes, v. 7,403-423.
Horowitz, A.J., Elrick, K.A., Robbins, J. A., and Cook, R.B.. 1995, Effect of mining and related
activities on the sediment trace element geochemistry of Lake Coeur d'Aiene, Idaho, USA. Pan
II: Subsurface sediments: Hydrological Processes, v. 9, 35-54.
Maest, A.S., 1999, Rebuttal expert report: Rebuttal to expert report of Thomas F. Pederson and
Eddy C. Carmack, December 17.
Pederson, T.F. and Carmack, E.C., 1999, Expert report: The physical and geochemical status of
the waters and sediments of Coeur d'Aiene Lake, Idaho: A critical review, October 28.
Woods, P.F. and Beckwith, M.A., 1996, Nutrient and trace-element enrichment of Coeur d'Aiene
Lake, Idaho: U.S. Geological Survey Water-Supply Paper 2485, 93 p.
4
-------
APPENDIX G : FATE AND TRANSPORT OF SURFACE WATER METALS
One of the fundan»ntal assessment questions for the Coeur d'Alene River Basin TMDL is the
following: Are there chemical, physical, and/or biological mechanisms occuring in the river that
consistently remove dissolved metals from the water column? EPA notes that the fate of
particulate metals (metals attached to particles) is not the subject of this TMDL, which is focused
on achieving Idaho water quality standards for dissolved metals in the water column.
While biological uptake processes may be important in the lake environment (see discussion of
potential planktonic uptake in Appendix F), biological processes are not expected to significantly
alter or remove dissolved metals in the upstream riverine environment.
Conversely, chemical/physical processes such as adsorption and precipitation can potentially
remove dissolved metals from the water column. These processes involve complex and dynamic
interactions between metal species in the presence of other waterbody consituents. Since the
water quality criteria are not established for specific metal complexes (e.g., cadmium sulfate) but
rather for the sum of metal ions (e.g., dissolved cadmium), which can be directly measured, it is
not important to evaluate physical/chemical processes that may occur in the water column or
sediments for the TMDL. However, it is important to determine the amount of total metal and
dissolved metal to calculate translators. Fortunately, for the Coeur d'Alene River and tributaries,
there is a sufficient body of paired river samples (dissolved vs. particulate metal) to directly
calculate the translators.
EPA has evaluated the ratio of particulate (total recoverable) metal to dissolved metal in the
Coeur d'Alene River and tributaries. This ratio is also called a "translator" in the NPDES
program. Cadmium and zinc in the river are almost entirely in the dissolved form at all of the
target sites (i.e., the translator is approximately 1). For lead, the particulate fraction is a
significant portion of the total lead concentration at a number of target sites. This is consistent
with preliminary analyses from the RI/FS indicating that lead can be expected to adsorb and/or
co-precipitate with iron in basin waters. The particulate lead fraction increases in the
downstream direction from the South Fork headwaters to the Spokane River.
EPA also reviewed the available data for the South Fork Pinehurst station to determine whether
the total-to-dissolved ratio varies with respect to river flow. Over the range of flow tiers
established in the TMDL (68 cfs to 1290 cfs), there was no discernible relationship between river
flow and the total-to-dissolved ratios for cadmium, lead, and zinc.
Recent data collected by the USGS indicates that during peak runoff events, the total-to-
dissolved ratio for lead increases significantly in basin waters. The flows at which this
phenomenon occurs are higher than the top flow tier in the TMDL (greater than 1290 cfs). Since
the total-to-dissolved ratio at the top flow tier is more stringent than the actual ratio during peak
runoff events, the lead translators in the TMDL provide a margin of safety during peak runoff
-------
events.
In conclusion, the available paired samples indicate that dissolved cadmium and zinc are not
appreciably removed from the water column in Coeur d'Alene Basin waters, while dissolved lead
is removed to some extent to the particulate form between the headwaters and lower basin. This
transformation of dissolved lead toward particulate lead is captured in the translator applied to
the wasteload allocations in the TMDL.
2
-------
APPENDIX H : TMDL CALCULATION SPREADSHEETS
-------
Cadmium Spreadsheet
-------
Cadmium Criteria Associated with Flow/Hardness Relationship
Canyon
Ninemile
Wallace
Pine
Pinehurst
Enaville
Harrison
7Q10
56
73
57
25
101
25
47
10th
56
73
56
25
96
25
45
50th
45
63
47
25
71
25
36
90th
25
36
25
25
28
25
25
ug/l
Canyon
Ninemile
Wallace
Pine
Pinehurst
Enaville
Harrison
7Q10
0.671
0.817
0.680
0.369
1.039
0.369
0.590
10th
0.671
0.817
0.671
0.369
1.000
0.369
0.571
50th
0.571
0.733
0.590
0.369
0.800
0,369
0.484
90th
0.369
0.484
0.369
0.369
0.402
0.369
0.369
Criteria in Ibs/ft3 ** Canyon Ninemile Wallace Pine Pinehurst Enaville Harrison
7Q10
4.19E-08
5.1OE-08
4.25E-08
2.31 E-08
6.48E-08
2.31 E-08
3.68E-08
10th
4.19E-08
5.10 E-08
4.19 E-08
2.31 E-08
6.25E-08
2.31 E-08
3.56E-08
50th
3.56E-08
4.57E-08
3.68E-08
2.31 E-08
5.00E-08
2.31 E-08
3.02E-O8
90th
2.31 E-08
3.02E-08
2.31 E-08
2.31 E-08
2.51 E-08
2.31 E-08
2.31 E-08
" conversion factor =
6.24267E-08
-------
South Fork Coeur d'Alene River Basin
Natural Background
Cadmium (Cd)
Nat. Background in ug/l
Nat. Background in Ibs/ft3
Canyon
0.06
3.7E-09
Background
Ninemlle Wallace Pine Plnehurst Enavllle Harriso .
0.06 0.06 0.1 0.08 0.08 0 080
3.7E-09 3.7E-09 6.2E-09 5.0E-09 5.0E-09 5 0E-09
-------
South Fort Coeur d'Alene River Basin
TMDL Allocations
Cadmium (Cd)
Carryon Creek
URS Qrelner Station ID 285
Allocated Loading
Final Loading
Dtachaif*
eta
Loading
Capacity
(fta/day)
Cadmium
6iok|roun4
(ft a/day)
Used
Capacity
(ft a/day)
100%
(ft a/day)
Safety
10%
(ft a/day)
Non-Olaorata
«%
(ftattay)
Dl*erata
24%
(fta/day)
Non-0 toera«»
(ft a/day)
Dtaerato
(ft a/day)
7O10L
7 1
2 57E-02
0 00E+00
2 34E-02
2 34E-03
^ SX-fli
SKEW
1 52E-02
5 656-03
itf" Percentile
11
3 98E-02
3 56E-03
oooe+oo
3 636-02
3 636-03
2 366-02
9 076-03
2 366-02
9 076 03
5tfn Percentile
25
7 706-02
0 09E-03
OOOE+OO
6 89E-02
6 696-03
4 466-02
1 726-02
4 466-02
1 726-02
9CT Percentile
149
2 97E-01
4 826-02
oooe+oo
2 496-01
2 4G6-02
1 626-01
6 216-02
1 626-01
6 216-02
Loading Allocatlona By Source
7O10L
1(T Percentile
5CT Percentile
9CT Percentile
Station ID
Avafaf a
Olachargo
(cla)
Proportion
of
Olacharg*
Dlaaolvad
WLA
(Ik a/day)
Tranalator
Tatal
WLA
(fta/dav)
OtaaoJvad
WLA
(fte/dey)
Tranalator
Total
WLA
(ftaftlay)
OtaaoJvad
WLA
(ftaMay)
Translator
Total
WLA
(ft a/day)
OtaaoJvad
WLA
(ft a/day)
Tranalator
Total
WLA
(ft a/day)
CC817 Heda #3
0 068
0008
4 856-06
1 006+00
4 856-06
7 516-06
1 006+00
7516-06
1 436-04
1 006+00
1 436-04
5 146-04
1 006+00
5 146-04
CC355. GEM
0 260
0 031
1 846-04
1 006+00
1 84E-04
2 856-04
1 006+00
2 656-04
5 426-04
1 006+00
5 426-04
1 96E-03
1 OOE+OO
1 966-03
CC816 (Star/Phx Tailings)
2 340
0 283
1 66E-03
1 006*00
1 66E-03
2 576-03
1 006+00
2 576-03
4 686-03
1 006+00
4 88E-03
1 76E-02
1 OOE+OO
1 76E-02
CC367 (WP Seep)
0 004
0 000
2 696-06
1 ooe+oo
2 696-06
4 176-06
1 006+00
4 176-06
7 926-06
1 006+00
7 92E-06
2 86E-06
1 006+00
2 866-05
CC372 Tam»7
1 590
0 192
1 136-03
1 006+00
1 136-03
1 756-03
1 006+00
1 756-03
3 326-03
1 006+00
3 32E-03
1 20E-02
1 006+00
1 206 02
CC353 Hercules »5
1 707
0 207
1 216-03
1 OOE+OO
1 216-03
1 876-03
1 006+00
1 876-03
3 566-03
1 006+00
3 566-03
1 28E-02
1 006+00
1 28E-02
CC371 Biackbear Fraction
1 165
0 141
8 256 -04
1 006+00
8 256-04
1 286-03
1 006+00
1 286-03
2 436-03
1 006+00
2 436-03
8 76E-03
1 006+00
8 76E-03
CC373 Anchor
0008
0 001
5 67E-06
1 006+00
5 676-06
8 786-06
1 006+00
8 786-06
1 676-05
1 006+00
1 67E-06
6 02E-06
1 OOE+OO
6 02E-06
CC354 Hidden Treasure
0 720
0 087
5 106-04
1 006+00
S 106-04
7 90E-04
1 006+00
7 906-04
1 506-03
1 006+00
1 506-03
5 426-03
1 OOE+OO
5 426-03
Tiger/Poorman
0 400
0 048
2 836-04
1 006+00
2 836-04
4 396-04
1 006+00
4 396-04
8 346 04
1 OOE+OO
6 34E-04
3 016-03
1 OOE+OO
3 01E-03
total Effluent Flow
55552
Tola! Loading 5.86E-03
i olal Loading t-oa
T ofal Loading i. /zt-uz
Total Loading 6.2ifc-oz
-------
South Fork Coeur d'Alene River Basin
TMDL Allocations
Cadmium (Cd)
Nlrvemlto Creek
URS Qrelner Station ID 305
Allocated Loading
Finei Loading
Dtacharf a
eta
LoadJrtf
Capacity
(ft a/day)
Cadmium
Background
(Ik a/day)
Uaad
Capacity
(fta/day)
too%
(fta/day)
Safety
10%
(fta/day)
NonOlaerata
(»*Xtay)
Dtacrata
24%
(••/day)
Nan4)haerata
Diacrata
(»«*«y)
7Q10L
$
fi ME-M
6 472E04
AM5+M
ft 17P-M
5 31E-03
2 04E: 03
5 31E-M
2 04E-03
1tfn Percentile
3
1 32E-02
9 709E-04
0 00E+00
1 226-02
1 226-03
7 96E-03
3 066-03
7 966-03
3 066-03
50"* Percentile
6 9
2 736-02
2 233E-03
0 OOE+OO
2 S0E-02
2 50E03
1 636-02
6 266-03
1 636-02
6 266-03
9
-------
South Fork Coeur d'Alene River Basin
TMDL Allocations
Cadmium (CD)
South Fork Coeur d'Alene River et Wallace
URS Orelner Station ID 233
Allocated Loading
Pinal Loading
OlMhugi
ota
Loading
Capacity
(lha/day)
Cadmium
Background
(ft a/ day)
Uaad
Capacity
(Ik a/day)
3 166-02
100%
(ftaMay)
Safety
10%
(»a/d«y)
Non-0 taofoto
«%
(» •>*•*)
0 lactate
24%
(fc*/d«y)
Non-0 laorote
(»a*ay)
Oiaetote
(ft a/day)
7Q1DL
££
7 15E-03
&75E-62
1 06fc-02
1 066-02
1tfn Percentile
35
1 27E-01
1 13E02
4 85E-02
6 69E-02
6 69E-03
4 36E-02
1 67E-G2
4 366*02
1 676-02
50^ Percentile
79
2 51E-01
2 5SE-02
9 38E-02
1 31E-01
1 31E-02
8 55E-02
3 296-02
8S5E-Q2
3 296-02
9tf" Percentile
469
9 34E-01
1 52E-01
3 42E-01
4 406-01
4 40E-02
2 566-01
1 10E-01
2 866-01
1 10E-01
Loading Allocations By Source
7Q10L
1IT Parcantlla
Btf" Parcantlla
9ff" Parcantlla
Station IO
Avaraf •
(Macharf*
(eta)
Proportion
of
Dlacharg*
Oiasolvad
WIA
(»a*ay)
Tranatatar
Total
WLA
<»>/doy)
Diaaolv«d
WLA
»lfy)
Tranalatar
Total
WLA
<»•«•*)
Dtaoolvod
WLA
(k«Moy)
Tranalator
Total
WLA
(It a/day)
DiMOlwd
WLA
<»•«•»)
Tranalatoc
Total
WLA
(koMoyl
SF 607 Lucky Fnday 001
1 27
fl W3
1 52E-03
1 OOE+OO
1 526-03
itise M
1 OOfc+OO
2 40E-03
1 OOE+OO
4 726 03
\ ME-SJ
1 OOE+OO
\ 5SE-62
SF609 Lucky Friday 003
085
0 096
1 026-03
1 OOfc+Ot)
1 02E-03
1 61E-03
1 OOfc+OO
1 61E-OS
3 16E-03
1 OOE+OO
3166-03
1 066-02
1 OOfc+OO
I KE 42
SF328. (Morn waste rock)
1 59
0 180
1 906-03
i ME+M
{ 55E-M
3 00E-03
< ME.W
3 MEW
S«E-03
1 OOE+OO
5 906 03
1 98E-02
1 006+00
\ 96E-A2
SF 396 Square Deal
008
0 009
9 57E-06
1 OOE+OO
A STE-flS
1 51E-04
1 006+00
rsiew
2 97E-04
1 OOE+OO
2 97E04
9 94E 04
1 OOE+OO
9 94E 04
SF3G5. Gciconda
003
0003
3 596-05
1 006+00
3 59E-06
5 67E-06
1 OOE+OO
5 87E-0S
1 11E-04
1 OOE+OO
1 11 E-04
3 736*04
1 OOE+OO
3 73E-04
SF627 STP Mullen
0 413
0 047
4 946-04
1 006*00
4 94E-04
7 80E04
i me;w
7 80E-04
1 53E-03
( ME+M
1 53E-03
5 136 03
1 OOE+OO
5 13E M
SF338 Snowstorm #3
2 00
0 226
2 396-03
' (ME+M
2 MEM
3 78E-03
-TB5E^5
37SE-M
7 43E-03
¦ nSSE+BB
7^53
2 496-02
1 006+00
2 49fc-02
SF339 Copper King
0 0664
0 006
6 75E-06
1 OOE+OO
6 756-05
1 07E-04
1 OOfc+OO
I 67E-&I
2 09E-04
1 OOE+OO
2 006-04
7 01 E-04
1 OOfc+OO
7 01 fc-04
SF345 Morning *4
0 0152
0 002
1 82E-06
1 OOE+OO
1 S2E-06
2 87E-06
1 OOfc+OO
iSK-X
5 64E-05
\ ME+M
5 646-06
1 89E-04
\ AAE+M
1 8SE-04
£^346 Morning No 5
0 0111
0 001
1 33E-05
1 OOE+OO
\ me«
2 10E-06
i i6E-5?
4 12E-06
i"5BE+BB
415EK
1 38E-04
1 OOfc+OO
1 38fc-04
SF347 Star 1200 Level
0 695
0 079
8 31 E-04
1 006+00
¦¦rae-w
1 31E-03
"TMKW
~T3TF5T
2 58E-03
1 (73ETM
258PM
8 64E-03
1 OOfc+OO
6 64E-03
SF349 Grouse
1 82
0206
2 186-03
1 OOE+OO
2 18E-03
3 44E-03
STJFSS
6 766-03
iTTSETW
875E-M
2 26E-02
1 006+00
2 266-02
£^386 Pnnceton-Magma
00003
0 00003
3 59E-07
1 OOE+OO
3 59E-07
5 67E-07
1 OOE+OO
S.ffE-W
1 11E-06
1 ooe+oo
1 11E-06
3 736-08
1 006+00
3 73fc-06
£^389 Unnamed Adit
0 011
0 001
1 32E-06
1 OOE+OO
\ 42E-S5
2 06E-06
\ mevm
2ME«
4 08E-06
1 ooe+oo
4 06E-06
1 376-04
1 OOE+OO
1 37E-04
SF390 Reindeer Queen
0 011
0 001
1 32E-05
1 OOE+OO
1 32fc-05
2 08E-06
(ME7W
4 06E-06
rWE+M
1 37E-04
1 OOE+OO
\ 57E-64
Total Effluent Flow
AAS6
lolal Loading J WE-M
I olal Loading 157E-02
T otnl Loading j.em-ui
lotal Loading l.ioe-oi
-------
South Fork Coeur d'Alene Rlvar Basin
TMDL Allocations
Cadmium (Cd)
Pin* Craak
URS Cfratoar Station 10 315
ARooatad Loadkig
Find Losdhg
Dtachargt
c*
lotting
Capaoity
(iba/oay)
Cadmium
Background
Uaad
Opacity
Oba/day|
100%
(Iba/day)
Safety
10%
(toa/day)
Non-Oiaorttt
M%
(Iba/day)
Olacrata
21%
(iba/dav)
Non-Otaorata
(iba/day)
Olaerata
(fta/day)
7Q10L
56
3 886-02
1 0796 02
oooeUo
2 916-02
2 916-03
?Mc-M
10" ParcxitlU
29
5 786-02
1 5646-02
oooe+oo
4 216-02
4 216-03
2 746-02
1 066-02
2 746-02
1 066-02
S
367
7 716 01
2 0676-01
0 006+00
S 626-01
5 026-02
3 066-01
1 416-01
3 056-01
1 416-01
Loading AlocaUona By Sourca
7Q1OL
1(T paroanflla
50" Paroantila
9CT Paroanflla
Station 10
Avtrag*
Dtocrwgt
loa)
Proportion
of
Otacharga
Diaaolvad
WLA
(iba/aay)
Tranatalor
To tat
WLA
(iba/day)
Diaaoivad
WLA
(iba/Oav)
Translator
Total
WLA
(iba/oav)
Oiaaolvad
\M_A
(iba/day)
Tranaiator
Tom
WLA
(iba/day)
Dtaaoivad
WLA
(Iba/day)
Translator
Total
WLA
(Iba/day)
PC329 North Amy
0 322
0 479
3 486-03
1 006+00
3 486-03
5 046-03
1 006+00
5 046-03
1 39E-02
1 006+00
1 396-02
0 736-02
1 006+00
6 736-02
PC330 Amy
0 005
0 007
5 406-06
1 006+00
5 406-06
7 836-06
1 006+00
7 836-06
2 106-04
1 006+00
2 106-04
1 066-03
1 006+00
1 056-03
PC331 Libaral King
ooos
0 007
5 406-06
1 006+00
5 406 06
7 836-06
1 006+00
7 836-06
2ieE-04
1 006+00
2 106-04
1 066-03
1 006+00
1 056-03
3C332 lookout
0 027
0 040
2 926-04
1 006+00
2 926-04
4 236-04
1 006+00
4 236-04
1 176-03
1 006+00
1 176-03
5 646 03
1 006+00
5 646-03
PC333 Uppar l*Kh
0 001
0 001
1 066-06
1 006+00
1 086-05
1 576-06
1 006+00
1 576-06
4 326-06
1 006+00
4 326-06
2 006-04
1 006+00
2 096-04
PC334 Lynch/Nabob
0 0006
0 001
6 486-06
1 006+00
6 486-06
9 406-06
1 006+00
9 406-00
2 596-06
1 006+00
2 596-06
1 256-04
1 006+00
1 256-04
PCS 35 Navada-Stawart
0 091
0 135
9 836-04
1 006+00
9 836-04
1 436-03
1 006+00
1 436-03
3 936-03
1 006+00
3 936-03
1 90602
1 006+00
1 906-02
PC330 Highland SurprtM
0 03®
0 067
4 106-04
1 006+00
4 106-04
5 956-04
1 006+00
5 956-04
1 646-03
1 006+00
1 646-03
7 946-03
1 006+00
7 946-03
PC375 Hiflhlsnd Surp Waata Rock
0 011
0016
1 156-04
1 006+00
1 156-04
1 666-04
1 006+00
1 606-04
4 586-04
1 006+00
4 586-04
2 226-03
1 006+00
2 226-03
PC337 Sidnay (Rad Cloud)
0006
0009
6 406-06
1 006+00
6 486-05
9 406-06
1 006+00
9 406-06
2596-04
1 006+00
2 596-04
1 256-03
1 006+00
1 256-03
PC340 Uppar Iffla Ptttsburg
0 002
0003
2 166-05
1 006+00
2 166-05
3 136-06
1 006+00
3 136-06
8 646-06
1 006+00
8 646-05
4 186-04
1 006+00
4 166-04
PC341 Lowar Lffla Pittsburg
0 006
0009
6 486 06
1 006+00
6 486-06
9 406-05
1 006+00
9 406-06
2 596-04
1 006+00
2 596-04
1 256 03
1 006+00
1 256-03
PC343 Nabob 1300 Laval
0066
0 098
7 136-04
1 006+00
7 13604
1 036-03
1 006+00
1 036-03
2 656-03
1 006+00
2 856-03
1 386 02
1 006+00
1 386-02
PC344 &Q It
0 001
0 002
1 156-06
1 006+00
1 156-06
1 666-06
1 006+00
1 606-06
4 586-06
1 006+00
4 586-06
2 226-04
1 006+00
2 226-04
PC348 Uppar Constitution
0 079
0117
8 536-04
1 006+00
6 536-04
1 246-03
1 006+00
1 246-03
3 416-03
1 006+00
3 416 03
1 656-02
1 006+00
1 656-02
PC351 Manrnon Tunnal
0 009
0 013
9 616-06
1 006+00
9 616-05
1 396-04
1 006+00
1 396-04
3 856-04
1 006+00
3 856-04
1 806-03
1 006+00
1 666-03
pC352 Saap BaJow Navada Stawart
0 003
0 004
3 026 05
1 006+00
3 026-06
4 396 06
1 006+00
4 396-06
1 216-04
1 006+00
1 216 04
5656 04
1 006+00
5 656-04
PC 400 Adrt Upstraam ot Littla Pittsburg
00004
0 001
4 566-06
1 006+00
4 506 -06
eoiEoe
1 006+00
6 616-00
1 62E-06
1 006+00
1 626-05
8 626-06
1 006+00
6 626-05
Total LffluantFlow
Total Loading 7.2C-03
ToU Loading" 'THBH
ToU Loading JTTF82
ToQToa3Tng " TTOW
-------
South Fork Coeur d'Alana River Basin
TMDL Allocations
Cadmium (Ca)
South Pork Coeur d'Alene River & Plnhurst
URS Qrelner Station ID 271
Allocated Loading
Final Loading
Otachaff*
eta
Loadtofl
Capacity
(»a7day)
CidfMum
Backgiownd
day)
Uaod
Capacity
(lks/d«y)
7 14E-02
100%
(toa/day)
Safety
10%
(fta/day)
Non-0 too* • to
•6%
(to a/day)
Otaeroto
2i%
(»a*ay)
Non4)tooi*to
(»a*ay)
Dtoeroto
<»•«•?)
701DL
68
3 81E-01
2 934E-02
2 80E-01
2 806-02
1 82E-01
7 00E-O2
1 826-01
7 006-02
1tf" Percentile
97
5 236-01
4 1866-02
1 096-01
3 736-01
3 736 02
2 426-01
9 31E-02
2 426-01
9 316-02
Stf" Percentile
266
1 166+00
1 1566 01
2 486-01
7 94E-01
7 94E-02
5 16E-01
1 986-01
5 166-01
1 986-01
90*n Percentile
1290
2 806+00
5 5666-01
1 006*00
1 24E+00
1 24E01
8 036-01
3 066-01
8 036-01
3 066-01
Loading Allocations By Source
7Q10L
1 (T Percentile
6(T Percentile
9
-------
South Fork Coeur d'Alene River Basin
TMDL Allocations
Cadmium (Cd)
North Fork Coeur d'Alene River @ Enaville
URS Greiner Station ID 400
Discharge
cfs
Loading
Capacity
(lbs/day)
Cadmium
Background
(lbs/day)
7Q10L
165
3.28E-01
7.115E-02
10m Percentile
253
5.04E-01
1.092E-01
50m Percentile
845
1.68E+00
3.646E-01
90th Percentile
5,090
1.01E+01
2196E+00
-------
South Fork Coeur d'Alene River Basin
TMDL Allocations
Cadmium (Cd)
Coeur aAlene River i# Harrison
Allocated Loading
Loading
Cadmium
Used
Safety
Non-Discrete
Discrete
Discharge
Capacity
Background
Capacity'
100%
10%
90%
0%
cfs
ilbt/day)
(lbs/day)
(lbs/day)
(lbs/day)
(IbVday)
(lbs/day)
(lbs/day)
7Q10L
239
7.60F-01
1.030E-Q1
3.51E-01
3.05E-01
3 05E-02
2.7SE-01
OOOE+OO
itf* Percentile
348
1 07E.00
1.5Q2F-01
4 82F-01
4.40E-01
4 40E-02
3 96E-01
0 00E+0O
50* Percentile
t.100
2.87E+00
4 746f--01
1 18ht00
1.24E-00
1 24E01
1 11E»00
0 00E«00
90" Percentile
6.870
1.37E*01
2.964fc-t00
3 43L+0O
7.29E+00
7.29E-01
6.56E*00
0 0CE-.00
1 Used Capacity includes total loading allocations lor South Fork Coeur d'Alene Rwei and background allocations fo« the North Fork Coeur d'Alene River
-------
Lead Spreadsheet
-------
South Fork Coeur d'Alene River Basin
Natural Background
Lead (Pb)
Canyon
Nat. Background in ug/l 0.17
Nat. Background in Ibs/ft3 1.1E-08
Ninemile Wallace
0.17 0.17
1.1E-08 1.1E-08
Pine Pinehurst
0.21 0.21
1.3E-08 1.3E-08
background
Enaville Harrison
0.21 0.210
1.3E-08 1.3E-08
-------
Lead Criteria Associated with Flow/Hardness Relationship
Hardness
Canyon
Ninemile
Wallace
Pine
Pinehurst
Enaville
Harrison
7Q10
56
73
57
25
101
25
47
10th
56
73
56
25
96
25
45
50th
45
63
47
25
71
25
36
90th
25
36
25
25
28
25
25
Criteria in ug/l
Canyon
Ninemile
Wallace
Pine
Pinehurst
Enaville
Harrison
7Q10
1.331
1.784
1.358
0.541
2.544
0.541
1.096
10th
1.331
1.784
1.331
0.541
2.407
0.541
1.045
50th
1.045
1.517
1.096
0.541
1.730
0.541
0.814
90th
0.541
0.814
0.541
0.541
0.615
0.541
0.541
Criteria in Ibs/ft3 **
Canyon
Ninemile
Wallace
Pine
Pinehurst Enaville
Harrison
7Q10
8.31 E-08
1.11E-07
8.48E-08
3.38E-08
1.59E-07
3.38E-08
6.84E-08
10th
50th
90th
8.31 E-08
1.11E-07
6.ilE-o6
3.38E-08
1.50E-07
3.38E-08
6.52E-08
6.52E-08
9.47E-08
6.84E-08
3.38E-08
1.08E-07
3.38E-08
5.08E-08
3.38E-08
5.08E-08
3.38E-08
3.38E-08
3.84E-08
3.38E-08
3.38E-08
** conversion factor
=
6.2427E-08
Coefficients
a b
1.27301 4.70501
-------
South Fork Coeur d'Alene River Basin
TMDL Allocations
Lead (Pb)
Nlnemlle Creek
URS Orelner Station ID 905
Allocatad Loading
Final Loading
Dtaohwf*
eta
Leadlni
C«#«city
<»a/d« y)
Zlne
Backfround
fl»«*ay)
Uaod
Capacity
Dtoaolvod
WLA
(fta/da*)
Translator
Total
mA
(IkaMw)
Dtaaolvod
WLA
(fta/day)
Tranalator
Total
WLA
(ft a/day)
NM360IC «4
0 040
0 020
0 776-05
1 106+00
9 656-05
1 326-04
1 106+00
1 45E-04
2526-04
1 106+00
2 786-04
7 186-04
1 106+00
7 906-04
NM362IC Waste Rock
1 790
0 902
3 926-03
1 106+00
4 326*03
5 896-03
1 106+00
6 486*03
1136-02
1106+00
1 246*02
3 216-02
1 106+00
3 536*02
NM363 IC Tailings Seep
0004
0 002
8 776-06
1 106+00
9 666-06
1 326-06
1 106+00
1 456-06
2.526-06
1.106+00
2 786*06
7 186-06
1 106+00
7 906*06
NM361 Rex #2
0 020
0 010
4 396-05
1 106+00
4 826-06
6586-06
1106+00
7 246-06
1 266-04
1106+00
1 36E-04
3596*04
1 10E+00
3 956-04
NM364 Tamarack 400 Level
0 040
0 020
6 77E-05
1 106+00
9 856-06
1 326-04
1106+00
1 456-04
2526*04
1 106+00
2 786-04
7 186*04
1 106+00
7 90E-04
NM366 Tamarack #5
0 030
0 015
6 586-06
1 106+00
7 246-06
9 876-06
1 106+00
1 006-04
1 866-04
1 106+00
2 086-04
5 396-04
1 106+00
5 926-04
NM368 Rex Tailings
0 020
0010
4 396-06
1 106+00
4 826-05
6586-06
1106+00
7 246-06
1 266*04
1 106+00
1 396*04
3 596-04
1 106+00
3 956-04
NM359 Success #0
0010
0 005
2 19E-05
1 106+00
2 416-06
3 296-06
1 106+00
3 626-06
6 316*06
1 106+00
6 946-06
1 806-04
1 106+00
1 97E04
NM367 Day Rock 100
0 007
0 003
1 496-05
1 106+00
1 646-06
2 246-06
1 106+00
2 466-06
4 296*06
1 106+00
4 726-06
1 226-04
1 106+00
1 34E-04
NM369 Dululh
0 0096
0 006
2 106-06
1 106+00
2326-06
3 166-06
1 106+00
3 476-05
8 066*06
1 106+00
6 676-06
1 726-04
1 106+00
1 90E-04
NM370 Silverstar
0 011
0006
2 416-06
1 106+00
2 656-06
3 626-05
1 106+00
3986*06
6 946*06
1 106+00
7646-06
1 976-04
1 106+00
2 17E-04
NM374 Success Tailings
0003
0 002
7 4SE-06
1 106+00
8 206-06
1 126-06
1 106+00
1 236-06
Si5E-oS
1 106+00
6 106*06
1 10E+00
6 71E-06
iota! Effluent Flow
rws
Total Loading 4.35E-03
Total Loading J S3E49
Tolal Loading TSPB5
Total Loading 3.&&fc-U2
I
-------
South Fork Coeur d'Alane River Baaln
TMDL Allocations
Lead (Pb)
Canyon Craak
URS Qralnar Station ID 285
Allocated Lousing
Final Loading
Olschar|o
cto
Loodfcif
Capacity
(»o*«y)
Zlno
Bookfround
Dtaerota
21%
(»¦*•*>
Non-0 borota
(fto*ay)
Olaorota
7Q10L
5 106-02
6 510E-03
0 OOfc+00
4 45E-02
4 4K-M
2 696-02
\ HE-flS
2KE-W
\ HE-flS
10™ Parcantlla
11
7 906 02
1 009E-02
0 006+00
6 89E-02
6 88E-03
4 466-02
1 726-02
4 486-02
1 72E-02
50*" Parcantlla
25
1 41E-01
2 2926-02
0 006+00
1 186-01
1 186-02
7 676-02
2 956-02
7 67E-02
2 95E-02
9tf" Parcantlla
149
4 35E-01
1 3666-01
0 006+00
2 986-01
2 986-02
1 946-01
7 45E-02
1 94E-01
7 456-02
Loading Allocation* By Sourca
7Q10L
1CT Parcantlla
6CT Parcantlla
9OT Parcantlla
Station ID
Avoraf•
Dlaeh«|0
(cla)
Proportion
of
Oioofcttfo
ou»»iw»a
WLA
<»•*•?)
Translator
Total
WLA
(*•«•*)
ObaoJvod
WLA
<»•*•*)
Translator
Total
WLA
(tasMav)
Dt—a iy*d
WLA
(»•«•*>
Translator
Total
WLA
<»•***)
Dtaaolvod
WLA
Translator
Total
WLA
(*•*•*)
CC817 Heda #3
0 066
0006
9 21E-05
1 106+00
1 01E-04
1 436-04
1 106+00
1 57E-04
2446-04
1 106+00
2 666-04
6 176*04
1 106+00
6 79E-04
CC355. OEM
0 260
0 031
3 506-04
1 106+00
3 656-04
5 426-04
1 106+00
5 966-04
9286-04
1106+00
1 026-03
2 35E-03
1 106+00
2566-03
CC816 (Star/Phx Tailings)
2 340
0 263
3 15E-03
1 106+00
3.466-03
4 886-03
1 106+00
5 376-03
6 366-03
1 106+00
9 19E-03
2 11E-02
1106+00
2 326-02
CC357 (WPSeep)
0 004
0 000
5 11E-06
1 106+00
5 636-06
7 926-08
1 106+00
8 726-06
1 366-06
1 106+00
1 496-05
3 436-06
1 106+00
3 776-06
CC372 Tam#7
1 590
0 192
2 14E-03
1 106+00
2 35E-03
3 326-03
1 106+00
3 656-03
5 876-03
1 106+00
6 246-03
1 436-02
1 106+00
1 586-02
CC363 Hercules #5
1 707
0 207
2 306-03
1 106+00
2536-03
3 566-03
1 106+00
3 926-03
6 096-03
1 106+00
6706-03
1 546-02
1 106+00
1 696-02
CC371 Biackbear Fraction
1 165
0 141
1 576-03
1 106+00
1 726*03
2 436-03
1 106+00
2 676*03
4 166-03
1 106+00
457E-03
1 066-02
1 106+00
1 166-02
CC373 Anchor
0006
0 001
1 086-05
1 106+00
1 166-06
1 676-06
1 106+00
1836-06
2656-06
1 106+00
3 146-06
7 226-06
1 106+00
7 946-06
CC354 Hidden Treasure
0 720
0 067
9 686-04
1 106+00
1 07E-03
1 506-03
1 106+00
1 666-00
2 576-03
1 106+00
2636-03
6 506-03
1 106+00
7 146-03
Tiger/Poorman
0 400
0 046
5 386-04
1 106+00
5 926-04
6 34E-04
1 106+00
9 176-04
1 436-03
1 106+00
1 576-03
3 61E-03
1 106+00
3 97E-03
Total kffiuanl now
5TSE
Total Loading TTTF82
Tolal Loading i. f osAw
Tolal Loading 1K43
ToTaiLoading_ 7 46fc-02
-------
South Fork Coeur d'Alene River Basin
TMDL Allocation*
Lead (Pb)
Pin* Craak
URS Qralnar Station 10 315
Alocatad Loadtofl
Find LoedhB
Otacrwg*
ClB
Loadng
Capacity
Zinc
Background
(iba/day)
Ua«d
CapMly
(iba/day)
100%
(iba/day)
Safety
10*
(Iba/day)
Non-Dtocrtl*
61%
(Iba/day)
Dlacrala
36%
Non-Dtaortta
(lbs/My)
Olaorala
(Iba/day)
7Q10L
20
5 4iE8J
2 266E-02
0 OOE+OO
3 57E-02
3 5?e-M
2 31-02
8 836-03
2 3S 02
8 93fc03
10*" Parcantlla
29
0 4CE 02
3 2856-02
0 OOE+OO
5 186-02
S 186-03
3 366-02
1 296-02
3 3(56-02
1 296*02
50* Parcantlla
60
2 336-01
9 061E-02
0 006+00
1 436-01
1 436-02
B 286-02
3576-02
9 286-02
3 576-02
SO"1 ParcantJb
387
1 13E+00
4 383E-01
OOOE+OO
6 91E-01
8916-02
4 496-01
1 736-01
4 496 01
1 736-01
Loading Allocations By Sourca
7Q10L
10"" Parcantlla
6
-------
South Fork Coeur d'Alene River Baaln
TMDL Allocation*
Lead (Pb)
South Fork Cotur d'Atone River at Wallaca
URS Qrelnar Station ID 233
Allocated Loading
Final Loading
Dlaoharf*
eta
Le*4A|
Capacity
(ftftttoy)
Zlftc
Backfiound
(»a*ay)
Uwd
Capacity
Oka/day)
6 19E-02
100%
<*•***)
•afaty
10%
(*aw«y)
Naa-Obofab
•6%
Oteorato
24%
(»•%)
Nan-Otoorato
(»•%)
21
7Q1UL
22
1 62E-01
TWE-62
7 97E-03
'HIE-M
1.8BE-02
5.18E-Q2
1 9QE-02
101" Percentile
35
2 51E-01
3 21E-02
9 506-02
1 24E01
1 24E-02
6 066-02
3 11E-02
8066-02
311E-02
5(T Percentile
79
4 67E-01
7 23E-02
1 68E-01
2 266-01
2 266-02
1 47E-01
5 65E-02
1 476-01
5 666*02
9Cfn Percentile
469
1 37E+00
4 30E-01
4 41E-01
4 98E-01
4 906-02
3 24E-01
1 24E-01
324E-01
V 246-01
Loading Allocations By Source
7Q10L
1
Translator
Total
WLA
<»•«•»)
DhMoflwd
WLA
(•¦May)
Translator
T.MI
WLA
(ha/day)
DtaaaMd
WLA
#¦»()
Tract atator
TeMI
WLA
pt>Mar)
DtaMlvtd
WLA
TrMttator
Tekl
WLA
<»•*•»>
SP 607 Lucky l-nday 001
1 27
0 143
1 206*00
3 436-03
4 466-03
1 206*00
5 MEM
8 116-03
\ %E*A6
873E-M
1 7tE-fli
1 206*00
2 14E-02
SF609 Lucky Friday 003
0 65
0 096
1 916-03
1 206*00
2 306-03
2 98E-03
1 206*00
3686-03
5 436-03
1 J6E*M
8SIE-M
1 19E-02
1 206*00
1 436-02
SF328, (Morn waste rock)
1 59
0 180
3 5BE-03
1 206*00
4 296-03
5 58E-03
1 206*00
SME-M
1 026-02
1 206*00
1 226-02
2 236 02
1 206*00
2 686-02
SF 396 Square Deal
006
0 009
1 60E-04
1 206*00
2166-04
2816-04
i J4C*M
53>L-fl4
5 116-04
12se*«
6 136-04
1 12E-03
1 206*00
1 366-03
SF395. Goiconda
003
0 003
6 75E-05
1 206*00
8 106-06
1 06E-04
1 266-04
1 926-04
\ SXM
S9K-U
4 22E-04
1.206*00
5 066-04
SF627 STPMullan
0413
0 047
9 306-04
1 206*00
1 126-03
1 45E-03
1 746-03
2646-03
I2K«U
3 176-03
5 81E-03
1 206*00
6 976-03
SF338 Snowstorm #3
200
0 226
4 506 03
\ 26E*M
5 406-03
7 026-03
1 206*00
44JE-M
1 286-02
1 206*00
\ HE-fli
2 81E-02
1 206*00
3 376-02
SF339 Copper King
0 0664
0 006
1 276-04
1 206*00
(SiE-64
1 986-04
1 206*00
2iWL-W
3 606-04
1 26E*M
4 326-04
7 936-04
1 206*00
SSIEU
5F34S Morning >4
0 0152
0 002
3 426 05
1 206*00
iHE-M
5 336-06
848E-W
9 716-06
1 20t*00
1 166-04
2 14E-04
1 206*00
2 566-04
SF346 Morning No 5
0 0111
0 001
2 506-06
1 206*00
3 006-06
3 886-06
1 206*00
4 87E-K
7 06E-06
1 XEM
8 51E-06
1 56E-04
1 206*00
\ WE-S4
SF347 Star 1200 Level
0 695
0 079
1 56E-03
1 206*00
1 886-03
2 44E-03
1 206*00
563C-65
4 44E-03
1 206*00
55K-M
9 77E-03
1 206*00
1 17E-02
SF349 Grouse
1 62
0 206
4 106-03
1 206*00
4 926-03
6 39E-03
1 20b*00
7 666-03
1 166-02
1 206*00
1 396-02
256E-02
1 206*00
3 076-02
SF386 Pnnceton-Magma
00003
000003
6 75E-07
1 206*00
8 106-07
1 066-06
4.2BE+06
1 2flE-M
1 926-06
\ 20E*M
2 306-06
4 226-06
1 206*00
5 066-06
SF389 Unnamed Adit
0 011
0 001
2 486 06
i 4fiE*M
2 976-06
3 866-06
{ JAE.M
4 83E-K
7 036-06
t zce*oo
8 436-06
1 S5E-04
1 206*00
1 866-04
S^390 Reindeer Queen
0 011
0 001
2 486-05
\ JflE*fl6
J87E-M
3 866-06
1 206*00
i 83£«
7036-05
1 S4E.M
8.436-05
1 55E-04
1 206*00
1 866-04
Total EJIIuenl Plow
5"S53
total Loading l.WH-US
Total Loading " 111E-85
Total Loading S.BE-05
Total Loading THFBT
-------
South Fork Coeur d'Alene River Basin
TMDL Allocations
Lead(Pb)
North Fork Coeur d'Alene River @ Enaville
URS Greiner Station ID 400
Discharge
cfs
Loading
Capacity
(lbs/day)
Zinc
Background
(lbs/day)
7Q10L
165
4.81 E-01
1.87E-01
10tn Percentile
253
7.38E-01
2.87E-01
50th Percentile
845
2.47E+00
9.57E-01
90m Percentile
5,090
1.49E+01
5.77E+00
-------
South Fork Coaur d'Alana Rlvac Basin
TMDL Allocations
Laad (Pb)
South Fork Coeur d'Alana River 0 Plnhurst
URS Qrelnar Station ID 271
Allocated Loading
Final Loading
Dioehari*
eta
Loadlnt
Capacity
(»a«ay)
Z)no
8«l|r«und
(taa/day)
Uaad
Ca**oi V
<%•*•*)
1 156-01
100%
Safety
10%
(ftaMay)
Naa-Olaorata
•»%
Dtoorata
»%
(ftattay)
Non-Olaotata
(**+r)
Dtoorata
<»•"¦*>
70 WL
ea
9 33E-01
T7ME-65
7 41E-01
T4JE-M
4 81 E-01
1 66k *01
4 81fc-01
\ .UE-JH
1(r Percentile
97
1 266*00
1 0996-01
1 76E-01
9 74E-01
9 746-02
6 336-01
2436-01
6336-01
2.436-01
50"1 Percentile
268
2 506*00
3 096E-01
3 69E-01
1 636*00
1 836-01
1196*00
4 576-01
1 196*00
4576-01
90^" Parcantlla
1290
4 286*00
1 461E+00
1 19E+00
1 ese+oo
1.636-01
1.066+00
4 076-01
1 066+00
4076-01
Loading Allocations By Source
701OL
10r P«rcantHa
6(T Parcantlla
9CT Parcantlla
Station ID
Avaraf a
Dlachari*
(eta)
Proportion
of
OI*ofcV|a
Dtaaolvad
WLA
<»a/day)
Translator
Total
WLA
(ftortav)
Dtaaotvad
WLA
Translator
Total
WLA
(»a*ay)
Dtaaalwad
WLA
(»a«av)
Trail a*a tor
Tatal
WLA
OftaMay)
DtaaoJvad
WLA
<»oAday)
Tranaialor
Tatal
WLA
Ob a/day)
SF382 Silver Dollar
0015
0 001
1 85604
2 206+00
4 076-04
2 436-04
2 206+00
536E-04
4 576-04
2 206+00
1 006-03
4 06E-O4
2 206*00
8 936-04
SF393 Western Union (Lower Adit)
0 001
0 0001
1 236-06
2 206+00
2 716-06
1 626-06
2 206+00
3 576-06
3 046-06
2206+00
6 706-06
271E-06
2206*00
5 966-05
SF3CTP
4 990
0332
6 156-02
2 206+00
1 366-01
8 06E-02
2.206+00
1 786-01
1 526-01
2206+00
3 346-01
1 366-01
2206*00
2 976-01
SF620 Page STP
3 870
0 258
4 776-02
2 206+00
1 06E-01
6 276-02
2 206+00
1.966-01
1 186-01
2.206+00
2.596*01
1 066-01
2 206*00
2 31 E-01
SF383 St Joe
0X7
0 0006
6 636-06
2 206+00
1 906-04
1 136-04
2 206+00
2.506-04
2 136-04
2 206*00
4 666-04
1 906-04
2 206*00
4 176-04
SF384 Coeur cfeiene (Mineral Point)
0 005
0 0000
6 176-06
2 206+00
1 366-04
8 106*06
2 206+00
1 786-04
1 526-04
2.206+00
3 366-04
1 356-04
2 206*00
2 986-04
SF365 Unnamed Location (adit)
0 001
000006
8 636 06
2 206+00
1 906-06
1 136-06
2 206+00
2506-06
2 136-06
2206*00
4 66E-06
1 906-06
2 206*00
4 17E-05
SF600 Caladay
0 210
0014
2 596-03
2 206+00
5 706-03
3406-03
2.206+X
7466-03
6 306-03
2 206*00
1 416-02
5 696-03
2 206*00
1 256-02
SF602 Silver Valley Galena
1 300
0 087
1 606-02
2206+00
3 536-02
2.116-02
2206+00
4 64E-02
3966-02
2.206*00
8716-02
3526-02
2 206*00
7 746-02
SF623 Smetterville STP
0 421
0 028
5 19E-03
2 206+00
1 14E-02
6 826-03
2 206+00
1 506-02
1 286-02
2206+00
2 826-02
1 146-02
2 206*00
2 516-02
SF624 Sunshine 001 .SUN-1
3 120
0 208
3 856-02
2 206*00
6 466-02
5 066-02
2 206+00
1 116-01
9506-02
2 206*00
2 066-01
8 456-02
2 206*00
1 866-01
Silver Valley (Coeur)
0 775
0 062
9 566-03
2 206+00
2 106-02
1 266-02
2 206+00
2 766-02
2 366-02
2 206*00
5.196*02
2 106-02
2 206*00
4 626-02
Consolidated Silver
0 300
0 020
3 706-03
2 206+00
8 14E-03
4 866-03
2 206+00
1 076-02
9 14E-03
2 206+00
2 01E-02
8 136-03
2 206*00
1 796-02
ToTal E/lluent How
-mm
Total Loading
Total Loading zaat-ui
Total Loading I.87E-01
Total Loading
-------
South Fork Coeur d'Alene River Basin
TMDL Allocations
Lead(Pb)
Coeur d'Alene River @ Harrison
Allocated Loading
Discharge
cfs
Loading
Capacity
(lbs/day)
Zinc
Background
(lbs/day)
Used
Capacity1
(lbs/day)
100%
(lbs/day)
Safety
10%
(lbs/day)
Non-Discrete
90%
(lbs/day)
Discrete
0%
(lbs/day)
7Q10L
239
1 41E+00
2 705E-01
9.27E-01
2.14E-01
2.14E-02
1 93E-01
0 00E+00
10,n Percentile
348
1 96E+00
3 942E-01
1 26E+00
3.07E-01
3 07E-02
2.76E-01
0 00E+00
50,h Percentile
1,100
4.83E+00
1 246E+00
2.79E+00
8.01 E-01
8 01E-02
7.21 E-01
0 00E+00
90,h Percentile
6,870
2 00E+01
7 781E+00
7.39E+00
4.87E+00
4.87E-01
4.39E+00
0 00E+00
1 Used Capacity includes total loading allocations for South Fork Coeur d'Alene River and background allocations for the North Fork Coeur d'Alene River
i
I
-------
Hardness
Canyon
Ninemile
Wallace
Pine
Pinehurst
Enaville
Harrison
7Q10
56
73
57
25
101
25
47
10th
56
73
56
25
96
25
45
50th
45
63
47
25
71
25
36
90th
25
36
25
25
28
25
25
Criteria in ug/l
Canyon
Ninemile
Wallace
Pine
Pinehurst
Enaville
Harrison
7Q10
63.9
80.0
64.9
32.3
105.4
32.3
55.1
10th
63.9
80.0
63.9
32.3
101.0
32.3
53.1
50th
53.1
70.7
55.1
32.3
78.2
32.3
44.0
90th
32.3
44.0
32.3
32.3
35.5
32.3
32.3
Criteria in Ibs/ft3 "
Canyon
Ninemile
Wallace
Pine
Pinehurst Enaville
Harrison
7Q10
3.99E-06
5.00E-06
4.05E-06
2.02E-06
6.58E-06
2.02E-06
3.44E-06
10th
3.99E-06
5.00E-06
3.99E-06
2.02E-06
6.30E-06
2.02E-06
3.32E-06
50th
3.32E-06
4.41 E-06
3.44E-06
2.02E-06
4.88E-06
2.02E-06
2.75E-06
90th
2.02E-06
2.75E-06
2.02E-06
2.02E-06
2.22E-06
2.02E-06
2.02E-06
** conversion factor
=
6.2427E-08
U
Coefficients
3
0.8473
D
-0.7614
-------
South Fork Coeur d'Alene River Basin
Natural Background
Zinc (Zn)
Canyon
Nat. Background in ug/l 6.1
Nat. Background in Ibs/ft3 3.8E-07
background
Ninemile Wallace Pine Pinehurst Enaville Harrison
6.1 6.1 3.1 6.1 5 5.32
3.8E-07 3.8E-07 1.9E-07 3.8E-07 3.1E-07 3.3E-07
-------
Zinc Spreadsheet
-------
South Fork Coeur d'Alene Rfver Basin
TMOL Allocations
Zinc (Zn)
South Fork Coeur d'Alene River at Wallace
URS Qrelner Station ID 233
Allocated Loading
Final Loading
Olschargt
ote
Losdbtf
<»*/day)
Zinc
B*ok|tound
U»»d
CapaeJty
(»«/4*y)
100%
(ft*/d«y)
Sifity
10%
Non-OI*ctol»
«%
(ftoXtey)
Oteorato
K%
(»•*•*)
Nen-OI»Of«ti
(*•*••,)
If
7Q10L
22
7 74E+00
7
3 01E+00
i 66E+M
4 ME-fll
2 60E+00
9 99b-01
2 80E+00
9 ME-Oi
1(T Percentile
35
1 216+01
1 15E+00
4 638*00
6 296*00
6 296-01
4 006+00
1 576+00
4 006*00
1 576+00
5CT Percentile
79
2 356+01
2 60E+00
8 74E+00
1 21E+01
1 21E+00
7 886+00
3 036*00
7 886+00
3 036+00
9
Prof or Hon
of
DlschWf*
Diwotod
WLA
Tiin«lile«
To til
WLA
(»*/day)
Dfaaolvod
WLA
(»•«.»)
Transit tor
Total
WLA
(••May)
Dtoaolvod
WLA
<»•«•*>
TrmaUtot
ToM
WLA
<»•«•»)
Ctoolvod
WLA
(»•«•»)
Tran»lalor
Total
WLA
(HoMT)
SF 607 Lucky Friday 001
1 27
fl US
'"TUFBT
—rasras
TT3F7ST
¦JME-W
fBBE+BB
-T38E-BV
i 5SE-ST
1 OOE+OO
4 386-01
1 326+00
1 006+00
\ 5JE+M
SF609 Lucky Friday 003
065
0 096
9 596 02
\ t&.x
SS5E-B2
1 51601
TBBE+M
1 51E-01
2 916-01
1 OOt+OO
2 91E-01
8 84E-01
1 OOE+OO
8 84fc-01
SF328. (Morn waste rock)
1 59
0 180
1 79E01
1 ooe+oo
I 75T-8)
2 82601
THEM
2 826-01
S.44E-61
lflW+86
5 44E-01
1 65E+00
1 OOE+OO
1 6Sfc+00
SF 396 Square Deal
o oa
0009
9 036 03
fMP+ M
sbt-bs
1 426 02
TBE+Bfl
~HS-BS
474E-62
1 OOfc+OO
2 74E-02
8 32E-02
1 OOE+OO
8 32fc 02
SF395. Qdconda
003
0003
3 396-03
f mt+m
jsfbs
5 336-03
THEIM
5 33E-B3
1 64E-6i
'IBSE+flB
1 03E-02
3 12E-02
1 OOE+OO
3 12E-02
SF627 STP Mullen
0413
0 047
4 666-02
1 OOE+OO
4 38^85
7 346-02
TSBE+BS
~J 34E-6J
1 41E-01
fflaevss
1 41E-01
4 26E-01
1 OOE+OO
4 29E-01
SF338 Snowstorm t3
2 00
0 226
2 266 01
1 006+00
3 S4E-01
"rOT+OB
3 55E-fl^
6 846-01
{MP+M
B 84E-01
2 08E+00
1 OOE+OO
2 08E+00
SF-339 Copper King
0 0564
0006
6 376-03
1 006+00
8 376-03
1 00E-02
\ ME.M
\ ME-M
1 936-02
i ME+M
1 936-02
S 86E-02
1 OOE+OO
5 866-02
SF-345 Morning *4
0 0152
0 002
1 726-03
1 flCT7?5B
¦"TEFB5
2 70E-03
TBBETBB
17BE-B3
5 20E-03
fBBETBB
5STJ5
1 58E-02
1 OOE+OO
1 581: 02
SF346 Morning No 5
0 0111
0 001
1 25E-03
I SflF+BB
1 97E-03
\ ME+M
—T57P-53
3 806-03
T flBE+BB
' 3MF-89
1 15E-02
1 OOE+OO
( H5C-I15
SF347 Star 1200 level
0 695
0 079
7 846 02
i 6tE7!7
737H!?
1 23E-01
' (ME+M
-rae-sr
2 386-01
fsarro
7 23E 01
1 OOE+OO
it
SF349 Grouse
1 82
0 206
2 06E-01
\ 66F7EB
5T5BT75T
3 23E-01
TBBE7BB
SME-Bf
8 236-01
-TMK755
1 89E.00
1 OOE+OO
1 89E+00
SF386 Princeton-Magma
0 0003
0 00003
3 39E-05
1 006+00
3 39E-05
5 33£-M
1 OOE+OO
5 336-06
1 03E-04
1 OOE+OO
\ 43E-W
3 12E-04
1 OOfc+OO
3 12E04
SF389 Unnamed Adit
0 011
0 001
1 24E-03
1 006+00
1 246-03
1 95E-03
1 OOE+OO
""T&5E-63
3 76E-03
1 OOE+OO
3 78E-03
1 146-02
I 44E+M
\ UE-6S
SF390 Reindeer Queen
0 011
0 001
1 24E03
1 006+00
1 24E-03
1 95E-03
1 OOE+OO
1 95E-03
3 78E-03
1 006+00
3 786-03
1 14E 02
1 OOE+OO
1 14E-02
Tola! Effluent Plow
8 853
Total Loading"" 9J9E3T
Tot.ILo.dlng l.B7E«W
Tot.! Loading—3HE+M
T oT«l Loading 9.21 E+uu
-------
South Fork Coeur d AI*ne Riv»r Baaln
TMDL Allocations
Zinc (Zn)
Pin* Cratk
URS Qralnar Station D 313
Alocatad Loadtoa
Find Loadtag
Diaehtrgt
cte
Loaang
Capacity
(Iba/day)
Z)rc
Background
(ite/day)
uaed
Capacity
(Iba/day)
100%
(Iba/day)
Safaty
10%
(Iba/day)
NorvDkacrala
68%
(iba/aay)
Dlaorata
21%
Ob«/
(Iba/day)
PC3» North Amy
0 322
0 479
3 776 01
1 OOE+OO
3 776-01
5 47E-01
1 OOE+OO
5 476-01
1 516+00
1 006+00
1 51E+00
7 296+00
1 006+00
7 296+00
PC330 Amy
0 006
0 007
5 8SE-03
1 OOE+OO
5 656-03
6 496-03
1 006+00
6 496-03
2 346 02
1 006+00
2 346-02
1 136-01
1 OOE+OO
1 136-01
pC331 Libard King
0006
0 007
sasE-os
1 OOE+OO
5 656 03
6 496-03
1 006+00
6 496-03
2 346 02
1 006+00
2 346-02
1 136-01
1 006+00
1 136 01
=0332 Lookout
0 027
0 040
3 166-02
1 00E+00
3 166-02
4 566 02
1 006+00
4 566-02
1 266 01
1 006+00
1 266-01
6 126-01
1 006+00
6 126-01
PC333 Uppaf Lynch
0 001
0 001
1 17E-03
1 OOE+OO
1 176-03
1 706 03
1 006+00
1 706-03
4 066-03
1 006+00
4 666-03
2 276-02
1 006+00
2 276-02
PC334 Lynch Nat)OB
0 0006
0 001
7 026-04
1 006+00
7 026-04
1 026-03
1 006+00
1 026-03
2 816-03
1 006+00
2 616 03
1 366-02
1 OOE+OO
1 366-02
PC33S Navada-Siawart
0091
0 135
1 076-01
1 OOE+OO
1 076-01
1 546-01
1 006+00
1 546-01
4 266-01
1 006+00
4 266-01
2 066+00
1 OOE+OO
2 066+00
:>C336 Highland Sucpnsa
0 038
0 067
4 456-02
1 OOE+OO
4 456 02
6 456-02
1 006+00
6 456-02
1 766-01
1 006+00
1 786-01
8 61E-01
1 006+00
8 61E-01
PC375 Highland Surp WastaRoc*
0 011
0016
1 246-02
1 OOE+OO
1 246-02
1 606-02
1 006+00
1 806-02
4 986-02
1 006+00
4 966-02
2 406-01
1 006+00
2 406-01
pC337 Sidnay (Rad Cloud)
0 006
0009
7 026-03
1 OOE+OO
7 026-03
1 026 02
1 006+00
1 026-02
2 616-02
1 006+00
2 616-02
1 366-01
1 OOE+OO
1 366-01
pC340 Uppar LrttJa Piffcbufg
0 002
0003
2 34E-03
1 OOE+OO
2 346-03
3 396-03
1 006+00
3 396-03
9 376-03
1 006+00
9 37E-03
4 536-02
1 006+00
4 536-02
PC341 Lovw LrtBa fittrt>urg
0 006
0 009
7 026-03
1 OOE+OO
7 026 03
1 026 02
1 006+00
1 026-02
2 616-02
1 006+00
2 616-02
1 366-01
1 OOE+OO
1 366-01
PC343 Nabob l300Lavai
0 066
0 096
7 736-02
1 OOE+OO
7 73E-02
1 126-01
1 OOE+OO
1 126-01
3 006-01
1 006+00
3 066-01
1 506+00
1 OOE+OO
1 506+00
=>C344 Big it
0 001
0 002
1 24E-03
1 006+00
1 246-03
1 606-03
1 OOE+OO
1 606-03
4 966-03
1 006+00
4 966-03
2 406-02
1 OOE+OO
2 406-02
3C346 Uppar Conttrtuton
0 079
0 117
9 256-02
1 OOE+OO
9 256-02
1 346-01
1 006+00
1 346-01
3 706-01
1 OOE+OO
3.706-01
1 796+00
1 006+00
1 796+00
PC351 Mammon Tunnal
0009
0013
1 CUE-02
1 006+00
1 046-02
1 516-02
1 006+00
1.516*02
4 176-02
1 006+00
4 176-02
2 026-01
1 006+00
2 026-01
PC352 Saap Baiow Navada Stawart
0003
0004
3 266-03
1 OOE+OO
3 266-03
4 756-03
1 006+00
4 756-03
1 316-02
1 OOE+OO
1 316-02
6346-02
1 006+00
6346-02
PC 400 Adit Upstream of LiflU Pit&burg
0 0004
0 001
4 Q4E-04
1 OOE+OO
4 84E-04
710E-O4
1 OOE+OO
714E-04
1.ME-03
1 OOE+OO
1 06E-03
0 56E-03
1 OOE+OO
9S6E-03
5T5725S
TolBToad|22__ 7.17C-01
To&fUoadna 1.14C+0C
ToSToadno 3.15E+00
Total Loading V62E+01
-------
South Fork Coeur d'Alene River Batln
TMDL Allocations }
Zinc (Zn)
Nlnemlle Creak
URS Qrelner Station ID 305
Allocated Loading
Hnai Loading
OUohMfo
eb
Loadbi|
Ca**olty
(Iks/day)
Z)ft«
B4Mhf*und
Und
Capacity
(»a*ay)
100%
(»«May)
•ffrty
10%
(»•«•*)
Non-0 Iterate
as%
(fts/day)
Dhsoroli
2S%
Non
-------
South Fork Coeur d'Alene River Baain
TMDL Allocation* '
Zinc (Zn)
Canyon Creek
URS Qrelner Station ID 288
Allocated Loading
Nnai Loading
Dtaoharf*
ofc
Loodbif
Capaotty
O^o/day)
Zfc*
Baafcgrowid
<**+*)
Uaod
Co* aojty
(taoMay)
100%
Safety
10%
p» a/day)
Non4)taerota
SS%
<» a/day)
OlNr*b
2S%
Ob a/day)
Non-0 taorota
II
7Q10t-
7 1
245E+M
2.3366-01
AUEiU
2 22E+00
2225-fll
f44E+flfl
5 54E-0f
VWe+M
554E41
10" Parcantll*
11
3 79E+00
3.6196-01
0 006+00
3 436+00
3 436-01
2 236+00
esaE-oi
2 236+00
8 586-01
SOT Parctntlla
25
7186+00
8 225E-01
0 006+00
6 346+00
6 346-01
4126+00
1 59E+00
4126+00
1 596+00
9(T P«rc*ntll«
149
259E+01
4 9026+00
0 00E+00
2106+01
2.106+00
1 376+01
5 266+00
1.37E+01
S26E+00
Loading Allocatlona By Source
7Q10L
1
DlaSOlvOd
WLA
(»a*av)
Translator
Total
WLA
Dlnolvid
WLA
<»•*•*)
Translator
Total
WLA
flk«*ay)
DUaoJvod
WLA
(••Aday)
Translator
Total
WLA
(tka/day)
CC817 Heda 93
0068
0 008
4 586-03
1 ooE+oo
4 586-00
7 106-03
1.006+00
7 106-03
1 31E-02
1 006+00
1 31E-02
4 366-02
1 006+00
4 366-02
CC355^GEM
0260
0 031
1 746-02
1 006+00
1 746-02
2.706-02
1 006+00
2 706-02
4 996-02
1 006+00
4 996*02
1.666-01
1 006+00
1 666-01
CC816 (Star/Phx Tailings)
2.340
0 263
1 576-01
1 006+00
1 576-01
2 436-01
1 oo6+oo
2 436-01
4 496-01
1 006+00
4 496-01
1 496+00
1 006+00
1 496+00
CC367 (WPSeSp)
0004
0 000
2.55E-04
1 006+00
2 556-04
3 956-04
1.006+00
3956-04
7 296-04
1 006+00
7 296-04
2 426-03
1 006+00
2 426-03
CC372 Tam#7
1 590
0192
1 076-01
1 006+00
1 076-01
1 656-01
1 006+00
1 656-01
3 056-01
1 006+00
3 066-01
1 01E+00
1 006+00
1 01E + 00
CC363 Herculfts «5
1 707
0 207
V14E-01
1 006+00
1 14E-01
1 776-01
V006+00
1 77E-01
3 286-01
1 006+00
3 286-01
1 096+00
1 006+00
1 09E + 00
CC371 Blacttear Fraction
1 165
0 141
7 816-02
1 006+00
7 816-02
1 21E-01
1 006+00
1 216-01
2 246-01
1 006+00
2 246-01
7 426-01
1 006+00
7 426-01
CC373 Ancftor
0008
0 001
5 366-04
1 006+00
5 366-04
8.31 E-04
1 006+00
8 31 E-04
1 536-03
1 006+00
1 536-03
5 096-03
1 OOE+OO
5 09E-03
CC354 Hidden Treasure
0 720
0 067
4 636-02
1 006+00
4 836-02
7 48E-02
1 006+00
7 486-02
1 386-01
1 006+00
1 386-01
4 586-01
1 006+00
4 58E-01
Tiger/Poorman
0 400
0 048
2 66E-02
1 006+00
2 68E-02
4 15E-02
1 006+00
4 156-02
7 67E-02
1 006+00
7 67E-02
2 55E-01
1 006+00
2 55E-01
|Total SHIuent Plow
—T55S
TolaTToadTng THFCT
To7aTCoa3Tnjj—ffOTJJT
Total Loading 1.59E+O0
Total Loading b 26E+00
-------
South Fork Coeur d'Alene River Basin
TMDL Allocations
Zinc (Zn)
Sooth Fork Coeur d'Alene River 0 Plnehurst
URS Qrelner Station ID 271
Allocated Loading
Final Loading
Dlacharfa
cU
Loading
Capacity
ZVtc
Background
(»«*ay)
Uaad
Capacity
(IfcaAlay)
100%
(lfca^ay)
tihly
10%
(*•*•*>
Noa-0 borate
ei%
<»•«•*)
Otoorata
21%
(»•«•*)
NanOiaorala
(»aM«y)
Dteorata
(»«%,
7Q10L
68
3 87E+01
S237E+M
715E+M
2 93fc+01
2.936*00
1 90fc+01
7 32E+00
\ WE+fll
7 326+00
1(T Percentile
97
5 286+01
3 1916+00
1 096+01
3 886+01
3 886+00
2 526+01
9 696+00
2 526+01
9 696+00
50" Percentile
268
1 136+02
e eisE+oo
2 476+01
7 956+01
7 95E+00
5 176+01
^ 996+01
5 17E+01
1 996+01
9CT Percentile
1290
2 476+02
4 2446+01
9 776+01
1 07E+02
1 076+01
6 966+01
2 686+01
6 966+01
2 686+01
Loading Allocations By Source
7Q10L
19" Percentile
5CT Percentile
9tfn Percentile
Station 10
Avaraf a
Dlachaig*
(eta)
Proportion
of
Olacharg •
Otaaolvad
WLA
(fea/day)
Tranalator
Total
WLA
(ftaXUy)
Dtaaolvad
WLA
Oba/day)
Translator
Total
WLA
<»a/day)
Dtaaolvad
WLA
(fta/day)
Tranalator
Total
WLA
<»«/day)
Olaaolvad
WLA
(lb a/day)
Tranalator
Total
WLA
(Ik a/day)
SF382 Silver Dollar
0015
0 001
7 316-03
1 OOE+OO
7 316-03
9 686-03
1 006+00
9 686-03
1 99E-02
1 006+00
1 996-02
2 676-02
1 ooE+oo
2 67E-02
SF393 Western Umon (Lower AcJt)
0 001
0 0001
4 876-04
1 OOE+OO
4 87E 04
6 466-04
1 006+00
6 466-04
1 326 03
1 006+00
1 326-03
1 786 03
1 006+00
1 786-03
SF3CTP
4 990
0 332
2 436+00
1 OOE+OO
2 436+00
3 226+00
1 006+00
3 226+00
6 606+00
1 006+00
6 606+00
8 906+00
1 OOE+OO
8 906+00
SF620 Page STP
3 870
0 258
1 89E+00
1 OOE+OO
1 896+00
2 506+00
1 006+00
2 506+00
5 126+00
1 006+00
5126+00
6 90E+00
1 OOE+OO
6 906+00
SF383 St Joe
0 007
0 0005
3 416-03
1 006+00
3416 03
4 526-03
1 006+00
4 526-03
9 266-03
1 006+00
9 266-03
1 25E-02
1 OOE+OO
1 256-02
SF364 Coeur dalene (Mineral Point)
0 005
00003
2 446-03
1 006+00
2 446-03
3 236-03
1 006+00
3 236-03
6 626-03
1 006+00
6 626-03
8 92E-03
1 006+00
8 926-03
SF385 Unnamed Location (adit)
0 001
0 00006
3 416-04
1 006+00
3 41604
4 526-04
1 006+00
4 526-04
9 266-04
1 006+00
9 266-04
1 2SE-03
1 006+00
1 256-03
SF600 Caladay
0210
0 014
1 02E-01
1 006+00
1 026-01
1 366-01
1 006+00
1 366-01
2 786-01
1 006+00
2 786-01
3 746 01
1 OOE+OO
3 746-01
SF602 Stiver Valley QaJena
1 300
0 087
6 34E-01
1 006+00
6 346 01
8 396-01
1 006+00
8 396-01
1 726+00
1 006+00
1 726+00
2 326+00
1 OOE+OO
2 326+00
SF623 Smelterville STP
0 421
0 028
2 066-01
1 006+00
2 06601
2 726-01
1 006+00
2 726-01
5 576-01
1 006+00
5 576-01
7 51E-01
1 OOE+OO
7 516-01
SF624 Sunshine 001 SUN-1
3 120
0 208
1 52E+00
1 006+00
1 52E+00
2 016+00
1 006+00
2 016+00
4 136+00
1 006+00
4 136+00
5 566+00
1 OOE+OO
5 566+00
Stiver Valley (Coeur)
0 775
0 062
3 786-01
1 006+00
3 786-01
5 006-01
1 006+00
5 006-01
1 036+00
1 006+00
1 036+00
1 386+00
1 OOE+OO
1 386+00
Consolidated Silver
0 300
0 020
1 46601
1 006+00
1 466-01
1 94E-01
1 006+00
1 946-01
3 976-01
1 006+00
3 97E-01
5 356-01
1 OOE+OO
5 356-01
ToTal Effluent Tlo'w
15.0148U
Total Loading / 32&+40
Total Loading TBE+H
Tolal Loading T35M1
Total Loading 2Wb+oi
-------
South Fork Coeur d'Alene River Basin
TMDL Allocations
Zinc (Zn)
North Fork Coeur d'Alene River @ Enaville
URS Greiner Station ID 400
Discharge
cfs
Loading
Capacity
(lbs/day)
Zinc
Background
(lbs/day)
7Q10L
in
CO
2.87E+01
4.45E+00
10m Percentile
253
4.41 E+01
6.82E+00
50in Percentile
845
1.47E+02
2.28E+01
90tn Percentile
5,090
8.86E+02
1 37E+02
I
I
-------
South Fork Coeur d'Alene River Basin
TMDL Allocations
Zinc (Zn)
Coeur d'Alene River @ Harrison
Allocated Loading
Loading
Zinc
Used
Safety
Non-Discrete
Discrete
Discharge
Capacity
Background
Capacity1
100%
10%
90%
0%
cfs
(lbs/day)
(lbs/day)
(lbs/day)
(lbs/day)
(lbs/day)
(lbs/day^
(lbs/day)
7Q10L
239
7 10E+01
6 854E+00
3.37E+01
3.04E+01
3 04E+00
2 74E+01
PI
o
+
UJ
o
o
o
10,n Percentile
348
9.97E+01
9 988E+00
4 56E+01
4.41 E+01
4.41 E+00
3 97E+01
0 00E+00
50'" Percentile
1,100
2 61E+02
3157E+01
1 02E+02
1 27E+02
1 27E+01
1 14E+02
0 00E+00
90in Percentile
6,870
1 20E+03
1 972E+02
2.44E+02
7 55E+02
7.55E+01
6 79E+02
0 00E+00
1 Used Capacity includes total loading allocations for South Fork Coeur d'Alene River and background allocations for the North Fork Coeur d'Alene River
-------
APPENDIX I: HARDNESS DATA
-------
Canyon Creek
cc
287
6/7/94 12:00
Hardness
24
mg/l
cc
287
10/27/93 12:00
Hardness
56
mg/l
cc
287
12/17/93 12:00
Hardness
72
mg/l
cc
287
4/19/94 12:00
Hardness
28
mg/l
cc
287
7/25/94 12:00
Hardness
48
mg/l
cc
287
4/7/94 12:00
Hardness
32
mg/l
cc
287
6/23/94 12:00
Hardness
38
mg/l
cc
287
9/13/94 12:00
Hardness
52
mg/l
cc
287
5/4/94 12:00
Hardness
24
mg/l
cc
287
2/18/94 12:00
Hardness
60
mg/l
cc
287
1/20/94 12:00
Hardness
64
mg/l
cc
287
3/24/94 12:00
Hardness
48
mg/l
cc
287
5/19/94 12:00
Hardness
16
mg/l
cc
287
11/30/93 12:00
Hardness
64
mg/l
cc
287
8/16/94 12:00
Hardness
52
mg/l
cc
287
3/8/94 12:00
Hardness
48
mg/l
cc
288
11/18/98 12:00
Hardness
57
mg/l
cc
288
5/27/99 9:00
Hardness
11
mg/l
cc
288
5/24/99 4:30
Hardness
11
mg/l
cc
288
12/28/98 2:15
Hardness
47
mg/l
cc
' 288
10/26/981:20
Hardness
52
mg/l
cc
288
3/23/99 8:45
Hardness
31
mg/I
cc
288
12/15/9812:25
Hardness
48
mg/l
cc
288
10/26/98 1:15
Hardness
49
mg/l
cc
288
4/19/99 11:00
Hardness
22
mg/l
cc
288
6/15/99 9:15
Hardness
10
mg/l
cc
288
5/5/99 12:55
Hardness
21
mj^l
cc
288
6/2/99 10:30
Hardness
11
mg/l
In(flow)
FLOW
7-Jun-94
63.45
cfs
IDEQ
4.15
FLOW
27-Oct-93
13.28
cfs
IDEQ
2.59
FLOW
17-Dec-93
11.7
cfs
IDEQ
2.46
FLOW
19-Apr-94
300
cfs
IDEQ
5.70
FLOW
25-Jul-94
19.04
cfs
IDEQ
2.95
FLOW
7-Apr-94
37.82
cfs
IDEQ
3.63
FLOW
23-Jun-94
28.96
cfs
IDEQ
3.37
FLOW
13-Sep-94
15.89
cfs
IDEQ
2.77
FLOW
4-May-94
111.05
cfs
IDEQ
4.71
FLOW
18-Feb-94
11.41
cfs
IDEQ
2.43
FLOW
20-Jan-94
13.28
cfs
IDEQ
2.59
FLOW
24-Mar-94
21.13
cfs
IDEQ
3.05
FLOW
19-May-94
102.01
cfs
IDEQ
4.63
FLOW
30-Nov-93
12.62
cfs
IDEQ
2.54
FLOW
16-Aug-94
16.3
cfs
IDEQ
2.79
FLOW
8-Mar-94
22.26
cfs
IDEQ
3.10
FLOWUSGS
18-Nov-98
16
cfs
USGS
2.77
FLOWUSGS
27-May-99
261
cfs
USGS
5.56
FLOWUSGS
24-May-99
384
cfs
USGS
5.95
FLOWUSGS
28-Dec-98
27
cfs
USGS
3.30
FLOWUSGS
26-Oct-98
13
cfs
USGS
2.56
FLOWUSGS
23-Mar-99
97
cfs
USGS
4.57
FLOWUSGS
15-Dec-98
25
cfs
USGS
3.22
FLOWUSGS
26-Oct-98
13
cfs
USGS
2.56
FLOWUSGS
19-Apr-99
138
cfs
USGS
4.93
FLOWUSGS
15-Jun-99
263
cfs
USGS
5.57
FLOWUSGS
5-May-99
84
cfs
USGS
4.43
FLOWUSGS
2-Jun-99
241
cfs
USGS
5.48
mln
max
11.41
384
-------
Canyon Creek
100 200 300 400 500
Flow in efs
flow tiers flow In(fow) 5%hardn«ss
7Q10 11 2.40 58 (*)
10th 11 2.40 66
80th 25 3.22 45
90th 149 5.00 18
prediction calculated using lowest
measured flow of 11 cfs
-------
Ninemile Creek
NM
305
5/5/99 2:00
Hardness
43
mg/l
NM
305
5/27/99 7:45
Hardness
16
mg/l
NM
305
3/23/94 12:00
Hardness
84
mg/l
NM
305
6/23/94 12:00
Hardness
56
mg/l
NM
305
10/27/9811:35
Hardness
61
mg/l
NM
305
5/31/99 12:30
Hardness
17
mg/l
NM
305
12/10/98 8:05
Hardness
74
mg/l
NM
305
10/28/93 12:00
Hardness
79
mg/l
NM
305
6/7/94 12:00
Hardness
48
mg/l
NM
305
12/16/93 12:00
Hardness
88
mg/l
NM
305
9/8/94 12:00
Hardness
64
mg/l
NM
305
3/22/99 2:05
Hardness
56
mg/l
NM
305
6/15/99 2:15
Hardness
16
mg/l
NM
305
1/21/9911:25
Hardness
71
mg/l
NM
305
8/15/94 12:00
Hardness
60
mg/l
NM
305
4/19/99 1:00
Hardness
48
mg/l
NM
305
11/19/98 8:55
Hardness
75
mg/l
NM
305
4/19/94 12:00
Hardness
46
mg/l
NM
305
1/24/94 12:00
Hardness
96
mg/l
NM
305
2/18/94 12:00
Hardness
88
mg/l
NM
305
5/23/99 1:55
Hardness
24
mg/l
NM
305
5/4/94 12:00
Hardness
44
mg/l
NM
305
4/7/94 12:00
Hardness
68
mg/l
NM 1
305
7/20/94 12:00
Hardness
52
mg/l
NM
305
5/20/94 12:00
Hardness
32
mg/l
NM
305
12/2/93 12:00
Hardness
84
mg/I
NM
305
5/26/99 8:45
Hardness
16
mg/l
NM
305
3/8/94 12:00
Hardness
80
mg/l
•LOWUSG:
5-May-99
•LOWUSG:
27-May-99
FLOW
23-Mar-94
FLOW
23-Jun-94
LOWUSG!
27-Oct-98
LOWUSG!
31-May-99
LOWUSG!
10-Dec-98
FLOW
28-Oct-93
FLOW
7-Jun-94
FLOW
16-Dec-93
FLOW
8-Sep-94
LOWUSG!
22-Mar-99
LOWUSG:
15-Jun-99
LOWUSG!
21-Jan-99
FLOW
15-Aug-94
rLOWUSG!
19-Apr-99
:lowusg:
19-NOV-98
FLOW
19-Apr-94
FLOW
24-Jan-94
FLOW
18-Feb-94
:lowusg:
23-May-99
FLOW
4-May-94
FLOW
7-Apr-94
FLOW
20-Jul-94
FLOW
20-May-94
FLOW
2-Dec-93
lowusg:
26-May-99
FLOW
8-Mar-94
min
max
In(flow)
34
cfs
USGS
3.53
110
cfs
USGS
4.70
12.97
cfs
IDEQ
2.56
7.39
cfs
IDEQ
2.00
3.2
cfs
USGS
1.16
55
cfs
USGS
4.01
6
cfs
USGS
1.79
4.7
cfs
IDEQ
1.55
10.72
cfs
IDEQ
2.37
4.8
cfs
IDEQ
1.57
3.91
cfs
IDEQ
1.36
78
cfs
USGS
4.36
49
cfs
USGS
3.89
13
cfs
USGS
2.56
4.32
cfs
IDEQ
1.46
80
cfs
USGS
4.38
4
cfs
USGS
1.39
86.89
cfs
IDEQ
4.46
5.87
cfs
IDEQ
1.77
4.11
cfs
IDEQ
1.41
61
cfs
USGS
4.11
14.89
cfs
IDEQ
2.70
18.12
cfs
IDEQ
2.90
5.16
cfs
IDEQ
1.64
15.31
cfs
IDEQ
2.73
4.7
cfs
IDEQ
1.55
123
cfs
USGS
4.81
10.44
cfs
IDEQ
2.35
3.2
123
-------
Ninemlte Creek
Flow In cfs
flow tiers flow ln(flow) 5% hardness
3.2
1.16
73
(*>
3,2
1.16
73
f)
8.9
1.93
63
41
3.71
36
prediction calculated using lowest
measured flow of 3.2 cfs
-------
South Fork above Wallace
SF
220
10/26/93 12:00
Hardness
58
mg/l
SF
220
11/30/93 12:00
Hardness
60
mg/l
SF
220
1/19/94 12:00
Hardness
64
mg/l
SF
220
6/24/94 12:00
Hardness
40
mg/l
SF
220
9/9/94 12:00
Hardness
52
mg/l
SF
220
3/23/94 12:00
Hardness
56
mg/l
SF
220
7/23/94 12:00
Hardness
44
mg/l
SF
220
4/6/94 12:00
Hardness
36
mg/l
SF
220
5/20/94 12:00
Hardness
28
mg/l
SF
220
6/8/94 12:00
Hardness
32
mg/l
SF
220
4/18/94 12:00
Hardness
36
mg/l
SF
220
8/16/94 12:00
Hardness
60
mg/l
SF
220
5/3/94 12:00
Hardness
28
mg/l
SF
220
3/7/94 12:00
Hardness
48
mg/l
SF
220
2/15/94 12:00
Hardness
60
mg/l
SF
220
12/20/93 12:00
Hardness
66
mg/l
In(flow)
FLOW
26-Oct-93
21.26
cfs
IDEQ
3.06
FLOW
30-Nov-93
19.68
cfs
IDEQ
2.98
FLOW
19-Jan-94
22.52
cfs
IDEQ
3.11
FLOW
24-Jun-94
41.99
cfs
IDEQ
3.74
FLOW
9-Sep-94
19.68
cfs
IDEQ
2.98
FLOW
23-Mar-94
44.55
cfs
IDEQ
3.80
FLOW
23-Jul-94
24.81
cfs
IDEQ
3.21
FLOW
6-Apr-94
133.87
cfs
IDEQ
4.90
FLOW
20-May-94
167.55
cfs
IDEQ
5.12
FLOW
8-Jun-94
76.11
cfs
IDEQ
4.33
FLOW
18-Apr-94
331.49
cfs
IDEQ
5.80
FLOW
16-Aug-94
20.06
cfs
IDEQ
3.00
FLOW
3-May-94
160.83
cfs
IDEQ
5.08
FLOW
7-Mar-94
47.26
cfs
IDEQ
3.86
FLOW
15-Feb-94
18.94
cfs
IDEQ
2.94
FLOW
20-Dec-93
18.94
cfs
IDEQ
2.94
-------
aAlflh saal.^ a^Esfe.-g^.® 1II t &%>, 1! M8H «g&
soutn rorK aDove Wallace
1
100 200
Flow In eft
300
400
South Fork toiow Canyon and Nlnemlle Confluence*
18.94
331.49
flows In(ftows) 5% hardness
19 2.94 55 f|
21 3.04 54
47 3.85 45
279 8.63 21
• prediction calculated using lowest
measured flow of 19 cfs
flow-weighted
flow 5* hardness
33.2 87 f)
35.2 56
78.9 47
469 21
** The combined lowest flows
are higher than predicted 7Q10
Therefore, 10th percentile is used
for both flow Iters
-------
ooooo
Hi UJ UJ UJ HI
Q O O Q Q
oqpo
uu ui uj uj _
OOOOOQOO
o o o
UJ HI UJ
bbbbIb
m
mMJIflW JB
? N N ® 6 B
<*>
3^.88
Ulill S|I|
S A® A
!579i|
555t
585?
S||S
Iff#
5 5 5 5 5 5
oooooo
_J _J _J _J J _J
IL Ui IL IL IL IL
5 5 5?
oooo
_l J _J _l
u. u. u. U.
5J55
OOOO
_J -J J _J
u. a u. u.
IHIf
oooooooo
0,0.0.0.0.0,0.0.
-------
South Fork at Pinehurst
SF
271
2/17/94 12:00
Hardness
104
mg/l
SF
271
6/2/99 7:45
Hardness
22
mg/l
SF
271
11/30/93 12:00
Hardness
104
mg/l
SF
271
7/23/94 12:00
Hardness
88
mg/l
SF
271
12/21/93 12:00
Hardness
92
mg/l
SF
271
12/9/98 12:10
Hardness
90
mg/l
SF
271
12/9/98 12:00
Hardness
85
mg/l
SF
271
12/30/98 2:45
Hardness
36
mg/l
SF
271
4/20/99 2:00
Hardness
27
mg/l
SF
271
10/29/93 12:00
Hardness
100
mg/l
SF
271
4/18/94 12:00
Hardness
32
mg/l
SF
271
4/13/99 7:30
Hardness
53
mg/l
SF
271
10/26/98 10:15
Hardness
90
mg/l
SF
271
11/17/98 12:50
Hardness
96
mg/l
SF
271
11/17/98 12:55
Hardness
98
mg/l
SF
271
3/9/99 9:25
Hardness
54
mg/l
SF
271
2/8/99 3:00
Hardness
51
mg/l
SF
271
5/6/99 1:30
Hardness
35
mg/l
SF
271
5/20/94 12:00
Hardness
40
mg/l
SF
271
3/7/94 12:00
Hardness
50
mg/l
SF
271
6/8/94 12:00
Hardness
52
mg/l
SF
271
8/16/94 12:00
Hardness
100
mg/l
SF
271
3/23/94 12:00
Hardness
66
mg/l
SF
271
4/6/94 12:00
Hardness
40
mg/l
SF
271
5/3/94 12:00
Hardness
40
mg/l
SF
271
6/24/94 12:00
Hardness
76
mg/l
SF
271
1/21/94 12:00
Hardness
76
mg/l
FLOW
17-Feb-94
LOWUSG:
2-Jun-99
FLOW
30-NOV-93
FLOW
23-Jul-94
FLOW
21-Dec-93
LOWUSG!
9-Dec-98
LOWUSG!
9-Dec-98
LOWUSG!
30-Dec-98
LOWUSG!
20-Apr-99
FLOW
29-Oct-93
FLOW
18-Apr-94
LOWUSG!
13-Apr-99
LOWUSG!
26-Oct-98
LOWUSG!
17-NOV-98
LOWUSG!
17-NOV-98
LOWUSG!
9-Mar-99
LOWUSG!
8-Feb-99
LOWUSG!
6-May-99
FLOW
20-May-94
FLOW
7-Mar-94
FLOW
8-Jun-94
FLOW
16-Aug-94
FLOW
23-Mar-94
FLOW
6-Apr-94
FLOW
3-May-94
FLOW
24-Jun-94
FLOW
21-Jan-94
min
In(flow)
cfs
IDEQ
4.80
cfs
USGS
7.68
cfs
IDEQ
4.65
cfs
IDEQ
4.75
cfs
IDEQ
4.87
cfs
USGS
5.62
cfs
USGS
5.62
cfs
USGS
7.07
cfs
USGS
7.69
cfs
IDEQ
4.61
cfs
IDEQ
7.18
cfs
USGS
6.41
cfs
USGS
4.58
cfs
USGS
5.09
cfs
USGS
5.09
cfs
USGS
6.10
cfs
USGS
6.27
cfs
USGS
7.03
cfs
IDEQ
6.30
cfs
IDEQ
6.36
cfs
IDEQ
5.85
cfs
IDEQ
4.37
cfs
IDEQ
6.22
cfs
IDEQ
6.45
cfs
IDEQ
6.42
cfs
IDEQ
5.29
cfs
IDEQ
5.32
122
2160
105
116
130
275
275
1180
2180
100
1310
610
98
162
162
446
527
1130
542
580
346
79
502
632
612
198
205
79
-------
South Fork at Pinehurst
BlIllilHll
max
2180
flow Iters
flow In (flow)
5% hardness
7Q10
79 4.37
101 o
10th
97 4.57
98
50th
268 5.59
71
90m
1290 7.16
28
* prediction calculated using lowest
measured flow of 79 els
-------
Hardness in mgfl
o ®» 5 « 3 H 8
»8
I
8
z z
-n n
8
ss
*
zzzzzzzz
n ft n n nn in-n
ssssgggs I
&
w
slisslS
o t9
igs
Ii!8i«5S
g§«8g«Si
XXJIX
» »
rrrrrrrrrrr
~OOOOOOOOOO
cccccccccc
OOOOOOOOOO
i|sil£lsnf
?f*s?|f
8S8ggSggS8g
£§§§£
IO
8*
ccccccccccc
wmmmmwwmmmm
OOOOOO0O0DO
mmmmmmmwmmm
-------
CdA River at Harrison
LC
60
5S HARRI
11/16/98 11:30
Hardness
47
LC
60
3S HARRI
4/21/99 11:15
Hardness
14
LC
60
3S HARRI
6/17/99 9:45
Hardness
16
LC
60
3S HARRI
12/14/98 11:15
Hardness
32
LC
60
3S HARRI
3/23/9912:15
Hardness
17
LC
60
3S HARRI
5/27/99 9:00
Hardness
13
LC
60
BS HARRI
5/6/99 1:30
Hardness
18
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
Hardness
44
34
20
20
20
20
24
32
32
24
24
32
36
44
40
56
52
40
24
28
20
28
36
28
24
32
40
In(flow)
mg/l
LOWUSG! 16-NOV-98
1100
cfs
USGS
7.00
mg/l
LOWUSG! 21 -Apr-99
10700
cfs
USGS
9.28
mg/l
LOWUSG! 17-Jun-99
6150
cfs
USGS
8.72
mg/l
LOWUSG! 14-Dec-98
2440
cfs
USGS
7.80
mg/l
LOWUSG! 23-Mar-99
7850
cfs
USGS
8.97
mg/l
LOWUSG! 27-May-99
12400
cfs
USGS
9.43
mg/l
LOWUSG! 6-May-99
8320
cfs
USGS
9.03
mg/l
IDEQ 10/6/94
281
cfs
IDEQ
5.64
mg/l
IDEQ 11/22/94
444
cfs
IDEQ
6.10
mg/l
IDEQ 12/16/94
774
cfs
IDEQ
6.65
mg/l
IDEQ 1/12/95
4822
cfs
IDEQ
8.48
mg/l
IDEQ 2/16/95
2626
cfs
IDEQ
7.87
mg/l
IDEQ 3/7/95
3326
cfs
IDEQ
8.11
mg/l
IDEQ 3/23/95
8328
cfs
IDEQ
9.03
mg/l
IDEQ 4/14/95
4631
cfs
IDEQ
8.44
mg/l
IDEQ 4/25/95
4235
cfs
IDEQ
8.35
mg/l
IDEQ 5/11/95
5456
cfs
IDEQ
8.60
mg/l
IDEQ 5/24/95
3064
cfs
IDEQ
8.03
mg/l
IDEQ 6/12/95
1723
cfs
IDEQ
7.45
mg/l
IDEQ 6/28/95
1369
cfs
IDEQ
7.22
mg/l
IDEQ 7/12/95
934
cfs
IDEQ
6.84
mg/l
IDEQ 7/26/95
634
cfs
IDEQ
6.45
mg/l
IDEQ 8/15/95
504
cfs
IDEQ
6.22
mg/l
IDEQ 9/14/95
414
cfs
IDEQ
6.03
mg/l
IDEQ 10/18/95
1377
cfs
IDEQ
7.23
mg/l
IDEQ 11/21/95
3172
cfs
IDEQ
8.06
mg/l
IDEQ 12/28/95
2430
cfs
IDEQ
7.80
mg/l
IDEQ 1/18/96
9036
cfs
IDEQ
9.11
mg/l
IDEQ 2/28/96
4063
cfs
IDEQ
8.31
mg/l
IDEQ 3/27/96
2986
cfs
IDEQ
8.00
mg/l
IDEQ 4/18/96
7272
cfs
IDEQ
8.89
mg/l
IDEQ 5/9/96
3508
cfs
IDEQ
8.16
mg/l
IDEQ 6/20/96
1733
cfs
IDEQ
7.46
mg/l
IDEQ 7/23/96
711
cfs
IDEQ
6.57
-------
Hardness
Hardness
50 mg/l
56 mg/l
CdA River at Harrison
80
—
Hi
5000 10000
Flow In cfs
15000
IDEQ 8/21/96 427 Cfs
IDEQ 9/26/96 388 cfs
IDEQ
IDEQ
6.06
5.31
min 281
max 12400
flow In(flow) 5% hardness
2S1
5.64
47 n
348
5.85
45
1100
7.00
36
6870
8.83
19
* prediction calculated wing lowest
measured flow of 281 cfs
-------
APPENDIX J: TRANSLATOR DATA
-------
Canyon Creek
Site 10
Date
Method
Metal
Result
Diss/Total
sqrt
arcsine
CC
288
09-NOV-97
Dissolved *
Cadmium
20.2
CC
288
09-NOV-97
Total
Cadmium
18.2
CC
287
05-Oct-91
Dissolved
Cadmium
21.6
CC
287
05-Oct-91
Total
Cadmium
20.8
CC
287
27-Oct-93
Total
Cadmium
22
CC
287
27-Oct-93
Dissolved
Cadmium
26
CC
287
30-Nov-OT
Total
Cadmium
22
CC
287
30-NOV-93
Dissolved
Cadmium
26
CC
287
17-Dec-93
Total
Cadmium
33
0.94
0.97
1.32
CC
287
17-Dec-93
Dissolved
Cadmium
31
CC
287
20-Jan-94
Dissolved
Cadmium
33
0.87
0.93
1.20
CC
287
20-Jan-94
Total
Cadmium
38
CC
287
18-Fab-94
Total
Cadmium
30
0.93
0.97
1.31
CC
287
18-Feb-94
Dissolved
Cadmium
28
CC
287
08-Mar-94
Total
Cadmium
26
CC
287
06-Mar-94
Dissolved
Cadmium
27
CC
287
24-Mar-94
Total
Cadmium
26
CC
287
24-Mar-94
Dissolved
Cadmium
27
CC
287
07-Apr-94
Total
Cadmium
18
0.94
0,97
1.33
CC
287
07-Apf-94
Dissolved
Cadmium
17
CC
287
19-Apr-94
Total
Cadmium
8.6
0.81
0.90
1.12
CC
287
19-Apr-94
Dissolved
Cadmium
7
CC
287
04-May-94
Total
Cadmium
8-2
CC
287
04-May*94
Dissolved
Cadmium
8.3
CC
287
19-May-94
Dissolved
Cadmium
7,5
0.97
0.99
1.41
CC
287
19-May-94
Total
Cadmium
7.7
CC
287
07-Jurt-94
Dissolved
Cadmium
11
0.92
0.96
158
CC
287
07-Jun-94
Total
Cadmium
12
CC
287
23-Juri-94
Dissolved
Cadmium
13
0.93
0.96
1.30
CC
287
23-Jun-94
Total
Cadmium
14
CC
287
25-Jul-94
Total
Cadmium
18
0.89
0.94
1.23
CC
287
25-J ul-94
Dissolved
Cadmium
16
CC
287
te-Aufl-94
Total
Cadmium
19
CC
287
16-Aug-94
Dissolved
Cadmium
20
CC
287
13-Sep-94
Dissolved
Cadmium
20
0.85
0.98
1.35
CC
287
13-Sep-94
Total
Cadmium
21
CC
287
t6-Oct-94
Total
Cadmium
21
0.95
0 98
1.35
CC
287
16-OC1-94
Dissolved
Cadmium
20
CC
287
16-Nov-94
Dissolved
Cadmium
32
1.00
1.00
1.57
CC
287
16-NOV-94
Total
Cadmium
32
CC
287
13-Dec-94
Total
Cadmium
38
CC
287
13-Dec-94
Dissolved
Cadmium
41
CC
287
tO-Jan-95
Dissolved
Cadmium
38
0.97
0.99
1.41
CC
287
10-Jar>-95
Total
Cadmium
39
CC
287
09-Feb-95
Dissolved
Cadmium
19
1.00
100
1 57
CC
287
09-Feb-95
Total
Cadmium
19
-------
cc
287
08-Mar-95
Total
Cadmium
16
0.94
0.97
1.32
cc
287
08Mar-95
Dissolved
Cadmium
15
cc
287
22-Mar-95
Dissolved
Cadmium
21
0.88
094
1.21
cc
287
22-Mar-9S
Total
Cadmium
24
cc
287
12-Apr-95
Dissolved
Cadmium
15
1.00
1.00
1.57
cc
287
12-Apr-95
Total
Cadmium
15
cc
287
25-Apr-95
Dissolved
Cadmium
12
1.00
1.00
1.57
cc
287
25-Apr-95
Total
Cadmium
12
cc
287
10-May-95
Dissolved
Cadmium
7.8
1.00
1,00
1.57
cc
287
10-May-95
Total
Cadmium
7.8
cc
287
23-May-95
Total
Cadmium
7
0.99
0.99
1.45
cc
287
23-May-95
Dissolved
Cadmium
6,9
cc
287
13-Jun-95
Dissolved
Cadmium
7
cc
287
13-Jun-95
Total
Cadmium
6.8
cc
287
27-Jurv95
Total
Cadmium
8.4
1.00
1.00
1.57
cc
287
27-Jun-9S
Dissolved
Cadmium
8.4
cc
287
11-Jul-95
Dissolved
Cadmium
11
0.92
0.96
1.28
cc
287
11-Jtrf-95
Total
Cadmium
12
cc
287
25-JuI-95
Dissolved
Cadmium
14
1.00
1.00
1.57
cc
287
25-Jul-95
Total
Cadmium
14
cc
287
14-Aug-95
Total
Cadmium
18
0.94
0.97
1.33
cc
287
14-AU9-95
Dissolved
Cadmium
17
cc
287
13-Sep-95
Dissolved
Cadmium
20
1.00
1.00
1.57
cc
287
13-Sep-95
Total
Cadmium
20
cc
287
18-Oct-95
Dissolved
Cadmium
200
cc
287
16-Oct-95
Total
Cadmium
21
cc
287
21-Nov-95
Total
Cadmium
13
0.8S
0.92
1.17
cc
287
21-NOV-95
Dissolved
Cadmium
11
cc
287
27-DSC-95
Total
Cadmium
18
1.00
1.00
1.57
cc
287
27-Dec-95
Dissolved
Cadmium
18
cc
287
17-Jan-96
Total
Cadmium
27
0.96
0.98
1.38
cc
287
17-Jar>96
Dissolved
Cadmium
26
cc
287
29-Fe6-96
Dissolved
Cadmium
15
1.00
1.00
1,57
cc
287
29-Feb-96
Total
Cadmium
15
cc
287
28-Mar-96
Dissolved
Cadmium
15
0.94
0.97
1.32
cc
287
28-Mar-96
Total
Cadmium
16
cc
287
17-Apf-96
Dissolved
Cadmium
9
0.95
0.97
1.34
cc
287
17-Apr-96
Total
Cadmium
9.5
cc
287
0&-May-96
Total
Cadmium
12
0.92
0.96
1.28
cc
287
08-May-96
Dissolved
Cadmium
11
cc
287
19-Jur>-96
Total
Cadmium
5.8
1.00
1.00
1.57
cc
287
1 9-Jur>-96
Dissolved
Cadmium
5.8
cc
287
24-Jul-96
Dissolved
Cadmium
14
1.00
1.00
1.57
cc
287
24-Jul-96
Total
Cadmium
14
cc
287
21-Aug-96
Dissolved
Cadmium
23
0.96
0.98
1.37
cc
287
21 Aug-96
Total
Cadmium
24
cc
287
26-Sep-96
Total
Cadmium
23
cc
287
26-Sep-96
Dissolved
Cadmium
24
cc
287
09-Nov-97
Dissolved
Cadmium
19.8
cc
287
09-NOV-9?
Total
Cadmium
17.8
cc
287
13-Jan-98
Total
Cadmium
31
0.98
0.99
1.42
-------
cc"
287
13-Jan-98
Dissolved
Cadmium
30.3
cc
288
13Jan-98
Total
Cadmium
31.5
0.97
0.99
1.40
cc
288
13-Jan-98
Dissolved
Cadmium
30.6
cc
287
14-May-98
Dissolved
Cadmium
5 2
cc
287
14-May-98
Total
Cadmium
5.1
cc
288
14-May-98
Total
Cadmium
5.2
cc
288
14-May-98
Dissolved
Cadmium
54
cc
288
17-May-98
Total
Cadmium
6.7
1.00
1.00
1.57
cc
288
17-May-98
Dissolved
Cadmium
6.7
1999 Data
Cadmium
Dissolved
Total
cc
288
02^Jun-99
4.4
5
0.88
0.94
122
cc
288
05-AU9-99
12
12.6
0.95238095
0.98
1.35
cc
288
08-Jui-99
5
5.4
0.92592593
0.96
1.30
cc
288
15-0oc-98
28
31
0.90322581
0.95
1.25
cc
288
15-Jun-99
3.6
4
0.9
0.95
1.25
cc
288
19-Apr-99
14
15
0.93333333
0.97
1.31
cc
288
23-Mar-99
26
26
1
1.00
1.57
cc
288
24-May-99
5.8
11
0.52727273
0.73
0.81
cc
288
27-May-99
4.8
5
0.96
0.98
1.37
cc
288
28-Dec-98
30
32
0.9375
0.97
1.32
cc
288
30-Aug-99
15
15
1
1.00
1.57
count
49.00
stddev
0.16
caJc
1.64
re-trans
1.00
95th
1.00
trans
1.00
cc
287
13-Jun-9S
Dissolved
Lead
27
0.73
0.85
1.02
cc
287
13-Jun-95
Total
Lead
37
cc
287
05-OCJ-91
Total
Lead
55
0.36
0.80
0.65
cc
287
05-Oct-91
Dissolved
Lead
20
cc
287
27-Oct-93
Total
Lead
56
0,98
0.99
1.44
cc
287
27-Oct-93
Dissolved
Lead
55
cc
287
30-Nov-93
Dissolved
Lead
34
055
0.74
0.83
cc
287
30-Nov-93
Total
Lead
62
cc
287
17-Dec-93
Dissolved
Lead
46
082
0.91
1.13
cc
287
17-Dec-93
Total
Lead
56
cc
287
20-Jan-94
Dissolved
Lead
38
0.64
0.80
0,93
cc
287
20-Jan-94
Total
Lead
59
cc
287
18-Feb-94
Dissolved
Lead
36
0.69
0.83
0.98
cc
287
18-Feb-94
Total
Lead
52
cc
287
08-Mar-94
Dissolved
Lead
38
0.69
0.83
0.98
cc
287
08-Mar-94
Total
Lead
55
cc
287
24-Mar-94
Total
Lead
53
0.70
0.84
0.99
cc
287
24-Mar-94
Dissolved
Lead
37
cc
287
07-Apr-94
Total
Lead
47
0.74
0 86
1.04
-------
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
287
.24
J6
,06
W
m
m
,04
.97
m
02
E.
ee
£2
80
m
90
56
96
02
07
03
£1
03
21
07-Apr-94
Dissolved
Lead
35
19-Apr-94
Total
Lead
383
0.06
19-Apr-94
Dissolved
Lead
22
04-May-94
Dissolved
Lead
28
0.67
04-May-94
Total
Lead
42
i9-May-94
Dissolved
Lead
26
0.76
19-May-94
Total
Lead
34
07-Jur>-94
Dissolved
Lead
29
0.74
07-Jurt-94
Total
Lead
39
23-Jun-94
Total
Lead
49
0.69
23-Jun-94
Dissolved
Lead
34
25-Jul-94
Total
Lead
55
0.76
25-JID-94
Dissolved
Lead
42
16-Aug-94
Total
Lead
62
0.74
l6-Aug-94
Dissolved
Lead
46
13-Sep-94
Total
Lead
53
0.68
13-Sep* 94
Dissolved
Lead
36
16-Oct-94
Dissolved
Lead
31
0.82
16-Oct-94
Total
Lead
50
16-Nov-94
Dissolved
Lead
40
0.68
16-NOV-94
Total
Lead
59
13-Dec-94
Total
Lead
54
0.72
13-Dec-94
Dissolved
Lead
39
10-Jan-95
Total
Lead
137
0.29
10-Jan-95
Dissolved
Lead
40
09-Feb-95
Total
Lead
44
0.58
09-Feb-95
Dissolved
Lead
26
Oe-Mar-95
Dissolved
Lead
22
0.71
08-Mar-95
Total
Lead
31
22-Mar-95
Total
Lead
66
0.52
22-Mar-95
Dissolved
Lead
34
12-Apr-95
Dissolved
Lead
27
0.59
12-Apr-95
Total
Lead
46
25-Apr-95
Dissolved
Lead
22
0.61
25-Apr-95
Total
Lead
36
10-May-95
Dissolved
Lead
23
028
10-May-95
Total
Lead
82
23-May-95
Total
Lead
33
0.67
23-May 95
Dissolved
Lead
22
27-Jun-95
Total
Lead
36
0.72
27-Jun-95
Dissolved
Lead
26
11 -Jul-95
Dissolved
Lead
34
0.77
11-Jul-95
Total
Lead
44
25-Jul»95
Total
Lead
45
0.73
25-JUI-95
Dissolved
Lead
33
4-Aug-95
Total
Lead
58
0.62
4~Aug»95
Dissolved
Lead
36
3-Sep-95
Dissolved
Lead
38
0 73
3-Sep-95
Total
Lead
52
8-Oct-95
Dissolved
Lead
48
0.11
8-OC1-95
Total
Lead
424
-------
cc '
287
21-NOV-95
Total
Lead
680
0,07
026
0.26
cc
287
21-NOV-95
Dissolved
Lead
45
cc
287
27-Dec-95
Dissolved
Lead
55
0.51
071
0.79
cc
287
27-Dec-95
Total
Lead
108
cc
287
17-Jan-96
Dissolved
Lead
223
0.88
0.94
1,21
cc
287
17- Jan-96
Total
Lead
254
cc
287
29-Feb-96
Total
Lead
282
0.16
0.40
0.41
cc
287
29-Feb-96
Dissolved
Lead
45
cc
287
28-Mar-96
Dissolved
Lead
53
0.54
0.74
0.83
cc
287
2&-Mar-96
Total
Lead
98
cc
287
17-Apr-96
Dissolved
Lead
55
0.40
0.64
0.69
cc
287
17-Apr-96
Total
Lead
136
cc
287
08-May-96
Dissolved
Lead
66
0.30
0.55
0.58
cc
287
Q8-May-96
Total
Lead
219
cc
287
19-Jun~96
Dissolved
Lead
36
0.49
0.70
0.77
cc
287
19-Jurv96
Total
Lead
74
cc
287
24-Ju)-96
Total
Lead
132
0.50
0.71
0.79
cc
287
24-Jul-96
Dissolved
Lead
66
cc
287
21-Aug-96
Dissolved
Lead
94
0.30
0.55
0.58
cc
287
21-Aug-96
Total
Lead
314
cc
287
2&-Sep-96
Total
Lead
588
0.17
0.41
0.42
cc
287
26*Sep-96
Dissolved
Lead
96
cc
288
09-NOV-97
Dissolved
Lead
49.9
0.64
0.80
0.93
cc
288
09-Nov-97
Total
Lead
77.5
cc
287
09-NOV-97
Dissolved
Lead
50.8
0.68
0.82
0.97
cc
287
09-NOV-97
Total
Lead
74,7
cc
287
13*Jfin*98
Dissolved
Lead
24.7
0.83
0.91
1.14
cc
288
13-Jan-98
Dissolved
Lead
29.9
cc
288
13-Jan-98
Total
Lead
115
0.64
0.80
0,93
cc
287
13-Jan-98
Total
Lead
179
cc
288
14-May-9e
Dissolved
Lead
25.3
0.52
0.72
0.80
cc
287
14-May-98
Total
Lead
48.8
cc
288
14May-B8
Total
Lead
51.1
0.50
0.71
0.79
cc
287
14-May-ee
Dissolved
Lead
25.7
cc
288
17-May-96
Total
Lead
64.3
cc
288
17-May-98
Dissolved
Lead
66.1
1999 Data
Lead
Dissolved
Total
cc
288
02*Jun-99
23
99
0.23232323
0.48
0.50
cc
288
05-Aug-99
31
58.9
0.52631579
0.73
0.81
cc
288
05-May-99
22
55
0.4
0.63
0.68
cc
288
08-Jul-99
20
33.2
0.60240964
0.78
089
cc
288
15-Dec-98
29
52
0.55769231
0.75
0.84
cc
288
15-Jun-99
18
150
0.12
0.35
0.35
cc
288
18-Nov-98
32
49
0.65306122
081
0.94
cc
288
19-Apr-99
22
370
0.05945946
024
0.25
cc
288
23-Mar-99
40
120
0.33333333
0.58
0.62
'cc
288
24-May-99
26
2000
0.013
0.11
0.11
cc
288
26-Oct-98
31
43
0.72093023
0,85
1.01
-------
cc
288
27-May-99
17
250
0,068
0.26
0.26
cc
288
28-Oec-98
31
230
0,13478261
0.37
0,38
cc
288
30-Aug-99
37
50.5
0,73267327
0.86
1.03
count
66.00
stddev
0.27
calc
1J27
re-trans
0.95
95th
0.91
trans
1.10
cc
287
22-Mar-95
Total
Zinc
3970
0.92
0.96
1J28
cc
287
22-Mar-9S
Dissolved
Zinc
3640
cc
287
OS-Oct-91
Total
Zinc
3430
cc
287
05-Oct-91
Dissolved
Zinc
3440
cc
287
27-Oct-93
Dissolved
Zinc
3470
cc
287
27-Oct-93
Totai
Zinc
3420
cc
287
30-Nov-93
Dissolved
Zinc
3980
0.98
0.99
1.44
cc
287
30-Nov-93
Total
Zinc
4050
cc
287
17-Dec-93
Total
Zinc
5180
cc
287
17-Doc-93
Dissolved
Zinc
5440
cc
287
2CWan-94
Dissolved
Zinc
5240
cc
287
20-Jan-94
Total
Zinc
5050
cc
287
1B-Feb-94
Dissolved
Zinc
4740
cc
287
18-Feb-94
Total
Zinc
4620
cc
287
08-Mar-94
Total
Zinc
4460
1.00
1.00
1.50
cc
287
08-Mar-94
Dissolved
Zinc
4440
cc
287
24-Mar-94
Total
Zinc
4600
cc
287
24-Mar-94
Dissolved
Zinc
4660
cc
287
07-Apr-94
Dissolved
Zinc
2440
cc
287
07-Apr-94
Total
Zinc
2350
cc
287
19-Apr-94
Dissolved
Zinc
1050
0.90
0.95
1.24
cc
287
19-Apr-94
Total
Zinc
1170
cc
287
04-May-94
Dissolved
Zinc
1200
cc
287
04-May-94
Total
Zinc
1160
cc
287
19-May-94
Dissolved
Zinc
1010
cc
287
19- May-94
Totai
Zinc
1000
cc
287
07-Jun-94
Dissolved
Zinc
1570
cc
287
07-Jun-94
Total
Zinc
1520
cc
287
23-Jun-94
Dissolved
Zinc
1720
cc
287
23-Jun-94
Total
Zinc
1690
cc
287
25-Jul-94
Dissolved
Zinc
2490
cc
287
25-Jul-94
Total
Zinc
2390
cc
287
16-Aug-94
Total
Zinc
2850
cc
287
16-Aug-94
Dissolved
Zinc
2940
cc
287
13-Sep-94
Total
Zinc
2880
cc
287
13-Sep94
Dissolved
Zinc
3020
cc
287
16-Oct-94
Total
Zinc
3430
-------
cc
287
16-Oct-94
Dissolved
Zinc
3480
cc
287
16-NOV-94
Tolal
Zinc
5500
cc
287
16-NOV-94
Dissolved
Zinc
5810
cc
287
13-D0C-94
Total
Zinc
6640
cc
287
13-Dec-94
Dissolved
Zinc
6730
cc
287
IO-Jan-95
Dissolved
Zinc
6370
cc
287
10-Jan-95
Total
Zinc
6320
cc
287
G9-Feb-95
Total
Zinc
3230
cc
287
09-Feto-95
Oissotved
Zinc
3380
cc
287
08-Mar-95
Total
Zinc
2530
cc
287
OB-Mar-95
Dissotvad
Zinc
2550
cc
287
12-Apr 96
Total
Zinc
2550
0.98
0.99
1.43
cc
287
12-Apr-95
Dissolved
Zinc
2500
cc
287
25-Apr-95
Dissolvad
Zinc
2100
1.00
1.00
1.57
cc
287
25-Apr-95
Total
Zinc
2100
cc
287
10-May-95
Total
Zinc
905
0 95
0.96
1.35
cc
287
IO-May-95
Dissolved
Zinc
861
cc
287
23-May-96
Dissolvad
Zinc
602
cc
287
23-May-95
Total
Zinc
786
cc
287
13-Jun-95
Dissolvad
Zinc
906
0.99
0.99
1.45
cc
287
13-Jun-95
Total
Zinc
91S
cc
287
27-Juf)-95
Dissolved
Zinc
1260
cc
287
27-sJurv85
Total
Zinc
1220
cc
287
11-Jui-95
Total
Zinc
1690
cc
287
11 -Jul-95
Dissolved
Zinc
1700
cc
287
25-Jul-95
Total
Zinc
1770
cc
287
25-Jul-95
Dissolved
Zinc
1790
cc
287
U-Aufl-95
Total
Zinc
2490
cc
287
H-Aub-95
Dissolved
Zinc
2580
cc
287
13-Sep-35
Dissolved
Zinc
2800
cc
287
13-Sep-95
Total
Zinc
2780
cc
287
18-Oct-95
Total
Zinc
3020
0.97
0.98
1.40
cc
287
18-Oct-95
Dissolved
Zinc
2930
cc
287
21 -Nov-95
Total
Zinc
1960
0.85
0.92
1.18
cc
287
21-NOV-95
Dissolved
Zinc
1670
cc
287
27-Dec-95
Dissolved
Zinc
2580
cc
287
27-D9C-95
Total
Zinc
2500
cc
287
17-Jan-96
Dissolved
Zinc
3870
cc
287
17-Jan-96
Total
Zinc
3830
cc
287
29-Feto-96
Dissolved
Zinc
2310
0.97
0.99
1.41
cc
287
29-Feto-96
Total
Zinc
2370
cc
287
28-Mar-96
Dissolved
Zinc
2220
1.00
1.00
1.50
cc
287
28-Mar-96
Total
Zinc
2230
cc
287
17-Apr-96
Total
Zinc
1230
0.99
1.00
1.48
cc
287
17-Apr-96
Dissolved
Zinc
1220
cc
287
08-May-96
Dissolved
Zinc
1650
0.99
1.00
1.49
cc
287
OS-May-96
Total
Zinc
1660
cc
287
19-Jun-96
Total
Zinc
836
cc
287
i9-Jun-96
Dissolved
Zinc
843
cc
287
24-Jul-96
Total
Zinc
1550
1 00
1.00
1.57
cc
287
24-Jul-96
Dissolved
Zinc
1550
-------
cc
287
21-Aug-96
Total
Zinc
3730
0.70
0.84
0.99
cc
287
21-Aug-96
Dissolved
Zinc
2620
cc
287
26-Sep-96
Total
Zinc
2770
0.95
098
1.35
cc
287
26-Sep-96
Dissolved
Zinc
2640
cc
287
OQ-Nov-97
Dissolved
Zinc
2610
0.95
0.97
1.34
cc
288
09-Nov-97
Dissolved
Zinc
2680
cc
288
09-Nov-97
Total
Zinc
2750
1.00
1.00
1,57
cc
287
09-NOV-97
Total
Zinc
2680
cc
287
13-Jan-98
Dissolved
Zinc
4200
0.95
0.98
1.35
cc
288
13-Jan-98
Total
Zinc
4410
cc
287
13-Jar>-98
Total
Zinc
4270
0.99
0.99
1.45
cc
288
13-Jan-98
Dissolved
Zinc
4210
cc
287
14-May-98
Dissolved
Zinc
688
cc
288
14-May-98
Total
Zinc
675
cc
287
14-May-98
Total
Zinc
641
cc
288
14-May-98
Dissolved
Zinc
673
cc
288
17-May-98
Total
ZMk
5410
0.87
0.93
1.20
cc
288
17-May-98
Dissolved
Zinc
4700
1999 Data
Zinc
Dissolved
Total
cc
288
02-Jun-99
571
570
cc
288
05-Aug-99
1480
1390
cc
288
05-May-99
1290
1300
0.99230769
1.00
1.48
cc
288
OS-Jul-99
702
664
cc
288
15-D0O-98
4330
4500
0 96??????
0.98
1.38
cc
288
15-Jun-99
451
470
0.95957447
0.98
1.37
cc
288
18-Nov-98
4270
3900
cc
288
19-Apf-99
1830
1900
0.96315789
0.98
1.38
cc
288
23-Mar-99
3630
3600
cc
288
24-May-99
671
1400
0,47928571
0.69
0.76
cc
288
26-Oct-98
2380
2300
cc
288
27-May-99
604
660
0.91515152
0.96
128
cc
288
28-Dec-98
4440
4200
cc
288
30-Aug-99
1790
1780
count
28.00
stddev
0.18
calc
1.65
re-trans
1.00
95th
0.99
trans
1.01
*
Note;
Samples with dissolved analyte > total analyte were removed from the analysis.
-------
Ninemile Creek
Site ID
Date
Mathod
Parameter
Result
Diss/Total
sqrt
arcsine
ugfi
NM
305
1 l-Nov-97
Total
Cadmium
27.4
NM
305
11-NOV-97
Dissolved
Cadmium
295
NM
305
15-May-91
Total
Cadmium
9
0.99
0.99
1.47
NM
305
15-May-91
Dissolved
Cadmium
8.9
NM
305
16May-91
Total
Cadmium
7.7
096
0.98
1.37
NM
305
1&-May-91
Dissolved
Cadmium
7.4
NM
305
03-Oct-91
Total
Cadmium
19
NM
305
03-Oc*-91
Dissolved
Cadmium
27
NM
305
04-Oct-91
Total
Cadmium
22.8
0.96
0.98
1.36
NM
305
04-Oct-91
Dissolved
Cadmium
21.8
NM
305
28-0&-83
Total
Cadmium
22
NM
305
28-Oct-93
Dissolved
Cadmium
26
NM
305
02-Dec-93
Dissolved
Cadmium
22
0.96
0.98
1.36
NM
305
02-Dec-93
Total
Cadmium
23
NM
305
16-Dec-93
Dissolved
Cadmium
29
NM
305
16-Dec-83
Total
Cadmium
26
NM
305
24-Jar»-94
Dissolved
Cadmium
20
NM
305
24-Jaiv94
Total
Cadmium
19
NM
305
18-Feto-94
Total
Cadmium
25
NM
305
18-Feb-94
Dissolved
Cadmium
26
NM
305
06-Mar-94
Total
Cadmium
24
NM
305
08-Mar-94
Dissolved
Cadmium
26
NM
305
23-Mar-94
Total
Cadmium
21
NM
305
23-Ma/-94
Dissolved
Cadmium
22
NM
305
0T-Apr-94
Dissolved
Cadmium
23
0.92
0.96
1.28
NM
305
0T-Apr-94
Total
Cadmium
25
NM
305
19*Apr-94
Total
Cadmium
28
079
0.89
1.09
NM
305
19-Apf-94
Dissolved
Cadmium
22
NM
305
20-May-94
Dissolved
Cadmium
19
0.95
0.97
1.35
NM
305
20-May-94
Total
Cadmium
20
NM
305
07-Jun-94
Total
Cadmium
25
NM
305
07-Jun-94
Dissolved
Cadmium
26
NM
305
23-Jun-94
Dissolved
Cadmium
24
1.00
1.00
1.57
NM
305
23-Jur>-94
Total
Cadmium
24
NM
305
20-JJ-94
Total
Cadmium
22
NM
305
20-Jul-94
Dissolved
Cadmium
23
•
NM
305
15-Aug-94
Total
Cadmium
21
1.00
1.00
1.57
NM
305
15-Aug-94
Dissolved
Cadmium
21
NM
305
08-Sep-94
Dissolved
Cadmium
32
NM
305
OS-Sap-94
Total
Cadmium
30
NM
305
28-Oct-94
Dissolved
Cadmium
27
NM
305
28-Oct-94
Total
Cadmium
25
NM
305
15-Nov-94
Total
Cadmium
4fl
1.00
100
1.57
NM
305
1 S-Nov-94
Dissolved
Cadmium
48
NM
305
13-Dec-94
Total
Cadmium
45
0.98
0.99
1.42
NM
305
13-Dec-94
Dissolved
Cadmium
44
NM
305
10-Jan-95
Total
Cadmium
38
0.92
0.96
1.29
-------
NM
305
l0-Jan-95
Dissolved
Cadmium
35
NM
305
09-Feb-95
Dissolved
Cadmium
27
1.00
1.00
1.57
NM
305
09-Feb-95
Total
Cadmium
27
NM
305
07-Mar-95
Dissolved
Cadmium
30
NM
305
07-Mar-95
Total
Cadmium
26
NM
305
22-Mar-95
Total
Cadmium
23
NM
305
22-Mar-95
Dissolved
Cadmium
24
NM
305
13-Apr-95
Total
Cadmium
27
0.96
0.98
1.38
NM
305
13-Apr-95
Dissolved
Cadmium
26
NM
305
25-Apr-95
Dissolved
Cadmium
25
1.00
1.00
1.57
NM
305
25-Apr-95
Total
Cadmium
25
NM
305
09-May-95
Total
Cadmium
16
NM
305
09-May-95
Dissolved
Cadmium
18
NM
305
23-May-95
Dissolved
Cadmium
16
NM
305
23-May-95
Total
Cadmium
15
NM
305
12-Jun-95
Dissolved
Cadmium
16
NM
305
12-Jun-95
Total
Cadmium
15
NM
305
27-Jun-95
Dissolved
Cadmium
22
NM
305
27-Jun-95
Total
Cadmium
20
NM
305
H-Jul-95
Dissolved
Cadmium
20
1.00
1.00
1.57
NM
305
11 -Ju(*95
Total
Cadmium
20
NM
305
26-JU-95
Dissolved
Cadmium
23
1.00
1.00
1,57
NM
305
26-Jul-95
Total
Cadmium
23
NM
305
14-Aug-95
Total
Cadmium
27
1.00 |
1,00
1.57
NM
305
14-Aug-95
Dissolved
Cadmium
27
NM
305
13-Sap-95
Dissolved
Cadmium
25
0.93
0.96
1.30
NM
305
13-Sep-95
Total
Cadmium
27
NM
305
18-Oct-95
Dissolved
Cadmium
38
NM
305
18-Od-95
Total
Cadmium
38
NM
305
21-Nov-95
Total
Cadmium
26
0,96
0.98
1.37
NM
305
21 -Nov-95
Dissolved
Cadmium
25
NM
305
27-Dec-95
Total
Cadmium
23
NM
305
27-Dec-95
Dissolved
Cadmium
24
NM
305
17-Jan-96
Dissolved
Cadmium
19
0.95
0.97
1.35
NM
305
17vtan-96
Total
Cadmium
20
NM
305
29-Feb-96
Total
Cadmium
16
NM
305
29-Feb-96
Dissolved
Cadmium
17
NM
305
28-Mar-96
Dissolved
Cadmium
17
0.94
0.97
1.33
NM
305
20-Mar-96
Total
Cadmium
18
NM
305
17-Apr-96
Total
Cadmium
20
1.00
1,00
1.57
NM
305
17-Apr-96
Dissolved
Cadmium
20
NM
305
0e-May-96
Dissolved
Cadmium
16
0.94
0.97
1.33
NM
305
08-May-96
Total
Cadmium
17
NM
305
19-Jun-96
Dissolved
Cadmium
19
NM
305
19-Jun-96
Total
Cadmium
14
NM
305
24-JuJ-96
Total
Cadmium
20
1.00
1.00
1,57
NM
305
24-Jul-96
Dissolved
Cadmium
20
NM
305
21-Aug-96
Dissolved
Cadmium
22
NM
305
21-Aug-96
Total
Cadmium
21
NM
305
26-Sep-96
Dissolved
Cadmium
20
1.00
1.00
1,57
NM
305
26-Sep-96
Total
Cadmium
20
-------
NM
305
15-May-S8
Total
Cadmium
112
1.00
1.00
1.57
NM
305
15-May-98
Dissolved
Cadmium
11.2
NM
305
17-May-98
Total
Cadmium
12.5
0.94
0.97
1.33
NM
305
i7May-98
Dissolved
Cadmium
11.8
1999 USGS Data
Cadmium
Dissolved
Total
NM
305
USGS
01-Sep-99
2t
NM
305
USGS
04-Aug-99
17
17.7
096045198
0.98
1.37
NM
305
USGS
05-May-99
16
17
0 94117647
0.97
1.33
NM
305
USGS
07-Juf-99
10
10.6
0 34339623
0.97
1.33
NM
305
USGS
10-0ec-98
31
39
0.79487179
0.89
1.10
NM
305
USGS
15-Jim-99
6
6
1
1.00
1.57
NM
305
USGS
19-Apr-99
14
17
0 82352941
0.91
1.14
NM
305
USGS
19-Nov-98
39
NM
305
USGS
21-Jan-99
22
21
NM
305
USGS
22*Msf'99
12
14
0.85714286
0.83
1.18
NM
305
USGS
23-May-99
8.3
9
0.96
129
NM
305
USGS
26-May-99
6.5
9
n 7W9999
0.85
1.02
NM
305
USGS
27-May-99
6.4
7
0.91428571
0.96
127
NM
305
USGS
27-Oct-98
28
31
0.90322581
0.95
125
NM
305
USGS
31 -May-99
6.4
6
39.00
sld dev
0.16
calc
1.65
re-trans
1.00
95th
0.99
trans
1.01
NM
305
09-Feb-95
Dissolved
Lead
73
0.68
0.83
0.97
NM
305
09-Feb-95
Total
Lead
107
NM
305
15-May-91
Total
Lead
42
0.33
0.58
0.62
NM
305
15-May-91
Dissolved
Lead
14
NM
305
16-May-91
Dissolved
Lead
14
0.35
0,59
0.63
NM
305
16-May-91
Total
Lead
40
NM
305
03-Oct-91
Dissolved
Lead
15
0.38
0.62
0.67
NM
305
03-Oct-91
Total
Lead
39
NM
305
04-Oct-91
Total
Lead
51
047
0.89
0.76
NM
305
04-Oct-91
Dissolved
Lead
24
NM
305
28-OC1-93
Dissolved
Lead
29
0.73
0.85
1.02
NM
305
2B-OC1-93
Total
Lead
40
NM
305
02-Dec-93
Dissolved
Lead
30
0.63
0.79
0.91
NM
305
02-Dec-93
Total
Lead
48
NM
305
16-OSC-93
Dissolved
Lead
40
0.63
0.79
0.91
NM
MS
16-Dec-93
Total
Lead
64
NM
305
24-Jan-94
Total
Lead
68
0.50
0.71
0.79
NM
305
24-Jan-94
Dissolved
Lead
34
NM
305
18-Fei>94
Total
Lead
73
0.47
0.68
0.75
NM
305
18-Fefa-94
Dissolved
Lead
34
NM
305
Oe-Mar-94
Total
Lead
108
0.43
0.65
071
-------
NM
305
OB-Mar-94
Dissolved
Lead
46
NM
305
23-Mar-94
Dissolved
Lead
53
0.61
0.78
0.90
NM
305
23-Mar-94
Total
Lead
87
NM
305
07-Apr-94
Total
Lead
85
0.67
0.82
0.96
NM
30S
07-Apr-94
Dissolved
Lead
57
NM
305
19-Apr-94
Total
Lead
442
0.11
0.33
0.34
NM
305
19-Apr-94
Dissolved
Lead
48
NM
305
20-May-94
Dissolved
Lead
4
0.80
0.89
1.11
NM
305
20-May-94
Total
Lead
5
NM
305
07-Jufi-94
Dissolved
Lead
54
0.82
0.90
1.13
NM
305
07-Jun-94
Total
Lead
66
NM
305
23-Jur>-94
Dissolved
Lead
52
0.75
0.87
1.05
NM
305
23-Ju«v94
Total
Lead
69
NM
305
20-Jul-W
Total
Lead
55
0.89
0.94
1.23
NM
305
20-Jul-94
Dissolved
Lead
49
NM
305
t5-Aug-94
Total
Lead
44
0.80
0.89
1.10
NM
305
15-Aug-94
Dissolved
Lead
35
NM
305
08-Sej>-94
Dissolved
Lead
26
0.65
0.81
0.94
NM
305
08Sep-94
Total
Lead
40
NM
305
28-Oct-94
Dissolved
Lead
30
0.57
0.75
0.85
NM
305
28-Oct-94
Total
Lead
53
NM
305
15-NOV-94
Total
Lead
134
0.67
0.82
0.96
NM
305
15-NOV-94
Dissolved
Lead
90
NM
305
13-Dac-94
Total
Lead
91
0.66
0.81
0.95
NM
305
13-Dec-94
Dissolved
Lead
60
NM
305
10-Jan-95
Dissolved
Lead
54
0.27
0.52
0.55
NM
305
10-Jan-95
Total
Lead
200
NM
305
07-Mar-95
Dissolved
Lead
61
064
0.80
0,93
NM
305
07-Mar-95
Total
Lead
95
NM
305
22-Mar-95
Dissolved
Lead
60
0.36
0.60
0.64
NM
305
22-Mar-95
Total
Lead
168
NM
305
13-Apr-95
Dissolved
Lead
58
0.55
0.74
0.83
NM
305
13-Apr-95
Total
Lead
106
NM
305
25-Apr-95
Total
Lead
79
0.81
0.90
1.12
NM
305
25-Apr-95
Dissolved
Lead
64
NM
305
09-May-95
Dissolved
Lead
64
0.59
0.77
0.88
NM
305
09-May-95
Total
Lead
108
NM
305
23-May-95
Total
Lead
87
0.62
0.79
0.91
NM
305
23-May-95
Dissolved
Lead
54
NM
305
12-Jun-95
Dissolved
Lead
62
0.75
0.86
104
NM
305
12-Jui>95
Total
Lead
S3
NM
305
27-Jurv95
Total
Lead
103
070
084
0.99
NM
305
27-Jur>-95
Dissolved
Lead
72
NM
305
11-Jul*95
Dissolved
Lead
72
0.71
084
1.01
NM
305
1 t-Jul-95
Total
Lead
101
NM
305
26-Jul-95
Total
Lead
100
0.75
0.87
1.05
NM
305
26-Jul-95
Dissolved
Lead
75
NM
305
14-Aug-95
Total
Lead
61
NM
305
14-Aug-95
Dissolved
Lead
74
NM
305
13-Sep-95
Dissolved
Lead
50
0.50
0.70
0.78
NM
305
13-Sep-95
Total
Lead
101
-------
NM
305
18-Oct-95
Dissolved
Lead
91
0 83
0.91
1.14
NM
305
18-Oct-95
Total
Lead
110
NM
305
21 -Nov-95
Total
Lead
196
0.34
0.58
0.62
NM
305
21 -Nov-95
Dissolved
Lead
67
NM
305
27-Dec-95
Dissolved
Lead
43
0.62
0.79
0.91
NM
305
27-Dec-95
Total
Lead
69
NM
305
17-Jan-96
Dissolved
Lead
65
0.59
0.77
0.88
NM
305
17-Jan-96
Total
Lead
110
NM
305
29-Feb-96
Dissolved
Lead
39
0.40
0.63
0.68
NM
305
29-Feb-96
Total
Lead
98
NM
305
28-Mar-96
Dissolved
Lead
39
0.75
0.87
1.05
NM
305
23-Mar-96
Total
Lead
52
NM
305
17-Apr-96
Dissolved
Lead
45
0.41
0.64
0.70
NM
305
17-Apr-96
Total
Lead
109
NM
305
08-May-96
Total
Lead
89
0.45
0.67
0.73
NM
305
08-May-98
Dissolved
Lead
40
NM
305
19-Jun-96
Total
Lead
46
0 80
0.90
1.11
NM
305
19-Jun-96
Dissolved
Lead
37
NM
305
24-Jul-96
Total
Lead
57
0.70
0.84
0.99
NM
305
24-Jui-96
Dissolved
Lead
40
NM
305
21-AUB-96
Dissolved
Lead
36
0.73
0.B6
1.03
NM
305
21-Aug-96
Total
Lead
49
NM
305
26-Sep-96
Total
Lead
46
0.80
0.90
1.11
NM
305
26-Sep-96
Dissolved
Lead
37
NM
305
H-Nov-97
Dissolved
Lead
41.6
0.87
0.93
1.21
NM
305
11 -Nov-97
Total
Lead
47,6
NM
305
15-May-93
Dissolved
Lead
25.5
0.64
0.80
0.93
NM
305
15-May-98
Total
Lead
39.7
NM
305
17-May-98
Total
Lead
61.6
0.77
0.88
1.07
NM
305
17-May-98
Dissolved
Lead
47.2
1999 USGS Data
Lead
Diss
Total
NM
305
USGS
01-Sep-99
29
NM
305
USGS
O4-AU0-99
33
48.2
0,6846473
0.83
0.97
NM
305
USGS
05-May-99
26
52
0.5
0.71
0.79
NM
305
USGS
Q?-vJul-99
29
45.6
0.63596491
0.80
0.92
NM
305
USGS
10-Dec-98
36
68
0.52941176
0.73
0.81
NM
305
USGS
15-Jun-99
25
81
0.30864198
0.56
0.59
NM
305
USGS
19-Apr-99
13
260
0.05
0.22
0.23
NM
305
USGS
19-NOV-98
36
50
NM
305
USGS
21-Jan-99
44
54
NM
305
USGS
22-Mar-99
23
330
0.06969697
0.26
0.27
NM
305
USGS
23-May-99
23
220
0.10454545
0.32
0.33
NM
305
USGS
26-May-99
23
800
0.02875
0.17
0.17
NM
305
USGS
27-May-99
23
270
0.08518519
0.29
0.30
NM
305
USGS
27-Oct-98
29
47
0 61702128
0.79
0.90
NM
305
USGS
31-May-99
22
100
61.00
std dev
0.25
-------
calc
1.25
re-trans
0.95
95tti
0.90
trans
1.11
NM
305
08-Sep-94
Dissolved
Zinc
4340
NM
305
08-Sep-94
Total
Zinc
4560
NM
305
15-May-91
Dissolved
Zinc
1940
NM
305
15-May-91
Total
Zinc
1800
NM
305
18-May-91
Dissolved
Zinc
1990
NM
305
16-May-91
Total
Zinc
1900
NM
305
03-Oct-91
Total
Zinc
3120
0.85
0.92
1.17
NM
305
03-Oct-91
Dissolved
Zinc
2640
NM
305
04-Oct-91
Dissolved
Zinc
4550
NM
305
04-Oct-91
Total
Zinc
4490
NM
305
28-Oct-93
Dissolved
Zinc
4510
NM
305
28-Oct-93
Total
Zinc
4490
NM
305
02-Dec-93
Dissolved
Zinc
4260
0.98
0.99
1.43
NM
305
02-Dac-93
Total
Zinc
4350
NM
305
16-Dec-93
Total
Zinc
4590
NM
305
16-Dec-93
Dissolved
Zinc
4830
NM
305
24-Jan-94
Total
Zinc
3830
NM
305
24-Jan-94
Dissolved
Zinc
4210
NM
305
18-Feb-94
Total
Zinc
4020
NM
305
18-Fob-94
Dissolved
Zinc
4070
NM
305
OS-Mar-94
Total
Zinc
3730
NM
305
08-Mar-94
Dissolved
Zinc
3760
NM
305
23-Mar-94
Dissolved
Zinc
3810
NM
305
23-Mar-94
Total
Zinc
3750
NM
305
07-Apr-94
Dissolved
Zinc
3940
NM
305
07-Apr-94
Total
Zinc
3840
NM
305
19-Apf-94
Dissolved
Zinc
3590
0.94
0.97
1.33
NM
305
19-Apr-94
Total
Zinc
3810
NM
305
20-May-94
Total
Zinc
2390
NM
305
20-May-94
Dissolved
Zinc
2520
NM
305
07-Jun-94
Dissolved
Zinc
3160
NM
305
07-Jun-94
Total
Zinc
3000
NM
305
23-Jun-94
Dissolved
Zinc
3300
NM
305
23-Jun-94
Total
Zinc
3250
NM
305
20-Jul-94
Dissolved
Zinc
2610
NM
305
20-Jul-94
Total
Zinc
2600
NM
305
15-Aug-94
Dissolved
Zinc
2280
NM
305
15-Aug-94
Total
Zinc
2260
NM
305
28-Ocl-94
Total
Zinc
3780
NM
305
28-Oct-94
Dissolved
Zinc
3890
NM
305
15-NOV-94
Dissolved
Zinc
6800
0.97
0 98
1.39
NM
305
15-NOV-94
Total
Zinc
7020
NM
305
13-Oec-94
Total
Zinc
7170
NM
305
13-Dec 94
Dissolved
Zinc
7390
-------
NM
305
10-Jan-95
Dissolved
Zinc
5500
0.99
0.99
1.46
NM
305
10-Jan-95
Total
Zinc
5570
NM
305
09-Feb-95
Dissolved
Zinc
4590
NM
305
09Feb-95
Total
Zinc
4370
NM
305
07-Mar-95
Dissolved
Zinc
4760
0.99
1.00
1.49
NM
305
07-Mar-95
Total
Z;nc
4790
NM
305
22-Mar-95
Dissolved
Zinc
3990
0.94
0.97
1.33
NM
305
22-Mar-95
Total
Zinc
4240
NM
305
13-Apr-95
Total
Zinc
4840
0.97
0.98
1.39
NM
305
13-Apr-95
Dissolved
Zinc
4690
NM
305
25-Apr-95
Total
Zinc
4900
0.97
0.98
1.39
NM
305
25-Apr-9S
Dissolved
Zinc
4740
NM
305
09-May-95
Total
Zinc
2860
0.92
0.96
129
NM
305
09-May-9S
Dissolved
Zinc
2840
NM
305
23-May-95
Dissolved
Zinc
2070
NM
305
23-May-95
Total
Zinc
2050
NM
305
12-Jur»-B5
Tola!
Zinc
2210
NM
305
12-Jur»-95
Dissolved
Zinc
2290
NM
305
27-Jun-9S
Dissolved
Zinc
2930
1.00
1.00
151
NM
305
27-Jun-95
Total
Zinc
2940
NM
305
11-JU-95
Total
Zinc
2910
NM
305
11-JU-95
Dissolved
Zinc
2920
NM
305
26-JJ-95
Total
Zinc
3030
NM
305
26-Jul-95
Dissolved
Zinc
3080
NM
305
14-Auq-95
Total
Zinc
3380
NM
305
14-Aug*95
Dissolved
Zinc
3470
NM
305
13-Sep-95
Dissolved
Zinc
2560
0.96
0.98
1.36
NM
305
13-Sep-95
Total
Zinc
2680
NM
305
18-Oct-95
Total
Zinc
5800
NM
305
18-Oct-95
Dissolved
Zinc
5920
NM
305
21-NOV-95
Total
Zinc
4210
1.00
1.00
1.57
NM
305
21-NOV-95
Dissolved
Zinc
4210
NM
305
27-Dec-95
Dissolved
Zinc
3800
NM
305
27-Dec-95
Total
Zinc
3690
NM
305
17-Jan-96
Total
Zinc
2760
0.98
0.99
1.41
NM
305
17-Jan-96
Dissolved
Zinc
2830
NM
305
29-Feb-96
Total
Zinc
2810
NM
305
29-Feb-96
Dissolved
Zinc
2970
NM
305
28Mar-96
Dissolved
Zinc
2830
NM
305
28-Mar-96
Total
Zinc
2730
NM
305
17-Apr-96
Total
Zinc
3310
NM
305
17-Apr-96
Dissolved
Zinc
3350
NM
305
08-May-96
Dissolved
Zinc
2910
NM
305
08-May-96
Total
Zinc
2900
NM
305
19-Jun-96
Dissolved
Zinc
1790
NM
305
19-Jurv96
Total
Zinc
1760
NM
305
24-Jul-96
Dissolved
Zinc
2470
NM
305
24-Jul-96
Total
Zinc
2440
NM
305
21-Aug-96
Dissolved
Zinc
2790
NM
305
2l-Aug-96
Total
Zinc
2780
NM
305
26-Sep-96
Dissolved
Zinc
2540
-------
NM
305
26-Sep-96
Total
Zinc
2500
NM
305
11 -Nov-97
Total
Zinc
5140
NM
305
11 -Nov-97
Dissolved
Zinc
5180
NM
305
15-May-98
Dissolved
Zinc
1960
0.92
0.96
1.28
NM
305
15-May-98
Total
Zinc
2130
NM
305
17-May-98
Dissolved
Zinc
2370
0.35
0.59
0.63
NM
305
17-May-98
Total
Zrtc
6750
1999 USGS Data
Zinc
Dissolved
Total
NM
305
USQS
OI-Sep-99
3570
NM
305
USGS
04-Aug-99
2280
2250
NM
305
USGS
05-May-99
2690
2600
NM
305
USGS
07-J»J-99
1570
1760
0.89204545
0.94
1.24
NM
305
USGS
10-Dec-98
6640
7000
0.94857143
0.97
134
NM
305
USGS
15-Jun-99
864
870
0.99310345
1.00
1.49
NM
305
USGS
19-Apr-99
2400
2600
0.92307692
0.96
1.29
NM
305
USGS
1MJOV-98
7460
7100
NM
305
USGS
21-Jarv99
3820
3800
NM
305
USGS
22-Mar-99
2010
2300
0.87391304
0.93
1.21
NM
306
USGS
23-May-99
1240
1300
0.95384815
0.98
1.35
NM
305
USGS
2©-May-99
981
1500
0.654
0.81
0.94
NM
305
USGS
27-May-99
1020
1100
0.92727273
0.96
1.30
NM
305
USGS
27-Oct-98
4850
NM
305
USGS
31-May-99
974
950
24.00
SKI cfev
0.21
calc
1.69
re-trans
0.99
95th
0.99
trans
1.01
Note:
Samples with dissolved analyte > total analyte were removed from the analysis.
I
-------
Diss Cd
Tot Cd
Diss/Tot
Sqrt
Arcslne
DISS Pb
Tot Pb
Diss/Tot
Sqrt
Arcslne
DissZn
TotZn
Diss/Tot
Sqrt
Arcslne
SF
233
09-NOV-97
9.19
8.3
21.5
30.6
0.70
0.84
0.99
1330
1420
0.94
0.97
1.32
SF
233
13-May-9f
2.8
2.7
10
21.7
0.46
0.68
0.75
443
447
0.99
1.00
1.48
SF
233
04-Sep-97
7.6
7.7
0.99
0.99
1.46
26
77
0.34
0.58
0.62
964
965
1.00
1.00
1.54
SF
233
13-Aug-97
5.7
5.8
0.98
0.99
1.44
20
43
0.47
0.68
0.75
789
798
0.99
0.99
1.46
SF
233
i5-May-9:
5.9
885
805
SF
233
17-Apr-97
7.6
7.6
1.00
1.00
1.57
19
55
0.35
0.59
0.63
1170
1160
SF
233
17-Dec-9(
13
13
1.00
1.00
1.57
21
34
0.62
0.79
0.90
2280
2190
SF
233
17-Oct-97
9.4
9.5
0.99
0.99
1.47
22
45
0.49
0.70
0.77
1400
1350
SF
233
18-D0C-97
16
28
0.57
0.76
0.86
474
2160
0.22
0.47
0.49
1810
2450
0.74
0.86
1.03
SF
233
19-Feb-97
11
11
1.00
1.00
1.57
18
52
0.35
0.59
0.63
1630
1670
0.98
0.99
1.42
SF
233
19-Mar-98
8.4
9
0.93
0.97
1.31
21
44
0.48
0.69
0.76
1210
1260
0.96
0.98
1.37
SF
233
22-Jan-98
9.8
9.7
15
36
0.42
0.65
0.70
1480
1440
SF
233
24-Apr-98
5
7
0.71
0.85
1.01
14
460
0.03
0.17
0.18
628
805
0.78
0.88
1.08
SF
233
24-Jul-97
4.4
4.6
0.96
0.98
1.36
18
39
0.46
0.68
0.75
704
666
SF
233
25-Jun-97
2.8
2.9
0.97
0.98
1.38
13
21
0.62
0.79
0.91
453
414
SF
233
25-NOV-97
8.8
9.6
0.92
0.96
1.28
21
54
0.39
0.62
0.67
1330
1300
SF
233
26-Feb-98
13
13
1.00
1.00
1.57
13
26
0.50
0.71
0.79
1510
1500
SF
233
26-Nov-9(
12
12
1.00
1.00
1.57
23
27
0.85
0.92
1.18
2140
2100
SF
233
27-Mar-97
8.2
8.3
0.99
0.99
1.46
21
38
0.55
0.74
0.84
1250
1220
SF
233
29-Jan-97
11
10
17
24
0.71
0.84
1.00
1430
1440
0.99
1.00
1.49
SF
233
29-0d-96
12
13
0.92
0.96
1.29
31
70
0.44
0.67
0.73
1680
1710
0.98
0.99
1.44
SF
233
24-May-95
2.4
4
0.60
0.77
0.89
8.8
480
0.02
0.14
0.14
319
560
0.57
0.75
0.86
std dev
0.23
std dev
0.24
std dev
0.22
calc
1.74
calc
1.12
calc
1.68
re-trans
0.99
re-trans
0.90
re-trans
0.99
95th
0.97
95th
0.81
95th
0.99
trans
1.03
trans
1.23
trans
1.01
-------
Pine CreeK
Sile ID
Date
Method
Parameter
Result
Diss/Tot
sqrt
arcsine
ugfl
PC
305
14-May-91
Dissolved
Cadmium
02
1.00
1.00
1.57
PC
305
14-May-91
Total
Cadmium
0.2
PC
3Q5
03-Ocl-9t
Dissolved
Cadmium
0.2
1.00
100
1.57
PC
305
03-Oct-91
Total
Cadmium
0.2
PC
305
29-Oct-93
Dissolved
Cadmium
0.25
1.00
1.00
1.57
PC
305
29-Oct-93
Total
Cadmium
0.25
PC
305
01 -Dec-93
Total
Cadmium
0.25
1.00
1.00
1.57
PC
305
01 -Dec-93
Dissolved
Cadmium
0.25
PC
305
21-Dec-93
Total
Cadmium
0.25
1.00
1.00
1.57
PC
305
21-Dec-93
Dissolved
Cadmium
0.25
PC
305
21-Jan-94
Total
Cadmium
0.25
1.00
1.00
1.57
PC
305
21-Jan-94
Dissolved
Cadmium
0.25
PC
305
17-Feb-94
Dissolved
Cadmium
025
1.00
1.00
1.57
PC
305
17-Fet>-94
Total
Cadmium
025
PC
305
08-Ma/-94
Total
Cadmium
025
PC
305
OS-Mar-94
Dissolved
Cadmium
0.6
PC
305
23-Mar-94
Total
Cadmium
0.25
1.00
1.00
1J7
PC
305
23-Mar-94
Dissolved
Cadmium
025
PC
305
Oft-Apf-94
Total
Cadmium
025
1.00
1,00
1.57
PC
am
0&-Apr-94
Dissolved
Cadmium
025
PC
305
18-Apr-94
Total
Cadmium
0.25
1.00
1.00
1.57
PC
305
18-Apr-94
Dissolved
Cadmium
0.25
PC
305
03-May-94
Dissolved
Cadmium
0.7
0.54
0.73
0.82
PC
305
03-May-94
Total
Cadmium
1.3
PC
305
19-May-94
Dissolved
Cadmium
025
1.00
1.00
1.57
PC
305
19-May-94
Total
Cadmium
0.25
PC
305
08-Jun-94
Total
Cadmium
0.25
1.00
1.00
1.57
PC
305
08-Jun-94
Dissolved
Cadmium
025
PC
305
24-Jun-94
Dissolved
Cadmium
04
PC
305
24-Jun-94
Total
Cadmium
0.3
PC
305
17-AU9-94
Total
Cadmium
0.5
0.50
0.71
0.79
PC
305
17-Aug-94
Dissolved
Cadmium
0.25
PC
305
26-Sep-94
Total
Cadmium
0.25
1.00
1.00
1.57
PC
305
26-Sep-94
Dissolved
Cadmium
0.25
PC
305
05-Oct-94
Dissolved
Cadmium
025
1.00
1.00
1.57
PC
305
OS-Oct-94
Total
Cadmium
025
PC
305
16-Nov-94
Dissolved
Cadmium
025
1.00
1.00
1.57
PC
305
1S-Nov-94
Total
Cadmium
025
PC
305
14-Dec-94
Total
Cadmium
025
1.00
1.00
1.57
PC
305
14-Dac-M
Dissolved
Cadmium
025
PC
305
10-Jan-9S
Dissolved
Cadmium
1,5
PC
305
1D-Jan-95
Total
Cadmium
1.4
PC
305
09-Feb-95
Total
Cadmium
1.1
0.82
0.90
1.13
PC
305
09-Feb-95
Dissolved
Cadmium
0,9
PC
305
22-Mar-95
Dissolved
Cadmium
1.2
0.55
0.74
0.83
PC
305
22-Mar-95
Total
Cadmium
2.2
PC
305
14-Apf-95
Total
Cadmium
25
0.40
0.63
0.68
-------
PC
305
14-Apr-95
Dissolved
Cadmium
1
PC
305
27-Apr-95
Dissolved
Cadmium
3.2
PC
305
27-Apr-95
Total
Cadmium
1.2
PC
305
H-May-95
Dissolved
Cadmium
2
PC
305
11 -May-95
Total
Cadmium
1.4
PC
305
24-May-95
Dissolved
Cadmium
0.5
0.53
0.79
0.91
PC
305
24-May-95
Total
Cadmium
0,8
PC
305
12-Jun-95
Total
Cadmium
0.5
0.50
0.71
0.79
PC
305
12-Jun-95
Dissolved
Cadmium
0.25
PC
305
27-Jurv95
Total
Cadmium
0.25
1.00
1.00
1.57
PC
305
27-Jun-9S
Dissolved
Cadmium
0.25
PC
305
11 -Jul-95
Total
Cadmium
0.25
PC
305
11-Juf-95
Dissolved
Cadmium
0.3
PC
305
25-Jui-95
Total
Cadmium
0.25
1.00
1.00
1.57
PC
305
25-JiH-95
Dissolved
Cadmium
0.25
PC
305
14-Aug-95
Dissolved
Cadmium
0.25
1.00
1.00
1.57
PC
305
14-Aug-95
Total
Cadmium
0.25
PC
305
13-Sej>95
Dissolved
Cadmium
0.25
1.00
1.00
1.57
PC
305
13*Sep-95
Total
Cadmium
0.25
PC
305
18-Oct-95
Dissolved
Cadmium
0.25
1.00
1.00
1,57
PC
305
18-Oct-95
Total
Cadmium
055
PC
305
22-Nov-95
Dissolved
Cadmium
0.8
1.00
1.00
1.57
PC
305
22-NOV-95
Total
Cadmium
0.6
PC
305
27-DOC-95
Total
Cadmium
1
0.80
0.89
1.11
PC
305
27-Dec-95
Dissolved
Cadmium
0.8
PC
305
18-Jan-96
Total
Cadmium
0.7
PC
305
18-Jan-96
Dissolved
Cadmium
1.1
PC
305
28-Feb-96
Total
Cadmium
0.6
PC
305
28-Feb-96
Dissolved
Cadmium
0.604
PC
305
27-Mar-96
Dissolved
Cadmium
0.7
PC
305
27-Mar-96
Total
Cadmium
0.6
PC
305
18-Apr-96
Total
Cadmium
0.25
1.00
1.00
1.57
PC
305
18-Apf-9€
Dissolved
Cadmium
0.25
PC
305
08-May-96
Total
Cadmium
0.5
1.00
100
1.57
PC
305
08-May-96
Dissolved
Cadmium
0,5
PC
305
19-Jun-96
Total
Cadmium
0.6
1.00
1.00
1.57
PC
305
19-Jun-96
Dissolved
Cadmium
0,6
PC
305
24-Jul-96
Total
Cadmium
0.8
1.00
1.00
t.57
PC
305
24-Jii-96
Dissolved
Cadmium
0.8
PC
305
2t-Aug-96
Dissolved
Cadmium
0.25
1.00
1.00
1.57
PC
305
21 -Aug-96
Total
Cadmium
0.25
PC
305
26-Sep-96
Dissolved
Cadmium
0,9
PC
305
26-Sap-96
Total
Cadmium
0.25
PC
305
04-Feb-97
Dissolved
Cadmium
3
1.00
1.00
1.57
PC
305
04-Feb-97
Total
Cadmium
3
PC
305
24-Apr-97
Dissolved
Cadmium
3
1.00
1.00
1.57
PC
305
24-Apf-97
Total
Cadmium
3
PC
305
12-Oc1-97
Dissolved
Cadmium
5
PC
305
12-Oct 9/
Total
Cadmium
4
PC
305
17-Feb-98
Total
Cadmium
4
1.00
1.00
1,57
PC
305
17-Feb-98
Dissolved
Cadmium
4
-------
38 00
stddev
0.29
calc
1.91
re-trans
0.94
95th
0.89
trans
1.12
PC
305
19-May-94
Dissolved
Lead
1.5
0.25
0.50
0.52
PC
305
19-May-94
TotaJ
Lead
6
PC
305
14-May-91
Total
Lead
3
1.00
1.00
1.57
PC
305
14-May-91
Dissolved
Lead
3
PC
305
03-Oct-91
Dissolved
Lead
1
1.00
100
1.57
PC
305
03-Oct-91
Total
Lead
1
PC
305
29-Oct-93
Dissolved
Lead
8
1.00
1.00
1.57
PC
305
29-Oct-93
Total
Lead
6
PC
305
01-Dec-93
Dissolved
Lead
1.5
0.12
0.34
0.35
PC
305
01-Dee-93
Total
Lead
13
PC
305
21-Dec-93
Dissolved
Lead
1.5
0.60
0.77
0.89
PC
•305
21-Dec-93
Total
Lead
2.5
PC
305
21-Jan-94
Total
Lead
2.5
0.60
0.77
0.89
PC
305
21-Jan-94
Dissolved
Lead
1.5
PC
305
17-Feb-94
Dissolved
Lead
1.5
0.60
0.77
0.89
PC
305
17-Fet>94
Total
Lead
2.5
PC
305
08-Mar-94
Dissolved
Lead
1.5
0.60
0.77
0.89
PC
305
OA-Mar-94
Total
Lead
2.5
PC
305
23-Mar-94
Total
Lead
2.5
0.60
0.77
0.89
PC
305
23-Mar-M
Dissolved
Lead
1.5
PC
305
08-Apr-94
Total
Lead
2.5
0.60
0.77
0.89
PC
305
08-Apr-94
Dissolved
Lead
1.5
PC
305
18-Apr-94
Dissolved
Lead
1.5
0.60
0.77
0.89
PC
305
18-Apr-94
Total
Lead
2.5
PC
305
03-May-94
Total
Lead
2.5
0.60
0.77
0.89
PC
305
03-May-94
Dissolved
Lead
1.5
PC
305
08-Jurv94
Total
Lead
5
0 30
0.55
0.58
PC
305
08-Jun-94
Dissolved
Lead
1.5
PC
305
24-Jun-94
Dissolved
Lead
1.5
0.60
0 77
0.89
PC
305
24-Jun-94
Total
Lead
2.5
PC
305
17-Aug-94
Dissolved
Lead
2.5
1.00
1.00
1.57
PC
305
17-AUQ-94
Total
Lead
2.5
PC
305
26-Ssp-94
Total
Lead
3
0.19
0.43
0.45
PC
305
26-Sep-94
Dissolved
Lead
1.5
PC
305
G5-Oct-94
Total
Lead
2.5
0.60
0.77
0.89
PC
305
05-Oct-94
Dissolved
Lead
1.5
PC
305
16-Nov-94
Dissolved
Lead
1,5
0.60
0.77
0.89
PC
305
16-Nov-94
Total
Lead
2.5
PC
305
14-Dec-94
Total
Lead
2.5
0 60
0.77
0.89
PC
305
14-D&C-94
Dissolved
Lead
1.5
PC
305
10-Jan-95
Dissolved
Lead
5
0.21
046
0.47
PC
305
10-Jan-95
Total
Lead
24
PC
30"
09-Feb-95
Total
Lead
10
0,15
0.39
0.40
-------
PC
305
09-Feb-95
Dissolved
Lead
1.5
PC
305
22-Mar-95
Dissolved
Lead
4
0.44
0.67
0.73
PC
305
22-Mar-95
Total
Lead
9
PC
305
14-Apr-95
Dissolved
Lead
1.5
0.30
0.55
0.58
PC
305
14-Apr-95
Total
Lead
5
PC
305
27-Apr-95
Total
Lead
2.5
0.60
0.77
0.89
PC
305
27-Apr-95
Dissolved
Lead
1.5
PC
305
11 -May-95
Dissolved
Lead
3
PC
305
11-May-95
Total
Lead
2.5
PC
305
24-May-95
Total
Lead
2.5
0.60
0.77
0.89
PC
305
24-May-95
Dissolved
Lead
1.5
PC
305
12-Jgn-95
Dissolved
Lead
1.5
0.30
0.55
0.58
PC
305
12-Jw*95
Total
Lead
5
PC
305
27-Jun-95
Total
Lead
2.5
0.60
0.77
0 89
PC
305
27-Jun-95
Dissolved
Lead
1.5
PC
305
11 -JuJ-96
Total
Lead
2,5
0.60
0.77
0.89
PC
305
11-JUI-95
Dissolved
Lead
1.5
PC
305
25-Jui-95
Total
Lead
2.5
PC
305
25>Jul-95
Dissolved
Lead
4
PC
305
14-Aug-95
Total
Lead
2.5
0.60
0.77
0.89
PC
305
14-Aug-95
Dissolved
Lead
1.5
PC
305
13-Sap-95
Total
Lead
8
0.50
0.71
0.79
PC
305
13-Sep-95
Dissolved
Lead
4
PC
305
18-Oct-95
Dissolved
Lead
2.5
1.00
1.00
1.57
PC
305
18-Oct-95
Total
Lead
2.5
PC
305
22-NOV-95
Total
Lead
2.5
0.60
0.77
0.89
PC
305
22-Nov-95
Dissolved
Lead
1.5
PC
305
27-DOC-95
Dissolved
Lead
1.5
0.60
0.77
0.89
PC
305
27-D0C-95
Total
Lead
2.5
PC
305
18-Jan-96
Dissolved
Lead
4
0.50
0.71
0.79
PC
305
18-Jan-96
Total
Lead
8
PC
305
28-Feb-96
Dissolved
Lead
1.5
0.30
0.55
0.58
PC
305
28-Feb-96
Total
Lead
5
PC
305
27-Mar-96
Total
Lead
5
0.60
0.77
0.89
PC
305
27-Mar-96
Dissolved
Lead
3
PC
305
18-Apr-96
Dissolved
Lead
11
0.85
0.92
1.17
PC
305
18-Apr-96
Total
Lead
13
PC
305
08-May-96
Total
Lead
6
0.67
0.82
0.96
PC
305
OS-May-96
Dissolved
Lead
4
PC
305
19-Jun-96
Dissolved
Lead
5
0.50
0.71
0.79
PC
305
19-Jun-96
Total
Lead
10
PC
305
24-Jul-96
Total
Lead
7
0.71
0.85
1.01
PC
305
24-Jul-96
Dissolved
Lead
5
PC
305
21 Aug-96
Total
Lead
5
0.30
0.55
0.58
PC
305
21 -Aug-96
Dissolved
Lead
1.5
PC
305
26-Sop-96
Dissolved
Lead
1.5
Oil
0.46
0.48
PC
305
26-Sep-96
Total
Lead
7
PC
305
04-Fe0-97
Dissolved
Lead
1.5
0.11
0.34
0.35
PC
305
04-Feb-97
Total
Lead
131
PC
305
24-Apr-97
Total
Lead
12.2
0.12
0.35
0.36
PC
305
24-Apr-97
Dissolved
Lead
1.5
|
-------
PC
305
12-Oct-97
Total
Lead
3
1,00
1.00
1.57
PC
305
12-Oct-97
Dissolved
Lead
3
PC
305
17-Feb-98
Total
Lead
3
1,00
1.00
1.57
PC
305
17-Feb-98
Dissolved
Lead
3
47 00
std dev
0.35
calc
1.45
re-trans
0.99
95th
0.99
trans
1.01
PC
305
27.Apr.95
Dissolved
Zinc
104
0.95
0.97
1.34
PC
305
27-Apr-95
Total
Zinc
110
PC
305
14-May-91
Total
Zinc
20
1,00
1.00
1,57
PC
305
14-May-91
Dissolved
Zinc
20
PC
305
03-0ct-9t
Total
Zinc
30
PC
305
03-Oct-91
Dissolved
Zinc
46
PC
305
29-Od-93
Dissolved
Zinc
131
PC
305
29-Oct-93
Total
Zinc
117
PC
305
01-Dec-93
Dissolved
Zinc
108
PC
305
OI-Oec-93
Total
Zinc
107
PC
305
21-Dec-93
Total
Zinc
124
0.93
0.96
1.30
PC
305
21-Oec-93
Dissolved
Zinc
115
PC
305
21-Jan-94
Total
Zinc
105
0.98
0.99
1.43
PC
305
21-Jan-94
Dissolved
Zinc
103
PC
305
17-Feb-94
Total
Zinc
91
re
305
17-Feb-94
Dissolved
Zinc
95
PC
305
08-Mar-94
Total
Zinc
133
PC
305
08-Mar-94
Dissolved
Zinc
135
PC
305
23-Mar-94
Dissolved
Zinc
121
PC
305
23-Mar-94
Total
Zinc
117
PC
305
0S-Apf-94
Total
Zinc
96
PC
305
08-Apr-94
Dissolved
Zinc
104
PC
305
18-Apr-94
Total
Zinc
60
0.95
0.97
1.35
PC
305
18-Apr-94
Dissolved
Zinc
57
PC
305
03*May-94
Total
Zinc
74
0,96
0.98
1.37
PC
305
03-May-94
Dissolved
Zinc
71
PC
305
19-May-94
Total
Zinc
76
0.96
0.98
1.37
PC
305
19-May-94
Dissolved
Zinc
73
PC
305
08-Jun-B4
Total
Zinc
83
PC
305
08-Jun-94
Dissolved
Zinc
86
PC
305
24-Jun-94
Total
Zinc
68
PC
305
24-Jun-94
Dissolved
Zinc
78
PC
305
17-Aug-94
Dissolved
Zinc
89
1.00
1.00
1.57
PC
305
17-Aug-94
Total
Zinc
89
PC
305
26»Sep-94
Total
Zinc
99
PC
305
26-Sep-94
Dissolved
Zinc
100
PC
305
05-Oct-94
Dissolved
Zinc
98
0.98
0,99
1.43
PC
305
05«Oct-94
Total
Zinc
100
PC
305
16-Nov-94
Dissolved
Zinc
129
-------
PC
305
16-Nov-94
Total
Zinc
110
PC
305
14 Dec-94
Dissolved
Zinc
124
0.96
0.98
1.37
PC
305
14-Dec-94
Total
Zinc
129
PC
305
10-Jan-95
Dissolved
Zinc
402
PC
305
10-Jan-95
Total
Zinc
374
PC
305
09 Feb-95
Total
Zinc
225
1.00
1.00
1.50
PC
305
09-Feb-95
Dissolved
Zinc
224
PC
305
22-Mar 95
Dissolved
Zinc
202
0.93
0.96
1.30
PC
305
22-Mar-95
Total
Zinc
218
PC
305
14-Apf-95
Total
Zinc
178
0.85
0.92
1.18
PC
305
14-Apr-95
Dissolved
Zinc
152
PC
305
11-May-95
Dissolved
Zinc
77
0.80
0.90
1.11
PC
305
11-May-95
Total
Zinc
96
PC
305
24-May-95
Dissolved
Zinc
82
0.98
0.99
1.42
PC
305
24-May-95
Total
Zinc
84
PC
305
12-Jun-95
Dissolved
Zinc
85
0.98
0.99
1.42
PC
305
12-Jun-95
Total
Zinc
87
PC
305
27-Jun-95
Dissolved
Zinc
88
PC
305
27-Jun-95
Total
Zinc
87
PC
305
11-Jul-95
Dissolved
Zinc
85
0.99
0.99
1.46
PC
305
11-Jul-95
Total
Zinc
86
PC
305
25-Jul-95
Total
Zinc
89
1.00
1.00
1.57
PC
305
25-Jut-95
Dissolved
Zinc
89
PC
305
14-Aug-95
Dissolved
Zinc
101
0.99
1.00
1,47
PC
305
14-Au^-95
Total
Zinc
102
PC
305
13-Sep-95
Total
Zinc
104
0.93
0.97
1.31
PC
305
13-Sep-95
Dissolved
Zinc
97
PC
305
18-Oct-95
Total
Zinc
107
0.98
0.99
1.43
PC
305
180ct-95
Dissolved
Zinc
105
PC
305
22-Nov-95
Dissolved
Zinc
123
PC
305
22-NOV-96
Total
Zinc
112
PC
305
27-D6C-95
Total
Zinc
157
0.95
0.97
1.34
PC
305
27-Dec-95
Dissolved
Zinc
149
PC
305
18-Jarv96
Total
Zinc
138
0.92
0.96
1.28
PC
305
18-Jan-96
Dissolved
Zinc
127
PC
305
28-Feb-96
Dissolved
Zinc
198
0.49
0.70
0.77
PC
305
28-Feb-96
Total
Zinc
406
PC
305
27-Mar-96
Total
Zinc
199
PC
305
27-Mar-96
Dissolved
Zinc
280
PC
305
18-Apr-96
Total
Zinc
134
0.96
0.98
1.38
PC
305
18-Apr-96
Dissolved
Zinc
129
PC
305
08-May-96
Total
Zinc
131
PC
305
08-May 96
Dissolved
Zinc
152
PC
305
19-Jun-96
Total
Zinc
108
PC
305
19-Jun-96
Dissolved
Zinc
186
I
PC
305
24-Jul-96
Dissolved
Zinc
106
PC
305
24-Jul-96
Total
Zinc
102
PC
305
21 Aug 96
Total
Zinc
104
0.93
0,97
1.31
PC
305
21-Aug-96
Dissolved
Zinc
97
PC
305
26-Sep-96
Dissolved
Zinc
114
PC
305
26-Sep-96
Total
Zinc
111
-------
PC
305
04-Feb-97
Total
Zinc
153
0 84
0.91
1.15
PC
305
04-Fat>-97
Dissolved
Zinc
128
PC
305
24-Apr-97
Total
Zinc
136
0.82
090
1.13
PC
305
24-Apr-97
Dissolved
Zinc
111
PC
305
12-Oct-97
Dissolved
Zinc
80
1.00
1.00
1.57
PC
305
12-Oct-97
Total
Zinc
80
PC
305
17-Feb-9B
Dissolved
Zinc
230
1.00
1.00
1.57
PC
305
17-Fob-98
Total
Zinc
230
30.00
std dev
0.17
calc
1.64
re-trans
1.00
95th
1.00
trans
1.00
Note;
Samples with dissolved analyte > lota) analyte ware removed from the analysis.
-------
South Forte Pinehurat
Site ID
Date
Method
Parameter
Result
Diss/Tot
sqrt
arcsine
ug/1
SF
271
04-NOV-97
Total
Cadmium
8.5
SF
271
Q4-NOV-97
Dissolved
Cadmium
983
SF
271
14-May-91
Total
Cadmium
29
0.97
0.98
1.38
SF
271
14-May-91
Dissolved
Cadmium
2.8
SF
271
15-May-91
Dissolved
Cadmium
2.5
0.89
0.94
1.24
SF
271
15-May-91
Total
Cadmium
2.8
SF
271
16-May-91
Total
Cadmium
2.5
0.96
0.98
1 37
SF
271
1&-May-91
Dissolved
Cadmium
2.4
SF
271
17-May-91
Total
Cadmium
2.9
0.76
0.87
1.06
SF
271
17-May-91
Dissolved
Cadmium
2J2
SF
271
18-May-91
Dissolved
Cadmium
1.6
0.08
0.28
0.28
SF
271
18-May-91
Total
Cadmium
20.9
SF
271
01-Oct-91
Total
Cadmium
15
0.61
0.78
0.89
SF
271
01 -Oct-91
Dissolved
Cadmium
9.1
SF
271
02-Oct-91
Total
Cadmium
14
0.86
0.93
1.18
SF
271
02-Oct-91
Dissolved
Cadmium
12
SF
271
03-Oct-91
Dissolved
Cadmium
14
SF
271
03-Oct-91
Total
Cadmium
8
SF
271
04-Oct-91
Total
Cadmium
9
1.00
1.00
1.57
SF
271
04-Oct-91
Dissolved
Cadmium
9
SF
271
05-Oct-91
Dissolved
Cadmium
8.1
0.90
0.95
1.25
SF
271
06-Oct-91
Total
Cadmium
9
SF
271
29-Oet-93
Dissolved
Cadmium
8.8
0.99
0.99
1.46
SF
271
29-Oct-93
Total
Cadmium
8.9
SF
271
30-Nov-93
Total
Cadmium
10.4
0.96
0.96
1.37
SF
271
30-Nov-93
Dissolved
Cadmium
10
SF
271
21-Dec-93
Total
Cadmium
11.8
SF
271
21-Dec-M
Dissolved
Cadmium
12,4
SF
271
21 -Jan-94
Dissolved
Cadmium
9.5
0.97
0.98
1.39
SF
271
21-Jan-04
Total
Cadmium
9.8
SF
271
17-Feb-94
Total
Cadmium
14
1.00
1.00
1.57
SF
271
17-Feb-94
Dissolved
Cadmium
14
SF
271
07-Mar-94
Total
Cadmium
7.2
SF
271
07-Mar-94
Dissolved
Cadmium
7.8
SF
271
23-Mar-94
Total
Cadmium
7.1
1.00
1.00
1.57
SF
271
23-Mar-94
Dissolved
Cadmium
7.1
SF
271
06-Apr-94
Total
Cadmium
5.7
SF
271
06-Apr-94
Dissolved
Cadmium
6.3
SF
271
18-Apr-94
Dissolved
Cadmium
2.7
0.59
0.77
0.87
SF
271
18-Apr-94
Total
Cadmium
4.6
SF
271
03-May-94
Dissolved
Cadmium
5
SF
271
03-May-94
Total
Cadmium
4.8
SF
271
20-May-94
Total
Cadmium
4.8
SF
271
20-May-94
Dissolved
Cadmium
5.2
SF
271
08-Jun-94
Total
Cadmium
6.7
1.00
1.00
1.57
SF
271
08-Jun-94
Dissolved
Cadmium
6.7
SF
271
24-Jun-94
Dissolved
Cadmium
7.2
099
0.99
1.45
SF
271
24-Jun-94
Total
Cadmium
7.3
-------
SF
271
23-Jul-94
Dissolved
Cadmium
7 2
0.86
0.93
1.18
SF
271
23-JuI-94
Total
Cadmium
8.4
SF
271
16-Aog-94
Dissolved
Cadmium
7.8
0.91
0.95
1.26
SF
271
16- Aug- 94
Total
Cadmium
6.6
SF
271
Q9-Sep-94
Dissolved
Cadmium
10,1
0.95
0.98
1.35
SF
271
09-Sep-94
Total
Cadmium
10.6
SF
271
05-Oct-94
Dissolved
Cadmium
11
0.92
0.96
1.28
SF
271
Q5-Oct-94
Total
Cadmium
12
SF
271
16-NOV-94
Dissolved
Cadmium
18
0.95
0.97
1 34
SF
271
16-NOV-94
Total
Cadmium
19
SF
271
14D9C-94
Total
Cadmium
18
SF
271
14-Dec-94
Dissolved
Cadmium
17
SF
271
10-Jan-95
Total
Cadmium
13
077
0.88
1.07
SF
271
1(KJan-95
Dissolved
Cadmium
10
SF
271
09-Feb-95
Dissolved
Cadmium
7
0.99
0.99
1.45
SF
271
09-Feb-95
Total
Cadmium
7.1
SF
271
07-Mar-95
Total
Cadmium
7,6
SF
271
07-Mar-95
Dissolved
Cadmium
8.3
SF
271
23-Mar-95
Total
Cadmium
8.8
090
0,95
1.25
SF
271
23-Mar-95
Dissolved
Cadmium
7.9
SF
271
14-Apf-95
Total
Cadmium
8.6
0.86
0.93
1.19
SF
271
14-Apc-95
Dissolved
Cadmium
7.4
SF
271
27-Apf-95
Dissolved
Cadmium
8
0.88
0.94
122
SF
271
27-Apr-95
Total
Cadmium
6.8
SF
271
11-May-95
Dissolved
Cadmium
4.6
096
0.98
1.37
SF
271
11 -May-95
Total
Cadmium
4.8
SF
271
24-May-95
Total
Cadmiim
6,6
0.64
0.80
0.92
SF
271
24-May-95
Dissolved
Cadmium
4.2
SF
271
13-Jun-95
Dissolved
Cadmium
5.2
0.90
0.95
1.24
SF
271
13-Jun-95
Total
Cadmium
5.8
SF
271
28-Jun-95
Total
Cadmium
6
0.87
0.98
139
SF
271
28-Jun-95
Dissolved
Cadmium
5.8
SF
271
12-Jti*95
Dissolved
Cadmium
8.6
0.99
0.99
1.46
SF
271
12-Jul-95
Total
Cadmium
8.7
SF
271
26-Jul-95
Total
Cadmium
10
1.00
1.00
1.57
SF
271
26-Jul-95
Dissolved
Cadmium
10
SF
271
15-Aug-95
Dissolved
Cadmium
10.2
SF
271
15-Aug-95
Total
Cadmium
9.8
SF
271
14-S©p-95
Dissolved
Cadmium
8.5
0.97
0.98
1.39
SF
271
14-Sep-95
Total
Cadmium
8.8
SF
271
1 l-May-98
Dissolved
Cadmium
3.1
0.89
0.94
123
SF
271
11 -May-96
Total
Cadmium
3.5
SF
271
18-May-96
Total
Cadmium
4.5
0.93
0.97
1.31
SF
271
l6-May-98
Dissolved
Cadmium
4.2
1999 Data
Cd
Diss
Tot
SF
271
USGS
02-Jun-99
2,1
3
0.70
0,84
0.99
SF
271
USGS
06-Mav-99
3.8
4
0.95
0.97
1.35
SF
271
USGS
07-Sep*99
7,5
8
0.94
0.97
1.32
SF
271
USGS
08-Feb-99
11
11
1.00
1 00
1.57
-------
SF
271
USGS
09-Aog-99
7.4
8
0.93
0.96
1.29
SF
271
USGS
09-Dec-98
13
13
1.00
1.00
1.57
SF
271
USGS
09-Mar-99
8.7
9
0.97
0.98
1,39
SF
271
USGS
13-Apr-99
6.2
7
0 89
0.94
1.23
SF
271
USGS
15-Jul-99
4.2
5
0.84
0.92
1.16
SF
271
USGS
17-NOV-98
15
16
0.94
0.97
1.32
SF
271
USGS
20-Apr-99
3
4
0.75
0.67
1.05
SF
271
USGS
25-May-99
1.5
5
0.30
0.55
0,58
SF
271
USGS
26-Oct-98
11
14
0.79
0.89
1.09
SF
271
USGS
27-May-99
SF
271
USGS
30-Dec-98
4.9
6
082
0.90
1.13
50.00
stddev
0.25
calc
1.67
re-trarts
0.99
squared
0.99
translator
1.01
SF
271
07-MaMH
Total
Lead
23
0.22
0.47
0.49
SF
271
07-Mar-94
Dissolved
Lead
5
SF
271
14-May-91
Total
Lead
41
0.07
0.27
0.27
SF
271
1*-May-01
Dissolved
Lead
3
SF
271
15-May-91
Dissolved
Lead
3
0.11
0.33
0.33
SF
271
15-May-91
Total
Lead
28
SF
271
16-May-91
Total
Lead
24
0.13
0.35
0.36
SF
271
16-May-91
Dissolved
Load
3
SF
271
17-May-91
Total
Lead
15
0.20
0.45
0 46
SF
271
17-May-91
Dissolved
Lead
3
SF
271
18-May-91
Dissolved
Lead
3
0.02
0.13
0.13
SF
271
18-May-91
Total
Lead
169
SF
271
O1-Oct-91
Dissolved
Lead
3
0.15
0.39
0 40
SF
271
O1-Oct-91
Total
Lead
20
SF
271
02-Oct-91
Dissolved
Lead
1
0.05
0.21
0.21
SF
271
Q2-Oct-91
Total
Lead
22
SF
271
03-OC1-91
Total
Lead
18
0.06
0.24
0.24
SF
271
03-0ct-91
Dissolved
Lead
1
SF
271
04-OC1-91
Total
Lead
18
0.06
0 24
054
SF
271
04-Oct *91
Dissolved
Lead
1
SF
271
05-Oct-91
Total
Lead
21
0.10
0.31
0,31
SF
271
05-Oct-91
Dissolved
Lead
2
SF
271
29-Oct-93
Total
Lead
17
0.09
0.30
0.30
SF
271
29-Oct-93
Dissolved
Lead
1.5
SF
271
30-Nov-93
Dissolved
Lead
1.5
0.07
0,26
0.26
SF
271
30-NOV-93
Total
Lead
23
SF
271
21-Dec-93
Dissolved
Lead
1.5
0.10
0.32
0.32
SF
271
21-Oee-93
Total
Lead
15
SF
271
21-Jan-94
Dissolved
Lead
15
0.12
0.34
0.35
SF
271
21-Jan-94
Total
Lead
13
SF
271
17-Feb-94
Total
Lead
16
0.09
0.31
0.31
-------
SF
271
17-Feb-94
Dissolved
Lead
1.5
SF
271
23-Mar-94
Dissolved
Lead
7
0.33
058
0.62
SF
271
23-Mar-94
Total
Lead
21
SF
271
06-Apr-94
Dissolved
Lead
6
0.27
0.52
0.55
SF
27!
06-Apf-94
Total
Lead
22
SF
271
18-Apr-94
Dissolved
Lead
6
0.03
0.18
0.18
SF
271
18-AJW-94
Total
Lead
195
SF
271
03-May-94
Total
Lead
16
050
0,71
0.79
SF
271
03May-94
Dissolved
Load
8
SF
271
2Q-May-94
Total
Lead
24
0.33
0.58
0.62
SF
271
20-May-94
Dissolved
Lead
a
SF
271
OS-Jun-94
Dissolved
Lead
6
0.30
0.55
0.58
SF
271
08-Jun-94
Total
Lead
20
SF
271
24-Jur*-94
Dissolved
Lead
3
0.17
0.41
0.42
SF
271
24-Jun-94
Total
Lead
18
SF
271
23-Jul-94
Total
Lead
2.5
0.60
0.77
0.89
SF
271
23-Jul-94
Dissolved
Lead
1.5
SF
271
16-Aug-94
Dissolved
Lead
2.5
0.10
0.32
0.33
SF
271
16-Aug-94
Total
Lead
24
SF
271
09-Sep-94
Total
Lead
24
0.06
0.25
0.25
SF
271
09-Sep-94
Dissolved
Lead
1.5
SF
271
05-Oct-94
Dissolved
Lead
3
0.12
0.34
0.35
SF
271
05-Oct-94
Total
Lead
26
SF
271
16-Nov-94
Total
Lead
17
0.09
0.30
0.30
SF
271
16-NOV-94
Dissolved
Lead
1.5
SF
271
14-Dec-94
Dissolved
Lead
12
0.50
0.71
0.79
SF
271
14-Dec-94
Total
Lead
24
SF
271
10-Jan-95
Dissolved
Lead
10
0.08
0.28
0.28
SF
271
10-Jan-95
Total
Lead
127
SF
271
09-Feto-95
Total
Lead
25
0.28
0.53
0.56
SF
271
09-Feb-95
Dissolved
Lead
7
SF
271
07-Mar-95
Total
Lead
23
0.48
0.69
0.76
SF
271
07-Mar-95
Dissolved
Lead
11
SF
271
23-Mar-95
Dissolved
Lead
10
0.21
0.46
0.48
SF
271
23-Mar-95
Total
Lead
47
SF
271
14-Apr-95
Dissolved
Lead
9
0.35
0.59
0.63
SF
271
14-Apr-95
Total
Lead
26
SF
271
27-Apr-95
Dissolved
Lead
0.8
0.02
0.15
0.15
SF
271
27-Apr-95
Total
Lead
36
SF
271
11 -May-95
Dissolved
Lead
10
0.15
0.39
0.40
SF
271
11 -May-95
Total
Lead
65
SF
271
24-May-95
Total
Lead
22
0.50
0.71
0.79
SF
271
24-May*95
Dissolved
Lead
11
SF
271
13-Jun-95
Dissolved
Lead
11
035
0.60
0.64
SF
271
13-Jun-95
Total
Lead
31
SF
271
28-Jun-95
Total
Lead
21
0 24
0 49
0.51
SF
271
28-Jun-95
Dissolved
Lead
5
SF
271
12-Jul-95
Total
Lead
22
0 32
0.56
0.60
SF
271
12-Jul-95
Dissolved
Lead
7
SF
271
26-JUI-95
Dissolved
Lead
6
0 19
0.44
0 46
SF
271
26-Jul-95
Total
Lead
31
-------
SF
271
15-Aug-95
Total
Lead
27
0.06
0.24
0.24
SF
271
15-Aug-95
Dissolved
Lead
15
SF
271
14 Sep-95
Total
Lead
25
0 06
0.24
0.25
SF
271
14-Sep-9S
Dissolved
Lead
15
SF
271
04-Nov-97
Total
Lead
28.2
0 13
0.36
0.37
SF
271
Q4-Nov-97
Dissolved
Lead
3.64
SF
271
11-May-98
Dissolved
Lead
5.3
009
0.30
031
SF
271
11-May-98
Total
Lead
58.4
SF
271
18-May-98
Total
Lead
32.6
0.13
0.37
0.38
SF
271
18*May-98
Dissolved
Lead
4.4
1999 Data
Pb
Diss
Tot
SF
271
USGS
02-Jur>-99
3.6
130
0.03
0.17
0.17
SF
271
USGS
06-May-99
5
44
0.11
034
0.34
SF
271
uses
07-Sef>-99
4.5
19
0.24
0.49
0.51
SF
271
USGS
08-Feb*99
3.3
16
0.21
0.45
0.47
SF
271
USGS
09-Aug-99
7.9
26
0.30
0.55
0.58
SF
271
USGS
09-Dec-96
3.3
34
0.10
031
0.32
SF
271
USGS
09-Mar-99
5.1
15
0.34
0.58
0.62
SF
271
USGS
13-Apr-99
3.6
21
0.17
0.41
0.43
SF
271
USGS
15-JU-99
6.7
29
0.23
0/46
0.50
SF
271
USGS
17-Nov-98
5.7
@3
0.09
030
0.31
SF
271
USGS
20-Apf-99
5.4
190
0.03
0.17
0.17
SF
271
USGS
25-May-99
4.6
790
0.01
0.08
0.08
SF
271
USGS
26-Oct-98
14
150
0.09
0.31
0.31
SF
271
USGS
27-May-99
2.8
SF
271
USGS
30-Dec-98
2.7
200
0.01
0.12
0.12
count
59.00
std dev
0.19
cak:
0.71
re-trans
0.65
squared
0.43
translator
2.34
SF
271
13-Jun-95
Dissolved
Zinc
908
0.98
0.99
1.42
SF
271
13-Jun-95
Total
Zinc
929
SF
271
14-May-91
Dissolved
Zinc
513
0 95
0.98
1.36
SF
271
14-May-91
Total
Zinc
538
SF
271
15-May-91
Total
Zinc
503
SF
271
15-May-91
Dissolved
Zinc
508
SF
271
16-May-91
Total
Zinc
565
SF
271
1 $-May-91
Dissolved
Zinc
585
SF
271
17-May-91
Dissolved
Zinc
498
0.93
0.97
1.31
SF
271
17-May-91
Total
Zinc
534
SF
271
18-May-91
Dissolved
Zinc
345
065
0.81
0.94
SF
271
18-May-91
Total
Zinc
531
SF
271
01 -Oet-91
Dissolved
Zinc
2640
SF
271
01 -Oct-91
Total
Zinc
2530
SF
271
02-OC1-91
Total
Zinc
2560
-------
SF
271
02-OCJ-91
Dissolved
Zinc
2620
SF
271
G3-Oct-91
Total
Zinc
2700
0.96
0 98
1.37
SF
271
Q3-Oct-91
Dissolved
Zinc
2590
SF
271
04-Oct-91
Dissolved
Zinc
2920
SF
271
04-Oct-91
Total
Zinc
2830
SF
271
Q5-Oct-91
Dissolved
Zinc
2810
SF
271
05-Oct-91
Total
Zinc
2860
SF
271
29 0ct-93
Dissolved
Zinc
2350
SF
271
29-Oct-93
Total
Zinc
2290
SF
271
30-Nov-93
Dissolved
Zinc
2310
SF
271
30-Nov-93
Total
Zinc
2290
SF
271
21 -D©C-93
Dissolved
Zinc
2100
0.98
0.99
1.42
SF
271
21-Dec-93
Total
Zinc
2150
SF
271
21-Jan-94
Total
Zinc
1640
SF
271
21-Jarv94
Dissolved
Zinc
1660
SF
271
17-Feb-94
Dissolved
Zinc
2460
SF
271
17-Feb-94
Total
Zinc
2370
SF
271
07-Mar-94
Total
Zinc
1040
SF
271
07-Mar-94
Dissolved
Zinc
1060
SF
271
23-Mar-94
Dissolved
Zinc
1160
SF
271
23-Mar-94
Total
Zinc
1130
SF
271
Q6-Apr-94
Total
Zinc
828
0.99
0.89
1.47
SF
271
06-Apr-94
Dissolved
Zinc
819
SF
271
18-Apr-94
Total
Zinc
606
0.69
0.83
0.98
SF
271
18-Apf-94
Dissolved
Zinc
417
SF
271
03-May-94
Total
Zinc
718
SF
271
03-May-94
Dissolved
Zinc
737
SF
271
20-May-94
Total
Zinc
752
SF
271
20-May-94
Dissolved
Zinc
788
SF
271
OB-Jun-94
Dissolved
Zinc
1130
SF
271
08-Jun-94
Total
Zinc
1120
SF
271
24-Jun-94
Total
Zinc
1360
1.00
1.00
1.57
SF
271
24-Jun-94
Dissolved
Zinc
1360
SF
271
23Jul-94
Dissolved
Zinc
1380
0.95
0.98
1.35
SF
271
23-Jul-94
Total
Zinc
1450
SF
271
16-Aug-94
Dissolved
Zinc
1510
0.94
0.97
1.33
SF
271
16-Aug-94
Total
Zinc
1600
SF
271
09-Sop-94
Total
Zinc
2400
SF
271
09-Sep-94
Dissolved
Zinc
2450
SF
271
05-Od-94
Total
Zinc
2540
0.99
1.00
1.48
SF
271
05-Oct-94
Dissolved
Zinc
2520
SF
271
16-Nov-94
Dissolved
Zinc
2030
0.99
0.99
1,45
SF
271
16-Nov-94
Total
Zinc
2060
SF
271
14-Dec-94
Total
Zinc
2030
1.00
1.00
1.50
SF
271
14-Dec-94
Dissolved
Zinc
2020
SF
271
10-Jan-95
Total
Zinc
1140
0 91
096
1.27
SF
271
IO-Jan-95
Dissolved
Zinc
1040
SF
271
09-Fet>-95
Total
Zinc
1010
SF
271
09-Fet>-95
Dissolved
Zinc
1030
SF
271
07-Mar-95
Total
Zinc
1250
1.00
1.00
1.57
SF
271
07-Mar-95
Dissolved
Zinc
1250
-------
SF
271
23-Mar-95
Dissolved
Zinc
901
0.97
0 99
1.40
SF
271
23-Mar-95
Total
Zinc
927
SF
271
14-Apr-95
Total
Zinc
1040
0.96
0.98
1.37
SF
271
14-Apr-95
Dissolved
Zinc
1000
SF
271
27-Apr-95
Total
Zinc
927
098
0.99
1,42
SF
271
27-Apr-95
Dissolved
Zinc
906
SF
271
11-May-95
Total
Zinc
622
0.80
0.90
1.11
SF
271
11 -May-95
Dissolved
Zinc
499
SF
271
24-May 95
Dissolved
Zinc
646
0.98
0.99
1.42
SF
271
24-May-95
Total
Zinc
660
SF
271
28-Jun-95
Total
Zinc
1100
1.00
1.00
1.57
SF
271
2B-Jun-95
Dissolved
Zinc
1100
SF
271
12-Jul-95
Dissolved
Zinc
1480
SF
271
12-Jul-95
Total
Zinc
1470
SF
271
26-Jul-95
Total
Zinc
1850
SF
271
26-Jul-95
Dissolved
Zinc
1860
SF
271
15-Aug-95
Total
Zinc
1950
0.98
0.99
1.45
SF
271
15-Aug-95
Dissolved
Zinc
1920
SF
271
14-Sep-95
Dissolved
Zinc
1790
0.97
0.98
1.39
SF
271
14-Sep-95
Total
Zinc
1850
SF
271
04-NOV-97
Total
Zinc
1670
0.92
0.96
1.29
SF
271
04-NOV-97
Dissolved
Zinc
1540
SF
271
11 -May-98
Dissolved
Zinc
502
0.88
0.94
1.21
SF
271
11 -May-98
Total
Zinc
572
SF
271
18-May-98
Dissolved
Zinc
674
0.96
0.96
1.36
SF
271
18-May-98
Total
Zinc
704
1999 Data
SF
271
USGS
02-JWV99
317
360
0,88
0.94
1.22
SF
271
USGS
06-May-99
601
590
SF
271
USGS
07-Sep-99
1340
1400
0.96
0.98
1.36
SF
271
USGS
Q8-Feb-99
1180
1300
0.91
0.95
1,26
SF
271
USGS
09-Aug-99
1210
1100
SF
271
USGS
OS-Dec-98
175
1800
0.10
0.31
0.32
SF
271
USGS
09*Mar-99
1310
1200
SF
271
USGS
13-Apf-99
979
950
SF
271
USGS
15-JJ-99
714
660
SF
271
USGS
17-Nov-98
191
2100
0.09
0.30
0.31
SF
271
USGS
20-Apr-99
453
540
0.84
0.92
1.16
SF
271
USGS
25-May-99
227
670
0.34
0.58
0.62
SF
271
USGS
26-Oct-96
2130
2300
0.93
0.96
1.30
SF
271
USGS
27-May-99
274
450
0.61
0.78
0,90
SF
271
USGS
30-Dec-98
661
700
0.94
0.97
1.33
36.00
std dev
0.15
calc
1.51
re-trans
1.00
squared
1.00
translator
1,00
-------
Cd Pb Zn
Date Diss Cd Diss Pb DlssZn Totaled Total Pb Total Zn
ratio aqrt a retina ratio aqrt arcalne ratio »qrt arcslne
95/10/02
0.11
0.17
51.2
0.16
1.4
48.4
0.688
0.829
0.978
0.121
0.348
0.356
95/12/04
0.29
0.21
92.1
0.47
3.7
102
0.617
0.786
0.904
0.057
0.238
0.241
0.903
0.950
1.254
96/02/05
0.38
1.15
94.5
0.46
5.4
89.6
0.826
0.909
1.141
0.213
0.461
0.480
96/04/09
0.37
3.87
86.1
0.4
14.8
82.3
0.925
0.962
1.293
0.261
0.511
0.537
96/06/03
0.28
1.64
66.5
0.34
5.6
67.1
0.824
0.907
1.137
0.293
0.541
0.572
0.991
0.996
1.476
96/08/05
0.28
0.21
46.1
0.45
1.4
45.7
0.622
0.789
0.909
0.150
0.387
0.398
96/10/08
0.22
0.23
50.2
0.18
1.2
46.9
0.192
0.438
0.453
1.070
1.000
1.571
96/12/03
0.25
0.34
81.6
0.3
1.5
78.6
0.833
0.913
1.150
0.227
0.476
0.496
97/02/04
0.34
0.91
105
0.34
3.1
110
1.000
1.000
1.571
0.294
0.542
0.573
0.955
0.977
1.356
97/06/03
0.34
1.65
78.9
0.45
9.1
91
0.756
0.869
1.054
0.181
0.426
0.440
0.867
0.931
1.198
97/07/08
0.16
0.38
40.4
0.22
1.6
47
0.727
0.853
1.021
0.238
0.487
0.509
0.860
0.927
1.187
97/08/05
0.16
0.13
45.3
0.18
1
44
0.889
0.943
1.231
0.130
0.361
0.369
97/10/06*
0.11
0.2
46.2
0.1
0.9
42
0.222
0.471
0.491
1.100
1.000
1.571
97/11/03*
0.17
0.23
61
0.19
1
50.8
0.895
0.946
1.240
0.230
0.480
0.500
97/12/08'
0.29
0.18
82
0.35
1.1
82.4
0.829
0.910
1.144
0.164
0.405
0.416
0.995
0.998
1.501
98/02/02*
0.33
0.12
102
0.3
0.8
83.4
0.150
0.387
0.398
1.223
1.000
1.571
98/03/02*
0.32
0.15
97.1
0.31
0.8
81.7
0.188
0.433
0.448
1.188
1.000
1.571
98/04/14*
0.36
0.64
96
0.36
2.2
96.9
1.000
1.000
1.571
0.291
0.539
0.570
0.991
0.995
1.474
98/06/08*
0.27
0.36
67.1
0.28
1.6
58.3
0.964
0.982
1.381
0.225
0.474
0.494
98/08/03'
0.13
0.1
42.3
0.16
0.9
40.1
0.813
0.901
1.123
0.111
0.333
0.340
1999 Data
Cd
Pb
Zn
Date
Diss Cd
Diss Pb
Diss Zn
Total Cd
Total Pb
Total Zn
ratio
sqrt
arcslne
ratio
sqrt
arcslne
ratio
sqrt
arcsine
07-Jun-99
0.26
0.77
62
0.31
6.3
57
0.839
0.916
1.158
0.122
0.350
0.357
07-Sep-99
0.15
0.21
32
0.16
1.7
36
0.938
0.968
1.318
0.124
0.351
0.359
0.889
0.943
1.231
09-Aug-99
0.14
0.08
37
0.19
1.2
39.8
0.737
0.858
1.032
0.067
0.258
0.261
0.930
0.964
1.302
10-Feb-99
82
89
0.921
0.960
1.287
11 -Mar-99
0.16
85
0.36
85
0.444
0.667
0.730
1.000
1.000
1.571
11 -May-99
72
76
0.947
0.973
1.339
12-Apr-99
0.34
0.28
88
0.39
2.5
89
0.872
0.934
1.205
0.112
0.335
0.341
0.989
0.994
1.465
12-Jul-99
0.22
0.18
45
0.23
1.6
47.2
0.957
0.978
1.361
0.113
0.335
0.342
0.953
0.976
1.353
13-Nov-98
0.19
0.19
1.000
1.000
1.571
16-Dec-98
0.22
0.1
77
0.28
0.8
77
0.786
0.886
1.090
0.125
0.354
0.361
1.000
1.000
1.571
28-Jan-99
0.35
91
0.35
96
1.000
1.000
1.571
0.948
0.974
1.341
-------
Count
29
26
30
29
26
30
* - Provisional data. Lab QC only.
std dev
0.320
0.122
0.336
calc
1.676
0.612
1.895
re-trans
0.994
0.575
0.948
squared
0.989
0.330
0.898
translator
1.011
3.029
1.113
Note:
Samples with dissolved analyte > total analyte were removed from the analysis.
-------
APPENDIX K : TMDL FEASIBILITY AT THE BUNKER HILL CTP
Introduction
This appendix summarizes the approach taken, and the results to date, for developing compliance
strategies for the Total Maximum Daily Load (TMDL) allocation assigned to the Central
Treatment Plant (CTP), which treats the drainage from the Bunker Hill Mine in Kellogg, Idaho.
Approach
The following summarizes the TMDL compliance approach to date:
~ A hydro logic comparison of recorded flows from the Kellogg Tunnel (KT) of the Bunker Hill
Mine and at the Pinehurst gauge on the South Fork of the Coeur d'Alene river was
conducted, because the Pinehurst gauge will be used to measure TMDL compliance for the
CTP. The allowable monthly average discharge of cadmium, lead, and zinc is dependent on
river flow rate.
»¦ Sampling of the current CTP effluent for dissolved metals was initiated. This was done to
determine the capability of the existing lime high density sludge treatment process to remove
dissolved cadmium, lead, and zinc. Previously only total cadmium, lead, and zinc of the
effluent were monitored.
~ Additional treatment technologies (sulfide precipitation, iron co-precipitation, and ion
exchange) were reviewed and tested in the laboratory for their ability to produce treated water
of sufficient quality for TMDL compliance. Emphasis was placed on technologies that could
complement the existing lime high density sludge process.
~ Source control measures, which could reduce the recharge of surface and groundwater to the
mine, were identified with the goal of reducing the amount of flow and pollutant loads
requiring treatment.
~ A computer model was developed to evaluate compliance with the TMDL assuming different
mine water flow rates, treatment plant sizes, effluent concentrations, water management and
storage facilities, and river flows.
Results to Date
~ The hydrologic evaluation found little correlation between historic mine and river flows on a
daily basis. This is likely due in part to the hydrologic differences between the South Fork's
large east-west trending watershed and the north-aspect watersheds that overlay the mine, and
1
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in part to historic in-mine water management activities. This lack of a correlation necessitated
selection of representative annual data sets of KT and river flows for computer modeling.
~ Several source control measures have been identified which have potential to reduce both the
peak and base flow rates from the mine. These measures may allow for operation of smaller
scale treatment equipment.
*¦ The computer model is being used to evaluate sizes of treatment equipment needed
depending on the amount of source control that is achieved. The model is also used to
evaluate use of pre-treatment storage of mine water for either peak flow reduction or
contingency storage in the event of treatment plant shutdown, mine flood, or other unforeseen
event.
~ The computer model results show that as long as the CTP effluent concentrations of
cadmium, lead, and zinc are below certain threshold values, that the TMDL toad allocations
do not restrict discharges below the design flow of the treatment plant. This reduces the need
for large volumes of pre-treatment storage for TMDL compliance.
Dissolved metals sampling of the CTP effluent indicates that the existing treatment process
may be sufficient to achieve compliance with the TMDL with addition of filtration. Average
CTP effluent concentrations of dissolved metals collected during treatability sampling are as
follows:
Cadmium; 0.50 mg/L
Lead: 0.1 mg/L
Zinc: 18 mg/L
~ Laboratory treatability testing has evaluated addition of sulfide precipitation, iron co-
precipitation, and ion exchange to the existing lime high density sludge treatment process to
further reduce concentrations of dissolved cadmium, lead, and zinc. The addition of soluble
sulfide into the lime neutralization process was selected for follow-on testing during the
summer of 2000 because it performed as good or better than the other technologies, plus it
was considered to be the most cost effective. Dissolved metals were lowered to the following
concentrations using sulfide addition during laboratory testing:
Cadmium; 0.07mg/L
Lead: < 0.32 mg/L
Zinc: 15 mg/L
~ Filtration of the CTP effluent using either media or micro filters will be needed to reduce
suspended metal in the CTP effluent. Both media and micro filtration will be tested during
the summer of 2000.
2
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APPENDIX L ; RIVER FLOW REGRESSIONS
-------
Flow Regression
Canyon Creek vs Silverton
c
o
>
c
CO
o
y = 0.2254X
FT = 0.9566
, , , , 1
.0 500.0 1000.0 1500.0 2000.0 2500
silverton
Tier Estimates
7Q10 10th 50th 90th
Silverton 31 48 109 649
Canyon 7.1 11.0 25.1 149.3
Source: USGS 1999 Sampling
Daily values from 10/01/98 thru 09/30/99
-------
Flow Regression
Ninemile vs Silverton
140.0
y = 0.0633X
R2 = n 7R75
120.0
100.0
a>
80.0
60.0
c
40.0
20.0
0.0
500.0 1000.0 1500.0 2000.0 2500.0
0.0
silverton
Tier Estimates
7Q10 10th 50th 90th
Silverton 31 48 109 649
9Mile 2.0 3.0 6.9 41.1
Source: USGS 1999 Sampling
Daily values from 10/01/98 thru 09/30/99
-------
Flow Regression
Pine Creek vs South Fork Pinehurst
1600.0
y - 0,304x
1400.0
H = 0.9045
1200.0
1000.0
800.0
600.0
400.0
200.0
0.0 1000.0 2000.0 3000.0 4000.0 5000.0
pinehurst
Tier Estimates
7Q10 10th 50th 90th
Pinehurst 68 97 268 1290
Pine 20.4 29.1 80.4 387.0
Source: USGS 1999 Sampling
Daily values from 10/01/98 thru 09/30/99
-------
Flow Regression
Harrison vs Cataldo
c
o
(0
•E
CB
s:
18000.0
16000.0
14000.0
12000.0
10000.0
8000.0
6000.0
4000.0
2000.0
0.0
v = 0.9872X + 37.565
R = 0 9981
0.0
5000.0
10000.0
cataldo
15000.0 20000
Source: USGS 1999 Sampling
Daily values from 10/01/98 thru 09/30/99
-------
Total Maximum Daily Load for Dissolved Cadmium,
Lead, and Zinc in the Coeur d'Alene River Basin
Response to Comments
August 2000
U.S. Environmental Protection Agency, Region 10
1200 Sixth Avenue
Seattle, WA 98101
Idaho Department of Environmental Quality
1410 North Hilton
Boise, Idaho 83706
-------
INTRODUCTION 3
CHANGES TO THE TMDL RESULTING FROM PUBLIC INPUT 3
REGULATORY OPTIONS . 4
Regulatory Relief Mechanisms in The Idaho Water Quality Standards 4
Coordination of Permitting and Standards Actions 8
RESPONSES TO INDIVIDUAL COMMENTS 10
1.0 Water Quality Standards 10
1.1 Appropriateness of Gold Book Criteria 10
1.2 Hardness Assumptions 14
1.3 Site-Specific Criteria 18
1.4 Beneficial Use for Coeur d'Aiene Basin Waters 21
1.5 National Toxics Rule 22
1.6 Antidegradatkm 24
2.0 TMDL 24
2.1 Source Identification 26
2.2 Target Sites 30
2.3 Attenuation of Metals - Upland Adits .31
2.4 Attenuation of Metals - Instream Reactions 31
2.5 Natural Background Conditions 35
2.6 Flow Tiers 39
2.7 Margin of Safety 42
2.8 Method of Allocation - CdA River and Tributaries 44
2.9 Method of Allocation - Spokane River 56
2.10 Legal Issues 57
3.0 Implementation Issues 70
3.1 Feasibility of Allocations 70
3 .2 Timing of TMDL and Permitting Actions 79
3.3 Relative Contribution of Discrete Sources 87
3.4 TMDL Implementation Issues Regarding Superfund Cleanup 88
3.5 Monitoring 89
3.6 TMDL Implementation Issues Regarding NPDES Permitting 90
3.7 TMDL Implementation Issues Regarding Effluent Trading 95
3.8 TMDL Implementation Issues Regarding Economic Considerations 96
3.9 TMDL Implementation Issues Regarding Removal Technologies 98
4.0 Other Issues 100
Appendix A: Comments Log 108
7
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INTRODUCTION
Oil April 15, 1999, the Environmental Protection Agency (EPA) and Idaho Department of
Environmental Quality (DEQ) released a draft TMDL for Dissolved Cadmium, Lead, and Zinc in
the Surface Waters of the Coeur d'Alene River Basin. The agencies held a 120-day public
comment period on the TMDL that closed on August 14, 1999. During the comment period,
EPA and DEQ held public meetings and hearings in Wallace, Osbum, and Coeur d'Alene. The
agencies have also participated in a number of meetings organized by interested parties regarding
the TMDL and/or related issues. In producing this document, the agencies reviewed
approximately 300 comment letters as well as testimony from public hearings, petitions, and
other information received during the comment period.
EPA and DEQ received several comments relevant to Superfund program activities that are not
pertinent to the Coeur d'Alene Basin TMDL. Because these comments are not pertinent to the
TMDL, they are not addressed in the Response to Comments for the TMDL. EPA notes that
most of these comments have already received responses in the context of EPA's on-going
Remedial Investigation/Feasibility Study (RI/FS). Further opportunities for public comment
concerning Superfund activities in the Coeur d'Alene Basin will be provided continuously
through EPA's participation in public meetings, circulation of draft documents, and other
outreach efforts.
CHANGES TO THE TMDL RESULTING FROM PUBLIC INPUT
Public comments on the draft TMDL have led to a number of changes and improvements to the
TMDL. The following is a general description of the most significant changes. The responses to
individual comments and the revised Technical Support Document for this TMDL describe these
changes in more detail.
1) The relationship between river flow and hardness has been built into the TMDL
loading capacities for the South Fork Coeur d'Alene River and tributaries. The
available data indicates that river hardness descreases with increased river flow at
these sites. This results in higher water quality criteria and thus higher loading
capacities during low flow conditions at these target sites,
2) Natural background metals concentrations have been revised upward (but not
exceeding the Gold Book criteria) based on significant new information and
analyses received since the release of the draft TMDL
3) The approach for determining performance-based wasteload allocations has been
revised. Rather than quantifying current performance in the TMDL, the TMDL
now contains a narrative requirement for performance-based allocations to be
established in the NPDES permitting process. This allows additional time for
sampling and analysis to establish accurate estimates of current performance.
4) The allocation method related to performance-based allocations has been revised.
Fur the South Fork and tributaries, loading capacity made available by
3
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establishment of performance-based allocations will be reserved for future growth
(new or expanding facilities). For the Spokane River, loading capacity made
available by establisliment of performance-based allocations will be allocated to
municipal stormwater discharges.
5) While the TMDL elements are still established at four flow tiers, a narrative
statement added to the TMDL will provide flexibility to incorporate additional
flow tiers as part of implementation in NPDES permits.
REGULATORY OPTIONS
A wide range of concerns about tte draft TMDL were raised in the comments and at the public
meetings. Foremost was the concern about the potential impact of the TMDL on the local
economy. Based on this concern, EPA and DEQ have evaluated the regulatory relief
mechanisms established in the Idaho water quality standards and options for integrating these
mechanisms into the NPDES permitting process.
Regulatory Relief Mechanisms in The Idaho Water Quality Standards
The Clean Water Act and implementing regulations include a number of mechanisms that can
provide regulatory relief to affected parties under special circumstances. Mechanisms in the
Idaho water quality standards include use-attainability analysis, site-specific criteria, and
variances.
Use Attainability Analysis
"Designated Uses" are those beneficial uses specified in the water quality standards for each
waterbody or segment whether or not they are being attained (40 CFR 131.3). The designated
use driving the TMDL analysis in the Coeur d'Alene basin is established in the Idaho water
quality standards as "maintenance of viable communities of aquatic organisms" (generally
referred to as the "cold water biota" use).
A "Use Attainability Analysis (UAA) must be completed to support a downgrade to the
beneficial uses of a waterbody. A UAA is defined as a structured scientific assessment of the
factors affecting the attainment of the designated beneficial use, which may include physical,
chemical, biological, and economic factors (40 CFR 131.3 and 40 CFR 131.10(j)). In a UAA, a
state or autliorized tribe (i.e., a tribe with approved water quality standards) evaluates the
"attainability" of the beneficial uses established in the water quality standards for a particular
water, h provides the technical basis for a formal change to a use designation in the state water
quality standards. States and tribes must obtain EPA approval of any changes that result in less
stringent water quality standards, and EPA must conduct Endangered Species Act (ESA)
consultations for the approval action.
4
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To achieve the goals of the Clean Water Act, states must seek to attain "fishable" and
"swimniable" goals for its waters. Specifically, states accomplish these goals by establishing
specific beneficial use categories (e.g., aquatic biota, contact recreation) and subcategories (e.g.,
cold water biota, warm water biota) in their water quality standards. Numeric criteria for toxic
pollutants (such as dissolved metals) are established to assure attainment of the designated use.
These criteria are used in regulatory activities such as impaired waters listings, TMDLs, and
NPDES permits. For example, an NPDES permit is developed such that the numeric criteria are
met in the receiving water, thereby protecting the uses of the waterbody.
For toxic pollutants, the feasibility of achieving the criteria to fully protect aquatic life (e.g., Gold
Book criteria) is a frequent concern to dischargers. The Clean Water Act and implementing
regulations allow for the creation of use subcategories in a state's standards. A use subcategory is
a refinement or clarification to a specific use classification. The state selects the level of
specificity it desires for identifying designated uses and subcategories of uses (see EPA's 1995
Water Quality Standards Handbook, Section 2.3).
A state must conduct a UAA whenever it wishes to adopt subcategories of uses which require
less stringent criteria (40 CFR 131.10(j)(2)). For the South Fork Coeur d'Alene River, this
requirement would apply to the application of the state of Idaho's "Partial Cold Water Biota Use"
subcategory, because it would represent a relaxation in the water quality standards from the cold
water biota use classification.
A change to the use classification requires a clear and thorough technical basis for the less
stringent use designation, the associated numeric criteria, and the delineation of specific
waters/segments to which it applies. The scale and complexity of the pollution problem in the
Coeur d'Alene basin presents a particularly complex UAA challenge. In order to establish
alternative uses and criteria to protect those uses, the state would need to predict the expected
quality of basin waters after clean-up actions are completed. To obtain these predictions, DEQ
would need to predict the feasibility, effectiveness, and funding of control actions for all discrete
and non-discrete sources. The cumulative TMDL and RI/FS work to date is only a beginning to
such an endeavor.
Based on the above considerations, EPA and DEQ do not believe a UAA will be a feasible
regulatory relief mechanism in the Coeur d'Alene basin in the near future.
Site-Specific Criteria
States can adopt Site-Specific Criteria (SSC) for a specific waterbody to replace the statewide
water quality criteria (which, in Idaho, are based EPA national criteria guidance). SSC are
developed to provide a more refined level of protection for aquatic life at the site, taking into
account such site-specific conditions as the species composition and water quality characteristics
(Standards Handbook, Section 3.7). An SSC must fully protect the designated use (e.g., cold
water biota), and must be formally adopted into the state water quality standards and approved by
EPA prior to its use in regulatory actions. In addition. EPA must complete Endangered Species
Act consultation on any approval action. Because state agencies usually do not have funding
5
-------
available for SSC development work, this work is typically funded by NPDES dischargers
seeking relief from statewide water quality criteria.
In the Coeur d'Alene basin, SSC have been under development for some time for the South Fork
Coeur d'Alene River segment above Wallace (upstream of the Canyon Creek confluence). This
effort has included extensive toxicity testing with a representative suite of resident species to
determine the metals levels that will fully support aquatic biota in this segment. This work has
been funded by the state of Idaho and Hecla Mining Company.
EPA and DEQ have evaluated the impact of a potential SSC on the TMDL. The draft SSC for
the Wallace segment would not have any effect on the TMDL allocations, because Idaho water
quality criteria would still be applied in the impaired segments downstream of the Wallace
segment. Meeting these downstream criteria would require the same calculations and wastetoad
allocations in the TMDL. On the other hand, an SSC for the entire South Fork mainstem (from
Pinehurst to the Montana border) could affect the TMDL allocations, because the dilution from
the North Fork would allow for higher metals concentrations than Idaho water quality criteria in
the South Fork.
Some affected parties have commented that the agencies should also be developing SSC for the
waters downstream from this segment. Development of SSC for the entire South Fork would
require an analysis of the biological community structure and water chemistry (hardness, etc)
downstream of Wallace. This work has not been funded by the state or mining companies to
date. Even if the testing and analyses indicate a substantially higher tolerance in resident species
for dissolved metals, the degree of regulatory relief provided by such an SSC would be governed
by the available dilution from the North Fork (at the confluence with the South Fork).
Variance
A variance is a temporary waiver from a water quality standard in an NPDES permit that is
specific to a discharger and pollutant. Variance provisions are a part of a state's water quality
standards and allow for relief from a water quality standard when specific conditions (see below)
apply to the pollution problem and/or affected dischargers. Variance provisions are also included
in EPA's 1997 promulgation of cold water biota uses in the South Fork watershed.
Under Idaho water quality standards, variances remain in effect for a period of five years or the
life of the permit. Upon expiration of a variance, the discharger must either meet the standard or
must re-apply for the variance. In considering a re-application for a variance, the discharger must
demonstrate "reasonable progress" toward achieving the standard. This is consistent with EPA
guidance for variances in the Water Quality Standards Handbook (Section 5.3). Like other
changes to water quality standards, any variance action by a state must be approved by EPA.
EPA must also consult on its approval action in accordance with the Endangered Species Act.
In order to obtain a variance, the discharger must demonstrate that meeting the standard is
unattainable based on one or more of the following grounds:
6
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1. Naturally occurring pollutant concentrations prevent the attainment of the
standard.
2. Natural, ephemeral, intermittent, or low flow conditions or water levels prevent
the attainment of the standard.
3. Human caused conditions or sources of pollution prevent the attainment of the
standard and cannot be remedied or would cause more environmental damage to
correct than to leave in place.
4. Dams, diversions or other types of hydro logic modifications preclude the
attaimrcnt of the standard, and it is not feasible to restore the water body to its
original condition or to operate such modification in a way that would result in
attainment of the standard.
5. Physical conditions related to the natural features of the water body, unrelated to
water quality, preclude attainment of the standard.
6. Controls more stringent than technology-based effluent limitations would result in
substantial and widespread economic and social impact.
In the case of the Coeur d' AJene basin, EPA and DEQ believe the sixth variance criterion may be
applicable to the municipal dischargers in the basin. During the comment period, EPA and DEQ
noted the significant level of concern about the potential impact of the TMDL on the local
economy. In particular, public and local officials raised concerns about the potential impact of
increased sewage treatment costs on residential sewage rates in communities along the South
Fork. Based on new information about the source of metals contamination in the municipal
discharges and potential costs of metals reductions, EPA and DEQ believe that these dischargers
may be appropriate candidates for variances based on a showing of widespread economic harm
(criterion #6 above).
Conclusions
Based on the above considerations, EPA and DEQ have come to the following conclusions:
1 Use Attainability Analysis (UAA) is not likely to be feasible in the near future. A
successful UAA and Use Subcategory promulgation cannot be started until completion of
Superfund cleanup plans with specific remedial actions and expected water quality
improvements.
2. Site Specific Criteria (SSC) continue to be an option for the upper part of tlie basin, but
SSC will only affect the TMDL if applied to the entire South Fork. Based on proposed
criteria to date and the applicability of Gold Book criteria downstream. SSC applied to
the entire Smith Fork will provide only limited relief for discrete sources. Nevertheless,
if SSC are eventually adopted by the state and approved by EPA, the TMDL would be
revised accordingly.
7
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3. Variances should be pursued by those facilities that can make showings of (1) widespread
economic harm due to pending permit requirements and (2) reasonable further progress
toward achieving water quality goals. If justified, variances could provide a higher
degree of regulatory relief than SSC for facilities in the Coeur d'Alene basin.
Coordination of Permitting and Standards Actions
EPA is developing new NPDES permits for the operating facilities in the basin. The public
process for NPDES permit issuance is similar to the process for the issuance of the Coeur
d'Alene TMDL, EPA develops a draft permit and supporting documentation, releases it for
public comment for a minimum 30 days, responds to substantive comments, and revises the draft
permit where appropriate based on public comments. Prior to issuance of the final permit, EPA
requests state certification that the final permit will achieve Idaho water quality standards in
accordance with Section 401 of the Clean Water Act. EPA also conducts ESA consultation for
each permit,
EPA and DEQ believe water quality standards and permitting activities can be integrated in a
manner that strikes a balance between the needs for timely permit issuance and regulatory
flexibility. At this time, each affected facility has an opportunity to affect its permit requirements
by (I) committing to a course of action with respect to the options for regulatory relief, and (2)
developing and submitting adequate information to the agencies in support of its proposals.
The agencies plan to pursue the following schedule of actions to implement the TMDL and any
changes to water quality standards into the NPDES permits. Note that actions should be pursued
concurrently where feasible.
1. EPA and DEQ issue final TMDLs
2. EPA begins development of NPDES permits for operating facilities in the basin.
3. Affected facilities decide whether or not to commit resources toward variances and/or
expanded site specific criteria (e.g., for mainstem South Fork from Pinehurst to
headwaters).
4. Based on decisions made by the facilities, EPA and DEQ provide guidance regarding the
required information needed to support the selected standards action. For example, the
agencies would help interpret the "reasonable progress" requirement for a facility seeking
a variance.
.5. At any time in the permit issuance process or alter the permit is final, if SSC affecting the
TMDL are promulgated by the State of Idaho and approved by EPA, the TMDL will be
modified accordingly. Tlie permit would also be modified as appropriate.
B
-------
Similarly, at any time in the permit issuance process or after the permit is final, if a
variance is promulgated by the State of Idaho and approved by EPA, the NPDES permit
will be modified accordingly,
6. After completing the public process and obtaining state certification, EPA issues the
NPDES permits. The permit limits for cadmium, lead, and zinc will be based upon either
wasteload allocations in the TMDL or an approved variance. Thus, depending on the
timing and the actions taken by the facility, these permits would contain either TMDL
wasteload allocations or alternate requirements based on an approved variance.
Permit limits for non-TMDL parameters will be based on technology-based effluent
guidelines and applicable water quality criteria
1. For a facility that needs time to design and install improvements to meet the permit limits,
a compliance schedule can be authorized in the permit by the State for up to 5 years. The
compliance schedule includes milestones for progress toward full compliance with the
permit limits.
9
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RESPONSES TO INDIVIDUAL COMMENTS
EPA and DEQ have endeavored to collect, review, and respond to each substantive comment on
the proposed TMDL. The agencies received approximately 300 comment letters and substantia]
hearing testimony on the draft TMDL. In some cases, the exact phrasing of detailed comments
is presented. In other cases, in order to develop a response to comments document of reasonable
length, it was necessary to group similar comments and paraphrase comments. To the best
abilities of the agencies, this "distillation" of comments was performed in a manner that
preserved the substance of each comment. In grouping comments, the agencies either
paraphrased the issue or incorporated the exact phrasing from the particular comment in the
group that most succintly captured the issue and relevant information.
EPA and DEQ received several comments relevant to Superfund program activities that are not
pertinent to this TMDL action under the Clean Water Act. Because these comments are not
pertinent to the TMDL, they are not addressed in this Response to Comments.
For each comment pertinent to the TMDL, one or more letter numbers is provided to indicate the
individual or organization that submitted the comment. In Appendix A, a Comments Log is
included. This lists the commenters and their letter number.
Administrative Record files containing copies of each comment letter are available for review at
EPA's Seattle office and DEQ's Coeur d'Alene office.
1.0 Water Quality Standards
I. I Appropriateness of Gold Book Criteria
Comment #1 Letler(s) 207
The Department of Ecology in the State of Washington supports the TMDL approach that assures that the Water
Quality Standards of Washington will be met as the Spokane River crosses into Washington, It is imperative that
this goal remains clear in any subsequent versions of the TMDL
Response: EPA and DEQ agree The final TMDL Technical Support Document (hereafter referred to as the
'TMDL TSD") retains this water quality goal.
Comment #2 Letter(s) 274
The toxicity of metals is related to their bioavailability, which in turn is mediated by inorganic and organic hgands
in the water column. Some of the inorganic ligands form insoluble precipitates (particulates) with metal ions, while
others form soluble complexes thai are less bioavailable than the free metal Free metal ions are considered to be the
most toxic form of metals and are thus likely to be the toxic form that drives the EPA water quality criteria for
cadmium, lead, and zinc It is important to understand that the EPA water quality criteria for these metals were
developed from laboratory toxicity tests in extremely low solids, low organic content waters, which are often not
representative of the chemistry of many streams and lakes.
10
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Response; EPA and DEQ generally agree as to the description of metal toxicity and chemistry. However, it is
the responsibility of EPA laboratories to develop protective water quality criteria applicable to a wide
range of conditions across the nation. Site specific conditions can be addressed through scientific
analyses in support of a site specific criterion. The assertion that the criteria are not representative is
not supported in the case of cadmium, which appears to be toxic to aquatic life in the South Fork at
levels similar to the national cadmium criterion
Comment #3 Letter(s) 255,266
The term "dissolved mat a]" is an operational rather than strict definition of "dissolved". In practice, the dissolved
fraction measured includes all matter passing a 0 45 micron filter Non-toxic colloidal particles will pass through a
0.45 micron filter and are equated with toxic forms of the metal. Thus the analytical procedure being used may be
grossly overstating the true dissolved metals levels in the stream. This concept is proven by the existing healthy
aquatic community in the South Fork of the Coeur d'Alene River above Wallace even though the Gold Book criteria
are routinely exceeded. The USGS has noted that true dissolved metals are those that pass through a 0.001 micron
filter - metal forms 450 times smaller than the 0.45 micron operational definition of "dissolved".
Hecla directed a contract laboratory to mix metal salt solutions (chlorides of lead, zinc, & cadmium) used for the
testing in the Gold Book criteria derivation process. These solutions were thai filtered through a 0.02 micron filter
(the smallest readily available to the contract laboratory). Virtually all the metal passed through the 0.02 micron
filter. EPA must address this scientific shortcoming in the Gold Book criteria to account for the coincidental
measurement of nontoxic colloidal particles in the current "operational" definition of "dissolved" metals.
"Dissolved" should be based upon filtration through at least a 0.02 micron (and perhaps a 0.001 micron) filter.
EPA's application of Gold Book criteria must be adjusted accordingly.
Response: The TMDL does not establish water quality standards or the methods for measuring dissolved metals
but is based on standards adopted by the State of Idaho. The Idaho water quality criteria for metals are
established for the "dissolved" portion of the sample, defined as the portion passing through a 0.45
micron filter This filtration technique is the standard method used in criteria development, ambient
sampling programs, and permitting programs under the Clean Water Act. The agencies do not
anticipate a change to the 40 CFR 136 approved methods for measuring dissolved metals.
Comment #4
Letter(s)
272
The interchangeable use of total recoverable and dissolved do not necessarily represent the bioavailable portion of
the metal that impact uses of the water resource EPA/IDEQ need to take a very close look at this relationship along
with flows, sediment loading and other conditions during sampling when assessing potential impacts.
Response: The TMDL does not use total recoverable and dissolved interchangeably. In presenting water
quality data in the TMDL TSD, EPA depicted current water quality in terms of dissolved metals to
the extent possible The dissolved fraction is a better representation of the bioavailable portion of
the metal in the water column. This understanding is reflected in the Idaho water quality
standards, which sjteufy the use of dissolved metals criteria. The TMDL establishes allocations
using the dissolved criteria, but it also translates these dissolved wasteload allocations into total
recoverable wasteload allocations for the discrete sources. This translation from dissolved to
total recoverable is necessitated by the water quality standards and NPDES permit regulations.
EPA and DEQ note that there is a 1 1 relationship between the dissolved and total recoverable
values tor cadmium and zinc, because these metals are almost entirely in the dissolved phase in
Coeur d'Alene Basin waters.
Comment #5
Letter(s)
278. 281
11
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The proposed TMDL only addresses the dissolved quotient of metals loading to the river system. This ignores the
fact that bound metals and metals-contaminated sediments also impact water quality and the health of cold water
biota.
Response: EPA and DEQ acknowledge that this TMDL does not directly address sediment quality. At this time,
water quality standards for the states of Idaho and Washington do not contain sediment quality criteria
fur freshwater systems. Therefore, fir a sediment-metals TMDL to be developed, the first step would
be to establish site-specific criteria for metals in nver/lake sediments Given the current level of effort
needed to address the water column contamination and criteria, DEQ does not currently have
sufficient resources to develop sediment quality criteria. While no sediment quality criteria are
established, the implementation of this water-column TMDL should signficantly reduce the release
and downstream migration of particulate metals from both discrete and non-discrete sources. This in
turn should improve overall sediment quality in the basin.
Comment #6
Letter(s) 7,9,11,20,23,
26, 27, 30, 32,
34, 35, 38, 39,
40, 47,48, 49,
50, 51, 52, 53,
54, 55, 102, 107.
109, 112, 113,
119,230,244,
246, 252, 265,
268, 291, C3, C9,
C14.C15.C16,
C24,03, 06,
Oil, W11.W14
The use of the "Gold Book" standards for implementing the proposed TMDLs in the Coeur d'Aiene River is
unreasonable and the standards are not attainable, due to the mineralized character of the area. Considering the
mineralization, it is unlikely that the water quality goals established in the TMDL are warranted.
Response: This statement rests on the assertion that the natural background metals concentrations in the Coeur
d'Aiene Basin are higher than Gold Book criteria concentrations due to the mineralized character erf
the area. The information available to EPA and DEQ does not support this assertion (see discussion in
the TMDL TSD and also in this document under Natural Background Conditions). EPA and DEQ
acknowledge that natural background levels of the three metals at issue are elevated in this basin
compared to many other basins, and the natural loadings reduce the loading capacity available for
allocation. However, the estimated natural background concentrations and loadings are well below the
Gold Book criteria.
Comment #7
Letter(s)
00
114,
120,
122
126
127,
128
165
167.
197
199
206,
211
212
213,
214
217
219,
220
221
222.
223
¦>24
226.
229
231
232
234
235
241,
242
245
250,
12
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253
260
275
281
307
254, 259,
264, 273,
276, 278,
286, 306,
CIO, C12,
07,08,013,
014
Support TMDL requirements to clean up river basin. They will protect public health and aquatic organisms while
enabling future generations to enjoy a clean and healthy environment.
Response: EPA and DEQ acknowledge the comment.
Comment #8
Letter(s) 4,7,10,11,12,
13, 15, 16,23,
24, 26, 27, 28,
29, 30,31,32,
33, 34. 35,36,
38, 39. 40,42,
43,44, 45, 46,
47, 48, 49, 52,
54, 55, 56, 57,
60, 61, 64, 67,
68, 71, 73, 102,
107, 110, 111,
112, 115, 119,
209,215, 225,
227, 233, 236,
237, 238, 239,
243, 244, 246,
247, 248, 249,
257, 261,271,
274, 280, 283,
293, 294, 297,
298,300, 301,
302, 303, 308,
309, C5. C6,
C13.C14.C17,
C24, C25, Ol,
02,020, 021,
027, 028, W3,
W4, W7, W8,
W10.W15.W16
Implementing the proposed TMDLs based on the "Gold Book" standards would create undue economic hardship on
the local businesses and residents, and would make it difficult or impossible to attract new business The TMDL
should consider the economic impacts of using Gold Book standards versus stle-specific criteria.
Response. The Clean Water Act requires thai TMDLs be based on applicable water quality standards. The water
quality standards used as (he basis for the TMDL. are those adopted by ihe Slate of Idaho. Furiher,
there is no requirement that a TMDL include an economic impact analysis Nonetheless, EPA and
DEQ have evaluated the poiential relief provided by finalizing site-specific criteria in the b3sin. While
stle-specific criteria may provide relief for sources if they are less sinngem than Gold Book criteria,
they are established based on biological testing ,md not an economic analysis. Therefore, the relief
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provided by site-specific criteria can be limited. See discussion of site-specific criteria and other relief
mechanisms under Regulatory Options.
Comment #9 Letter(s) 274
EPA should not establish a TMDL based cm water quality standards for cadmium and zinc that the Agency itself
now recognizes is overly stringent and has in fact modified. On December 10, 1998, EPA published revised water
quality criteria in the Federal Register that represent a significant change in the water quality criteria for cadmium
(0.80 /ig/1 at hardness of 25 mg/1) and a smaller difference for zinc (36.5 ^g/l at hardness of 25 mg/1). See 63 Fed.
Reg. 68353, 68357-59 (Dec. 10, 1998). EPA has nonetheless ignored its own science and developed the proposed
TMDL based on water quality standards that are clearly outdated. Any TMDL that is developed should be based on
the best and most up-to-date science.
Response: EPA periodically updates national water quality criteria guidance based on updated scientific
information and analysis. States and tribes are responsible for updating or revising state or tribal water
quality standards, and they may elect to adopt EPA's national criteria. TMDLs are governed by the
applicable state water quality standards, not federal criteria recommendations. The Coeur d'Alene
Basin TMDL correctly applies the water quality criteria that are currently applicable to these waters in
the Idaho water quality standards.
Comment #10 Letter(s) C13, C16
The TMDL limits are based on extremely stringent water quality criteria which do not consider the characteristics of
the native Coeur d'Alene aquatic species and their habitat.
Response: EPA and DEQ do not view the Gold Book criteria as "extremely stringent"; in fact, they are adopted in
all the EPA Region 10 slates (Alaska, Idaho, Washington, and Oregon) for protection of aquatic life.
However. EPA and DEQ concur with the comment that the TMDL is not based cm site-specific
en ten a. Rather, it is based on water quality criteria adopted by the Stale of Idaho for all state waters.
These statewide criteria are based on EPA's nationally-developed water quality criteria
recommendations Site specific criteria that reflect specific habitats or species within the Coeur
d'Alene basin have not been adopted by the State of Idaho (See discussion under Regulatory Options)
1.2 Hardness Assumptions
Comment # 1 Letter(s) 272,274
There was apparently no effort made to determine whether hardness varies as a function of stream flow. In this
proposed TMDL. Region 10 proposes to have different wasteload allocations as a function of stream {low
Hardness and other inorganic constituents often are correlated to stream How, e.g., at high stream flows hardness
concentrations are lower. If hardness is inversely correlated to stream flow, then the 5* percentile values chosen by
EPA are likely to be too conservative for the low flow conditions in the streams, resulting in overly conservative
larget criteria This in turn will make the WLA and LA values too conservative ai low flow Region 10 should
evaluate all of the available hardness data to determine whether the concentrations are correlated to stream flow. If
they are, EPA should develop separate hardness concentrations for each stream flow category that it uses in the
TMDL,
There is generally an inverse relationship lietween stream flow and hardness. It is logical that during low stream
Hows, the streams will receive a greater jx:rcemage of their flow from groundwater and from effluents which may
also have a groundwater origin, and as such will be harder water. The proposed TMDL clearly recognizes and
credits the addition of loading capacity associated with the harder water in the effluents of the municipalities that
14
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discharge to the Spokane River The same phenomenal holds true for the other dischargers to the South Fork Coeur
d'Alenc system and needs to be appropriately accommodated by the TMDL
The TMDL TSD shows that varied hardness values occur in sections of the South Fork However, EPA and DEQ in
effect set the hardness value of 25 mg/l as a ceiling rather than a floor value. For the South Fork target sites, EPA
and DEQ use available data to calculate 5th percentile hardness values. Because some of these values fall below the
minimum recommended hardness values for the derivation of criteria limits, the draft TMDL uses the minimum 25
mg/l hardness value throughout. However, it is unclear why a 5th percentile hardness was selected. What guidance
or rules state that such an approach to selecting hardness is warranted or justified? The only apparent reasoning
offered in the TMDL TSD appears in the sentences following Table 6-2, which state, "Toxicity increases as
hardness decreases. For this reason, hardness based water quality criteria are most stringent at low hardness levels."
This rationale is insufficient to justify this approach. Use of a single value (25 mg/1) to characterize the natural
hardness dynamics of the system discounts the effects of flow, seasonal variation, and source differences on
hardness and yields excessively stringent criteria The derivation of criteria for use in determining the total loading
capacity at a target site must consider the changes in hardness that occur with changes in these factors.
Response; In response to this comment, EPA and DEQ have revisited the seasonal variation of hardness. EPA
has obtained sufficient information to discern a clear relationship between river flow and hardness in
the South Fork and tributaries. The available data indicates that river hardness clearly decreases with
increased river flow at these sites. This feature of the streams calls for higher water quality criteria
and thus higher loading capacities during low flow conditions at these target sites.
Since the TMDL elements are flow-based for the Coeur d'Alene River and tributaries, EPA has
incorporated the flow/hardness relationship into the TMDL. At each target site showing a
flow/hardness relationship, a linear regression between In(flow) and hardness was performed using the
available data for the target site. The resulting regression equation is used to predict hardness values
at the flow tiers The lower bound of a 90A percentile confidence interval for the regression equation
is used in the prediction. Hardness values were not estimated outside the range of available data,
which did not include flows at or below the 7Q10 flows. Table 6-4 of the revised TMDL TSD lists the
flows, hardness values, and resulting criteria applied in the TMDL The data and regression
calculations for those sites that show a flow/hardness relationship is included in Appendix I of the
TMDL TSD.
The use of 5* percentile hardness values is a guideline of the NPDES permitting program at EPA
Region 10 to provide an adequate level of conservatism when implementing water quality criteria
Comment #2 Letter(s) 266,284,.295
The proposed TMDL should discuss the reasons for the low and high hardness values. For example, were these
values related to seasonality or flow regimes or water hardness of effluent?
Response: As described above, EPA has obtained sufficient information to discern a clear relationship between
river (low and hardness (hardness decreases with increased river flow) in the South Fork and
tributaries. High-hardness mining discharges are likely a contributing factor to the higher hardness
values observed instream during tow flow
Comment #3 Letterfs) 267
The State of Washington's use of hardness values less than 25 mg/1 in calculating Cold Bix>k criteria is not
technically defensible, because the total recoverable criterion is less than the dissolved criterion when hardness is
less than 25 mg/1 It is evident that the dissolved conversion factor cannot be applied at this hardness value EPA
and DEQ should use a minimum river hardness of 25 rng/l for CaCO> for the Spokane River at the state line
15
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Response: The State of Washington's water quality standards apply la the Spokane River at the
Idaho/Washington border. The same Gold Book criteria equations that apply to Idaho waters also
apply to Washington waters. However, the Washington water quality standards allow for the use of a
hardness value below the lower limit of 25 mg/1 established in the Idaho water quality standards. The
State of Washington used a value below 25 mg/1 m its approved TMDL for the Spokane River EPA
and DEQ believe it is reasonable and consistent to use the lower hardness value (20 mg/1) to calculate
the dissolved metal goals for the Spokane River at the slate line. It should be noted that this goal does
not have a direct affect on the wasteload allocations for the communities in Idaho along the Spokane
River, which are based on the hardness of the effluents and not the hardness of the river.
Comment #4 Lelter(s) 266
It is unclear from the tables and text how the tiers and seasonality are accounted for in the hardness values of Table
6-2. Is the "9" for the "South Fork al Pmehurst" value an outlier that should be excluded from the data set? The
number of samples ("n") should be stated in the table so an independent evaluation can be made.
Response: EPA has included more detailed and updated database information about hardness in the revised
TMDL TSD. For the Pmehurst site, the commeater has correctly identified a sample value that the
agencies believe is an outlier that should be excluded from the data set (the updated information does
not include that data point).
Comment #5 Letters) 284
The Pine Creek site's water hardness of 8 mg/1 is well below the 25 mg/1 that is being used to calculate the criterion.
The proposed TMDL may underestimate the toxicity of the metals related to the Pine Creek site.
Response: It is recognized that the hardness of the water is less than 25 mg/1 as calcium carbonate in some
instances. However, in accordance with die Idaho water quality standards, a minimum hardness value
of 25 mg/1 is used in calculating freshwater aquatic life criteria for metals, even if the actual ambient
hardness is less than 25 mg/1.
Comment #6 Letter(s) 244
Does EPA realize that the water is generally high in iron and a lower than neutral pH, which affect water hardness?
Response: EPA and DEQ are using direct measurements of hardness to establish the TMDL elements It is
therefore unnecessary, for purposes of developing the TMDL. to evaluate the relationship between
iron. pH, and hardness.
Comment #7 Letter(s) 274
Tlie TMDL TSD incorrectly interprets the National Toxics Rule with respect to minimum hardness. The National
Toxics Rule in Section 13136 (c)(4)(I) sets a range of not to be exceeded values for hardness when calculating
criteria (from 25 to 400 mg/1) with 25 mg/1 being the minimum hardness value if the ambient hardness falls below
25 mg/I and 400 mg/i being the maximum hardness if the ambient hardness is greater than 400 mg/1 However,
establishing this range does not mean that the minimum hardness value should be used throughout, and this
especially should not be done when hardness values are greater than 25 mg/1. As shown in Table 6-2 of the TMDL
TSD. hardness in various surface waters of the Basin exceeds 25 mg/1
Response: Idaho was removed from the Toxics Rule; therefore, the TMDL is based on the metals criteria adopted
by the State of Idaho, which incorporate the NTR criteria by reference (including the 25 mg/1 lower
bound on hardness). EPA and DEQ disagree that the TMDL TSD misinterprets the state's criteria.
16
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The lower end of the acceptable hardness range (25 mg/1) is used when the actual river hardness is
below 25 mg/I
Comment #8 Letter(s) 266,212,274
Hardness values used in determining applicable water quality criteria are too conservative for the actual conditions
which exist in the river system. Data collected as part of the overall Basin studies suggest the hardness continues to
increase down river. For this reason, the recommended hardness value of 25 is too conservative and is on the far
edge hardness curve (extrapolated data), making it unreliable.
The hardness values presented by EPA ft* the South Fork through the Spokane River include values only from the
South Fork Basin. Available data show, for example, that hardness levels in the mainstream of the Coeur d'Alene
River can be twice those found in South Fork. It is extremely important to characterize correctly the hardness of the
waters included in this TMDL. Using an appropriate hardness of 40 mg/1 to characterize receiving water conditions
rather than an inappropriate 25 mg/1 hardness would increase the metals criteria and available metal loading
potentials for cadmium by 41%, for zinc by 49%, and for lead by 70%. These differences would likely produce
significantly different levels of economic impacts in the affected communities.
Response: See discussion above regarding adjustments to the hardness values used in the TMDL.
The commenters did not supply the data alleged to show higher hardness levels in the mainstem CdA
River than in the South Fork. The TMDL is developed using direct sampling information. The data
available to EPA and DEQ indicate that mainstem Coeur d'Alene River has lower hardness levels than
the South Fork (e.g., at Pinehurst) The low hardness in the North Fork dilutes the hardness m the
South Fork at the confluence.
Comment #9 Letter(s) 284
Further discussion is needed regarding the municipal dischargers along the Spokane River, whose effluent water
hardness levels are greater than the ambient water hardness levels. What is the distance and effect of their effluent
on the receiving waters? What is the attenuation of the water hardness and its resulting effects on the toxicity of the
metals in the Spokane River?
Response: It can be shown that the mixture of the effluent and mainstem waters will not result in any local criteria
exceedances. A detailed analysis of the relationship between the water quality criteria equations and
the mixing of two waters with different hardness levels is included in the approved State of
Washington TMDL. EPA and DEQ relied on this analysis in applying the effluent criterion approach
for the Spokane River.
Comment #10 Letter(s) 274
Table 6-2 [of the TSD) presents the hardness data used to develop the projxsed TMDL One problem with the data
presentation in Table 6-2 is that the report does not indicate how many hardness analyses were available for each
target site The number of samples is important, because it is used to determine the confidence intervals on the
statistics developed from the data sets including the standard deviation, the mean, and the 51" percentile. Without
this information, u is impossible to determine whether the estimates of the 5'h percentile are reliable. EPA did not
actually use the 5"1 percentile hardness concentrations m its analysis, but instead used default hardness
concentrations of 25 mg/1 for all CdA streams and 20 mg/1 for the Sfxskane River However, understanding the
reliability of the measured hardness concentrations is essential io determining whether the default hardness
17
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concentrations and the target water quality criteria are reasonable. Also, EPA states that the 5® percentile is below
25 mg/1 for target site 228; this is incorrect, the percentile value is 28 mg/1.
EPA should show how many samples are available for hardness m each water body and should calculate the
confidence intervals on the relevant statistics that it proposes to use m the TMDL. At a minimum, the confidence
interval on the means, standard deviations, and 5th percentile values are needed.
Response: EPA has significantly revised the section on hardness in the TMDL TSD and added an appendix
including hardness data and charts to better depict the hardness information.
1.3 Site-Specific Criteria
^3omimciit 01
The Federal Clew Water Ad provides for site-specific criteria to be used instead of the Gold Bode, because the law
recognizes the Gold Bode standards are not always necessary to protect water uses for fishing mid swimming.
Response: EPA and DEQ acknowledge that the Clean Water Act implementing regulations do allow states to
adopt site-specific criteria (40 CFR 131.11) in appropriate cases
Comment #2 Letter(s) 33,93,202,243,
244, 252, 272,
C7.CI3.C16,
C18.015, W2,
W8.W12.W15.
W19
The Gold Book criteria are not. appropriate or necessary because the Coeur d'Aiene Basin already supports a healthy
fishery in areas with good habitat. Fisheries are thriving in sections of the stream system where water quality
exceeds the criteria, indicating a different standard can be established that meets all the goals and objectives erf
improving the water quality without impacting the local economy
Response: The TMDL must be based upon the currently applicable water quality standards (which include the
beneficial use and the water quality criteria to protect that use). In the Coeur d'Aiene Basin, the
currently applicable criteria are those adopted by the state of Idaho.
EPA and DEQ believe the relative health of the fishery in the basin is dependent upon both habitat and
water quality. In many areas, aquatic life uses are impaired by both habitat loss and metals
contamination. While focused cm water quality in this TMDL, the agencies recognize the importance
of physical habitat to the fishery. The current site-specific criteria work includes an evaluation of the
water quality necessary to support a healthy fishery in areas with relatively good physical habitat.
Upon completion, this work could lead to changes in the applicable state criteria and modifications of
the TMDL. See discussion of site-specific criteria under Regulatory Options.
Comment #3 Letter(s)ll, 13, 15,20.32,33,41,
42, 48, 49, 53, 76, 94,
112, 113, 119, 233, 242,
243.244,247. 248, 251,
252, 266, 268, 271, 279,
284, 285, 287, 288, 289.
290, 291, 292, 295, 297,
302, CI, C2, C7. C8, C13,
18
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C15.C18.C19, C20.C2I,
C22. C23.C25, 01,011.
019. 020, 023, W3, W5.
W8.W9.W13.W17,
W18, W20. W21, W22.
W23
Existing information about site-specific conditions should be further studied to provide dala for developing
reasonable water quality criteria
Response: EPA and DEQ are continuing to review the data being generated for site-specific criteria in this basin.
See discussion of Site-Specific Catena under Regulatory Options.
Comment #4 Letter(s) 272
EPA states on Page 3 of the TMDL that 'the dissolved cadmium, lead, and zinc exceed water quality standards that
protect fish and other aquatic life.' This statement is not completely accurate. Federal water quality regulations were
established as a base or guideline letting the states set limits that meet their site-specific conditions. Regulations
allow new standards to be developed based on site-speafic conditions as long as they protect the uses of the water
resource. In other states, EPA has approved water quality standards that are not consistent with Gold Book
standards but still meet the intent of the regulations and protect the use of the resources, which includes protection
of fish. This basic concept should be an important aspect to setting TMDLs. When a resource is identified as
'impacted.* programs should be developed that emphasize site-specific conditions to resolve complex local issues.
Response: EPA and DEQ believe that the quote from the TMDL TSD is accurate. The commeoter is correct in
noting that states and tribes have the authority to establish water quality standards and that standards
can vary across the country while still meeting the intent of the Clean Water Act. DEQ does not have
funding to develop site-specific "programs" for each TMDL. However, the agencies encourage
affected parties to col lea information and perform analyses to improve TMDL development.
Comment #5 Letter(s) 266
Appropriate numeric criteria are undo* development, In fact, an agreement to conduct the site-specific criteria study
has been in place since 1993, and the study is continuing. It is. however, disturbing to review the TMDL documents
where the public is led to believe that this study is and has been only a state activity. EPA is a signatory to the
site-specific study agreement and has actively participated in the process from the beginning.
Response: EPA has reviewed and commented on study plans and data evaluations to improve the likelihood that
the resulting criteria will be approved.
Comment #6 Letter(s) 266
The Clean Water Act mandates the development of site-specific criteria at Sec. 304(a)(1).
Response. The Clean Water Act does not mandate the development of site-specific criteria at Section 3Q4(a)( 1).
This section authorizes EPA's development of national criteria guidance. The most recent criteria
guidance is known as the "Gold Bcx>k" Site-specific are allowable but not mandated under the
regulations at 40 CFR 11 11(b)
Comment #7 Letler(s) 266
Federal regulations allow for the development of site-specific numeric criteria at 40 CFR 131.11 (b) as follows: "In
establishing criteria. States should (1) Establish numerical values based on: (i) 304(a) Guidance; or (n) 304(a)
Guidance modified to reflect site-s[>ecihe conditions, or (in) Other scientifically defensible methods "
19
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In addition. Slate regulations approval by EPA at IDAPA 16 01.02.275 allow for both the "resident species
procedure" and "other scientifically defensible procedures" - both of which are being used to develop the
site-specific criteria for the South Fork of the Coeur d'Alene River. These criteria must be developed prior to, and
utilized for, the TMDL for the South Fork of the Coeur d'Alene River
Response: EPA and DEQ agree that states have a number of options in establishing water quality criteria,
including a variety of procedures to establish site-specific criteria. However, EPA and DEQ do not
agree that site-specific criteria must be developed prior to issuance of a TMDL for the South Fork.
Site specific criteria for the upper South Fork (above Wallace) have not been promulgated into the
Idaho water quality standards, DEQ expects the promulgation for this portion of the river to begin this
year and be completed in 2001. Any further application of the site specific criteria is three to five
years in the future.
Comment #8 Letter(s) 267
EPA/DEQ should provide some rationale for rejecting the work completed toward developing site-specific criteria.
Response: EPA and DEQ have not rejected the work completed toward developing site-specific criteria. See
previous comment regarding the current status of site-specific criteria.
Comment #9 Letter(s) 274
The use of biological monitoring to establish ecological goals makes sense so long as EPA and DEQ implement the
following procedures:
1. If reference sites are included, their selection should include considerations of altered habitat and
other anthropogenic effects that may influence the populations and communities of organisms.
2. Appropriate statistical considerations should be included for the purposes of comparisons between
the reference and the assessment areas such that overly strict alpha levels are not used. Use of x 0.05,
rather than x 0.1 or 0.2, would more likely result in a type 1 error Such error would potentially indicate
that effects have occurred when, in reality, no effects occurred. Using biological criteria can quickly
generate issues of ecological versus statistical significance.
3. Clear guidance must be provided on how the data will be collected. Then, when comparison are
made, data integrity would be maintained due to consistent and reliable data collection.
4. Clear and concise definitions of target goals are developed. Too often vague definitions of
ecological goals are established that are not clearly measurable and thus, determination of attainment is
then not clear
Response, EPA and DEQ will consider these issues if a biological monitoring program is developed.
Comment #10 Letter(s) 274
"Hie absence of any provision for accounting for bioavailability is a major deficiency of the proposed TMDL. Even
it it were determined that modeling of the transformation and transport of these metals in the subject watersheds
cannot be performed successfully because of data limitations, it is still possible to incorporate bioavailability of
metals into the TMDL by allowing the use of water effect ratio (WER) studies to adjust the target criteria to reflect
site-specific water chemistry, EPA has issued guidance on how to determine and use WERs for metals, and
specifically included the WER provisions in the National Toxics Rule, In fact, because Region 10 is basing the
TMDL on the metals criteria m the National Toxics Rule, it has erred by not including the WER provisions in the
TMDL, The use of a site-speahc WER is no different than the application ot a site-specific hardness value, which
EPA h as included in this promised TMDL.
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EPA should consider as a minimum measure thai the WER methodology of the National Toxics Rule he included in
any final TMDL, The inclusion of the WER methodology will formally recognize that dischargers or groups of
dischargers can develop site-specific WERs to account ft* the bioavailability of metals in their discharges and the
receiving waters.
Response: EPA and DEQ agree that the regulations allow for water effect ratios (WERs) to be developed fa-
Idaho waters. However, the commenter does not indicate how WERs would be developed or applied
in this basin, and the agencies are not aware of any effort to date by affected parties to generate
analyses and laboratory data to support WERs in this basin. Therefore, EPA and DEQ do not agree
that the absence of "WER provisions" tn the TMDL is in error.
Comment # 11 Letter(s) 266,270,272
The State of Idaho's proposal to establish "biological end points" as a measure of site-specific water quality
standards has two potential problems First, how does the State propose to account for stream habitat alteration in
determining ail appropriate biological end point? Especially since highway construction has impacted most of the
South Fork from Mullan to Pinehurst, including riparian zones and associated vegetation. Second, it could lake
several years after appropriate metal concentrations have been established in the South Fork for an acceptable
biological community to become established. What numeric standard would the Stale propose until the biological
ead-potnt is reached? The State must recognize that there are a variety of problems that could affect biological
establishment in the South Pork, other than water-borne pollutants. The details of such a proposal should be subject
to public comment prior to implementation.
Response: EPA and DEQ agree that both physical habitat and water quality will play a role in improving aquatic
life communities. Biological endpoints would not replace the numeric metals criteria, but biological
monitoring and evaluation would provide information on the improvement in the aquatic life
communities over the long term.
1.4 Beneficial Use for Coeur d'Alene Basin Waters
Comment#! Letter(s) 274
When EPA promulgated a cold water biota designated use for South Fork, Canyon Creek and Shields Gulch, it did
so even though it recognized that the concentrations of metals in these water bodies regularly and significantly
exceed the Gold Book criteria for such use. EPA claimed that, at least in the South Fork, the presence of aquatic life
indicated that aquatic organisms had adjusted to the higher metals levels in the stream While Asarco disagrees with
EPA's conclusions, the Agency cannot "have it both ways." It cannot assert that organisms have adapted to higher
metals levels and designate a use on that basis, but then promulgate a TMDL that assumes lower metals
concentrations must be achieved in order to sustain the designated use.
Response: The presence of aquatic life does not necessarily indicate that the aquatic life use (i.e., cold waler
biota) is fully supported Different aquatic species and life stages exhibit different tolerances for
habitat and water quality impairments. Thus, while certain species at certain life stages may reside in a
impaired river segment, others are absent because of the degree of impairment. The water quality
criteria are not necessarily established to sastain a designated use at its existing condition, to that
condition may be impaired. Rather, they are established to fully support all aquatic species and life
stages, siime of which may be absent due to ongoing impairments.
Comment #2 Leller(s) 70
EPA's national policy of applying cold water biota and the a>.soaaled Gold B
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Response:
Uses and criteria applicable to waters of the Slate are determined by the State when it adopts its water
quality standards. States can adopt criteria less stringent than EPA guidance values if tt can
demonstrate scientific validity (40 CFR 13111)
Comment #3 Letter(s) 255
The "Cold Water Biota" designation for the South Fork of the Coeur d'Alene River may not be appropriate. The
"Cool Water Biota" designation under development byDEQ may be more appropriate.
Response: In the absence of a use attainability analysis that justifies a lower use than full aquatic life protection,
the cold water biota use is the appropriate designation for the South Fork. See also the discussion of
use attainability analysis under Regulatory Options.
Comment #4 Letter(s) 205,272, C22.
016, W8, W21
No reference has been made to any scientific assessment of use protection and the ability to attain all uses
designated for the stream system. The South Fork is heavily impacted from other activities in addition to mining
which may have permanently limited the ability to meet uses as designated in the rules. The interstate highway has
virtually changed the stream system into a channel designed to cany water through this narrow section. Without fish
habitat, only a limited fish population can be present. However, it is important to note that no information is
presented that suggests the agencies have looked at scientific data on the attainability of uses in all reaches of the
stream system. More information should be developed to assess stream conditions and uses prior to setting TMDLs.
Response: There is no legal requirement to perform a use attainability analysis as part of a TMDL. In the absence
of a use attainability analysis that justifies a lower use than full aquatic life protection, the cold water
biota use must be fully protected in basin waters to meet the requirements of the Clean Water Act. The
regulations require that any TMDL achieve the currently applicable uses and criteria in the state water
quality standards. See discussion of Use Attainability Analysis under Regulatory Options.
Comment #5 Letter(s) 266
The TMDL lists two full pages of data sources m Table 5-1. This data set does not provide evidence that "cold
water biota" is an "existing use" for all portions of the South Fork of the Coeur d'Alone River, Canyon Creek,
Ninemile Creek, or Government Gulch.
Response: EPA and DEQ provided water quality-related data pertinent to the TMDL in Table 5-1; it was not
intended to provide biological information pertinent to the existing aquatic life use. The TMDL does
not establish the beneficial use, but rather establishes allocations to achieve the applicable water quality
criteria and thereby protect the beneficial use. The applicable criteria are those adopted by the State of
Idaho.
15 National Toxics Rule
Comment#! Letter(s) 266
The TMDL states that "Idaho was unable to issue and submit the TMDLs to EPA for approval, however, for a
number of reasons, including the fact that the State could not use site-specific criteria while Idaho was still subject
to the federally promulgated National Toxics Rule (NTR)" We find no authority in either the CWA or the
legislative history of the CWA to support a position that Congress intended to punish NTR states by disallowing
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site-specific criteria in those states. Indeed, EPA has approved Idaho regulations specifically allowing for the
development of site-specific criteria as specifically allowed tor under the CWA. Offering up the NTR as an excuse
circumvents direct Congressional intent to develop "criteria for water quality accurately reflecting the latest
scientific knowledge."
Response. This is primarily a comment an the provisions of the national NTR rulemaking and not the Coeur
d'Alene River Basin TMDL. Since Idaho was removed from the National Toxics Rule on April 12,
2000 (FR 19659), the state can now adopt site-specific criteria in waters of the state.
Comment #2 Letters) C4
Idaho should be removed from the National Toxics Rule.
Response: Idaho was removed from the National Toxics Rule on April 12, 2000 (FR 19659). EPA is continuing
to consult with the National Marine Fisheries Service and U.S. Fish and Wildlife Service under the
Endangered Species Act on the Idaho water quality standards, including the state's adopted metals
criteria for cadmium, lead, and zinc implemented in this TMDL.
Comment #3 Letter(s) 266
In the partial settlement agreement in the NTR litigation, EPA admitted that the duration and return frequencies of
the Gold Book criteria had absolutely no scientific basis. The agreement entered into with the court by EPA directed
EPA to develop the appropriate science for the correct frequency and duration of Gold Bode criteria. EPA has
failed to comply with this court directive and must not apply either acute or chronic Gold Book criteria until the
science is developed. Indeed, the in stream flow used in the TMDL for 'worst case' scenario is a 7Q10 flow
correlated to the chronic value. Upon development of adequate science for the frequency and duration of the Gold
Book criteria, in compliance with full APA requirements, the correct instream flow tiers may thai be developed.
Response: Idaho was removed from the National Toxics Rule on Apnl 12, 2000 (FR19659). The TMDL is
developed using the currently applicable water quality criteria The standards which are the basis for
the TMDL are those adopted by the State of Idaho. The establishment of a 7Q10 low flow tier is both
reasonable and consistent with Idaho water quality standards (IDAPA 16.01.02, Section 210 02) and
EPA's Technical Support Document for Water Quality-based Controls (EPA, 1992).
Comment #4 Letter(s) 266
The statement by EPA in the rulemaking that "The total recoverable metals method is an intermediate method which
uses a weak acid treatment to dissolve readily soluble solids and filtration to remove residual solids" is not true The
numerous scientific faults in this statement include:
• The pH of the sample prepared for total recoverable metals is subjected to a pH of
approximately 0.1 SU. This is an extremely strong, not weak, acid! Once again, pH is a
logarithmic scale, thus a biota protection standard for pH of up to 9 SU instream vs. the pH of
the analysis procedure is over eight orders of magnitude more acidic.
The sample is subjected to temperatures thai would also kill all aquatic life prior to nitration
and analysis,
• Tlie filtration step has the "dissolved" metals shortcomings discussed above.
Response This comment apparently refers 10 a statement m an EPA rulemaking {which has already been subject to
public comment) and not in the TMDL. documents. The TMDL wasteload allocations are established
and monitored in a manner consistent with the metals requirements in the NPDES program. EPA must
express metals limits as total recoverable in NPDES permits by regulation (40 CFR 122.45). The
methods lor compliance monitoring in NPDES permits are also established by regulation (40 CFR 136)
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16
Antidegradation
Comment # 1
Letter(s)
266, 274
The TMDL states in "Step 8" lhat in certain cases "the assigned allocation is set at the current discharge level" and
that "EPA believes this allocation step is consistent with the anti-degradation requirements," The CWA Section
303(d) does not mandate a "zero increase in discharge," The legislative history of the CWA does not support this
position. Idaho's antidegradation policy applicable to these waters does not mean "zero," Idaho's antidegradation
policy applicable to waters other than "high quality" or "outstanding resource waters" reads "Maintenance of
Existing Uses for All Waters. The existing in stream water uses and the level of water quality necessary to protect
the existing uses shall be maintained and protected." As discussed in our previous comments, the majority of the
waters affected by the proposed TMDL do not have "existing uses" upon which the TMDL is based. Further, the
"level of water quality" is a range, not an absolute "zero" baseline.
EPA and DEQ incorrectly allocate loads to a number of sources based on current discharges where those sources
are already meeting their WLAs. They base this requirement cm a purported policy against anu-degradation. This is
an incorrect reading of anti-degradation requirements. Anti-degradation prohibits the relaxation of permit limits or
new discharges to impaired waters, except in prescribed circumstances. It does not require sources that achieve
greater reductions than what is already required by their permits to maintain these lower discharge levels.
Response: This step in the allocation process does not require reductions in current discharges from affected
facilities. The intent of an ti-degradation requirements is to prevent further water quality degradation,
except in prescribed circumstances. EPA and DEQ believe that allocating loads based on current
performance for sources that are already meeting their WLAs is consistent with intent of anti-
degradation provisions. Otherwise, some sources would be assigned allocations that allow for an
increase in discharges, which could further degrade water quality. In the agencies' view, this outcome
is not reasonable and would run counter to the intent of anti-degradation provisions and the goal of the
TMDL.
The anU-degradation rules do not seem to be applied appropriately. If a reach of a stream is below applicable water
quality criteria and enters another stream which is above applicable water criteria, an ti-degradation would only
apply to discharges to the stream reach which is of better quality. Natural background conditions will impact those
streams as part of the drainage system. While EPA suggests natural background metal concentrations are not
significant, natural mineralization in this area cannot support this assumption. Anti-degradation does not seem
applicable because this natural metal loading which does occur, would naturally degrade water as it (lows
downstream. TMDLs should be based on site-specific criteria and conditions not based on an inappropriate
an ti-degradation rule.
Response: The TMDL is not based on ami-degradation rules, though EPA and DEQ believe one step in the
allocation method is consistent with anti-degradation provisions (see comment above) Anti-
degradation policy is focused on actions that may degrade water quality from its current condition
Natural background amcentrations would only impact an anti-degradation analysis if they were higher
than the discharge concentration (i.e., the discharge was cleaner than the natural condition of the
receiving water). As discussed in the Natural Background section, estimated natural conditions m the
Coeur d'Alene River basin are below Gold Book concentrations
Comment #2
Letter(s)
272
2.0
TMDL
Comment #1
Letter(s)
C4.C13
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EPA, the State of Idaho and local stakeholders should develop an alternative TMDL which will (1) protect water
quality and the regional economy: (2) establish attainable milestones; and (3) be based on data that reflects the local
conditions of the watershed
Response: As noted by EPA and DEQ, the TMDL can be modified m the future based on new information or
changes to the applicable water quality criteria.
Comment #2 Letter(s) 262, C7, W12
We believe that EPA has taken an extremely conservative approach to establishing TMDLs because of the
limitations erf the data. We think EPA should develop an alternative TMDL that incorporates the data collection
programs that are currently underway.
Response: The final TMDL incorporates all of the information available to EPA and DEQ from data collection
programs in the basin, including data collected during and after the close of the comment period (e.g.,
USGS data collected in 1999). Incorporation of additional hardness data generally resulted in higher
allocations to sources.
Comment #3 Letter(s) 274
In moving ahead with a TMDL for the Coeur d'Alene River. EPA and DEQ are ignoring the important findings and
recommendations of the National Advisory Council for Environmental Policy & Technology Development, Report
of the Federal Advisory Committee on the Total Maximum Daily Load (TMDL) Program (July 1998). In that report,
the federal advisory committee identified two categories of "extremely difficult problems" where "water quality
standard nonattainment is due in part, or entirely, to . . historic problems." Report at 46. The TMDL for the Coeur
d'Alene Basin involves both of these "extremely difficult problems." The first problem includes, among other
circumstances, areas involving interstate freeways, contaminated sediments where clean-up would do more harm
than good, urban impervious surfaces, waste sites where complete removal is impracticable, and channelization nght
up to the bank. Report at 46. These problems are prevalent in the Coeur d'Alene Basin.
The second "extremely difficult problem" includes the following, all of which also arise in the Coeur d'Alene Basin:
small dams, culverts, abandoned roads, abandoned railways, abandoned mines, contaminated sediments, urban
stormwater runoff, combined sewer ova-flows, sanitary sewer overflows, land clearing activities, active CERCLA
cleanup sites, extreme stream modification (e g., channelization and loss of habitat), and operatim and management
of dams and channels Report at 47.
Not only should the coexistence of these "extremely difficult problems" in the Coeur d'Alene Basin counsel against
proceeding with this TMDL, the many, varied types of problems within each category should as well. By taking on
TMDL development for the Coeur d'Alene Basin, EPA and DEQ are trying to address one of the most complex and
difficult TMDL problems in the country. Yet the agencies appear to be ignoring the complexity and difficulty of this
situation by developing a simplistic loading analysis ill at ignores most of the fundamental problems identified in the
TMDL Report,
Response- EPA and DEQ are required to develop a TMDL for ihe Coeur d'Alene Basin pursuant to the court
approved TMDL schedule for Idaho The agencies acknowledge the complexity of the pollution
problems in the basin and are committed to working through the regulatory relief mechanisms when
appropriate. The agencies disagree that the TMDL ignores fundamental problems m the basin On the
contrary, m addition to fully satisfying the regulalcry requirements pertaining to TMDLs, this TMDL
has hel[>ed answer a number of important questions ahout ihe pollution problems in this basin. It has
also provided a framework tor cmrdmation ol Clean Water Act and CERCLA activities in the basin.
Comment #4 Letteris) 30.44.46
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The EPA is proposing TMDL criteria thai require the Caeur d' Alene River to be cleaner than our own drinking
water. Is this reasonable''
Response: The TMDL is based on criteria adopted by the State of Idaho in its water quality standards. For the
three metals (cadmium, lead, and zinc), the Idaho water quality standards for protection of aquatic life
are more stringent than the standards for protection of drinking water. This is reasonable, because the
available scientific information indicates that these metals are toxic to aquatic life at levels that are
safe for human consumption.
The draft TMDL inflates the numbers of true point sources by including traditional nan-point sources as "discrete"
point sources. The draft TMDL includes as "point" sources historic adits on hillsides where there is no outfall. The
TMDL presumes that all "pollutants" contained in this seepage to groundwater "discharges" to the receiving water
even though there is no outfall involved. EPA defines an "outfall" as follows: The place where an effluent is
discharged into receiving waters
In addition, the TMDL proposes that a pile of rocks along a stream is also a "point" source. Any "pollutants" in the
waters in (he area of the rock pile is presumed, in the TMDL, to come from that pile of rocks, rather than from either
natural background sources or historically deposited materials in the streambed and banks. Here again, an outfall is
absent. If indeed a pile of earth malarial is a point source, there should be a wasteload allocation for the largest
"point" source in the basin. Interstate Highway 90.
The simple fact of the matter is that the law requires point sources operating under technology-based effluent
limitation guidelines, and to our knowledge there are only two such point sources operating in the basin where lead,
zinc, and cadmium are discharged under a technology-based effluent limitation guideline.
Response: EPA and DEQ maintain that the source categorizations and terminology in the TMDL are legally
accurate.
As discussed m the TMDL TSD, the definition of "point source" includes waste piles. These "waste
pile" point sources may discharge to receiving waters via surface water runoff and/or seepage,
reaching the receiving water via overland flow, through a pipe, or through a groundwater hydraulic
connection. Regarding the question of seepage to groundwater, the TMDL is not based on a
presumption that all pollutants contained in ...seepage to groundwater enter the receiving water.
Rather, the TMDL presumes that some fraction of the dissolved metals seeping into groundwater
enters the downgradient receiving water. In these cases, it is reasonable and prudent to assign an
allocation to the source.
As described in the TMDL TSD, the agencies do not possess sufficient information to identify
wasteload allocations for waste pile sources at this time. If individual wasteload allocations for
individual waste piles are developed in the future, tailings materials incorporated into the highway
would be considered tor inclusion.
The Clean Water Act requires both technology-based and water Qualitv-based effluent limitations in
N'PDES permits, and jxiint sources must obtain NPDES permits whether or not they are covered by
national technology-based guidelines
2.1
Source Identification
Comment #1
Letter(s)
266,274
Comment #2
Let terCs)
274
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The TMDL fails to adequately identify a number of point sources, thereby making it impossible for the public and
Asarco to comment on those point sources. For example, the TMDL includes unnamed adits "Unnamed Adit -
Deadman Gulch (SF 389)*' and "Unnamed Adit (SF 385)*' that are impossible to locate. Anyone owning property on
which these adits are located would have no notice that EPA and DEQ intend to include them in the TMDL and
require an NPDES permit for them. The descriptions of point source locations m Appendix B are also wholly
inadequate for locating the different sampling stations. Some descriptions are too vague to provide the public with
notice of the location. Others are left completely blank.
Further mere, some of the identified point sources do not appear to correspond to actual identifiable flows or
discharges. For example, Asarco personnel attempted to identify the Mineral Point discharge and were unable to
find any flow from the Mineral Point Mine adit. Consequently, Asarco is uncertain to which point source EPA is
assigning loads. Likewise, the TMDL lists the Rainbow (SF 392) as a point source but this point source is routed to
the Osburn Tailings Pond and does not discharge to surface waters.
The failure of EPA to identify adequately large number of point sources makes it impossible for the owners of
property where these point sources are allegedly located to provide meaningful comment. How can a property owner
dispute data such as flow and concentration if the owner cannot even find the point source?
Response: EPA and DEQ provided source identification numbers, source names, and detailed maps in the TMDL
TSD. The shea* number of sources and sampling locations, as well as the remoteness of some
locations, increases the potential for errors in the database and/or maps. EPA and DEQ (with
additional coverage by the local press) have clearly provided notice of the TMDL to property owners
m the Coeur d" Alene River basin. The mine owner is responsible for identifying sources under its
ownership and providing information to the agencies to correct any errors in the source listings or
maps.
EPA and DEQ note that SF385 and SF389 are clearly located on the maps provided in the draft TMDL
TSD. Adit SF385 is located in the East Fork of Two Mile Creek, northeast of Ostwrn, Adit SF389 is
located on a fork of Deadman Gulch, northeast of Mull an.
EPA and DEQ concur that the Rainbow adit (SF 392) was routed to the Osburn Tailings Pond in Apnl
1998. This adit has been removed from the final TMDL wasteload allocations accordingly.
Regarding the Mineral Point adit, it is clear that Asarco does not dispute the existence of this adit.
However, its flowrate is less certain. Asarco has not provided information to improve the agencies*
database, other than to point out that a single reconnaisance found zero adit flow. It is possible that
this adit is an intermittent discharge or that the database is in error. EPA and DEQ presume that
Asarco does not wish to eliminate the wasteload allocation for this adit based on its reconnaisance
Therefore, the wasteload allocation for this source remains unchanged in the final TMDL. If future
monitoring confirms that this adit does not discharge at any time, its allocation can be reserved for
future growth
Comment #3 Letter(s) 30,44,46.270
EPA failed to consider the natural metal concentration of public drinking water in the basin. Although the water
provided by the various water districts meets federal Sale Drinking Water Act requirements, historic sample results
indicate metal concentrations m excess of the proposed TMDL standards. Paragraph 4, page 44 of the TSD states
"Possible sources of metals to these systems [municipalities] include lntlow/infiltrution of runoff through tailings
material to the collection system, illicit connections, high residential loads, and /or leaching of metals into
wastewater in unlined ponds constructed from tailings materials" Drinking water data collected from the Pinehurst
Water District and the Kingston Water district showed lead and zinc concentrations above both the Gold Book
water quality criteria and the proposed TMDL limits "('lean drinking water" is not mentioned or addressed in the
TMDL as a jxissible source of metals to the municipalilies The EPA needs to evaluate the possibility that the clean
puNic drinking water in the Silver Valley does no! meel the criteria proposed in this TMDL, The Clean Water Act
does not require facilities to treat water below naturally occurring background concentrations
27
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Response: Drinking water data was not provided to the agencies, but EPA and DEQ agree that water systems
likely carry a measurable metals load that ultimately enters the sewage collection systems. Any
drinking water sources of metals are addressed by the wasteload allocations for the municipal sewage
treatment plants. Based on the available information from the sewage treatment plants along the South
Fork, the primary source of metals appears to be infiltration into the collection system of contaminated
groundwater (migrating through floodplain tailings). The contribution from the drinking water supply
is believed to be relatively minor, because drinking water sources are located outside of the Bunker
Hill site.
Comment #4 Letter(s) 38,65
The EPA is not addressing additional point sources, such as the Bunker Hill Superfund site, abandoned mine
dumps, and riverside tailings dumps, because there are no financial gains in pursuing these major sources.
Response: Contrary to this comment, EPA is pursuing a number of cleanup actions and pant source controls in
the basin in areas where cost recovery is not a factor in the acuao EPA is performing the cleanup at
the Bunker Hill complex at a cost of nearly $130 million to the federal government EPA and DEQ
are currently evaluating remedies for meeting the TMDL allocations in the Bunker Hill CTP discharge,
and the agencies are now conducting treatability tests for this discharge.
Comment #5 Letter(s) 266
The TMDL states that "In the Spokane River, between the lake and the state line, the only identified sources of
metals are three municipal treatment plants." The proposed TMDL would lead the public to believe that the only
sources of the metals would be mining, a minor amount of natural background and POTWs. However, in EPA's
December 1983 document Results of the Nationwide Urban Runoff Program (NURP), the sampling data set results
for lead and zinc from urban runoff show 90th percentile levels of lead at 350 ppb and zinc at 500 ppb. Extremely
high metals levels occur nationwide where there are no mining operations.
Response: While EPA aid DEQ do not have any discharge characterization data for urban stormwater in the
Coeur d'Alene Basin, the agencies agree that urban stormwater is a likely source of metals to the river
network. For the upper part of the basm, this source would be included in the non-discrete gross
allocation (similar to intermittent runoff from a waste pile) For the Spokane River, EPA and DEQ
have included language that establishes a stormwater allocation equivalent to the difference between
the calculated wasteload allocation and the current performance for the three municipalities (Coeur
d'Alene, Post Falls, and Hayden Lake). This approach satisfies the following considerations:
1. For planning purposes, it is prudent to establish a mechanism for stormwater allocations at this
time.
2 The allocation method for the Spokane River, using current discharge performance anil the
effluent-based criterion as an upper bound, allows for allocations for both sewage treatment plants and
urban runoff that meet water quality standards in the Spokane River.
Comment #6 I^tter(s) 266
The statement is made in the proposal TMDL that "The South Fork has been heavily impacted by historic and
ongoing mining activities below Daisy Gulch." This is not true. The egregious nature of this statement is witnessed
by EPA's calculations of Ixith the carrying capacity of the South Fork drainage and the minute fraction attributable
to the "ongoing mining activities" at the Lucky Friday. Coeur/Galena. and Sunshine operations. Once again, the
impacts to the basm art* clearly trom historic impacts and natural background levels of metals. The CWA is
prospective in application and any retroactive application is not in accordance with law. There is nothing in the law
or legislative history indicating Congressional intent to punish current point source dischargers for historic
activities
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Response: EPA and DEQ disagrees with the suggestion thai ongoing mining operations do not contribute to the
water quality problems in the South Fork, and that only historic and natural background conditions are
sources of impairment (see discussion of Natural Background Conditions), As slated elsewhere in the
TMDL Technical Support Document, EPA believes the operating mines contribute significant metals
loads to the river system and have feasible options for reducing these loads.
Comment #7 Letter(s) 240,282,296
Lead sulfide and its associated oxidized minerals are very resistant to dissolution and resist leaching into
groundwater. The lead present in the groundwater, river water, and lake bottom water is most probably not derived
from the mine tailings.
Response: Lead sulfide is very resistant to dissociation in water, but its oxidation products
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Comment #11
Letter(s) 205,207,
284, 295
If heavy metals currently suppress algae growth, will the removal of these metals from the water result in the
eutrophication erf Lake Coeur d'Alene?
Because of increased development pressure around Lake Coeur d'Alene . . . specific requirements for
implementation of a lake nutrient management plan is needed to guarantee that the lake does not eventually become
eutrophic and the water column does not become anoxic above contaminated lake sediments.
Any TMDL must also include an enforceable nutrient management plan lo protect Lake Coeur d'Alene from future
remobilization of metals as the result of anoxia due to accelerated eutrophication.
Response: EPA and DEQ have added an appendix to the TMDL TSD describing the latest studies of metals
fluxes from lake sediments. Based on our current understanding of the lake dynamics, EPA and DEQ
believe the long-term risk for a substantial release of metals from lakebed sediments is low because (1)
Coeur d'Alene Lake's large assimilative capacity for nutrients makes it unlikely that an anoxic
hypolimnion will develop, and (2) core samples did not release larger metals loads under anoxic
conditions (in fact, cadmium and zmc fluxes were negative in the tests). In this context, EPA and
DEQ believe it is reasonable to finalize this TMDL. However, the agencies agree that continued
monitoring and analysis of the lake condition is needed as cleanup proceeds to detect any increased
eutrophication. If it is determined in the future that nutrient loading reductions are necessary to
maintain oligotrophy conditions in the lake, the TMDL can be modified to include requiremrats on
nutrient sources.
Comment #12 Letler(s) 267
Recent studies of Coeur d'Alene Lake suggest that it is unlikely that metals will re-mobilize from the lake bottom to
the water column under anoxic conditions because most of the lead, zinc, iron and arsenic are bound as sulfates.
This is contrary to the conclusion presented ro the TMDL (i.e., metals m oxide form; better to maintain aerobic
conditions). The results of these studies should be considered in developing the final version of the TMDL.
Response: See comment above. USGS is near completion on a report of a study in August 1999, Preliminary
findings are discussed in an appendix to the final TMDL TSD
2.2 Target Sites
Comment #1 Letter(s) 272,274
Data in Table 5-2 of the TSD (current conditions at TMDL target sites) indicate that sufficiently sensitive analytical
methods were not used in at least some of the CdA basm studies. Data for dissolved cadmium at stations NF at
Enaville and Coeur d'Alene Lake have reported minimum concentrations of "<1 ^g/1"; the target water quality
criterion is 0.38 ug/l. Similarly, the data for dissolved lead at these same two stations are reported as <1 «g/l while
the target criterion is stated to be 0.54 ug/l.
Response The water quality targets in the final TMDL are no longer single values, they are ranges based on the
range of hardness levels at a particular target site. For the Harrison site, cadmium targets range from
0 37 ug/l (o 0 59 ug/1 and lead targets range from 0.54 ug/1 to 1.1 ug/1, depending on the river flow.
In the final TMDL TSD, EPA and DEQ have noted and addressed the limitations m the North Fork
data with respect to detection levels for cadmium and lead. EPA has estimated background metals
concentrations for the North Fork using the most recent rreaiitoring information from the USGS
(October 1998 to September 1999). As in previous samplings. The North Fork was below the
detection limits lor dissolved cadmium (I ug/l) and dissolved lead (1 ug/l) Assuming similar natural
characieristics of the North and South Forks, HPA and DEQ have set the North Fork background
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values equal in the South Fork natural background estimates for cadmium ( 06 ug/1) and lead (.18
ug/1), For zinc, the background value was set at the maximum detected concentration in the North
Fork (5 ug/1).
Comment #2 Letier(s) 2
A target site should be added to address Milo Creek.
Response: Given the scale of this TMDL, it is not practical at this time to establish target sites on each creek and
gulch delivering metals to the South Fork. The agencies acknowledge that Milo Creek is clearly one
of several important tributaries in the Kellogg area that warrant further evaluation during TMDL
implementation and/or later refinement of the TMDL.
Comment #3 Letter(s) 65,87
EPA should examine mining sources in Beaver Creek and Eagle Creek (tributaries to the North Fork).
Response: TMDL allocations sure not established far the North Fork because it does not exceed water quality
standards for dissolved cadmium, lead, and zinc. Nevertheless, EPA and DEQ support further
evaluation and control of the mining sites in the North Fork watershed. Improvements in water quality
of the North Fork would benefit downstream waters.
2.3 Attenuation of Metals - Upland Adils
Comment#! Letter(s) 270,272
EPA's assumption that the full flow and metal load carried by all discrete point sources in the basin eventually
enters surface waters (even if those sources do not directly enter surface waters) is overly conservative. It ignores
basic geochemistry to assume that dissolved metals in a water column move through soils without retardation, sal
attenuation, or plant uptake. Also, it cannot be assumed that 100% of all water discharged onto the land surface
eventually ends up in surface waters. Evapotranspiration, soil absorption aid potential aquifer recharge need to be
taken into consideration for all discharges that do not visibly enter surface waters Data should be collected at each
site to quantify the true lead to the system, EPA could then eliminate those discrete sources that do not directly
discharge to surface waters and re-assign the point source loading to appropriate point sources.
Response: EPA and DEQ acknowledge that there may be attenuation of metals in an adit discharge when its
pathway to the receiving water is overland or through soils. However, the agencies disagree that this
attenuation must be quantified before setting an allocation for the source. The allocation is based on
the source flowrate and not its current metals loading to the system.
The allocation applies to the loading of the source to the receiving water. EPA and DEQ anticipate that
an adit that does not directly discharge to a receiving water will be regulated (based oil the TMDL
wasteload allocations) and monitored at the point closest to the receiving water where compliance
monitoring can be conducted. If it is demonstrated during permitting that an adit portal discharge is
attenuated down gradient from ihe compliance monitoring location and prior to reaching the receiving
water, the limits that apply to the adit portal source can be adjusted upward while remaining a insistent
with the TMDL wasteload allocations. The permittee will bear the burden of demonstrating the
attenuation of the source. If this analysis demonstrates that the source has been given an allocation
greater than its current loading to the river, the remainder would be reserved for future growth. (See
related discussion under Method of Allocation - CDA River and Tributaries).
2 4 Attenuation of Metals - Instream Reactions
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Comment #1
Letter(s) 41. 255, 270,
272, 274, CI8
By nol incorporating fate and transport mechanisms for metals into the TMDL analysis. Region 10 has developed
unnecessarily conservative allowable loadings. There are demonstrated methodologies for considering metals
transformation processes in TMDL studies. Recent research has added to the capability to determine the influence
of humic substances on metal binding, modeling metal speciation in aquatic systems, and modeling of metals
partitioning to suspended solids. Removal of metals from stream flows in the Basin as a result of natural
attenuation has been well documented m a 1996 study by A J. Paulson for the U.S. Bureau of Mines.
The proposed TMDL does not consider any of these approaches, although any or all of them would result in
increased allowable WLAs and LAs. Given that the proposed TMDL will have extremely large economic effects on
all affected parties, this failure to thoroughly evaluate and apply current scientific knowledge is unjustifiable.
Response: EPA and DEQ have further evaluated the fate and transport mechanisms that warrant consideration in
the TMDL and has added an appendix with a discussion of this topic to the TMDL TSD.
Chemical/physical processes such as adsorption and precipitation can potentially remove dissolved
metals from the water column These processes involve complex and dynamic interactions between
metal species in the presence of other walerbody consituents. Since the water quality criteria are not
established for specific metal complexes (e.g.t cadmium sulfate) but rather for the sum of metal ions
(e.g , dissolved cadmium), which can be directly measured, it is not important to evaluate
physical/chemical processes that may occur in the water column or sediments for the TMDL.
However, it is important to determine the amount of total metal and dissolved metal to calculate
translators. Fortunately, for the Coeur d'Alene River and tributaries, there is a sufficient body of
paired river samples (dissolved vs. particulate metal) to directly calculate the translators at the target
sites. The data refect actual conditions, so there is no need to predict how fate and transport may have
resulted in these actual conditions.
The results of EPA/DEQ's evaluation of metals translators are consistent with the findings in the
report on Moon Creek by Paulson. The available paired samples indicate that dissolved cadmium and
2mc are not appreciably removed from the water column in Coeur d'Alene Basin waters, while
dissolved lead is removed to the particulate form between the headwaters and Iowa* basin. This
transformation (or attenuation) of dissolved lead toward particulate lead is addressed by the calculated
translator. The translator is applied to wasteload allocations for lead in the TMDL.
Comment #2 Letter(s) 274
Because no attempt is made in the TMDL to simulate current loading levels and resulting water quality for
comparison to measured ambient data, there is no way to evaluate how overly conservative the allowable loadings
are.
Response; Hie large number and varied types of melals sources in this basin precludes a detailed simulation of all
source loadings at the present time. At the same time, EPA and DEQ disagree that there is no way to
evaluate the loading capacities and allocations established in the TMDL. The TMDL TSD sets forth
the parameters used to calculate each of the TMDL elements, and raw data and graphs for key
parameters (e.g., hardness, flow, translators) are included in the appendices. Attenuation processes are
quantified in the TMDL translators, using direct measurements of total and dissolved metals in the
river network at the target sites.
Comment #3 Letter(s) 274
Tile TMDL ignores most of EPA's recommendations on the factors that should be considered in developing WLAs
and LAs tor metals
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Response: This TMDL is consistent with the statutory and regulatory requirements of the Clean Water Act and
EPA guidance publications EPA included a discussion of several factors and options that were
considered for developing allocations in an appendix to the TMDL TSD The commenter has not
identified a relevant factor that was ignored in the TMDL
Comment #4 Letter(s) 272,274, CIS
Physical and chemical metal transformation mechanisms may have particular importance at higher stream flows,
where more suspended solids are likely to be transported in discharges and the streams. When streams carry high
loadings of suspended solids, the metals associated with particulates may represent a high proportion of the total
metals loading. The proposed TMDL does not consider this aspect of metals transport, and in fact does not present
or use any suspended solids data in the analysis and assumes that all of the metals in the surface water at all stream
flows are in the dissolved form This assumption is not scientifically supportable in the absence of data
demonstrating its accuracy. In fact, sedimentation, resuspension, and partitioning of metals are well documented as
dominant factors in determining metals concentrations in water columns and assessing the toxicity of such metals to
resident aquatic biota.
Response: The Idaho water quality standards for metals are expressed in the dissolved form (based on
bioavailability). Therefore, allocations of dissolved metals loadings to sources is both reasonable and
necessary. EPA has not asserted that "all of the metals in the surface water at all stream flows are in
the dissolved form". Rather, EPA has provided information on the concentrations of dissolved metals
in the river network for comparison to the water quality standards. In addition, contrary to the
assertion in the comment, EPA and DEQ have considered particulate versus dissolved metals in the
water column (partitioning m ambient suspended solids) by calculating dissolved-to-total-recoverable
translators. This calculation does indicate that cadmium and zinc are almost entirely in the dissolved
form in the surface waters of this basm.
Comment #5 Letter(s) 41,255,270,
272,274
Water quality toxicity test work that established the Federal Water Quality Criteria was developed using laboratory
water. There was no way possible for EPA to develop representative water samples from around the country.
Therefore, the tests are very conservative and do not account for natural attenuation. For this reason, using the water
quality criteria to establish total loading capacities without consideration to attenuation is overly conservative.
TMDLs should incorporate and/or expand the development of site-specific criteria to establish the true total loading
capacity for the river system using attenuation. Mere water quality data for each target site would help establish
attenuation, which occurs seasonally in the river.
Response: The TMDL is based on the water quality criteria adopted by the Stale into the Idaho water quality
standards. EPA and DEQ have further evaluated the fate and transport mechanisms that warrant
consideration in the TMDL and has added an appendix with a discussion of this topic to the TMDL
TSD
The available paired samples indicate that dissolved cadmium and zinc are not appreciably removal
from the water column in Coeur d'Alene Basm waters, while dissolved lead is removed to the
particulate form between the headwaters and lower basin. This transformation (or attenuation) of
dissolved lead toward particulate lead is addressed by the calculated translator. The translator is
applied to wasteloud allocations for lead m the TMDL
EPA and DEQ acknowledge that the Gold Book criteria are based on laboratory bioassays (using
laboratory water!, and that constituents in river waters may affect the relative toxicity of metals. SSC
development work has examined the dissolved metal concentration at which the resident aquatic
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species in the South Fork Coeur d'Alene River (above Wallace) can be supported. The SSC testing
has been conducted using river water from South Fork,
Comment #6 Letter(s) 274
The most significant flaw in the proposed TMDL calculation of loading capacity is that Region 10 has based it on a
purely theoretical mass balance and has made no quantitative attempt to consider the complex transport and
transformation processes that affect in-stream metals concentrations under a range of stream flow regimes. There is
no calibration or validation of the mass balance approach using ambient and discharge data for the target metals-it
simply assumes that each of the dissolved metals is completely conservative in the aqueous environment (i.e.,
additive).
Response: EPA and DEQ acknowledge that our understanding of the fate and transport mechanisms in the Coeur
d'Alene basin is incomplete Nevertheless, the agencies believe that the mass balance approach (or
"conservation of mass" approach) in the TMDL is the best available method to develop the TMDL
Furthermore, the agencies disagree that no attempt has been made to quantify fate and transport
processes affecting metals discharged to the rivers. The translators developed in the TMDL quantify
the transformation processes occurring in the river network between dissolved and particulate metals;
the translators are calculated using ambient data at the target sites. See also technical evaluation of
fate and transport in an appendix to TMDL TSD.
Comment #7 Letter(s) 274
The TMDL assumes that 100% of the cadmium and zinc in the discharges is in the dissolved form, because a total
recoverable metal:dissolved metal partitioning coefficient of 1.0 is used to set permit limits for point sources. This
assumption that dissolved:particulate transformations of these metals is not important is not scientifically tenable,
given the existing knowledge of metals behavior in surface water environments.
Response: The translators (equal to 1.0) for cadmium and zinc are not based on an assumption that partitioning of
these metals is not important. Rather, they are calculated from the available dissolved and total
recoverable data (paired samples) in the basin, which indicates that cadmium and zinc in basin waters
is almost entirely in the dissolved form .
Comment #8 Letter(s) 233
One of the ncm-point sources presently contributing dissolved metals to the river are thousands of tons of oxidized
mine tailings and metal precipitates incorporated into the active bed load of the Coeur d'Alene River. If water is
treated to lower concentrations than the equilibrium and discharged into the river to contact the tailings, then the
metals will dissolve out of the tailings until equilibrium is reached. Setting discharge limits lower than the
equilibrium will not lower the dissolved metals concentration by a measurable amount.
Response: The equilibrium of metals in the water column can 1* affected by numerous factors and
physical/chemical changes. It is likely that changes to a wastewater (reduced melals and changes to
other chemical properties (e g., pH)) due to wastewater treatment will result in complex changes in the
local equilibrium near the discharge point. EPA and DEQ do not have sufficient information or
resources to evaluate the variety of potential outcomes of these changes at each discharge site. Such
an effort would be further complicated by changes to the receiving water itself due lo floodplain
cleanup actions.
EPA and DEQ also note that available data for the Coeur d'Alene River indicates that downstream
improvement in water quality is dominated by the dilution process, where cleaner tributaries
(pariicularly the North Fork) dilute the metals originating in the South Fork and tributaries This
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would suggest that it is reasonable to expect a direct improvement tn water quality from reduced
individual discharges.
2 5 Natural Background Conditions
Comment #1 Letter(s) 274
EPA's database for determining background concentrations is scant and of questionable applicability. It relies on
data from one location to characterize background concentrations throughout a 1,500 square mile area. Furthermore,
the TMDL TSD fails to indicate the flow conditions present when these data samples were taken. As the TMDL
itself acknowledges, metals concentrations will vary considerably as flow conditions change. It is technically,
scientifically, and legally unsupportable to base the TMDL for the entire Basin on such a limited and poorly
documented data set.
Response: EPA and DEQ agree that the natural background estimates in the draft TMDL were based on limited
data and analysis. The agencies have reviewed a number of recent technical analyses regarding
estimated natural background conditions to improve this element of the TMDL. Improved estimates,
based on the analysis of over 40 sites, have been incorporated into the TMDL TSD aid calculations.
Comment #2 Letter(s) 47,49,52,63,
64,68,010
What studies has the EPA conducted to evaluate erosion rates and the resulting calculated metal flowrates from
rocks and ore bodies in the Silver Valley?
Response: The natural background estimates are based on direct measurements of metals m surface waters of the
basin. Additionally, the Maest report referenced in the TMDL TSD includes an evaluation of baseline
geochemistry data for the Coeur d'Alene River basin. The report noted that the area] extent of
potential exposed ore bodies would be a very small fraction area of the entire watersheds, indicating
that the effect of ore body erosion on natural background water quality would be minor.
Comment #3 Letter(s) 87
Is the North Fork being monitored at Enavilte simply to provide background comparison for the South Fork?
Response: No. The North Fork monitoring has a direct affect on the TMDL allocations, because metals loadings
from this tributary must be subtracted from the loading capacity available for allocation in the
mam stem Gieur d'Alene River,
Comment #4 Lxtler(s) 266.274
Where the TMDL addresses "Natural Background Conditions." it leads the reader to believe that areas outside
mineralized areas (where mineralization is insufficient to support mining activities) should represent "natural
background conditions" within the mineralized areas. This is inherently incorrect. Indeed, natural mineralized
conditions may exceed Gold Book criteria. The highly mineralized nature of ihe South Fork of the Coeur d'Alene
mining district is well documented in numerous l.'SGS professional papers that are known, or should be known, by
EPA during ihe ongoing RI/FS process. One such USGS example would be the "Geochemical-Exploration Studies
in the Coeur d'Alene District. Idaho and Montana" (USGS Professional Paper 1116), The obvious result of a highly
mineralized area is an effect im water quality DEQ has monitoring data for seeps above Shoshone Park (above the
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mineralized area) showing excellences of chronic Gold Book criteria for all three metals, it is a fact that the South
Fork of the Coeur d'Alene River and its tributaries flow through one of the most highly mineralized areas in the
United Slates Mineralized outcrops occur throughout the basin. The physical structure of the valley contains
numerous faults and fractures and many of these faults and fractures occur in mineralized zones. It is obvious that
surface water would reflect the characteristics of the basin through which il flows.
The Removal Work Plan for 1994 Ninemiie Drainage Projects (May 10, 1994) document (developed as a
cooperative effort by DEQ, Idaho State Natural Resource Damage Trustees, Heel a, BLM, Coeur d'Alene Basin
Restoration Project, & Coeur d'Alene Tribe) contains excavation logs with both lead and zinc analysis results of
alluvium (below the tailings, lailings/sand/alluvium mix, and organic layers) ranging as high as 10,(X)0 ppm for both
parameters. Similar results of elevated metal levels in the alluvium are also found in Canyon Creek as documented
in the Canyon Creek - Woodland Park Response Action 1995-1996 Tailings Removal and Stream - Floodplain
Stabilization Work Plan. The same entities sponsoring the Ninemiie Creek work also were involved with the
corresponding Canyon Creek acuon except that EPA was also involved as a participant in the Canyon Creek wcrk
plan. It is clear that the water and sediments in mineralized areas will have metals levels elevated above those which
occur in non-mineralized areas (and which are used for background in this TMDL)
Other mineralized areas, such as the Red Dog mine, are examples where the streams, prior to mining, had elevated
levels of metals. Natural background levels of metals in stream sediments in the Red Dog area include zinc
concentrations up to 5,900 ppm and lead concentrations up to 36,300 ppm. Natural background water quality in the
Red Dog area streams include zinc levels as high as 24.0 ppm and lead as high as 0.286 ppm. The point is that "cold
water biota," as clearly explainedm comments above, cannot be the appropriate use designation any more than Gold
Book criteria can apply "throughout the basin" in a highly mineralized area. It is important to note that, as we
understand other situations, EPA has recognized the fact of naturally elevated levels of parameters in certain areas
where EPA has an "economic" consideration (Summitville, New World, Moab).
Response: The revised natural background estimates are based on a broader analysis that includes samples from
over 40 sites, including numerous mineralized areas in the basin.
Comment #5 Letter(s) 37,77
In your bulletin (page 5), there are no authors or indication of where the information was obtained to make the
statement that 'To date, EPA has seen no compelling information to indicate that metals concentrations are naturally
high in the CdA rivers and streams."
Response: At the time of the proposal, EPA's administrative record for the TMDL contained no studies of the
natural background condition of Coeur d'Alene rivers and streams. Since that time, four reports about
natural background conditions have been produced by technical experts. EPA and DEQ have included
references to these reports and an analysis of their conclusions in the TMDL TSD chapter cm natural
background conditions.
Comment #6 Letter(s) 87
In determining natural background conditions, has the EPA tested hillside spring runoff from erosion channels
before it mixes with mine tailings and other obvious metal sources?
Response- EPA has not conducted this kind of monitoring Because of the large scale of this TMDL. EPA and
DEQ do not consider discrete runoff sampling io be a practicable method to establish natural
background conditions throughout the basin. EPA and DEQ rely on a larger scale analysis of
nver/crtxk water quality and regional geochemistry information to evaluate natural background
conditions
Comment #7 Lctter(s) 51, 70. 274
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EPA has asserted that the water samples taken at Larson represent natural background levels that could be attained
throughout the South Fork, This conclusion is inaccurate, as these samples were collected outside the area naturally
high m minerals, and therefore will not show elevated levels of lead, zinc, or cadmium.
Response: The natural background estimates used in the final TMDL no longer rely on the Larson station. See
natural background section in the fmal TMDL TSD
Comment #8 Letter(s) 272
Elevated lead and zinc values have been monitored in Lake Creek and Shields Gulch above mining impacts. This
data clearly identifies that natural background contributions to the system do exist, at least within the defined
mineralized area of Silver Valley. It would be expected that others in the Basin have similar data to support a natural
background audition. However, this background data should not be removed from the allocation but [used to
demonstrate] that higher levels of metals do exist and do not necessarily impact the biological communities.
Response: The commenter has not supplied the agencies with data for Lake Creek and Shields Gulch; therefore,
the agencies can neither confirm nor refute the assertion about those creeks. Nevertheless, EPA and
DEQ have clearly recognized in the TMDL development that there are natural background
contributions to the system. The revised natural background estimates used in the final TMDL are
based on large data set of surface water samples. It is unlikely that data for two additional creeks
would significantly change these estimates.
The suggestion that background contributions should not be subtracted from the loading capacity is not
consistent with the requirements of the Clean Water Act. Natural background metals loads must be
subtracted from the loading capacity to insure that the allocations do not exceed the loading capacity
of the system.
Comment #9 Letter(s) 262,272,274
Few separate sampling events were used to determine background conditions which represent a limited time period
of 1991, 1997, and 1999 and only during the months of May, October, and November. In the case of cadmium and
lead, all background concentrations were below the detection limit of the analytical methods used for collecting
ambient surface water data. Therefore, Region 10 selected one-half the minimum reported detection limit for these
two metals. Although this is a commonly accepted assumption, it highlights the concern about the use of a
sufficiently sensitive analytical method for measuring ambient metals at trace concentrations. The detection limits
used to calculate the background concentrations were 0.1 ugfl for lead and 0.04 ^g/1 for cadmium. The
concentrations used for background were thus 0.05 ug/1 and 0.02 ug/] for lead and cadmium, respectively. These
two "background" concentrations represent 9% and 5% of the respective water quality criteria used in the TMDL
study These are not insignificant background loadings in (he context of this TMDL. If the background
concentrations had been determined with the most sensitive analytical methods for lead and cadmium given in Table
I of Method 1669, the detection limits would have been 0.0081 ug/1 and 0 0024 ug/1 fix lead and cadmium,
respectively Thus, it is possible that the background concentrations for these two metals could be over 10 times
lower than those used m the proposed TMDL This change in background concentration would represent a
significant change in the allowable loadings of cadmium and lead in all of the surface waters of the CdA basin
In the case of zinc, there were measurable concentrations above the detection limits used in the study. Region 10
selected the maximum detected zinc concentration in the entire data base C6 78 ug/1) to apply as the natural
background concentration to all streams in the basin This concentration represents over 21% of the zinc water
quality criterion used in the TMDL and thus reduces the allowable loading by this amount. This selection is overly
conservative and is not scientifically supported in the TMDL TSD.
Metals data collected with sampling and analytical methods that generate data sets with minimum detection limits
that are above the applicable water quality criteria are not an adequate foundation for the TMDL This is also true
for NPDF.S permit limits set at a fraction of the water quality criteria.
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Response: EPA and DEQ agree that detection levels are an important constraint in analyzing natural background
(low contamination) conditions. Background estimates would be improved at some locations by
employing analytical procedures that achieve lower detection levels. However, a significant body of
sampling data is available to obtain estimates of natural background conditions. The agencies have
reviewed a number of recent technical analyses regarding estimated natural background conditions to
improve this element of the TMDL Improved estimates, based on larger data sets and lower detection
limits, have been incorporated into the TMDL TSD and calculations.
Regarding permit limits, EPA and DEQ note that the total recoverable wasteload allocations are
expressed as loads for the mining sources. Therefore, the allocations cannot be directly compared
against the water quality criteria. If u is demonstrated during permit development that compliance
monitoring will be constrained by limits of detection, appropriate conditions will be included in
permits to address the constraints.
Comment #10 Letter(s) 47,87
Why does the EPA assume that because there are few surface outcroppinp of ore that surface runoff metal content
would be negligible?
Response: In the draft TMDL, EPA and DEQ based the natural background estimates on river sampling at the
Larson site. EPA and DEQ also made a general observation that the mines in the basin are
underground mines, and that metals contributions from a relatively small number of natural
outcxoppings would be significantly diluted by clean water from the rest of the basin. The final TMDL
estimates for natural background are based not oil general observations but rather on actual river/creek
sampling at ova- 40 sites in the basin.
Comment #11 Letter(s) 255
Considering the mineralization of the area, the goal of the TMDL appears to be to elevate the water quality in the
river above its pre-mining condition.
Response: Based on the agencies' analysis, pre-mining (natural background) metals levels were lower than the
TMDL goal (Gold Book criteria levels).
Comment #12 Letter(s) 274
The background data used in the TMDL analysis are an extremely important component of the allowable loading
analysis. In the case of zinc, over 21% of the allowable loading is taken by the assumed "natural background." It is
important that the background loadings of these three metals be based on reliable analytical data, and it is not.
Region 10 and DEQ must arrange to collect new background samples from suitable sites using appropriate sampling
and detection limits. In selecting suitable sites, EPA cannot simply select locations above areas of historic mining. It
stands to reason that background concentrations of metals would be higher in areas where there were sufficient ore
deposits to justify mining than in areas where there were not. Because background effects are important to the
overall loading allowances, resampling is a requirement for a valid TMDL, not just an improvement.
Response; EPA and DEQ concur that the background analysis is an important component of the TMDL. The
revised natural background estimates are based on a broader analysis that includes samples from over
40 sites, including numerous mineralized areas in the basin. The agencies disagree that new sampling
is required tor a valid TMDL.
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Comment # 13
Letter(s) 274
The TMDL should examine the entire data base of background data and, as appropriate, use elevated background
data only for those streams where the elevated concentrations are found. Other streams should be assigned
background concentrations that are more appropriately defined as natural.
Response: As discussed above, EPA and DEQ have incorporated analyses of largo- data sets in its revised natural
background estimates.
Comment #14 Letter(s) 7,68
Mud in the walls of the Cataldo mission contains 1,000 ppm lead, indicating high natural background levels of
metals in the basin.
Response: EPA and DEQ cannot verify the results of mission wall sampling by other parties. When estimating
background metals levels in rivers, it is preferable to collect and analyze river water samples rather
than rely on surrogate analyses of materials in historic buildings. The natural background estimates
used in the final TMDL are based on direct measurements of metals levels found in rivers in both
mineralized and non-mineralized areas in the basin.
2 6 Flow Tim
Comment # 1 Letter(s)
In developing the low flow analysis, EPA used 1991 data (Silvertcm) rather than 1997 data because there was lower
variability in the MFC 1991 data. Generally, Agency policy and guidance support using more recent data rather than
older data to support risk-related decisions because they are more representative of current conditions. It is not clear
how the uncertainty in the TMDL decision-making process is affected by using these different data sets.
Response: EPA and DEQ believe that the general rule of thumb to use Lhe most recent information applies more
to contaminant data than to flow data, because contaminant levels may be influenced by human
activities or natural processes. In this case, EPA/DEQ's use of 1991 versus 1997 flow data was an
appropriate attempt to use data from a sampling period with stable flows.
EPA and DEQ have revised the flow tier values in the TMDL for Canyon Creek, Ninennle Creek, and
Pine Creek based on extensive flow monitoring at these sites by the USGS in 1999 (see discussion of
flow estimation in the TMDL TSD). Because the South Fork above Wallace was not monitored by
USGS, the estimates for this tributary (and its contribution to the Wallace target site flows) remain
unchanged. EPA and DEQ believe sufficient flow data is available to provide reasonably accurate
flow tiers for calculation of the TMDL elements.
Comment #2 Letter(s) 241
There is concern that the TMDL did not take into account the increase in water yields from rain-on-snow events in
watersheds "above the South Fork oi the Coeur d'Alene River" that have been clearcut. The final document should
discuss the effects (direct, indirect and cumulative) of increased peak flows to the South Fork, North Fork, and
Little North Fork from past logging and road building m relation to the proposed TMDL.
Response: EPA and DEQ disagree that the TMDL does not address peak flows. The flow-tier approach
constrains source allocations to an equal or lower flow condition (and loading capacity) than the actual
condition. This approach provides a margin of safety during [>eak runoff periods.
Comment #3 Letter(s) 259,278
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estimation method is more technically .supported than the use of actual stream flow measurements.
The drainage area ratio approach cited in the comment, using appropriate watershed geomorphological
parameters, is an accepted method of estimating (lows when flow data are not available. In this case,
however, EPA and DEQ do possess flow data for the ungauged tributaries. In the TMDL, the method
selected for establishing flows for ungauged tributaries capitalizes on this available data and therefore
provides direct rather than modeled estimates of flow ratios
Comment #9 Letter(s) 267
The 7QI0 value of 211 cfs for the Spokane River at Post Falls dam is incorrect. The policy of the Avista Dam
(built in 1981) is to release 300 cfs (per EPA's request) The data therefore should be recalculated using 1982-1999
data to reflect the current condition.
Response: Since the release of the draft TMDL, EPA reissued NPDES permits for municipalities along the
Spokane River in Idaho. During this process, EPA and DEQ responded to concerns about Spokane
River low flows. The flow record from 1960 to 1998 was used to recalculate the 7Q10. The
recalculated value is 329 cfs, and the TMDL TSD table has been revised accordingly.
EPA and DEQ note that the design flow values for the Spokane River at Post Falls were included for
information purposes only. They are not used in the calculated of TMDL allocations.
2 7 Margin of Safety
Comment #1 Letter(s) 255,266,274
The so-called "margin of safety" in the proposed TMDL is expressed as "10%." EPA must, by law, mset the
"reasonable" test for its actions to be neither arbitrary nor capricious. DEQ is limited to an "adequate" margin of
safety. What appears to be hidden "margins of safety" plus the stated "10%" results in a margin of safety that is
arbitrary and capricious, as well as excessive.
A 10 percent margin of safety is appropriate if other estimates do not build margins of safety as well. However, it is
apparent that multiple layers of safety are added in each component of the TMDL allocation process. When
considering all assumptions, a safety factor on the order of 40 percent is realized in the proposed TMDL. If pant
sources only contribute approximately 5 percent of the total loading, the number is even higher. Multiple layers of
safety are found m:
* 65/25 allocation (point sources only account for approx 5 percent);
* Hardness data suggests average values would be significantly higher - which improves overall total
loading
capacity of the system;
* Permit limitations - daily maximum vs. monthly averages,
* Using the 5th percentile on Total Recoverable:Dissolved ratios instead of averages overstates
bioavailability
of metals,
* No consideration to site-specific conditions - increase loading capacity; and
* Using the lowest flow conditions for each tier (four) to establish allowable loading capacity -
underestimates
actual loading capacities
Response: Federal regulations governing TMDLs require that they be established with a margin of safety to
account for these uncertainties and insure the TMDL will achieve water quality standards. Each
element of the TMDL is developed with some degree of uncertainty While some uncertainties can be
addressed using conservative analyses and assumptions, others are cannot addressed in that fashion.
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For this reason, the margin ol safely for this TMDL consists of a combination of conservative
assumptions used in building the TMDL elements and a small, explicit margin of safety equal to 10%
of the loading capacity The TMDL TSD includes a list of conservative assumptions and a discussion
of the uncertainties considered m establishing this dual margin of safety.
EPA and DEQ disagree that the use of 65/25 allocation, establishment of permit limitations, and use of
statewide water quality criteria provide any margin of safety. Since hardness values have been
significantly changed in the revision to a flow-hardness relationship in the TMDL elements, they are
not considered to provide a margin of safety (see discussion in the TMDL TSD). Row tiers also
cannot be said to provide a consistent margin of safety, since the actual flow cculd be equal to the flow
tier value in a given month.
Comment #2 Letters) 266,274
The Gold Book criteria have built-in safety factors due to both the mathematical manipulations of the data and the
inclusion of highly sensitive laboratory organisms not native to, nor could they survive in, the South Pork of the
Goeur d'Alene River. For example, there does not appear to be any science behind the "divide by 2" concept in
deriving Gold Book values. The use of criteria developed through testing nan-native organisms raised in a
laboratory does not comply with the Congressional mandate of "criteria for water quality accurately reflecting the
latest scientific knowledge." This represents another "margin of safety" as evidenced by the healthy aquatic
community in the South Park of the Coeur d'Alene River above Wallace even though the Gold Book criteria are
routinely exceeded
Response: While EPA and DEQ agree (hat the Gold Book criteria are developed using conservative assumptions,
the margin of safety in the TMDL addresses the uncertainty in achieving the applicable water quality
criterion adopted by the State of Idaho. The concern raised in the comment can be addressed in the
water quality standards process through site-specific criteria.
The "divide by 2" step in criteria development is used to calculate acute criteria. The TMDL
calculations are based on chronic criteria. The derivation of these chronic criteria do not include the
"divide by 2" step referenced m the comment. Therefore, the reference to the "divide by 2" step in the
comment is not pertinent to this TMDL. For clarification, EPA notes that the "divide by 2" step is
based on scientific principle. It is employed to convert the criteria from an LC50 basis (where
concentrations would be lethal to 50% of the organisms) to a value that approximates an LCO (non-
lethal). Without this step, the enter,a would not be adequately protective of the most sensitive species.
Comment #3 Letter(s) 266,274
The TMDL suggests that the total recoverable metals procedure is reflective of conditions a particle would endure
in the real world. Indeed, the TMDL states that "EPA has calculated the ratio of total recoverable metal to dissolved
metal for each sample taken at or near a target, and then calculated an estimated 5th percentile ratio in order to
assure compliance with water quality standards." The limited data set was reduced by 95% to guarantee that
virtually all metals in the discharges were equated with "dissolved" metals. This procedure is another hidden
margin of safety which ignores 95% of the data and any seasonality, resulting m a very stringent translator.
Response The Idaho water quality standards for metals are expressed as dissolved metal concentrations.
Consistent with the letter of the applicable NPDES regulation, permit limits must be expressed as total
recoverable metals (40 CFR 122,45), Therefore, it is appropriate to translate dissolved wasteload
allocations into total recoverable wasteload allocations. EPA has published national guidance on
translators (referenced in TMDL TSD), and the method used in this TMDL is consistent with that
guidance. To insure that the final wasteload allocations (in total recoverable metal) achieve the
dissolved criteria al all times, it is reasonable to use a conservative estimate (5* percentile) of the
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translator. This approach addresses seasonal critical conditions and is one of the conservative
assumptions forming the margin of safety.
Comment #4 Letter(s) 272
Upstream allocations discussed in the TMDL (page 25) are appropriate when considering downstream target sites.
However, it is important that flow data and other information are accurate to allow appropriate allocation of metal
loading. Without this, it tends to cause a multiplying effect of safety factors to the estimates as allocations occur
downstream.
Response: EPA and DEQ have adjusted the flow tiers based on the available data, including more recent USGS
sampling (see also responses under Flow Tiers).
Comment #5 Letter(s) 266
Fart of the excessive margin of safety is hidden in the TMDL's distortion of the "mixing zone" concept. In the
way the mixing zone concept is bang misrepresented, the TMDL would lead the public to believe that the
discharged metals are only allowed to occur in a 25% swath of the stream! The fact of the matter is that a TMDL is
the load for the entire stream.
Response: The use erf the mixing zone guidelines (as a basis to allocate 25% of the loading capacity to discrete
sources) in the gross allocation has no bearing on the margin of safety. EPA and DBQ disagree that
the draft TMDL TSD is misleading and does not address the entire stream. The document clearly sets
forth the allocation erf not only 25% of the loading capacity to discrete sources but also 65% to non-
discrete sources and 10% to a margin of safely.
2.8 Method of Allocation - CdA River and Tributaries
Comment #1 Letter(s) 224,255,262,
270
The proposed TMDL does not account for any growth in the Silver Valley, including new connections to the
municipalities. EPA provides limits for the municipal dischargers along the Spokane River that allow for "future
growth" while denying such an allowance for the municipalities and industries in the Silver Valley.
The last paragraph on page 31 erf the TMDL TSD states that for those pant sources currently nwtjng their load
allocation, the reduced allocations are "subtracted from the total discrete point source gross allocation and added to
the nan-point source allocation." In cither words, point source load allocation is arbitrarily transferred to the
non-point source allotment. Any point source loading assigned to but not used by a particular point source should
be reassigned to other point sources within the [allotment category}.
The TMDL should not reallocate excess point source allocations to non-point sources. Instead, the excess
allocations should be reserved for point sources. This reserve would serve two objectives: (1) it would allow growth
of point sources in the basin, if that is desired; and (2) until that lime, it would add to the margin of safety.
Resptmse: EPA and DEQ agree that a process for establishing a reserve allocation for future growth is needed for
ths.South Fork and tributaries (the concentration-based allocations allow for future growth on the
Spokane River). If it is determined that a source has been given an allocation greater than its current
loading to (he river, the remainder will he set aside as a reserve and made available to new or
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expanding facilities EPA and DEQ note that a formal TMDL modification must be completed to
quantify the reserve and make it available for allocation to a new or expanding source. In the
meantime, consistent with the comments above, any unused allocation adds to the margin of safety
f, OH.
Rather than establish individual performance-based allocations in the TMDL, the TMDL has been
revised to contain the calculated allocation and companion language that requires use of performance-
based limits in NPDES permits when the allocation is greater than the current leading from the source.
The actual performance-based limits will be developed as part of the NPDES pernfct development; this
allows additional tiro for sampling and analysis of current performance. Reserve loading from the
source in question can be allocated to the general future growth reserve "acocunrafter issuance of a
final NPDES permit containing performance-based loadings for a particular source. Allocation of the
future growth reserve to individual sources will require formal modification of the TMDL.
Comment #2 Letter(s) 1 "267
» v.
The TMDL does not adequately address the uncertainties associated with the analytical determinations at these low
concentrations. The TMDL should account for analytical limitations in establishing wasteload allocations.
* »/
Response: A TMDL must establish allocations that achieve the water quality standards.' EPA lahd DEQ recognize
that in son*; instances, EPA's permitting program may need to address analytic limitations (e.g.,
detection limits for the nxtals) in developing permit limits and monitoring requirements. This is a
relatively common issue in NPDES permitting, driven by low level water quality criteria
concentrations for some parameters (including some metals). EPA and DEQ do hot have adequate
information on each source to address this issue in the TMDL, but the issue can be addressed in the
permitting process.
Comment #3 Letters) 267,274
The TMDL should not require loading concentrations below water quality standards. The TMDL must allocate
loading capacity among sources that use, or need to use, that capacity. The TMDL fails to understand or implement
this concept. If a pollutant source does not use or need to use any loading capacity, then that source does not require
any allocation of the capacity. (Such a discharge might not even require a permit limit if the data showed it had no
reasonable potential to exceed an applicable standard.) No discharger, however, should receive an allocation of less
than the water quality standards, which is in essence a zero share of the loading capacity
The folly erf the agencies' approach is demonstrated by the fact that whenever a limit below the applicable criterion
is imposed, the discharger may need (at great cost) to cease any discharge in order to meet the limit. In some cases,
this would result in a net loss (not gain) of assimilative capacity for the very parameters the TMDL is addressing. If
the municipalities of Coeur d'Alene, Post Falls and Hayden Lake all ceased their discharges, the Spokane River
would lose loading capacity for metals, rather than gain it. Similarly, if all of the dischargers to Ninemile Creek
went to zero discharge to meet the requirements developed for 7Q10, 10® and 50* pctc^ftl^'hb^; this would
result in less loading capacity than if they had to meet limits based on a zero share of loadfri|f cafdfety, i.e., based on
compliance with the criteria at the end-of-pipe. Became the TMDL imposes such extreme limitJ, tHe creek would be
worse off Moreover, while the TMDL says that it is allocating a 25% share of the loading drjf&dfy to the point
source dischargers, it actually allocates a less than 0% share of the loading capacity sihe^t r^ufltt point sources to
comply at the end of their discharge pipes with limits that are more stringent than the appli&bw'kfeter quality
criteria Consequently, the TMDL is overly restrictive and technically flawed.
Response: This comment focuses on concentrations associated with the assigned allocsti6nS/J "fchi TMDL,
however, establishes wasteload allocations expressed not as etweerttrations but rikh^flas loads
(lbs/day). Therefore, the general assertion that the TMDL reqUfffei"{xani,%<3tfcri| W$Anply at the end
of their discharge pipes with limits that are more stringent than tftfe'appliei&e \®$'qtiality criteria" is
not accurate. In addition, two factors make up an effluent metals load: flow concentration.
A facility can reduce either flows or metals concentrations. or both,'to redthft thi'kSffl1' it a facility
45
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reduces its flows, via recycling or other water management measures, the allowable discharge
concentration can be proportionally higher to achieve the same loading level.
In the context of significant reductions required of many sources, EPA and DEQ maintain that it is not
reasonable to allocate more load to a source than it is currently discharging. This would run counter to
the goal of improving water quality throughout the basin. The TMDL provides for establishment of
performance-based limits for this reason.
EPA and DEQ acknowledge that reductions or cessation of a relatively clean wastewater discharge
could reduce the dilution of metals in the river in the short term (it is unclear whether the Nmemile
Creek dischargers referenced fit into this category). This is fundamentally a concern about timing of
implementation actions rather than a deficiency of the allocation method itself. See Timing of
Implementation and Permitting Actions for further comment Mid discussion.
EPA and DEQ agree that if the municipalities along the Spokane River ceased discharging, the river
would lose loading capacity. Conversely, however, increasing their discharged metals concentrations
would degrade water quality. Therefore, assigning performance-based allocations is appropriate.
Comment #4 Letter(s) 267,272,274
A number of sources in the Coeur d'Alene Basin apparently already meet their assigned load allocations For these
sources, including small seeps and adits as well as permitted pant sources like the Galena Mine (zinc) and Caladay
Mine (zinc), EPA and DEQ are proposing to set their load allocations based on their current discharge levels. This
approach is fundamentally flawed and contrary to EPA's own guidance for establishing perfcrmance-based effluent
limits ("PBLs"). EPA and DEQ do not appear to have adequate, statistically valid data for establishing such
performance-based discharge limits.
EPA and DEQ's approach is especially inappropriate for currently unpermitted sources. Setting wasteload
allocations based on a limited data set is rife with practical and statistical problems. First, in order to set PBLs, an
agency must have a data set that is "independent" and "uncorrelated" (EPA, Technical Support Document for
Water Quality-Based Toxics Control, Appendix E). The data must all fit the normal or log normal distributions.
EPA's data do not satisfy these criteria. EPA and DEQ cannot set performance-based limits in the absence of any
performance data.
Setting WLAs based on current discharges at 50% flow is technically and legally (insupportable. For a number of
sources that currently meet their WLAs, the TMDL sets WLAs based on the discharger's effluent concentration at
50% flow, then scales that number proportionately to the 7Q10, 10% and 90% flows. This methodology is
unreasonable and illogical for sources where the flow and/or discharge concentration do not vary or vary minimally
with stream flow rate. A source whose effluent concentration and volume do not vary with flow rate would be
virtually assured of permit violations if its WLA is set at the 50% flow concentration and then scaled down to the
7Q10 and 10% flow rate. For example, the Galena Mill is assigned a zinc source loading concentration of 36.1 Mg/l
at 50% flow based on its actual current discharge. The TMDL then requires the Galena Mill to achieve an effluent
concentration of 7.96 fj.g/1 when the flow is at the 7Q10 level. What this means, in effect, is that the Galena Mill
will have to find ways to ensure it meets a 7.96 ^g/1 discharge concentration, even though EPA and DEQ have
nowhere demonstrated that the Mill's ability to achieve metals loadings that are lower than its allocation at the 50%
stream flow can be replicated at lower stream flows.
Reviewing a site's status and re-apportioning allocation on one tier is inappropriate. All data should be reviewed
before reducing a discharger's limits. If insufficient data is available, a phased approach would allow collection of
this data and determine growth requirements for each project and the ability to reduce loading through cost effective
techniques.
The TMDL assigns Spokane River municipalities a performance-based criterion for the three metals to prevent
significant increases in metals discharges. The performance criteria are based on grab samples. These grab samples
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are not adequate lo accurately characterize the plant's long term discharges with a reasonable level of confidence.
Uncertainties associated with the analytical determinations at low concentrations compounds the problem. Finally,
setting the performance criteria so far below the water quality criteria will mean that slight exceedances will result
in NPDES violations negating the NPDES intent that "only a significant increase in concentration will trigger an
exceedance "
The chance for the Coeur d'Alene POTW to exceed the cadmium limit expressed in the TMDL depends on the
statistical distribution pattern of the metals concentration. Under a normal distribution, there is little chance of
exceeding the limits. However, there is over a 10 percent chance of exceeding the limit if the concentrations are log
normally distributed- This means that the TMDL limits could regularly be exceeded even if the distribution of
cadmium concentration does nc* change over time. This is contrary to the intent of the NPDES permits to...ensure
that only a significant increase in the metals concentrations will trigger an exceedance."
Response: Based on the above concerns about quantification of performance-based allocations, quantified
wasteload allocations based on performance have been removed from the TMDL and replaced by a
narrative requirement. EPA and DEQ agree that the TMDL can and should provide flexibility for
additional evaluation to establish performance-based allocations. Because of the need for case-by-case
evaluations of performance and the number and variety of sources, the TMDL has been revised to
include the calculated allocation and companion language thai requires use of performance-based
limits in NPDES permits when the calculated allocation is greater than the current loading from the
source. This approach defers the case-by-case evaluation of current performance to the permitting
process, thereby allowing additional time for sampling and analysis of current performance at each
source.
Comment #5 Letter(s) 274
An allocation scheme that relies entirely on flow is inequitable and results in wholly arbitrary allocations. While
flow-based allocation schemes may make sense in circumstances where all point sources are similar, it makes little
sense where there is a significant variability in the different types and locations of point sources. It implicitly treats
all sources as equivalent even though there are significant differences. Par example, .it treats a waste rock pile as the
equivalent of a mine that is employing hundreds of miners and supporting thousands of families. It treats an adit
with low metals concentration the same as one with high metals concentrations. It treats a mine producing ore the
same as one that was shut down decades ago. It treats municipal wastewater discharges the same as an old mine adit.
This overly simplistic approach to setting a TMDL ignores the complexity of the Basin and the unique problems that
each type of source will face to meet the wasteload allocations (WLAs).
Response: EPA and DEQ recognize that there is variety in the types of sources in the basin, and the TMDL
recognizes this variety in establishing allocations by source category. EPA and DEQ have used
effluent flow as an objective, rather than arbitrary, basis for allocating loadings to discrete sources
This approach is relatively simplistic but also reasonable, given that (1) a measureable flow is a
distinguishing feature of discrete sources, (2) metal loading is directly proportional to flow, and (3)
treatment costs are largely driven by a facility's design flow. EPA and DEQ believe the alternauve
allocation process implied by the comment er, where each type of source and unique situation factors
into the individual allocation decisions, would not provide an objective basis for distribution erf"
allocations lo sources.
Comment #6 Letter(s) 233
EPA should conduct current metal equilibrium concentrations in the Coeur d'Alene River and base reasonable
effluent limitations on these values.
Response: The wasteload allocations m a TMDL must, in combination with load allocations and a margin of
safety, achieve water quality .standards.
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Comment #7
Letter(s) 266
The mixing zone was never intended 101*; utilized this way Idaho's regulatory definition of mixing zone is "a
defined area or volume of the receiving water surrounding or adjacent to a wastewater discharge where the receiving
water, as a result of the discharge, may not meet all applicable water quality criteria or standards. It is considered a
place where wastewater mixes with receiving water and not as a place where effluents are treated." By the very
definition, the en ten a do not have to be met in the mixing zone
The arbitrary and capricious (as well as preposterous) nature erf* this approach can be highlighted with an example of
a situation where point sources truly are the source of the impairment, as intended by Congress under CWA Sec.
303(dXl). If several point sources ail discharged the total load of pollutant "X" and there was no natural
background, under the TMDL's approach, all point sources would only be allocated 23% of the actual carrying
capacity of the receiving water, less the 10% margin of safety. The unsuspecting regulated public would comply
with this nefarious scheme by installing costly and unnecessary treatment that would result in instream water quality
77.5% below the applicable standard! If the water quality is consistently below the applicable standard, even at 99%
of the applicable criteria, the water would not be impaired at all and would not belong on the 303(d)(1) list.
EPA has long attempted to intrude in the mixing zone arena, which is a state-only issue as guaranteed by Congress
at CWA Sec. 101(b). EPA admits as much in In the Matter of Star-Kist Caribe, Inc., where the EPA Administrator
said "whether limited forms of relief such as variances, mixing zones and compliance schedules should be granted
are purely matters of state law, which EPA has no authority to override" (NPDES Appeal No. 88-5, at 15-16
(1990)). The CWA has not been amended since 1990. In addition, if DEQ is attempting to apply a new regulatory
concept to the mixing zone regulations, Idaho APA requirements mast be-met.
Response: EPA and DEQ have discussed a number of options for determining the percentage of the loading
capacity to be allocated to point sources. EPA and DEQ are not directly applying the mixing zone
regulation in this TMDL, and the agencies do not take the position that the state's 25% mixing zone
guideline dictates the percentage of the loading capacity to be allocated to point sources. Rather, this
guideline reflects state policy on the use of river flow for assimilation of point source discharges,
allowing up to 25% of the flow for this purpose. Because loading capacity is directly proportional to
the river flow, there is a nexus between mixing zones and TMDL allocations. Therefore, it is
reasonable to analogize to this guideline and allow the use of the guideline maximum of 25% of the
loading capacity far point source discharges. This analogy provides a reasonable, objective policy
basis for distributing the river's loading capacity between discrete point sources and non-discrete
sources.
The commenter presents a hypothetical situation that is fundamentally different than the Coeur
d'Alene TMDL. The presence of significant nonpoint sources (e.g., tailings deposits in the floodplain)
in this basin must be addressed in the allocation process. The agencies believe the use of an objective
basis (i.e., the mixing zone guideline for point sources) to divide the loading capacity among discrete
and non-discrete sources is reasonable m this TMDL.
Comment m Letter(s) 270,272
Using the State mixing zone rules to determine load allocation is not appropnate or applicable for a loading-based
approach. The TSD defines the loading capacity of a water body as based on exceedanee of water quality criteria.
IDEQ mixing zone guidelines specify water quality can be exceeded in 25 percent of Ihe river's flow. This does not
equate to 25 percent allocation to point sources In fact, it would be much higher. If EPA/IDEQ are to develop
loading in this manner, allowable concentrations above the criteria need to be developed to be consistent with
mixing zone guidelines which will result in higher loadings than proposed in the TMDL and strll will be consistent
with regulations.
Response: See response to previous comment
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Comment #9
Letter(s) 52,63, 266, 267,
270, 272. Ol,
019
Allowing municipalities to be treated as a tributary due to higher hardness of the groundwater ultimately discharged
is no different than the mine situation. Mines pump groundwater with a higher hardness than the stream system.
Consideration should be given to allowing increased hardness due to groundwater discharges and actual stream
hardness.
EPA's arbitrary application of hardness based effluent criteria to some permittees but not others covered under the
same proposed TMDL is inappropriate. The EPA (second paragraph, page 34 of the TSD) and Slate of
Washington's TMDL slate that the "Mixture of [a higher hardness] tributary and [a lower hardness) mainslem
waters would not result in any local criteria exceedance." Why do the scientific principles applied to the dilution of
high hardness tributary water to the Spokane River mainslem not apply to high hardness tributary [effluent] waters
in the South Fork of the Coeur d'Alene River? Dilution principles are, after all, universal in their applicability.
Why does the EPA have a different standard for Hayden. CdA, and Post Falls than the mines?
Not all ore bodies have been discovered in the Coeur d'Alene mining district because only about 10 cubic miles of
rock have been explored. If a new orebody is discovered, is it the intent of the EPA to prevent it from being mined?
For example, in the allocation of the TMDLs, the point sources will have an allocated quantity. Does the new mine
get a zero quantity, or do the other point sources have to reduce their discharge because of the new mine coming on
stream? It is noted that sewers can be expanded while maintaining a certain ccncentration of metals thus increasing
their daily discharge. Why are the mines treated differently?
Some NPDES permit holders covered under this TMDL discharge water with a considerably higher hardness than
any receiving waters in the Coeur d'Alene River basin. There is no scientifically defensible reason why the dilution
principles applied to the tributaries in the Spokane River should not apply lo the South Fork. Therefore, EPA should
either 1) further evaluate the possibility of applying the same hardness based effluent criteria to [all] NPDES permit
holders in the basin or 2) produce scientifically valid reasons why such criteria cannot be used for other NPDES
permits issued m the CdA basin.
Response: Assignment of allocations in the South Fork is a distinctly differ ait technical challenge than allocation
in the Spokane River. The Spokane River allocation requires only the assignment of wasteloed
allocations to three discrete sources. This contrasts with the South Fork watershed, where EPA and
DEQ must quantify an allocation for mining wastes in piles and in the floodplain. If EPA and DEQ
were to assign waste!oad allocations using effluent hardness in the South Fork, the leftover loading
capacity available for these non-discrete sources must be quantified. Since EPA and DEQ have no
data on "nonpoint source hardness" (a concept with questionable practicality), this leftover fraction
must be calculated as the loading capacity at a number of flow conditions minus the wasteload
allocations and margin of safety. This is precisely the method used in the TMDL, albeit without using
effluent hardness as the allocation method for discrete sources.
Another difference with the Spokane River is that the mining sources along the South Fork are
distinctly different than municipal sources with respect to flow and hardness variability. Adits drain
inner mine workings, and may or may not show significant swings in effluent flow and hardness based
on the characteristics of the surrounding geology and hydrology within the mine. Unfortunately, EPA
and DEQ do not have sufficient information to characterize the variability in flow and hardness of
many of these mining sources. For some sources, EPA and DEQ have only one or two samples, and
EPA and DEQ have not received any data for most of the unpermitted adits during the comment
period
Despite the data constraints. EPA and DEQ have nonetheless reviewed the limited available
information to evaluate the feasibility and outcome of an effluent hardness approach to the allocations
in the South Fork. Discharges were assigned a concentration based on the measured effluent hardness.
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EPA and DEQ used average effluent and river flows in this evaluation Based on this evaluation, the
effluent hardness approach allocates a large fraction of the loading capacity to the discrete sources,
and a commensurablv low fraction to nonpomt sources EPA and DEQ do not believe it is reasonable
to assign most of the loading capacity to discrete sources given the extent of n on point sources in the
basin.
Even if EPA and DEQ believed this method provided a reasonable allocation outcome in the South
Fork under average flowrates, completing the allocation process for the full range of river flows would
require assignment of individual effluent flowrates at each river flow tier to calculate loads. As
discussed in the Technical Support Document, EPA and DEQ do not have sufficient information to
estimate these effluent flowrates for a majority of discrete mining sources. EPA and DEQ could in
this case arbitrarily assume a relationship far effluent flow with respect to river flow or use a single
average effluent flowrate for all river flowrates. This exercise introduces enough uncertainty and error
into the calculations as to defeat the purpose of using effluent hardness as the allocation method in the
first place.
Comment #10 Letters) 251
EPA's allocation to "conventional" point sources (mining operations, sewer districts, etc.) and to
"non-coDventional" point sources places unattainable requirements an the conventional sources. Further, the data
used to justify the specific allocations for these non-conventional sources "is laughable when subjected to normal
scientific and statistical criteria."
Response: EPA and DEQ have used the best available information to establish the allocations, recognized the
data limitations that constrain the TMDL calculations. EPA and DEQ note thai affected parties have
had ample opportunity (including a 120-day comment period) to submit additional information to fill
data gaps.
Comment #11 Letter(s) 259
The inclusion of "non-traditional" point sources is a good first step in assessing loadings but EPA and DEQ should
take the next step and devise a strategy to reduce loadings from these point sources.
Response: EPA and DEQ are not prescribing particular technologies in the TMDL, but the agencies agree that
one of the first implementation steps is to evaluate measures that reduce loadings from different types
of sources (inactive adits, waste piles, etc.). Ultimately, the application of specific measures and
technologies to a source is under the responsibility and control of the mine owner or land management
agency.
Comment #12 Letter(s) . 272,274
The method of allocating 25 percent of the load to point sources is without scientific merit.
Response: The use of a 25% gross allocation to discrete sources is a policy decision by the agencies, based on
legal and technical considerations (these are discussed in the TMDL TSD). The allocation method is
not selected on the basis of a scientific determination.
Comment #13 L Letter(s) 272
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Given that the loading from point sources is on the order of 5 percent of the total load to the system (based on
average loads/average discharges), it is unwarranted to place such extreme restrictions cm point sources without
addressing non-point sources and the ability to cost effectively remediate the situation Addressing point sources in
this manner could result in millions of dollars of expenditures for little or no significant improvement in water
quality The low concentrations (based on allocations and flows) at the cnd-of-the-pipe are not consistent with the
25 percent point source allocation. Certain growth allowances merit some consideration, but the 0.5 percent
allocation is overly conservative.
Response: Because of the number of sources and limited data, EPA and DEQ have low confidence in the
estimates of metals contributions from discrete versus nan-discrete sources. Nevertheless, in the
TMDL TSD, EPA made an attempt to develop such estimates far informational purposes. For all
metals and sites, EPA estimates that the individual discrete source contnlxiUons vary widely
depending on the target site and metal under evaluation. At the Pinehurst target site, the discrete
source contributions were estimated at 28% for cadmium and 12% for zinc (lead estimates were highly
variable).
Contrary to the comment, EPA and DEQ have addressed non-point sources by establishing gross
allocations for non-discrete sources (which include nonpoint source tailings in the floodplain) in the
TMDL.
It is not clear to EPA and DEQ how the concentrations associated with the allocations are not
consistent with the 25 percent allocation. Regardless, the TMDL allocates a load and not the
associated concentration.
It is also not clear to EPA and DEQ what is meant by the "0.5 percent allocation".
Comment #14 Letter(s) 272
There is little basis far any of the allocations. More information is needed to fully assess loading from all sources in
the Basin.
Response: EPA and DEQ have set forth in detail the basis for the allocation calculations employed in the TMDL.
The data limitations do not preclude the issuance of a sound TMDL,
Comment #15 Letter(s) 272
The allocation based on flow is not a fair or equitable method of distributing load allocations. No consideration is
given to current concentrations or metal loading and seasonable variability to flows and concentrations.
Incrementally lower removal requirements become extremely expensive. Some consideration should be given to
weighting allocation based on flows, concentrations and seasonal variations for a more equitable allocating method
to point sources.
Response; EPA and DEQ disagree that distributing allocations based on effluent flow is inequitable. It is unclear
to the agencies how the oommenter would factor both flow and current discharge concentrations into
the allocation method. Seasonal variation has been considered and addressed through the use of flow-
ba.sa.1 allocations.
Comment #16 Letter(s) 207
Given Ihe uncertainly of the sources of metals m the upper system, the approach of allocating 25% of the TMDL to
the point sources is understandable. However, there should be much more explanation and verifications using
evaluation of mass loadings to substantiate the assumptions thai lead to these allocations. There should also be some
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recommendations on future information needs to confirm the original assumptions and more explanation into how
allocations between point and non-point sources may change if it is revealed that these assumptions are incorrect
Response; The sheer number of sources (both point and nonpomt), and a lack of data for some sources, inhibits a
detailed characterization of the relative contribution of discrete source loadings to the overall
contamination problem over the full range of conditions As stated in the TMDL Technical Support
Document, EPA and DEQ believe a uniform 25% gross allocation to discrete sources for all metals is
both straightforward and reasonable. EPA and DEQ used Idaho's mixing zone guidelines as a basis to
propose a 25% gross allocation, not an assumption about the current contribution of point sources (see
discussion of method of allocation in the TMDL TSD).
Comment #17 Letter(s) 266
The TMDL asks for comments on "The sufficiency of the wasteload allocations and NPDES permit limits for the
Coeur d'Alene River facilities expressed as monthly average loadings of metal." We would ask why EPA is
choosing this approach when EPA's Technical Support Document for Water Quality-based Toxics Control (1991)
explicitly recommends against this approach, for numerous reasons, at Section 5.3.I? We would again pant out that
if all true point sources were eliminated, the receiving water would still not meet the inappropriate Gold Book
criteria.
Response: EPA continues to support and apply the guidance in the Technical Support Document for Water
Quality-based Control (1991) to individual NPDES permits in Idaho. In the case of the metals
contamination problem in the Coeur d'Alene basin, the TMDL is addressing a large number of point
sources rather than a single source. EPA and DEQ believe that the TMDL margin of safety adequately
addresses the combined variability of multiple discharges, eliminating the need for applying this
portion of the 1991 guidance.
EPA and DEQ agree that eliminating the all discrete point sources would not be sufficient to meet the
Gold Book criteria. However, eliminating all waste piles and nonpoint sources would also not be
sufficient to meet the criteria. This highlights the scale of the metals problem and points to the need to
reduce both discrete and non-discrete loadings in this basin.
Comment #18 Letter(s) 274
The most appropriate method for gross allocation of allowable loads derived from a TMDL is to base these
allocations on the relative existing contributions. The TMDL TSD states that this approach was considered but
rejected because the percentage of contribution from point sources varied substantially between target sites and
metals. In fact, this is the very reason that the gross allocation should be made on a relative contribution basis, for
each watershed (target site) and metal. Region 10's examples of point source contributions (from 7% for cadmium in
Pine Creek to 100% for zinc above Wallace) clearly demonstrate that the gross allocations must be based on
existing loadings of each metal to each watershed. For example, in the stream segment above Wallace the proposed
25%:65% point:non-point source allocations would require point sources to have zinc loading limits that are only
28% of what should be allowed, because the effective margin of safety would be 75% (there are essentially no non-
point source contributions). Conversely, in Pine Creek the non-point sources would be assigned allowable cadmium
loadings that are reduced by 22% because the point source gross allocation is larger than its actual contribution.
The allocation method should not end with the gross allocation between point and non-point sources. The next step
for each stream segment should be to evaluate the technical feasibility of achieving the allocated loadings for each
type of source. If the gross allocation results in unachievable discharge levels, or would require excessively costly
solutions for either point or non-point sources, then the allocation should be reevaluated, considering these
treatability factors to maximize the economic efficiency of the TMDL. A cost-effective approach will require
balancing the required load reductions between point and non-point sources.
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Response EPA and DEQ disagree that gross allocations are more appropriately based on relative existing
contributions from discrete and non-discrete sources. The estimates of relative contribution between
discrete and non-discrete sources are rough estimates based on very limited data, because monitoring
efforts to date have not been designed to determine these relative contributions The estimates were
performed only for average conditions and not the full range of flow conditions. Also, based on
general feasibility considerations, EPA and DEQ are concerned that the relatively low contributions
from discrete sources at some target sites (such as the Pine Geek example cited in the comment) might
result in unachievable discrete source allocations if they were based on the percent contribution.
EPA and DEQ acknowledge that if the estimates for the non-discrete source contributions of zinc at
the Wallace target site reflect actual conditions over the full range of flow conditions (which is highly
uncertain), the gross allocation would be adding to the margin of safely for zinc at that site.
While EPA and DEQ agree that technical feasibility of achieving the allocated loadings is an important
issue (see comments under Feasibility of Allocations), an evaluation of technical feasibility is not
required to establish a TMDL. TMDLs are required to achieve water quality standards. While the
agencies do not have adequate information or resources to evaluate the feasibility of each allocation
and make case-by-case adjustments to the allocations at this time, EPA and DEQ have evaluated the
regulatory relief mechanisms (particularly variances) that may be available to individual sources that
cannot achieve the allocations.
Comment #19 Letters) 266,274
A number of point sources (waste rot* piles, mine adits) will have lew flows during drier months (more akin to
noil-point sources) while other point sources (e.g., mines, mills, sewage treatment plants) will experience a less
significant decrease in flow.
Yet EPA and DEQ have apparently not considered this issue in setting the TMDL. Rather, the agencies have
assumed that during low flow, all point sources and non-point sources will continue to discharge at the same relative
concentrations. EPA and DEQ should revise the TMDL to take into account this potentially significant factor. For
example, point sources could be given a larger WLA during low flow events when non-point source loadings are
small.
Response: EPA recognized in the TMDL TSD that average flowrates do not take into account that individual
sources and source categories likely vary differently with climatic events (and resulting stream flow
variations). In an attempt to correlate individual source types to stream flow, EPA compared data from
NPDES-permitted adit sources with long-term flow measurements to the corresponding stream flow
data for die USGS Station at Elizabeth Park. While EPA observed some increased source flow under
high stream flow conditions, these relationships were not consistent and varied significantly by source.
Similarly, EPA found that flows in the Bunker Hill Kellogg Tunnel and the South Fork Coeur d'Alene
River are poorly correlated (CH2M Hill, 2000). Since source flows do not necessarily correlate to
river flows, EPA has allocated loadings among discrete sources using a single flow ratio (based on
average flow rates) for all river flow tiers
The comment implies that the gross allocation should be adjusted for each flowrate based on the
relative contribution of discrete and non-discrete sources. As described above, EPA and DEQ do not
agree that this is a better method of allocation (See below for a more detailed response to this
comment).
Comment #20 Letter(s) 274
Recognizing that a source may discharge up to the criteria levels without using any of the stream's loading capacity
is important for the TMDL The TMDL already understands this in the case of the municipal dischargers to the
Spokane River. When a discharger is meeting the water quality standard at ihe end-of-pipe, it is neither adding to
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nor taking away any of the stream's loading capacity. The capacity used in such a situation is just equal to the
capacity that is added to the stream by the volume of flow and the hardness of the discharge.
If discharges do not vary in hardness from the hardness used lo determine the wasteload allocations, then the
discharges do not increase the loading capacity of the receiving stream as a result of their hardness. In these
circumstances, a TMDL must allow the discharges 100% of the capacity that they have added by their own flow,
plus some portion of the stream's loading capacity, if any, that is independent of the discharge's additional flow. The
effect of this is to allocate a greater percentage of (he capacity to the point sources during the periods of low stream
flow than at times of higher stream flow. This approach makes sense m view of the dichotomy between point source
discharges during low flow and non-point discharges during high flow that is recognized in the Basin.
Any allocation of loading capacity must fully credit the addition of capacity is a result the addition of flow. Such an
allowance is most significant at times of low stream flow, when non-point contributions are minimal. Hence, the
TMDL should provide higher allocations to point sources when non-point source contributions would be minimal.
Response: As staled above, EPA and DEQ disagree that gross allocations are more appropriately based on
relative existing contributions from discrete and non-discrete sources. The agencies have not
performed a data evaluation (nor has the oommenter supplied one) that supports the stated assumptions
about relative contribution erf discrete and non-discrete sources during different flow regimes.
EPA and DEQ recognize that by adding flow to the receiving water, a wastewater discharge increases
the receiving water's loading capacity (which is equal to flow multiplied by the criterion). However,
there is no requirement in the TMDL regulations that a source must be allocated a minimum loading
equal to the increment of loading capacity added by its flow. In fact, in certain watersheds, it is
reasonable to set an allocation below this amount or even at zero. Far example, a source may be able
to cease discharge during certain times of the year by employing land application cr wastewater
storage.
Comment #21 Lettar(s) 274
The TMDL ignores the dichotomy between point source discharges during low flow and non-point discharges
dunng high flow. In allocating 25% and 65% of the total loading to point sources and non-pant sources,
respectively, EPA assumes that the ratio of point and non-point source contributions remains constant and that the
ratio within the point source category also remains the same. This assumption is unsupported and contrary to EPA's
own guidance, which states: "The design flows under which the TMDL is determined can significantly alter its
value. This phenomenon results in a somewhat unusual dichotomy. The design flow for aquatic life protection most
applicable lo point source loadings (WLAs) usually involve low-flow events (e.g., 7Q10) because the volumes
associated with point sources generally do not decrease with decreased stream flow. As a result, the highest
concentrations associated with specific point source loads would be expected under low flow conditions.
Conversely, elevated non-point source pollutant loadings (i.e., urban, agricultural) generally correspond to storm
events. In fact, agricultural and urban run-off are often minimal or nonexistent in the absence erf precipitation (i.e.,
non-existent under low-flow drought conditions) "
Response: The allocation method is not based on a presumption that the contribution of discrete and non-discrete
sources remain constant, the only presumption is that it is reasonable to apply the same gross
allocation to the full range erf flow conditions in the river. The quoted, general guidance (no citation
was provided) is valid for many pollution problems across the country (e.g., fecal ooliform bacteria
pollution). It is not necessarily valid for the metals contamination in the Coeur d'Alene River basin.
For example, non-point source contributions of dissolved metals from tailings wastes in the bed/banks
of the river do not necessarily correspond to storm events as do urban stonmwater and agricultural
runoff.
Comment #22
Letter(s) 274
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On page 20 of ihe TMDL TSD, EPA and DEQ state lhat "the total loading capacity is calculated by multiplying the
river flow rate by the water quality criterion concentration. . . They make this statement as if this were the only
method for determining the loading capacity when EPA's own guidance states, "The loading capacity of TMDLs
have been determined in many different ways" ITechnical Support Document for Water Quality-Based Toxics
Control at 63 (Mar. 1991)).
EPA's Technical Support Document lists 19 different methods for developing wasteload allocations. M at 69.) EPA
also admits that there may be others. In spite of the many different allocation schemes, Ihe TMDL includes minimal
explanation of why the agencies selected the allocation they did. Indeed, it is not evident whether EPA and DEQ
even considered a number of allocation methods that are applicable to the Coeur d'Alene Basin The lack of
discussion of this issue makes meaningful comment on the proposed method impossible because neither the public
nor the regulated community can respond to EPA's and DEQ's undisclosed decision making. EPA and DEQ should
review the different allocation methods available and select the most appropriate method after giving the public and
regulated community the opportunity to review and comment on it.
Response: EPA and DEQ acknowledge that loading capacity estimates can be performed in a variety of ways. In
particular, the agencies considered the merits of further evaluation and adjustment of the loading
capacity bused co in-stream attenuation (See comments under Attenuation). The approach used to
calculate loading capacity in this TMDL is a straightforward, reasonable approach thai is consistent
with the guidance in the Technical Support Document for Water Quality-Based Toxics Control.
The TMDL TSD acknowledges that there are a plethora of methods for allocating the loading capacity
to sources. EPA included an appendix in the document listing several general methods considered in
developing the TMDL. Additional discussion was provided in the body of die document (e.g., EPA
discussed various alternatives for the gross allocation to discretefacn-discrete sources). EPA and DEQ
specifically solicited comments on the proposed allocation method, and the vast majority of comments
provided meaningful input on the same alternatives EPA identified in the appendix (e.g., methods
based on effluent flow, technical feasibility, effluent trading, etc).
EPA and DEQ have conducted the very process recommended in this comment. The agencies have
reviewed the different allocation methods available and selected the most appropriate method after
giving the public and regulated community the opportunity to review and comment on it.
Comment #23 Letter(s) 270
Insufficient data were used to estimate loading from most of the discrete point sources listed in Table H-I of the
TSD. [Twenty-five of the discrete point sources were sampled only once; another 24 were sampled twice ] Data
obtained from [only] one or two sampling events were used to estimate the loading from three particular sources.
[TJhe use of one or two data points to calculate metal loading is statistically invalid and not sufficient to adequately
calculate point source load contributions. Section 303 of the Clean Water Act specifies that TMDL establishment
shall lake into account seasonal variation .. . one or two samples [could not] adequately represent seasonal variation
as required in the Clean Water Act.
Response: While EPA and DEQ recognize that there are limitations in the available data for discrete sources, the
agencies find no basis in the assertion that the data is insufficient to develop a TMDL. The agencies
also note that no additional source flow data was submitted during the public comment period
Since the TMDL has been changed to replace numeric performance-based allocations with a narrative
requirement (which will allow for further characterization during permitting), loading estimates are no
longer a facior in establishing wastelnad allocations for discrete sources.
Seasonal variation was addressed by establishing flow-based loading capacities and allocations (sue
comments under Flow Tiers)
Comment #24
I>eiter(s) 266
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The TMDL states that one option could include end-of-pipe Gold Book criteria concentrations. The
fishable/swjmmable goal of the CWA is to be met in the nation's waters and not in 100% effluent. EPA cannot
circumvent Congressional intent, ignore economics, and ignore technology cost effectiveness under the guise of
some nonexistent authority of CWA Sec. 303(d).
Response; EPA and DEQ are required under the Clean Water Act to establish allocations in a TMDL sufficient to
achieve the applicable Idaho water quality standards (which are the same as the Gold Book criteria).
Also, there is no statutory or regulatory requirement to consider cost effectiveness or economics in
establishing allocations. While EPA and DEQ considered applying the water quality standard at end-
of-pipe, this was not the selected approach in the proposed or final TMDL.
2.9 Method of Allocation - Spokane River
Comment # 1 Letter(s) 205
The TMDL program, at least as 1 understand it, would result in a limitation on (be metals in the effluent from the
sewage treatment plants of Coeur d'Alene, Haydea Lake, and Post Falls, which would fix the discharges at the
present level, even though the discharges have metals at concentrations lower than the receiving waters of the
Spokane River. This does not appear to be appropriate. This effectively limits or even punishes the cities due to the
historical conduct of other persons (i.e., mining companies).
Response: EPA and DEQ believe that sating the aliocauons at the current discharge level is appropriate. These
concentration-based allocations are not expected to result in capital costs or growth restrictions for the
Spokane River dischargers, provided the facilities continue to manage industries discharging to their
collection systems.
Comment #2 Letter(s) 267
EPA should consider setting effluent concentrations at a level high enough to assure compliance with the standard
and the dischargers' NPDES permit (suggest effluent concentration at 90% of the standard) using the mean
hardness rather than minimum values.
Response: For discharges below the effluent-based criterion, EPA and DEQ believe that setting the allocations at
the current discharge level is appropriate. In calculating the effluent-based criterion, use of the mean
hardness would not be a conservative approach and would not insure that the resulting allocation
achieves the criteria in the effluent/receiving water mixture at all times.
Comment #3 Letters) 267
The effluent-based criteria calculations are unclear and confusing. The document should present the appropriate
translator as well as a detailed explanation showing the method(s) of calculations and the corresponding
assumptions.
Response: EPA referenced the detailed technical analysis in the State of Washington's Spokane River TMDL as
the technical basis of the effluent-based criteria approach. The TMDL includes the equations (from
the Washington analysis) used to calculate the wasteload allocations. The Washington TMDL is part
of the record for this TMDL and is available for review upon request.
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2 10 Legal Issues
Comment # 1
Lelter(s) 266,274
The Clean Water Act does not authorize EPA to list under section 303(d)(1) or establish TMDLs for water bodies
like the Coeur d'Alene Basin that are dominated by non-point sources of pollutants.
Response: EPA disagrees with this comment for the following reasons. EPA's position, articulated below, has
been upheld in the case of Pronsotino v. Marcus. 91 F. Supp.1337 2d (N.D, Ca. 2000).
A. Section 303(d) Clearly Provides that TMDLs Must Account for Nonpoint Sources
1. Congress' Placement of the TMDL Provisions of the 1972 Amendments in Section 303
Demonstrates That TMDLs Are An Integral Part of a Water Quality-Based Approach That by Its
Nature Accounts for All Sources of Pollutants
Section 303 of the Act is entitled: "Water Quality Standards and Implementation Plans." Congress' decision to
place the TMDL-related provisions of the 1972 Amendments in Section 303 plainly demonstrates that Congress
intended TMDLs to be part erf a water quality-based approach that, by its nature, is not limited to particular
sources. As the Ninth Circuit explained, under the water quality-based approach EPA and the States "work
backward from an over polluted body of water and determine which entities were responsible." NRDC, 915 F.2d at
1316. Asa component of the water quality-based approach, the TMDL process must account for both point and
noopotnt sources of pollution. As explained in EPA's Standards Handbook: "The TMDL process is a rational
method for weighing the competing pollution concerns and developing an integrated pollution reduction strategy for
point and nonpoint sources. The TMDL process allows States to take a holistic view of their water quality problems
from the perspective of instream conditions." Numerous courts have examined the language of Section 303(d) and
recognized the integrated characteristics of the TMDL process as part of a water quality-based approach. (13)
As one court within the Ninth Circuit explained:
EPA's regulatory program for water protection focuses on two potential sources of pollution: point
sources and nonpoint sources. Point source pollution was addressed in the 1972 amendments to the
Act, where Congress prohibited the discharge of any pollutant from any pant source into certain
waters unless that discharge complies with the Act's specific requirements. Sees. 301(a) and 502(12),
33 U.S.C. §§ 1311(a) and 1362(12). Under this approklj, compliance is focused on technology-based
controls for limiting the discharge of pollutants through the National Pollution Discharge Elimination
System ("NPDES") permit process.
When these requirements are found insufficient to clean up certain rivers, streams or smaller water
segments, the Act requires use of a water-quality based approach. States are required to identify such
waters and designate them as "water quality limited." The states are then to establish a priority ranking
for these waters, and in accordance with that ranking, to establish more stringent pollution limits called
"total maximum daily loads" or "TMDLs." 33 U.S.C. §§ 1313(d)(1)(A), (€). TMDLs are the greatest
amount of a pollutant the water body can receive daily without violating a state's water quality
standard.
Hie TMDL calculations help ensure that the cumulative impacts of multiple point source discharges are accounted
for, and are evaluated in a injunction with pollution from other nonpoint sources. States are thai required to take
whatever additional cleanup actions are necessary, which can include further controls on both point and nonpoint
pollution sources. As a recent GAO report concluded, the TMDL process:
provides a comprehensive approach to identifying and resolving water pollution problems regardless
of the sources of pollution. If implemented, the TMDL process can provide EPA and the states with a
complete listing of key water pollutants, the source of the pollutants, information on the amount of
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pollutants that need to be reduced, options between point and/or nonpoint approaches, costs to clean
up, and situations where it may not be feasible to meet water quality standards. Alaska Ctr. for the
Env't v Reilly. 762 F Supp 1422, 1424 (W D Wash 1991)()(footnote omitted)
On appeal, the Ninth Circuit recognized this interpretation and explained that
"Congress and the EPA have already determined that establishing TMDLs is an effective tool for
achieving water quality standards in waters imparted by nonpotnt source pollution." Alaska Ctr. for
the Env't v. Browner, 20 F 3d at 985; accord Dioxin, 57 F.3d at 1520 ("[A] TMDL represents the
cumulative total of all... loading attributed to non point sources, natural background sources, and...
the total load allocated to individual point sources.).(14)
2. The Elements of a TMDL Must Account for Loads from Non pant Sources Because Congress
Directed That TMDL Calculations Be Performed For All Waters
In addition to the structure of the Act, Congress' intent that TMDLs account for nonpointsources is clear from its
use of the term "total maximum daily load" in Section 303. It is a maxim of statutory construction "that identical
words used in different parts of the same act are intended to have the same meaning." Commissioner v. Lundy, 516
U.S. 235,250 (1996) (quoting Sullivan v. Stroop, 496 U.S. 478,484 (1990)). Congress used the term "total
maximum daily load" several times throughout Section 303(d). In Section 303(dX1XQ, Congress required "(e)ach
State [to} establish for [listed] waters the total maximum daily load..33 U.S.C, § 1313(d)(1)(C). In
Section 303(d)(3), Congress addressed all remaining waters not on the 303(d) List: "For the specific purpose of
developing information, each Stale shall identify all waters within its boundaries which it has not identified under
paragraph (iXA) and (1KB) of this subsection and estimate far such waters the total maximum daily load "33
U.S.C. § 1313(dX3). When the waters on the 303(d) List are added to the maters identified under subsection (d)(3),
every water in a state is accounted for, and therefore Sections (d)(1) and (d)(3) together require TMDL calculations
for all waters. Given that "all waters" obviously include those impaired by nonpotnt sources, even those impaired
exclusively by acupoint sources, Congress unambiguously intended for "total maximum daily loads* to account for
nonpoint source impairments. Accordingly, TMDLs established under Section 303(dXlXQ, such as the Garcia
River TMDL, must account for nonpoint source impairments
3. Sections 303(d)(1)(C) and 303(d)(2) Require That TMDLs Be Established To Implement the
Applicable Water Quality Standards," Which Is Not Always Possible Without Accounting for
Impairments Caused By Nonpoint Sources
The legislative history to Section 303(d) also plainly supports the notion that TMDLs must account for nonpoint
sources of pollution. In both Sections 303(d)(1)(C) and 303(dX2), Congress expressly stated that "loads" (i.e.,
TMDLs) must be established to implement the applicable water quality standard. Section 303(d)(IXQ provides in
pertinent part:
Each State shall establish for the waters identified in paragraph (1XA) of this subsection, and in
accordance with the priority ranking, the total maximum daily load, for those pollutants which the
Administrator identifies under section 1314(a)(2) of this title as suitable for such calculation. Such
load shall be established at a level necessary to implement the applicable water quality standards with
seasonal variations and a margin of safety which takes into account any lack of knowledge concerning
the relationship between effluent limitations and water quality. 33 U.S.C. § 1313(d)(1)(C).
In addition, Sectim 303(d)(2) states:
If the Administrator [of EPAJ disapproves such identification and load, he shall not later than thirty
days after the date of such disapproval identify such waters in such State and establish such loads for
such waters as he determines necessary to implement the water quality standards applicable to such
waters and upon such identification and establishment the State shall incorporate them into its current
plan under subsection (e) of this section. 33 U.S.C § 1313(d)(2).
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The House Committee Report on the bill that introduced Section 301(d) into the 1972 Amendments plainly states,
however, that point source controls alone are inadequate lo implement applicable water quality standards
Any required more stringent effluent limitations will be set on the basis of that reduction in the
quantity and quality of the discharge of pollutants which would be required to make the total discharge
load in the receiving waters from municipal and industrial sources consistent with water quality
standards This should not be interpreted to mean that such more stringent industrial and municipal
effluent limitations will, in themselves, bring about a meeting of water quality standards for receiving
waters. The Committee clearly recognizes that noil-point sources of pollution are a major contributor
to water quality problems. H.R, Rep, No. 92-911, at 105-06 , Att. 3 at 792-93.
Thus, while in Sections 303(d)(1)(C) and (d)(2) Congress directed that TMDLs must be established to implement
the applicable water quality standard for a water, in the accompanying Committee Report, Congress made plain that
point source controls were inadequate to this task and expressly recognized that "non-point sources of pollution are
a major contributor lo water quality problems "
As Professor Houck ocrrectly explains:
It is logical thai the committee report describes only municipal and industrial sources as needing
additional "emissions limitations" because these are the only sources directly subject to emissions
limitations under the Act. The committee goes on to recognize, however, that water quality standards
were also violated by acupoint sources in a "major" way. This sentence implies the obvious: there is
no way to determine the appropriate contributions from, and limitations on, municipal and industrial
point sources without considering these nonpoint sources as well. How a state would choose to
allocate its limits among point and nonpoint source contributors would, at least in the first instance, be
to states to decide. But the only logical sources were a big fact of life in achieving water quality
standards, mid they would have to be included in the assessments of polluted waters and their TMDL
allocations. Were they not included, a process to ensure that municipal and industrial limits were
"consistent with water quality standards'" would make no sense; it literally could not be done. Oliver
A. Houck, TMDLs: "Hie Resurrection of Water Quality Standards-Based Regulation Undo* the Clean
Water Act, 27 Envtl. L Rep. 10329, 10337 n 100 (1997), Att. 10.
It is dear then that Congress intended TMDLs to account for nonpoint sources.
B. The Structure of the Act and the Plain Language of Section 303(d) Demonstrate That Congress Did
Not Intend to Exclude Waters Impaired by Non point Sources From the Section 303(d) List
Section 303(d)(1)(A) sets forth the criteria for the Section 303(d) List:
Each State shall identify those waters within its boundaries for which the effluent limitations required
by section 1311(b)(1)(A) and section 1311(b)(1)(B) of this title arena stringent enough to implement
any water quality standard applicable to such waters. 33 U.S.C. § 1313(d)(1)(A).
On its face, this provision does not exclude from the 303(d) List waters impaired by nonpoint sources. Any water
(whether impacted by point sources, nonpoint sources, or both) may fail to meet applicable water quality standards
because the effluent limitations identified in Section 303(d)(l )(A) alone are inadequate to the task. Indeed, the
Ninth Circuit already has upheld EPA's interpretation that the effluent limitations referred to in Section
303(d)(1)(A) do not limit listing under Section 303(d) to waters where those controls have been applied and found
not to be stringent enough to achieve water quality standards. In Dioxin, the Ninth Circuit upheld a TMDL for the
Columbia River upon challenge by pulp mills and environmental groups. The pulp mills attempted to persuade the
Court that Section 303(d)(1)(A) had a plain meaning contrary to EPA's interpretation:
The Mills focus particular attention 011 the present tense language of § 1313(d)(1)(A), i.e., "the
effluent limitations of § 1311 are not stringent enough to implement any water quality standard
applicable to such waters..." The Mills argue that the "plain language" of the provision prohibits
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tiPA trom developing TMDLs prior to the proven failure of technology-based limitations. 57 F.3d at
1526,
The Ninth Circuit flatly rejected the Mills' argument because it found that "EPA's interpretation is reasonable and
not contrary to congressional intent." Id. at 1527. The Court held;
[the technology limitations identified in Section 303(d)(1)(A)] are not required by § 1313(d) for dioxin
because the limitations required by the provisions of § 1311, as a matter of law, "are not stringent
enough" to achieve established water quality standards. Nowhere does the Act prohibit the EPA from
listing waters as impaired and implementing TMDLs for toxic pollutants pursuant to § 1313(d). Id. at
1528.
In the same way, nowhere does the Act prohibit EPA from listing waters as impaired and establishing TMDLs for
nonpoint source impaired waters pursuant to Section 303(d). Therefore, as the Ninth Circuit has held, the
application of the technology-based limitations identified in Section 303(d)(1)(A) is nol a condition precedent to
303(d) listing. Like the TMDL at issue in Dioxin, TMDLs for waters with nonpoint sources are not prohibited based
on the absence of applicable technology-based requirements. All that is necessary far 303(d) listing is that the
technology-based limitations identified in Section 303(d) be inadequate to achieve water quality standards. As the
District Court in Dioxin held, those limitations function as a "minimum level" for the 303(d) List.
In addition, the structure of the Act makes clear that waters impacted by nonpoint sources should not be excluded
from the 303(d) List. It is no surprise that Congress chose to condition Section 303(d) listing on the insufficiency of
effluent limitations because the water quality-based approach is to be invoked when the technology-based approach
fails to achieve standards. See NRDC, 915 P.2d at 1317 ("Congress supplemented the "technology-based"
limitations with "water-quality-based" limitations. See CWA §§ 302,303, 33 U.S.C. §§ 1312,1313."). The 303(d)
List therefore identifies the waters where a technology-based approach will not achieve standards and where resort
to a water quality-based approach is necessary, a structure which mirrors the compromise that Congress struck in the
1972 Amendments between the technology-based and water quality-based strategies with passage of Section 303.
The purpose of Section 303 and its place within the Act as part of the source neutral, water quality-based approach
therefore establishes that Congress could not have intended the 303(d) List to exclude nonpoint source impaired
waters.
C. EPA's Interpretation that Congress Intended the Listing of Waters Pursuant to Section 303(d)(1)
Without Regard to the Source of Impairment and Establishment of TMDLs for Those Water Is
Reasonable and Entitled to Deference
As demonstrated above, it is clear from the language, structure, and legislative history of the Act that Congress
plainly intended that TMDL calculations account for nonpoint source contributions and did nol expressly exclude
waters unpaired by nonpoint sources from the Section 303(d) List. Moreover, a restrictive reading of Section 303(d)
is disfavored because the Act is intended to protect public health and safety. In any event, EPA's interpretation that
waters impaired by nonpoint sources can be included on the Section 303(d) List and that TMDL calculations can
account for nonpoint source contributions is entitled to deference because it is based on a reasonable reading of the
language, structure, and legislative history of the Act. Chevron, 467 U.S. at 842-4. According to the Supreme Court,
"[t}he court need not conclude that the agency construction was the only one it permissibly could have adopted to
uphold the construction, or even the reading the court would have reached if the question initially had arisen in a
judicial proceeding." Chevron, 467 U.S. at 843, n. 11. Rather, as the Ninth Circuit stated, "(a) court should accept
the 'reasonable' interpretation of a statute chosen by an administrative agency except when it is clearly contrary to
the intent of Congress" Dioxin, 57 F.3d at 1525(citing Chevron, 467 U.S. at 842-44). Deference to the agency's
interpretation is especially warranted where, as here, the agency charged with administering the CWA is required to
exercise its "ecological judgment" and "technical expertise" about how best to achieve Congress' objectives of
protecting aquatic ecosystems. United States v. Riverside Bayview Homes. Inc., 474 U.S. 121, 134 (1985). Thus,
EPA's interpretation is reasonable and not contrary to Congress' intent
EPA's interpretation of Section 303(d) is entitled to deference because, as explained in detail above, it is consistent
with the structure, language, legislative history, and attainment of the overarching goals of the Clean Water Act
Nonpoint source impaired waters can satisfy the criteria for 303(d) listing (i.e.. the technology-based limitations
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identified in Section 303(d) arc inadequate to achieve water quality standards), and therefore EPA's interpretation
thai such waters can be included on the 303(d) List is reasonable Congress also did not expressly exclude n on point
source contributions from TMDL calculations To the contrary, the language of Section 303(d) demonstrates that
Congress clearly intended that TMDL calculations be performed for all waters, a position that is consistent with the
structure of the Act and the legislative history for Section 303(d). EPA's interpretation also fulfills the goals of the
Act TTie stated objective of the Clean Water Act "is to restore and maintain the chemical, physical, and biological
integrity of the Nation's waters." 33 U.S.C. § 1251(a)(1). The legislative history to Section 303(d) emphasized "that
non-point sources of pollution are a major contributor to water quality problems,", and in hearings leading up to
Section 303(d)'s enactment, the Senate expressed its fear that acupoint sources erf pollution would prevent
attainment of the Act's goal:
One of the most significant aspects of this year's hearings on the pending legislation was the
information presented on the degree to which n on point sources contribute to water pollution.
Agricultural runoff, animal wastes, soil erosion, fertilizers, pesticides and other farm chemicals that
are a part of runoff, construction runoff and siltation from mines and add mine; drainage are major
contributors to the Nation's water pollution problem. Little has been done to control this major source
of pollution.
It has become clearly established that the waters of the Nation cannot be restored and their quality
maintained unless the very complex and difficult problem of nonpoint sources is addressed. S. Rep.
No. 92-414, at 39 (1971), repnnted in 1972 USCCAN 3668, 3705.
Thus, Congress recognized that the primary goals and objectives of the CWA cannot be realized without an
effective means to identify and address nonpoint sources of pollution. When viewed in this light, EPA's
interpretation that waters impaired by nonpoint sources can be included on the Section 303(d) List and that TMDL
calculations can account for nonpoint source contributions is not only reasonable, it is necessary to achieve the
stated objectives of the Act.
DEQ is also acting pursuant to state water quality law, Idaho Code section 39-3601 et.seq.. State law clearly
requires TMDLs address both pant and nonpoint sources of pollutants.
Comment #2
Letter(s) 274
EPA does not have authority to issue a TMDL for waters within the boundaries of the Coeur d'Alene Reservation.
Response: EPA disagrees. EPA is using its discretionary authority under section 303(d) to issue TMDLs m
Indian country where no tribe has been authorized and where EPA has not found a state to have
demonstrated jurisdiction to issue TMDLs. A portion of Lake Coeur d'Alene and the St. Joe River
have been determined to lie within the boundaries of the Coeur d'Alene Indian Reservation. See
United State of America et. al. v. State of Idaho. 210 F 3d. 1067 (9* Ctr., 2000). Under the authority
of CWA section 518(e), EPA may approve tribes to carry out the responsibilities erf CWA section 303.
However, at this time, the Coeur d'Alene Tribe has not been approved to exercise this authority.
Therefore, to the extent that the above mentioned waterbodies lie within reservation boundaries. EPA.
rather than the State of Idaho, has the authority to develop TMDLs for those waters. It is
acknowledged that ownership and jurisdiction over portions of the submerged lands underlying waters
covered by this basin-wide TMDL are contested between the State of Idaho, United States and/or
Coeur d'Alene Tribe. This TMDL is not intended as a waiver or admission of ownership or
jurisdiction regarding the contested submerged lands by any of those parties. EPA has coordinated
with the Coeur d'Alene tribe in developing the TMDL
EPA's discretionary authority derives from the CWA and its overall scheme and purposes The main
objective of the CWA is to restore and maintain the chemical, physical, and biological integrity of the
nation's waters. 33 U.S.C. § 1251(a). Congress intended TMDLs to play an important role in
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achieving this objective- See 33 U S C. § 1313(d) (imposing short deadlines for state and EPA
action) Thus, while states have primary responsibility for many CWA programs, see 33 U.S.C. §
1251(b), including the TMDL program, it would be anomalous and contrary to the objectives of the
CWA if stales could stymie the implementation of section 303(d) simply by refusing to submit TMDLs
as required by Congress E g . Scott v. City of Hammond. 741 F 2d 992,997 (7th Cir. 1984) (stating
that the court did not believe that Congress could have intended to allow the states lo prevent the
implementation of TMDLs through inaction); Alaska Center. 762 F. Supp. at 1428 (same); ACA II at
628 (same).').
Similarly, EPA believes that Congress would not have left EPA powerless to act where tribes chose
not to apply for authorization and issue TMDLs. In this instance, the Coeur d'Aleoe tribe has not
submitted TMDLs for the portioo of Lake Coeur d'Alene and the St. Joe River that are within Indian
Country. In view of Congress's push for state action, the TMDLs* place in the statutory scheme, and
Idaho's schedule for developing TMDLs for the state Coeur d'Alene basin waters, EPA believes it is
reasonable and necessary for EPA lo step in to develop the complementary TMDLs for the portions of
the waters that are within Indian Country. Indeed, it weuld frustrate the purposes of the CWA if EPA
lacked authority to do anything but sit idly by. Section 303(d) does not explicitly address this
situation. Therefore, in order to fill the gap left by Congress, EPA has determined that it possesses
authority to develop TMDLs in these circumstances where necessary to enable the agency to fulfill its
statutory responsibility to administer the CWA.
In developing this basin wide TMDL, EPA has utilized federally recommended "Gold Book." water
quality catena for those waters within Indian Country. EPA also considered the water quality
standards of the downstream jurisdiction (Idaho) at the border. Those water quality standards are
identical to EPA's Gold Book water quality criteria guidance. This approach ensures consistency
within the basin and assures that the standards of the downstream state waters of Idaho and
Washington will be met.
Comment #3 Letters) 266,274
EPA and DEQ cannot establish TMDLs for water bodies that are not included in Idaho's section 303(d) lists and
cannot impose requirements on sources discharging into segments that are not on the section 303(d) list-
Response: EPA has developed TMDL for the Coeur d'Alene Basin lo address water quality impairments in 28
water bodies that appear on Idaho's 1998 section 303(d) list for metals. The TMDL thus directly
relates to the listed waters and the causes of impairment in those waters. Therefore, the commenter's
threshold assumption is incorrect.
Specifically, the TMDL is established using nine target sites. With the exception of two target sites,
each target site is located on a segment listed on the current Idaho 303(d) list. The two target sites on
unlisted waters (North Fork of the Coeur d'Alene River and St. Joe River) are established only for
tracking purposes and allocation of loading capacity through the river network. That EPA and DEQ
are not establishing TMDLs on these two unlisted waters is evidenced by the absence of any
allocations for sources on these waters. .
To achieve water quality standards, the TMDL must address all sources of dissolved metals to waters
at a given target site. In the South Fork and tributaries, the loading capacity at each target site is
allocated to all identified sources of dissolved metals that are upgradient from the target site. Thus,
while the TMDL addresses impairment on listed waters, the allocations includes sources in upstream
watersheds that are tributary to the listed waterbody Some of these smaller, upstream watersheds are
not on the 303(d) list (Note thai omissions in the 303(d) list are to be expected in this case, because the
- This understanding of congressional intent prompted these courts to find a nondiscretionary duty for EPA to
act; at a minimum, it implies that HPA has authority to act
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contamination extends across a lage geographic area and water quality monitoring is extending to more
remote tributaries over time. See also discussion in TMDL TSD on scope of the TMDL).
Nevtrtheless, sources m these watersheds discharge dissolve 1 metals to the upstream watershed, and
the stream network then transports the meals downstream 10 he waters at the t:irget site location. For
example, the Star 1200 adit discharges dissolved metals to Grouse Creek, a tributary to the South Fork
above Wallace that is not yet included on the Idaho 303(d) list. Grouse Creek flows into the South
Fork upstream from the Wallace target site. Since the metals from the Star adit ultimately reach the
Wallace target site, this adit is included in the wasteload allocations for that target site, even though the
creek immediately adjacent to the adit portal is not alisted water body.
It is neither practical nor equitable to limit TMDL allocations only to those sources that discharge
directly into 303(d) listed waters. Prom a practical standpoint, the agency issuing the TMDL may have
a wide range of information sources for waters and sources in a given watershed. From a facility
inspection, for example, the ageocy collect information dearly identifying a major source of pollutants
to a downstream 303(d)-listed water body. But the same agency may not have information for the
waterbody to which the source discharges for inclusion on the 303(d) list. It would be inappropriate
and contrary to the goals of the Clean Water Act to either ignore this source in a TMDL for the
downstream water or delay action until samples of the waterbody adjacent to the source could be
collected for 303(d) list administration.
In terms of equity, if the agency failed to consider and subsequently control this upstream source in the
TMDL allocations, its unregulated discharges could severely (and unfairly) impact allocations for
downstream sources. In order to establish an equitable and effective TMDL, all known sources
contributing loadings to the impaired water must be addressed in the TMDL allocations.
Idaho and EPA are authorized to adopt this approach because of the requirement in section
303(dXl)(C) that TMDLs be established at levels necessary to implement applicable water quality
standards. Absent controls on upstream sources, EPA would lack the assurance that the TMDL for
downstream waters would result in the attainment erf* water quality standards. EPA also notes that the
comment cites the deciston in NRDCv Pox. 30 F. Supp. 2d 369 (S.D.N. Y. 1998). The question
presented there was whether EPA had a duty to approve or disapprove TMDLs for waters on the
state's § 303(d) list. Notwithstanding the commenter's assertions to the contrary, the court's holding
that EPA does indeed have such a duty is irrelevant to the issue presented here i.e., whether a TMDL
may assign wasteload allocations to sources that discharge to waters within the jurisdiction of the
TMDL authority but that do not appear on the relevant § 303(d) list. As discussed above, EPA has
such authority undo- section 303(d)(1)(C), and nothing in the Fox decision undercuts it.
Comment #4
Letter(s) 266,272,274
Idaho Code Section 39-3611 limits controls on point sources in this TMDL.
Response: The limitations on point source controls in 39-3611 are not applicable under either state or federal
law to the TMDL for the South Fork Coeur d'Alene River for the following reasons.
Under State law, Idaho Code section 39-3611 applies to water bodies where the applicable water
quality standard has not been met due to impacts that occurred prior to 1972. While there were
significant impacts to the SFCDA river that occurred prior to 1972, there are also continuing and
post-1972 discharges that have contributed and continue to cot tribute to the nonattainment of
state water quality standards in the Coeur d'Alene basin.
Application of section 39-3611 to the Coeur d'Alene TMDL would not comply with the CWA,
because even if the point source contribution of metals is less than 25% of the total load. the load
contributed by point sources alone exceeds the loading capacity of the South Fork Coeur d'Alene
river by a considerable amount Therefore, if the TMDL could not assure reductions in current
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loadings from the point sources (reflected as restrictive wasteload allocations), the TMDL could
not assure compliance with state water quality standards and would not comply with the
requirements of section 303(d) of the CWA.
Furthermore,, if as a result of the application of 39-3611, the allocations in the TMDL did not
assure that the NFDES permit limitations would comply with the state's water quality standards,
EPA has an independent obligation under section 301(bXlXQ of the Clean Water Act to do so.
The effluent limitation in NPDES permits must be sufficiently stringent so as lo comply with
state water quality standards if a discharge would be likely to cause or contribute to an exceedence
of the state's WQS,
Finally, although this TMDL is being issued by the State of Idaho as to state waters, should it be
determined that the stale of Idaho cannot .under section 39-3611, issue a TMDL as to those waters
that complies with the CWA, then EPA will, in the alternative, immediately issue the TMDL for
the entire Coeur d'Alene river basin under its authority in section 303(d) of the CWA,
Comment #5 Letter(s) 266
The proposed TMDL is a "joint" EPA/DEQ action and therefore Idaho law cannot be ignored. Idaho law at IC 39-
3611 clearly spells out statutory limitaiirws en DEQ actions and authorities pursuant to TMDL development.
Pertinent sections of IC 39-3611 have not been met.
Response: Idaho Code section 39-3611 provides thai TMDLs must be developed in accordance with the
CWA and must include certain elements. EPA and DEQ believe the TMDL meets the
requirements of the CWA and includes each of the dements identified in 39-3611. Hie TMDL
identifies the pollutants, provides an inventory of sources of pollutants, a discussion of the
implementation of the TMDL, including control strategies, and a future evaluation process. In
addition, as provided in the TMDL Schedule for the state of Idaho, Idaho is preparing an
implementation plan that addresses some of these elements in more detail following the approval
of this TMDL.
Comment #6 Letter(s) 266,272,274
Adits, waste rock piles, and other potential sources of metals are not "point sources" if there is no discernible
discharge to surface waters.
Response: The commenter's assertion would be correct if there was proof that no pathway existed between
adit discharges and adjacent receiving waters. This is not the case. EPA's statement in the Draft
TMDL TSD should not be construed as a statement that discharge pathways from all adit portals
to adjacent receiving waters are non-existent. In fact, numerous adits are known to discharge
directly lo an adjacent stream.
Some adits, however, are located m remote areas. They have been sampled at the adit portal but
have not been surveyed in detail to chart the pathway to the adjacent stream. Potential pathways
could include direct piped-discharge to the stream, overland flow to the stream, and seepage into
the groundwater. Since groundwater is known to deliver metals to the adjacent stream, it is
reasonable to assume that there is a hydraulic connection between the visible expressions of flow
from an adit and the adjacent, down gradient stream. While some attenuation could occur between
the adit and the receiving water, it is reasonable to assume that some fraction 'of the dissolved
metals m any adit discharge will reach the adjacent stream. Thus, in the absence of evidence to
the contrary, adits are assumed to be sources of dissolved cadmium, lead, and zinc to the receiving
water. Since they are point sources (via a direct discharge or indirect hydraulic connection to the
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receiving water), it is reasonable and appropriate to assign them wasteload allocations in the
TMDL.
The commenter has not provided any additional information about particular adits, nor has the
commenter demonstrated that there is no hydraulic connection between a particular adit and the
receiving water. Therefore, EPA and DEQ have no basis to eliminate adits that were assigned
wasteload allocations in the draft TMDL.
Comment #7 Letter(s) 266,274
Waste piles are not point sources. Runoff, if any, from such piles should be considered n on point source discharges
Response: The treatment of discrete waste piles as point sources has been upheld in a number of mining
cases. These cases have found that the definition of point source is broad and encompasses runoff
from mining waste rock piles including runoff which enters surface waters , directly or indirectly
through a ground water connection. The court in Earth Sciences found that "Even though runoff
may be caused by rainfall or snowmelt, percolating through a pond or refuse pile, the discharge is
from a pant source because the pond or pile acts to collect and channel contaminated water".
U.S. v. Earth Sciences. Inc. 599F2d 36E, 374 (10th Cir. 1979). See also Trustees for Alaska 749
F2d 549(9th Cir. 1984); Siena Club v. Abston Construction Co.. 620 F2d41 (5* Cir. 1980),
Consolidated Coal Co. v. Costle. 604 F.2d 239,249 (4th Cir. 1979) (point sources include slurry
ponds, tfrainage ponds, and coal refuse piles), Washington Wilderness Coalition v. Hecla Mining
a, 870 F. Supp. 983 (E D. Wash 1994).
Comment #8 Letter(s) 266
The section 303(d) list applies only to waters impaired by point soiree discharges operating under the technology-
based effluent limitations of CWA section 301. It does not apply to waters impaired by nonpoint sources.
Response: For a discussion of the applicability of section 303(d){ 1XA) to waters unpaired by nonpoint
sources, see Response to Comment A (ASARCO II B.l) With respect to the commenter's
assertion that the § 303(d) list applies only to pant sources operating under technology-based
effluent limitations of CWA section 301, see Dioxin/Qrganochlorine Cento- v. Clarke. 57 F.3d
1517 (9* Cir. 1995). In that case, the Ninth Circuit held that EPA has the authority to develop
TMDLs for pollutants (toxics, in that case) even before technology-based effluent limitations for
those pollutants a* sources have been developed and implemented. Id. at 1527. The court found
that EPA's interpretation was reasonable and was supported by legislative history for the Clean
Water Act, as well as its overarching purposes.
The commenter also relies on the term "effluent limitations" and the scope of nonpoint source
programs under CWA section 319 to support its position. EPA believes this view is not supported
by the statute or the legislative history. (The oommenter's view was also rejected by the court in
the Pronsolino case) First, the commenter's reliance on Section 319 to interpret the scope of
Section 303(d) is misplaced. The commenter argues that EPA should ascertain Congress' intent in
passing Section 303(d) by looking to Section 319, a section of the Act that was passed 15 years
later. As the Supreme Court has emphasized, however, it is a peculiar form of statutory
interpretation that looks to the views of a subsequent Congress to determine what the earlier one
intended, "The will of a later Congress that a law enacted by an earlier Congress should bear a
particular meaning is of no effect whatever The Constitution puts Congress in the business of
writing new laws, not interpreting old ones. [LJater-enacted laws do not declare the meaning
of earlier law.'" United States v. Estate of Romani, 523 U S. 517, 536 (Scalia, J concurring in part
and concurring m the judgment) (quoting Almendarez-TorreK v United States, 523 U.S. 224, 237
(1998)); see also O'Gilvie v. United Stales. 519 li S 79. 90 (1996). citing United States v. Price,
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361 U S 304, 313 (i960), Higgins v. Smth. 308 U S. 473, 479-80 (l940K"[T]he view of a later
Congress cannot control the interpretation of an earlier enacted statute ") (23) Therefore, to
determine Congress' intent in passing Section 303(d), the Court should look to the intent of the
92nd Congress that passed Section 3G3(d)(!)-(3), and not to the intent of the 100th Congress that
passed Section 319.
The commenter also contends that Congress' use of the terns "effluent limitations," and "daily
load" in "total maximum daily load," plainly limit the application of Section 303(d) to point
sources. Not oily does the commenter misconstrue the Act, its "plain language" argument is
undermined by the fact that numerous courts, including the Ninth Circuit, have read the terms
"effluent limitations" and "daily load" m Section 303(d) and consistently reached a conclusion
exactly opposite to the one the commenter urges EPA to accept. Under such circumstances, it is
hard to imagine that the Act in fact has the plain and obvious meaning on its face that the
commenter advances. Specifically, the commenter argues that the appearance of the term
"effluent limitations" in Section 303(d)(1)(A), which addresses the 303(d) List, and in Section
303(d)(1)(C), which addresses TMDL establishment, demonstrates thai Section 303(d) applies
only to point sources. This view is in error because it fails to take into account the purpose of
SectioQ 303, and makes the applicability or proven failure of the technology-based limitations
identified in Section 303(d) to point sources a condition precedent to 303(d) listing - neither of
which Congress intended.
As explained above. Congress* decision to include on the 303(d) list waterbodies where effluent
limitations are not stringent enough to implement water quality standards reflects the approach
adopted in the 1972 Amendments that effluent limitations occupy the first line of attack in
cleaning up the Nation's waters, and when that effort is inadequate the State must turn to the
safety net of a water quality-based approach. Given that it is the insufficiency of technology-based
effluent limitations that triggers the need for a TMDL, it is hardly surprising to find a reference to
"effluent limitations'in the listing provision in Section 303(d). Moreover, as explained supra, the
Ninth Circuit has held that the applicability or proven failure of the technology-based limitations
identified in Section 303(d) is not a condition precedent to 303(d) listing. See Dioun, 57 F,3d at
1527-28. Contrary to the commeater's contention that the effluent limitations identified in Section
303(d)(1)(A) limit listing under Section 303(d) to waters where controls are subject to those
effluent limitations, by its plain terms, all that Section 303(d)(1)(A) requires for listing is that the
technology-based limitations identified in Section 303(d) be inadequate to achieve water quality
standards. Id, see discussion supra.
Comment #9 Letter(s) 266
The TMDL is unlawful because it does not based on "applicable" water quality standards, but rather on water
quality standards unlawfully approved by EPA in 1997.
Response; The CDA TMDL is based on the water quality standards applicable under the CWA. EPA's
promulgation of the cold water biota use for specific waterbodies in the Coeur d'Alene basin was
upheld by the court in IdAhn Mining Association v. Browner 90 F. Supp.241078, (D.Idaho,
2000). This promulgation included the South Fork of the Coeur d'Alene River and Canyon
Creek. The court vacated the rule only as to Shields Gulch and remanded that portion of the rule
to EPA for further consideration The status of Shields Gulch has no impact on the calculations
and allocations m the TMDL (see also discussion above regarding sources located upgradient
from a target site).
Comment #10 Letter(s) 266
EPA has failed to comply with the requirements of CWA section 304(a)(2)(D) to identify pollutants suitable for
TMDL calculation.
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Response
The commenter disagrees with EPA's decision in 1978 that all pollutants are suitable for TMDL
development. The issue is outstde the scope of this TMDL, and the commenter does not explain
how it has any bearing on a TMDL developed for metals
Comment# 11 Letter(s) 266
EPA lacks the authority to prohibit development in a watershed, accomplished by developing a TMDL that does not
allow any new permits in the watershed in question (where the allocation is "used up"). This contravenes section
101(b), which accords to States the sole authority to plan the development and use of land and water resources.
Response: This TMDL contains no blanket prohibition on new permits as implied in the comment. In
response to comments, the final TMDL has been revised to include a process for allowing new or
expanded discharges cadmium, lead, and zinc.
The State of Idaho is issuing this TMDL. Therefore, the comment that EPA is contravening the
State's authorities under section 101(b) is not pertinent to this TMDL.
As required by section 303(d) and EPA's implementing regulations, TMDLs develop allocations
sufficient to meet applicable water quality standards. The water quality-based effluent limits in
NPDES permits, in turn, must be consistent with any wasteload allocation in an applicable
TMDL. See 40 C.F.R. § l22.44(dXlXvii)(B). Section 301(a) of the CWA prohibits the
discharge of any pollutant to a water of the United States except in compliance with an NDPES
permit or similar permit or license. Section 301(b) then requires point source discharges to
achieve water quality-based effluent limitations. Depending on the circumstances in the
watershed, TMDL and NPDES requirements can have an effect on development patterns in a
community
Comment #12 Letter(s) 266
The commenter asserts that the proposed TMDL is incomplete because it does not account for all point and
n on point sources and does not allocate a load to each source.
Response: EPA has the legal authority to assign allocations in a reasonable manner, so long as the sum of
the allocations is equal to or less than the loading capacity of the receiving water (and allows for a
margin erf safety). In addition, with respect to nonpoint sources, EPA's regulations provide that
load allocations "are best estimates erf" the loading, which may range from reasonably accurate
estimates to gross allotments, depending on the availability of data and appropriate techniques for
predicting the loading." 40C.F.R. § 130 2(g).
The TMDL identifies all the source categories in the basin and allocated gross loadings to these
categories. Then the TMDL assigns individual wasteload allocations to those point sources for
which the EPA and DEQ have sufficient information in order to develop an equitable allocation
scheme. Allocation among the large number of non-discrete source areas will require additional
data and technical analysts.EPA and the state will be able to establish additional individual source
allocations, if necessary, as the Superfund RJ/PS process is completed.
Comment# 13 Letter(s) 266
The proposed TMDL alludes to some uncited statutory authority that requires a TMDL to meet downstream
standards including those in other states. We cannot find any statutory authority to support this position. Please
specifically cite the authority under the CWA for this position.
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Response: It is unnecessary to reach the question whether the Coeur d'Alene TMDL is"required" to meet
downstream water quality standards, including those in other stales. As a factual matter, the
Coeur d'Alene TMDL is calculated at levels to meet applicable water quality standards for Idaho
for the metals at issue The TMDL was not adjusted to reflect any other jurisdiction's water
quality standards. As it happens, however, the TMDL as calculated will also assure that
Washington's water quality standards are met at the border, because (1) Coeur d'Alene River and
tributary allocations will achieve Idaho standards in Lake Coeur d'Alene and its outlet (Spokane
River ongin) with a margin of safety, (2) allocations for municipal sources on the Idaho portion of
the Spokane River are set at protective levels, and (3) Washington's water quality standards for
the three metals are identical to Idaho's standards (except for minor differences in hanfriess
assumptions), While EPA and DEQ have referred to the Washington standards for the Spokane
River in the TMDL TSD, these references are provided for informational purposes only and do
not affect the calculated TMDL
Comment # 14 Letter (s) 266
Hie oommeoter asserts that EPA acted improperly in indicating to Idaho that it would not approve a TMDL based
on site-specific criteria as the applicable water quality standards while Idaho was subject to the National Toxics
Rule.
Response: The State of Idaho has adopted the EPA "Gold Book" criteria as part erf its standards, and it is
these criteria that were used as the basis for the final TMDL. Idaho was removed from the
National Toxics Rule in April, 2000, and issues regarding the Rule and its application are no
longer relevant to the final TMDL. The status of SSC and the potential impact of SSC on the
TMDL are discussed in the Regulatory Option section of the Response to Comments.
Comment# 15 Letter(s) 266
The oommanter disputes the assertion in the proposed TMDL that water quality standards are adopted by states to
maintain and restore the nation's waters for beneficial uses, such as drinking, swimming and fishing. The
commenter asserts that this goal of the act applies only where attainable.
Response: EPA's water quality standards regulations authorize stales to adopt water quality standards that do
not protect the Tishable/swimmable" goals of the Clean Water Ad when the state demonstrates
that those uses are not attainable. See 40 C.F.R. § 131.10(g). By allowing states to develop such
use attainability analyses to justify not protecting 'Tishable/swimmable" uses, EPA acts
consistently with section 101(a)(2), which established such uses as the national goal "wherever
attainable.". See Idaho Mining Association v.Browner. 90 F. Supp. 2d 1078 (D. Idaho, 2000).
Comment # 16 Letters) 266
The commenter asserts that the proposed TMDL incorrectly characterizes water quality standards as including an
"anti-degradation requirement" and asserts that EPA's regulations at 40 C.F.R. § 131.3(i) do not include
antidegradation policies as a component of water quality standards. Finally, the commenter describes
antidegradation policies as '"nothing more than guidance on the implementation of water quality standards and
cannot be portrayed as an enforceable component of a 'water quality standard.'"
Response: EPA disagrees Under CWA sections 303 and 304(d)(4)(B), EPA's regulations, and as
recognized by the Supreme Court and many other courts, water quality standards contain three
components: (1) use designations consistent with sections 101(a)(2), (2) 303(c)(2) of the Act,
water quality criteria to support those uses, and (3) an antidegradation policy consistent with 40
CFR § 131,12, See 40 CFR § 131 6 (Minimum requirements for water quality standards
submission ): PUD No, I of Jefferson County v Washington Department of Ecology. 511 U.S.
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700, 704 (1994); See also. National Wildlife Federation v. Browner. 127 F.3d 1126, 1127 (D.C
Cir 1997); Natural Resources Defense Council. Inc. v. U.S. EPA, 16 F.3d 1395, 1400 (4* Cir.
1993V. Manasnta-88. Inc. v. Tidwell. 8% F2d 1318 1320 (11* Cir. 1090); American Paper
Institute. Inc. v U.S. EPA. 890 F 2d 869, 871 (7* Cir 1989).
Comment# 17 Letter(s) 266
The commenter argues that the TMDL's consideration of historic impacts amounts to improper retroactive
application of the Clean Water Act. The commenter says that there is nothing in the law or legislative history
indicating Congressional intent to punish current point source discharges for historic activities.
Response: Section 303(d) of the Clean Water Act requires the establishment of TMDLs at levels necessary to
achieve applicable water quality standards. EPA's regulations at 40 C.FR. f 131.10(g) establish
procedures whereby states can elect not to designate a receiving water for fishaWe/swimmaWe
uses if it can show that those uses are not attainable. Listed among the reasons that attaining a use
might not be feasible is the presence of naturally occurring pollutant concentrations that prevent
the attainment of the use. See 40 C.F.R. § 131 lOCgXD Also included are human-caused
conditions or sources of pollution that cannot be remedied or would cause more environmental
damage to correct than to leave in place. See 40 C.F.R. § 131.tO(gX3). With proper showings, a
state may be able to change the designated uses for a water body based on cue or more of these
conditions. If it does so, the water quality standard - and the target for the TTMDL - would
change accordingly. In any case, as noted above, the TMDL works toward achievement of the
applicable water quality standard. First, the TMDL must ascertain the water's loading capacity,
which is the greatest amount of loading that a water can receive without violating water quality
standards See 40 C.F.R. § 130.2(f). Next, the TMDL allocates that load among point and
nonpotnl scwrces. Ncnpoinl scwrces may include sources of pollution (such as contaminated
sediments) that resulted from past human activity. If the acupoint sources consume the loading
capacity, there is proportionally less loading capacity (eft over for point source wasteload
allocations. See 40 C.F R. § 130.2(h). In this sense, the TMDL takes the receiving water as it
finds it, which may include historical and ongoing pollutant releases. This may mean that there is
limited loading available for point sources that come later in time, but this is simply a result of the
statutory requirement that the TMDL must be established at levels necessary to achieve applicable
water quality standards.
Comment # 18 Letter(s) 266
The commenter asserts that the Clean Water Act does not authorize Slates or EPA to list waters "believed to be
unpaired."
Response: This comment is outside the scope of this TMDL. The commenter appears to argue that certain
waters should not be included in Idaho's section 303(d) list. Any such argument should be raised
in the context of a challenge to that list, not to the development erf a TMDL. As one court has
noted, EPA must approve or disapprove TMDLs submitted for waters identified on a state's §
303(d) list without inquiring whether different listed waters deserve different treatment. See
NRDC v. Fox, slip op. at 55, 94 Civ 8424 (PKL) (S D N Y. May 2, 2000). In any case, there is
ample data in the record for the listing decisions that the contested waters are indeed impaired.
Comment# 19 Letter(s) " 266
The TMDL stales that [EPAJ has "not issued final guidance or regulations on acceptable trading mechanisms" for
"effluent trading." There is no authority under the CWA for this activity because Congress did noi intend for CWA
Sec. 303(d) to result in such an outcome
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Response. EPA disagrees that it lacks authority under the CWA to promote trading through TMDLs For
example, EPA noted as long ago as 1985 in one of us earliest versions of the TMDL regulations
that the TMDL process can provide for poini/nonpoint source tradeoffs, e g . tn situations where
controls on nonpoint sources might allow for less stringent wasteload allocations than might
otherwise be established. See 40 C.F.R.§ 130 2(i). 50 Fed. Reg. 1774, 1780 (Jan, II, 1985).
3.0 Implementation Issues
3.1 Feasibility of Allocations
Comment #1 Letter(s) 266
It is clear that a particular treatment technology, similar to that utilized by Red Dog, is being prescribed in the
TMDL. Will permits be issued that require monitoring and reporting only if the specified technology is installed?
Also, the TMDL states that "operating mines have options for implementing tailings decant recycling and other
water management measures to reduce effluent flow and thereby increase allowable effluent concentrations." The
CWA does not provide options for EPA to dictate technology.
EPA's own treatability manuals describe a range of effluent quality for a given pollutant under certain treatment
technologies and further that a well-maintained and operated wastewater treatment facility could be expected to
operate within these ranges 95% of the time. The resultant permit limits would require 100% compliance, thus
subjecting the facility to fines and penalties under the CWA. Do the agencies expect the mining industry to install a
treatment technology that cannot guarantee 100% compliance with permit limitations, thus exposing the permittee to
potential fines and penalties?
Response: EPA and DEQ are not dictating the use of a particular treatment technology or water management
system in the TMDL. Far the South Fork Coeur d'Alene River and trihitanes, the TMDL establishes
wasteload allocations in terms of lbs/day of metal discharged.
Anticipating concerns over the feasiblity of the allocations, EPA cited an example of technology
available to mining facilities to achieve metals concentrations in the range of those required in the
TMDL. EPA also noted the potential for reducing effluent flows by recycling or other water
management measures These examples should not be construed as regulatory requirements to employ
a particular technology. The specific measures and technologies employed by a facility are under the
responsibility and control of the facility.
In accordance with the NPDES regulations, EPA must establish permit limitations necessary to
achieve technology-based requirements and Idaho state water quality standards. NPDES permits
establish the limits on a discharge. Like the TMDL, they do not dictate the technology to be employed
at the facility It is the permittee's responsibility to lake the necessary steps to comply with its permit
(including selection and installation of pollution control technologies). The commenter is correct that
violation of permit conditions can result in monetary penalties. EPA treatability evaluations are one of
many sources of information available to permit applicants regarding performance of treatment
technologies.
Comment #2 Letters) 266,270,023
Discharge values reported by "the Red Dog facility are average discharge concentrations ... To avoid permit
non-compliance, water treatment goals would need to be based on the 98th or 99th percentile concentration, NOT
the 50th percentile . , [Therefore,! the Red Dog treatment levels are {not] "similar" to those levels proposed in the
TMDL and . , it is [inappropriate to compare "average" water treatment concentrations to proposed TMDL
concentrations and subsequent NPDES permit limits A more appropriate approach would be to compare Red Dog's
99th percentile waier treatment performance to TMDL and NPDES permit concentrations ..."
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Response: A detailed comparison lietween performance ai Red Dog and requirements of the TMDL for ihe Coeur
d'Alene mines is not possible, because EPA and DEQ do not have adequate information about the
flow reduction opportunities at operating rranes in the Coeur d'Alene basin to calculate the necessary
end-of-pipe concentrations for these facilities with certainty. In this context, EPA and DEQ believe U
is reasonable to use average performance at the Red Dog facility for the purpose of making a general
comparison to the TMDL requirements.
Comment #3 LeUer(s) 52,67,266, W21
The largest discharge in the South Fork is from the Bunker Hill treatment plant A study concluded by CH2M Hill
on 1/99 for Ihe EPA Region 10 Bunker Hill Mine Water Presumptive Remedy revealed if a zero discharge treatment
plant was constructed, it would cost taxpayers over $70,000,000 to build and $7,000,000 per year to operate.
If CH2M Hill is correct in its opinion that evaporation may be the only means of meeting the proposed TMDL
limits, then the allocations are infeasible.
If the EPA cannot meet the TMDLs at the Bunker Hill facility, then why should the mines in the Silver Valley be
held to a standard that is unattainable?
Response: As noted in the discussion of the latest information from the Bunker Hill project (see TMDL TSD and
Appendices), EPA and DEQ believe an upgraded Bunker Hill Central Treatment Plant will achieve the
TMDL allocations.
The cited report was a preliminary study containing a full range of alternatives for improving the
wastewater treatment performance at the Central Treatment Rant (which treats the Kellogg Tunnel
drainage). The report was prepared prior to treatability testing of any of the alternatives. The cited
cost figures wore associated with the worst-case scenario of building a plant that evaporates the water
and discharges only distilled water (zero discharge of metals). EPA does not believe this type of
facility is necessary to meet the TMDL wasteload allocations. For this reason, no further evaluation
of the evaporation alternative was undertaken Rather, further evaluation has focused on commonly
used metals precipitation technologies and upgrading the existing Central Treatment Plant.
Comment #4 Letter(s) 274
The agencies should require no more than "reasonable reductions" from the existing sources, and not the extreme
reductions the TMDL now proposes. On this point, the federal advisory committee wrote, "The Committee
recommends that reasonable reductions be required of existing sources in light of the relative contribution of special
challenge sources. During the time a TMDL is being developed for a water impaired by these sources, States may
need to make permitting decisions for existing point sources of the pollutant whose contributions of the problem
pollutant may be minor in relation to the special challenge source. In deciding on control actions for existing point
sources during that time, States should apply a principle of requiring reasonable reductions, but should not impose
extensive burdens on these sources where the reductions accomplished will not significantly contribute to
attainment of the water quality standard." Report at 47.
The last part of this recommendation is especially important and relevant for the Coeur d'Alene Basin. The TMDL
should not impose excessive burdens where the reductions "will not significantly contribute to attainment of the
water quality standard." While Asarco concurs with the principle of this recommendation, Asarco supports even
more strongly the position of the Minority Report Pollutant allocations for current dischargers should not be
affected by the perceived need to address "special challenge sources" unless reasonable reductions by the current
dischargers would be expected to significantly improve water quality for the pollutant of concern within the next
five-year NPDES permit cycle
Response EPA and DEQ must develop a TMDL that achieves Ihe water quality standard Despite the stringency
of Ihe criteria and the large numlier of sources, the available information from the Bunker Hill facility
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indicates that the TMDL allocations are achievable Regulatory relief mechanisms can be pursued by
those facilities that cannoi achieve the allocations (see discussion in introductory section).
It stands to reason that, m general, significant reductions in current metals releases from both discrete
and non-discrete sources will significantly improve water quality, EPA and DEQ will prioritize
permitting and cleanup actions to address higher loading sources in the early phases of
implementation.
Comment #5 Letter(s) 266
A closer look at the above Red Dog/Lucky Friday information concerning cadmium indicates that, for a 30-day
month, sulfide reagents costs alone for cadmium removal result in a cost per pound of cadmium removed of
approximately $1.25 at the Red Dog mine. Using the same sulfide concentration, and assuming (an impossible)
100% cadmium removal from Lucky Fnday effluent results in an approximate cost of $2,196.00 per pound of
cadmium removed As stated above, the only reason Red Dog added the sodium sulfide treatment was for cadmium
removal. Another way of looking at the comparison of Red Dog versus Lucky Friday is thai Red Dog removes
approximately 12,600 pounds of cadmium in a month whereas at the Lucky Friday current discharge rate erf
cadmium, it takes approximately one month to discharge cue pound of cadmium. Thus, Red Dog removes in one
month what it would lake Lucky Friday over 1,000 years to discharge! To mandate, or even imply, that sulfide
precipitation is the appropriate technology to be utilized is economically and technologically inappropriate.
Response: See Comment #15 below.
Comment #6 Letter(s) 266
Even if an operating mine such as Lucky Friday were to reduce discharge by one-half of the recent historic range,
the resultant concentration required in the discharge would still be either submicron or a fraction of an mstream
Gold Book criteria for the three metals. It should be pointed out that while operating mines may have some water
management options, a FQTW must treat what it receives.
The practical effect of the proposed TMDL wasteload allocations for the mines is ZERO discharge. The
concentrations corresponding to the allocated pounds/day of the three metals and existing discharge flow volumes
result in concentrations that are both fractions of Gold Book values and sub-micron levels in concentration. This is
also true for the POTWs discharging to the South Fork of the Coeur d'Alene River. Nowhere in either the law or
legislative history did Congress intend such an approach under CWA Sec. 303(d). We need to consider the
objective of the CWA and the goals (to achieve the objective) that must be both "consistent with the provisions of
this Act" and "wherever attainable" as directed by Congress.
Response: The TMDL wasteload allocations are clearly not set al zero, nor is a "zero discharge" requirement the
practical effect of the allocations. The comment focuses on concentrations associated with the
assigned allocations. The TMDL, however, establishes wasteload allocations expressed not as
concentrations but rather as loads (lbs/day). Two factors make up an effluent metals load: flow and
metals concentration. A facility can reduce either flows or metals concentrations, or both, to reduce
the load. If a facility reduces its flows, via recycling cr other water management measures, the
allowable discharge concentration can be proportionally higher to achieve the same loading level.
Lucky Friday has not submitted information on the degree of flow reduction it can achieve by the use
of recycling and flow segregation. To adopt the example m the comment, if Lucky Friday reduced its
discharge by one-half, its allowable discharge concentration (to meet it wasteload allocation loading)
would double. However, the assertion that a one-half reduction in flowrate at Lucky Friday would still
require the facility to keep discharges below the Gold Book criteria assumes that Lucky Friday
currently discharges at its long term average flowrate during 7Q10 conditions. This assumption is not
supported. It is more likely that Lucky Friday already discharges at a lower flowrate during these
critical low flow periods. Recycling and other water management measures would reduce flowrates
further, resulting in proportionally higher allowable discharge concentrations.
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EPA and DEQ agree that waier management options are more limited for municipal (realmerit plants
This is one reason the agencies believe variances may be appropriate for the municipalities in the
Silver Valley. The agencies note, however, that inflow and infiltration into a sewage collection system
directly affects efficiency of the system and effluent flowrates. and treatment facilities commonly
modernize their collection systems to minimize inflow and infiltration.
Comment #7 Letter(s) 266
The TMDL states that "Cost-effective technologies to remove metals from mining wastewaters are in widespread
use in the industry," but the Red Dog mine is the only example of a full-scale operation ill the EPA contractor
document. The TMDL preparers stale that they have "used information about treatment options to evaluate the
wasteioad allocations in this TMDL." It appears instead that selected information was used to support a
predetermined conclusion. If this were not so, why the significant differences in the SAIC and CH2M Hill reports
discussed in our previous comments? Why isn't recognition given to the removal efficiency of the tailings ponds at
the operating mines (over 99% removal of all metals)?
Response: While numerous facilities employ water management and technology to remove metals from mining
wastewaters, permit limitations in the range of the TMDL allocations are less common. EPA
discussed the Red Dog facility in some detail in the draft TMDL TSD, because its concentration-based
permit limits are in the range of the TMDL requirements.
See above regarding the scope of the referenced CH2M Hill report on alternatives. Both the SAIC and
CH2M Hill reports have been supplanted by a significant body erf information from the Bunker Hill
CTP review. This information generally confirms EPA's statements in the draft TMDL TSD
regarding wastewater treatment.
EPA and DEQ affirm the importance of current waste management practices at operating mines,
including the backfilling of coarse tailings and settling of tailings wastewater in ponds, in reducing
metals loads to adjacent rivers and achieving technology-based permit limits. The TMDL establishes
allocations necessary to meet water quality standards.
Comment #8 Letter(s) 272
Conventional water treatment cannot meet the proposed TMDL levels. Extensive analyses show that 99 percent
removal efficiencies must be achieved to meet the proposed TMDL for one Coeur project. This is neither possible
nor cost effective as an alternative to meet the proposed TMDLs. Montgomery Watson, under retainer from Coeur,
estimated from the limited information available, that water treatment for Coeur's three operations in the CdA Basin
would require a three-phased approach including chemical precipitation, reverse osmosis, and ion exchange
polishing. Cursory costs for implementation range from S10 million to over $20 million, depending on the flow
range to be treated. Such costs would result in mine closure and subsequent impacts to the local economy.
Phasing the TMDL may identify significant sources that could and are presently being mitigated and result m
significant improvement in stream quality without imposing discharge concentrations a fraction of Gold Book
Criteria, which are not attainable with conventional treatment methods.
Response: The concept of a phased TMDL is that a TMDL should be completed based on available data and
information even when that information is limited, and the TMDL can be modified when further
information is available, EPA and DEQ have noted that the Coeur d'Alene TMDL will be modified if
warranted by new data and information. At the same time, NPDES permit limits must be based on
wasteioad allocations in a TMDL, whether or not it is a phased TMDL. When a TMDL is mcxiified,
NPDES permit limits based on the TMDL wasteioad allocations can be modified as well.
As noted in comment #3 under Method of Allocation, the TMDL does not impose discharge
concentrations at a fraction of the Gold Book criteria.
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Coeur has not supplied information supporting its assertion that it will need lo construct and operate
relatively cosily reverse-osmosis or ion-exchange treatment to meet the allocations. Available
information indicates that the Bunker Hill facility can achieve the allocations with less-costly
precipitation technology Further, this comment does not discuss the effect of recycling and water
management cm the treatment goals.
Comment #9 Letter(s) 251,255
The proposed allocations for municipalities along the Spokane River are not attainable under projected growth
scenarios without major expenditures.
Response: The TMDL establishes wasteload allocations at the level of current performance for those facilities
that discharge below their calculated wasteload allocation. The calculated allocation is expressed as a
concentration for the Spokane River facilities. As noted in the TMDL TSD, it appears that the
wasteload allocations for the Spokane River facilities will be based on current performance (estimates
of current effluent concentrations). EPA and DEQ also assume that growth will be manifested in
higher influent flows but not in higher influent metals concentrations, and the agencies received no
information to dispute this assumption during the comment period. Higher diluent flow at a facility
would not be a concern with respect to the TMDL provided the performance-based wasteload
allocation (concentration) is maintained over time. Based an these considerations, EPA and DEQ do
not agree that the wasteload allocations represent growth restrictions for these dischargers
Comment #10 Letter(s) 272
To achieve the water quality criteria set, based on the maximum values shown in the table at Cataldo, approximately
87 percent of cadmium, 93 percent of lead, and 95 percent of zinc would have to be removed from the system
Standard technology doesn't exist to remove this level of metals consistently from a water system.
Response: EPA and DEQ confirms the calculated reductions needed based oil maximum reported concentrations
at Cataldo. EPA and DEQ acknowledge that achieving such reductions is a major challenge. The
effectiveness of tailings removal actions is uncertain, however, some standard treatment technologies
do achieve percent-removals in this range. EPA and DEQ note that target concentration, and not
percent removal, is the limiting factor for treatment system design.
Comment #H Letter(s) 272
Figure 7.2 in the Technical Support Document presents theoretical solubility of metal hydroxides and sulfides. Such
theoretical data are of limited usefulness in assessing the practicality of treatment of actual discharges. Theoretical
data ignore interactions that occur naturally between substances both chemically and physically. Figure 7.2 also
indicates that the industry standard of hydroxide precipitation is not capable of achieving dissolved cadmium, lead,
and zinc concentrations The theoretical solubility for sulfide compounds is unstable, as current analytical methods
cannot quantify concentrations of these compounds at such minute levels.
Response: EPA and DEQ agree that the theoretical solubility is a starting point for analysis of feasibility, and
actual treatment efficiencies are dependent upon a number of factors (e.g., wastewater characteristics,
treatment process, physical/chemical interferences, etc)
EPA and DEQ agree that hydroxide precipitation alone may not be sufficient to achieve the wasteload
allocations. It should be noted, however, that this type of treatment may be sufficient in combination
with How management measures tor some sources.
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Comment #12
Letter(s) 266
EPA/DEQ fail to address technological feasibility and economics in the TMDL. "[Tjhe TMDL presumes that under
the CWA Sec. 303(d) economics may be ignored. [Section] 303(d) does not negate CWA sections that specifically
address effluent limitations. This would not be "consistent with the provisions of this Act" as mandated by
Congress Therefore, it is curious that EPA would conduct an economic analysis (albeit an insufficient economic
analysis) on its water quality standards rulemaking for Idaho (in 1997) and yet ignore economics under a 303(d)
TMDL. The EPA's 1997 economic analysis & accompanying technical support document (Economic Analysis for
the Final Water Quality Standards for Idaho -July 21,1997) at least provided some form erf cost effectiveness
guidelines for a given technology, even though reality appeared to play a minor role in this exercise. For example,
the economic analysis only included one Lucky Friday pond under an incorrect assumption that another pond
already was permitted unto the national toxic rule (NTR) requirements. The Lucky ftiday permit already is water
quality-based, hut not under the NTR. Further, in the Economic Analysis, individual pollutants are given specific
factors based upon obscure "toxic weights." The effect of this mathematical manipulation is a distortion of the true
"cost-effectiveness" of a given treatment technology. This occurs because the "toxic weights* result in a much larger
denominator of the formula (treatment cost - pounds of metal removed), with the actual estimated annualized
treatment costs (annual O & M + annualized capital) as the numerator.
To further the Lucky Friday example, the Economic Analysis used permit limits rather than actual discharge levels
of metals, resulting in a distorted overestimate of "toxic weights," thus a lower "cost effectiveness." Using
procedures from ihe ANALYSIS, the "cost effectiveness" was estimated as $64 for Lucky Fnday. Using actual
discharge levels of metals and the same procedure from the ECONOMIC ANALYSIS, actual "cost effectiveness" is
$939. Using real numbers is important because EPA used a "$200 per toxic pounds-equivalent trigger" above which
a facility "qualified" for "alternative regulatory approaches." These "alternative regulatory approaches* include
procedures "such as phased total maximum daily loads (TMDLs), site-specific criteria, and water quality variances."
As detailed in comments above, the proposed TMDL is not appropriate. Further, it is not necessary to request a
"water quality variance" for a use/critena not applicable to the receiving water (also as detailed in comments above).
Therefore, it appears that the site-specific criteria currently is the best known approach available; this is the
approach being taken under the 1993 agreement between EPA, DEQ and Hecla."
Response: In the Clean Water Act and implementing regulations, there is no requirement to conduct an economic
analysis of wasteload allocations derived m a TMDL Nevertheless, EPA and DEQ discussed the
feasibility erf meeting NPDES effluent limits based on the TMDL in the TMDL TSD, and the agencies
solicited comment from the public on this topic to assist in developing implementation strategies.
The economic analysis referenced by the commenter was performed for EPA's 1997 rulemaking for
water quality standards (including cold water biota use designations) in the South Fork Coeur d'Alene
River and tritwtanes. This analysis is not relevant or applicable to this TMDL EPA's 1997
rulemaking was challenged in Idaho District Court. See Idaho Mining Assoc. vs. Browner (D id . CV-
98-0390-S-MHW). The court upheld EPA's rulemaking. Since the TMDL is based on applicable
water quality standards for Idaho, the effect of the court's ruling is that the applicable standards have
not changed at the target sites in the TMDL.
Comment #13 Letter(s) 272
Based on the concentrations suggested in the TMDL, there is only a limited amount of recycling and water
management that can be completed to reduce metal loading. The concentrations are so low that a combination of
water management and water treatment will have to be employed. Metal removal requirements for SVR must exceed
90 percent, well beyond the capacities of present conventional techniques. To ensure compliance on a continuous
basis, removal efficiencies would need to exceed 95 percent Water treatability analyses for the Kensington Gold
Project in Southeast Alaska suggest 50 to 60 percent removal efficiencies could be expected continuously. This
would be insufficient to meet the discharge criteria established by the proposed TMDL. Overall, point source
dischargers would need to routinely treat discharges to achieve metals concentrations that are four to eight times
lower than the concentrations listed in the TSD
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Response While more detailed information from facilities about water management opportunities is warranted,
EPA and DEQ acknowledge that achieving the TMDL reductions is a significant challenge. However,
some standard treatment technologies do achieve percent removal in the range cited in the comments.
Both the Red Dog and Bunker Hill facilities perform at a level surpassing 90% removal. However,
EPA and DEQ also note that target concentration, and not percent removal, is the limiting factor for
treatment system design This may explain the lower percent removals at the Kensington facility,
where the influent metals concentrations to the treatment system are relatively low.
The reference to the need to treat to levels 4-8 times lower than the concentrations appears to assume
that facilities will discharge at their long term average flowrate during lower flow conditions (e.g.,
7Q10 conditions) This assumption is not supported in the comments. It is marc likely that facilities
already discharge at a lower flowrate during these critical low flow periods. Recycling mid other water
management measures would reduce flowrates further, resulting in proportionally higher allowable
discharge concentrations.
Comment #14 Lettar(s) 266
The TMDL states that "Figure 7-2 shows theoretical lowest residual metal concentrations* and that the sulfide
precipitation at Red Dog treats metals "to concentration ranges similar to levels specified in this TMDL." Since
Figure 7-2 was undoubtedly basal upon the operational definition of "dissolved" metals, it has very little scientific
validity.
Response: Figure 7-2 depicts the relationship between pH and dissolved metals. It was developed for the TMDL
by SAIC using standard, published solubility product data.
Comment # 15 Letter(s) 266,270,272,
274
The sulfide and/or sulfide/hydroxide precipitation processes have not been demonstrated as being capable of
achieving the cadmium and lead concentrations proposed by the TMDL Theoretical solubilities of metal salts
cannot be achieved in full scale systems because solubilities are affected by other physical and chemical factors,
including temperature and the presence of other cations and anions. Moreover, filters are not 100% efficient and
fine (colloidal size) particles will pass through filters and cause an exceedance of these extremely low metals
concentrations. EPA's statement that these processes can achieve the target limits "with refinement" is speculative
and not based on any technical analysis. We have reviewed the EPA's Risk Reduction Engineering Laboratory
technology data base and it contains no treatability data that demonstrate the ability of any of the available treatment
technologies to consistently achieve the target cadmium and lead concentrations.
EPA recently evaluated metals removal technologies and performance data for its proposed effluent limitations
guidelines and standards for the centralized waste treatment industry. This study evaluated sulfide
precipitation/filtration and reverse osmosis treatment for metals removal. The performance that was demonstrated in
these studies resulted in effluent concentrations for cadmium, lead, and zinc that were orders of magnitude greater
than the target effluent concentrations developed from the TMDL. Although these waste streams do not have
identical characteristics to the wastewaters that are the target of the TMDL for the CdA basin, these EPA data do
indicate that the performance of the most widely used technologies, when applied to actual waste in field-scale
operation, falls far short of that required by the proposed TMDL.
Based cm our review of available, demonstrated treatment technologies for metals, we believe that the ability of
point sources to achieve the proposed wasteload allocations is problematic. We did not find any field-scale data in
the technical literature that document that the cadmium and lead concentrations required by the proposed wasteload
allocations could be consistently achieved by any available chemical precipitation-filtration treatment. This is a
serious limitation to successful implementation of the TMDL and mast be investigated further before these
wasteload allocations are used for setting NPDES permit limits
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The regulated community must qwate in the real world, not a theoretical world. The Red Dog wastewater is not
directly comparable to any mining wastewater m the Coeur d'Alene Basin, and the Red Dog results do not meet the
levels associated with the proposed TMDL
Response: The CWA requires the reduction of current discharges to achieve water quality standards. The CWA
does not require that the TMDL evaluate or specify a particular technology to achieve this reduction
Nonetheless, in establishing the allocation scheme, EPA and DEQ can consider feasibility of achieving
the necessary reductions. Anticipating concerns over the feasiblity erf the allocations, EPA cited the
performance erf the Red Dog facility as an example to show that there are technologies available to
mining facilities to achieve metals concentrations in the range of those required in the TMDL.
The TMDL, however, establishes wasteload allocations expressed not as concentrations but rather as
loads (lbs/day) for the mining facilities. Two factors make up an effluent metals load: flow and metals
concentration. A facility can reduce either flows or metals concentrations, or both, to reduce the load.
EPA and DEQ attempted to highlight both factors in the feasibility discussion. Regarding effluent
flow management, as noted in the Technical Support Document, EPA and DEQ believe that water
management measures to reduce effluent flows are an option for operating mines in the basin. Since
the cost of treatment operations is proportional to the flowrate, the oost of treatment requirements
could be significantly reduced through recycling and other water management actions. Regarding
management of effluent metals concentrations, EPA endeavored in the TSD to assist facilities by
highlighting technology that is currently in use in the industry.
The specific measures and technologies employed by a facility are under the responsibility and control
of the facility. In order to evaluate the feasibility of the allocations at individual facilities, EPA and
DEQ requested that facilities submit information during the comment period regarding their ability to
meet the wasteload allocations, including information on both treatment and water management
options.
The mining facilities did not supply sufficient information on the feasibility of the allocations to justify
a change to the allocation scheme. None of the facilities addressed specific water management and
treatment options at their facilities to reduce loads to the TMDL levels.
Comment #16 Letter(s) 274
EPA and DEQ should not irrpose a TMDL without knowing whether the source reductions will be technically or
economically feasible. By their own admissions, the agencies do not know whether the wasteload allocations in the
proposed TMDL will be achievable either technically or economically. To the question "Can Basin waters be
cleaned-up to meet current water quality standards," the agencies answered "We do not know." While Asarco
appreciates the candor of the agencies' response, the answer reinforces the absurdity of proceeding with the
development and implementation of a TMDL when neither agency knows (1) whether there are technologies that
can achieve the load reductions required, nor (2) whether, after reducing the loads of all point sources, the Coeur
d'Alene Basin will achieve water quality standards
Response: To the extent practicable, EPA and DEQ have considered feasibility in the development of the TMDL
The agencies recognize that the successful implementation of the TMDL throughout the basin is
uncertain; however, the agencies firmly believe that the TMDL provides a needed framework for
cleanup actions and NPDES permitting. To cite an example, the proposed TMDL set forth preliminary
goals for the ongoing work to evaluate the long term design and operation of the Central Treatment
Plant at the Bunker Hill site. Based on the analyses to date, the facility can meet the TMDL
requirements with precipitation and filtration technology Control of point source'loadmg through
implementation of the TMDL is a step in the direction of achieving standards protective of aquatic life.
Because of the extensive tailings dqxisiis m the lloodplain. the South Fork and mainstem Coeur
d'Alene River are not expected to achieve water quality standards with point source controls alone.
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Comment #17
Letter(s) 274
It is disturbing lhat EPA and DEQ specifically request comment on their assumption that the permitted point sources
can achieve the proposed wasteload allocations wuh improved water management and/or conventional treatment
technologies (e.g., metals precipitation technology).
EPA and DEQ rely on (his assumption yet al the same time -- including at the public meetings -- they acknowledge
that EPA has not yet determined whether the largest pant source of metals in the basin (the Central Treatment
Plant) can achieve its allocation through these kinds of technologies and how much it would cost to do so. EPA's
own consulting firm has concluded that sulfide precipitation is not likely to achieve the kinds of reductions required
by the TMDL and that the only technology that can will require evaporation and crystallization. EPA nonetheless
expects the regulated community and the public to disprove the assumption that point sources can meet their
wasteioad allocations when EPA is usable to provide information to show that these allocations can be met
Response: EPA and DEQ believe that the regulated community, particularly the mining industry, is clearly in the
best position to answer the question of whether the NPDES effluent limits based on the TMDL
allocations can be achieved at their facilities. EPA and DEQ provided an extended comment period to
afford the regulated community adequate time to supply additional information on the feasibility of the
allocations. The agencies have evaluated and considered the information received during the comment
period. In addition, the agencies have evaluated feasibility of TMDL allocations for the Bunker Hill
CTP (See appendix in TMDL TSD).
Comment #18 Letter(s) 266,270,272
Other concerns for CdA basin operators related to similar treatment facilities include high lime consumption, sludge
managemnt issues, water storage facilities, and high operating costs.
Response: EPA and DEQ acknowledge that chemical consumption, sludge management, water storage, and
operating costs are relevant concerns for mining facilities. However, EPA and DEQ have received no
facility-specific information indicating that any erf these particular concerns render the allocations
infeasible.
Comment #19 Letter(s) 266,270
It is inappropriate to compare Red Dog's achieved effluent concentrations to other facilities without a complete
evaluation of each facilit/s influent characteristics. Chemical thermodynamic properties (such as adsorption) can
differ significantly between high concentration influents (e.g., Red Dog) and low concentration influents (e.g.,
Silver Valley dischargers).
Response: See above regarding the purpose and basis of comparison to the Red Dog facility. EPA and DEQ
recognize that wastewater properties can vary and that these differences can affect treatability.
However, the mining facilities have not provided any sampling or treatability information specific to
their discharge to support this concern. The oily Silver Valley facility for which the agencies have
treatability test data is the Central Treatment Plant (CTP) at Bunker Hill. These tests indicate that the
sulfide precipitation technology and filtration similar to that used at Red Dog is effective at reducing
metals in the CTP wastewater
Comment #20 Letter(s) 255, W18
On the basis of initial treatability studies, the treatment EPA is proposing will not meet the necessary removal
levels, such as 99 95% for lead The processes would in fact include something much more stringent and much mere
costly to operate.
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Response: The only Silver Valley facility for which the agencies have treatability test oala is the Central
Treatment Plant (CTP) at Bunker Hill These tests indicate that the sulfide precipitation technology
and filtration similar to that used at Red Dog is effective at reducing metals in the CTP wastewater It
is projected that the CTP can achieve the TMDL allocations.
Comment #21 Letter(s) 273
The implementation plan for the Idaho TMDL should set a goal of ensuring that Spokane River TMDL criteria are
met at the border during transient events.
Response: EPA and DEQ agree thai achieving Washington criteria at the border at all times is one of the goals of
the TMDL and its implementation.
3.2 Timing of TMDL and Permitting Actions
Comment #1 Letters) 266
Since Congress did not intend for CWA Sec. 303(d) to negate all other provisions of the CWA, including
technological and economic considerations, we believe the proposed TMDL is illegal and must be set aside pending
resolution of issues raised in these comments.
Response: EPA and DEQ discuss provisions of the CWA that address technological and economic considerations
in this document (See Regulatory Options). This TMDL has not "negated" any of these mechanisms.
On the contrary, the TMDL has brought about a better understanding of these mechanisms under the
CWA. The TMDL can be modified as necessary to reflect changes in the water quality standards (e.g.,
site-specific criteria or use attainability).
While EPA and DEQ recognize the complexity and controversy of the TMDL, the agencies disagree
that it should be set aside because of the issues raised in the comments.
Comment #2 Letter(s) 272,274
Under the court's order in Idaho Sportsmen's Coalition v. Browner, the State of Idaho has the authority to revise the
schedule and order for developing and implementing TMDLs on Section 303(d) listed waters. DEQ should exercise
this discretionary authority and defer developing a TMDL for these waters until the Basin-wide RI/FS and cleanup
are complete. The reason for such a deferral is simple: DEQ cannot know how much load reduction from point
sources will be necessary until DEQ and EPA understand the amount of load reduction that can be achieved through
cleanup of non-point sources. It makes no sense to impose overly stringent load reductions on point sources when
the possibility exists that the cleanup of non-point sources will obviate the need for such stringent point source load
reductions.
Some attempt should be made to better understand the non-point sources and the feasibility of reducing loads from
them, before embarking on restrictive water quality criteria for point sources. TMDLs should include expected
loading reductions from point/non-point sources from Bunker Hill Superfund Site and other projects throughout the
Basin
Response; EPA and DEQ agree that a better understanding of non-point sources would benefit the cleanup
actions. However, the nature and extent of the n on-discrete sources in this basin will limit our ability
to predict the effectiveness of cleanup actions with confidence. In this context, EPA and DEQ believe
that reductions in discrete sources and non-discrete sources can and should proceed on a parallel path.
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A listing of expected loading reductions us not required in a TMDL. Rather, TMDLs must allocate the
loading capacity of the river to known sources and/or source categories. As described above, available
information indicates that the CTP facility at Bunker Hill can achieve its allocation.
Comment #3 Letter(s) 272
The NPDES permit should also be tied to the TMDL program. At the present time, they appear to be operating on
two different schedules and directions. There is no reason to issue new NPDES permits until EPA/IDEQ determine
the criteria from the TMDL process.
Response: The timing of the NPDES permits and TMDL are coordinated, and the requirements of the permits
will be consistent with the TMDL. NPDES permits for the South Pork dischargers will be issued after
the TMDL is finalized, and the permit limits will be based on the wasteload allocations in the TMDL.
TMDLs do not determine the applicable water quality criteria; TMDLs are established to achieve the
applicable water quality criteria. This TMDL is based on the applicable water quality standards (and
criteria) for Idaho.
Comment #4 Letter(s) 259,260
Active NPDES permits should be renewed immediately to include limits consistent with the TMDL.
Response: EPA is actively working on the NPDES permit renewals for the basin.
Comment #5
Letter(s) 3, 4, 5, 6, 8, 12,
13, 14, 17, 18,
19,21, 22, 59,
304
Request a formal public hearing.
Response: EPA and DEQ responded to these requests by holding three public hearings on the proposed TMDL.
Hearings were held in Wallace (May 18, 1999), Coeur d'Alene (May 19,1999), and Osburne (May
25, 1999).
Comment #6 Letier(s) 2S4
What is the status of the NPDES permits for the 70 discrete point source discharges?
Response: Most of the 70 discrete sources identified in the TMDL are mining sources not currently discharging
under an NPDES permit. The following table shows the permitted facilities in the basin and expiration
date of each permit. Expired permits are still in effect, because they have been administratively
extended pending permit reissuance.
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Individual NPDES Permits in the South Fork CdA River Watershed
Permit ID No.
Facility
Owner/Operator
Facility Name
Expiration
Date of Permit
Facility Description
ID-0000175
Hecia Mining
Company
Lucky Friday Mine
12-31-80
operating lead/zinc mine & mil
ID-0000167
Hecta M'rhg
Company
Star and Morning
Mines
3-13-95
biactwe talhgs pond and ad it
ID-0000027
Siwr VaJtey
Resources Corp.
(Coeurd'Alene
Mines Corp.)
Galena and
Coeur Mhes
1-10-94
operating copper/stor mine &
mi
ID-0025429
SiverValey
Resources Corp.
(Coeur d'Atene
Mhes Corp.)
Caladay Mine
3-30-95
inactive exploration adit
ID-0000060
Sunshine Mliing
Company
Sunshine Mine
and Mi
9-9-96
operating antimony/
sirer/copper
mine, ml & refinery
10-0000159
Sunshine Mliing
Company
Consolidated
SIverMine
9-28-93
inactive adit
ID-0021296
South Fork CdA
River Sewer
District
City of Mulan
Wastewater
Treatment Plant
10-9-90
wastewater treatment plant
ID-0021300
South Fork CdA
R'wer Sewer
District
City o( Page
wastewater
treatment plant
6-28-99
wastewater treatment plant
ID-0020117
City of
Smehervfle
City of
Smeftervite
wastewater
treatment plant
6-26-90
wastewater treatment plant
NA
EPA
Bunker Hi
Central Treatment
Plant
NA
mine drainage
treated/discharged under
CERCLA authority
The three NPDES permits for nxioicipalities along the Spokane River ^ver© reissued last year, 3s
indicated in the table below:
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Individual NPDES Permits in the Spokane River Watershed
Permit ID No.
Facility
Owner/Operator
Expiration
Date of
Permit
Facility Description
ID-002585-2
City of Post Falls
Nov. 2, 2004
wastewater treatment plant
ID-002285-3
City of Coeur d'Alene
Nov. 2, 2004
wastewater treatment plant
ID-002659-0
Hayden Area
Nov. 2, 2004
wastewater treatment plant
Comment #7 Letter(s) 255,266
Given the numerous legal and technical deficiencies in the proposed TMDL, it is difficult to understand the
"fast-track" procedure EPA and DEQ appear to be on to complete this TMDL. Judge Dwyer's directions clearly
authorize modifications to the timing of Idaho's TMDL development process. In fact, DEQ requested mare time for
the development of the state TMDL. This additional time was necessary to collect all information requisite for
scientifically defensible TMDL. Idaho's request was rejected by EPA Region X (letter dated November 9, 1998). It
appears the deciding factor to rush into the subject inadequate TMDL is stated in EPA's letter in that "EPA has
decided to move forward expeditiously to develop TMDLs for the Coeur d'Alene basin in order to ensure that, it has
the information and analyses necessary to implement its responsibilities under the NPDES permit program and the
CERCLA program." These are not valid reasons for developing an indefensible TMDL, A responsible and
scientifically sound TMDL must precede both NPDES permits and the RI/FS process. It is sad to note that the
"substantive concerns" EPA identified with the state draft TMDL in EPA's letter (Non-NTR Issues with LDEQ
Draft TMDLs) are rqpeated and even exaggerated in the joint EPA/DEQ TMDL. EPA and DEQ must take
advantage of the flexibility allowed in Judge Dwyer's ruling in order to develop a scientifically sound and legally
defeasible TMDL.
Response: Given the 120-day comment period and several months expended on responding to comments, EPA
and DEQ do not view this as a "fast-tracked" TMDL. There are several reasons for issuing a TMDL
at this time. The two primary reasons are captured in the comment. The November 9, 1998, letter
referenced in the comment accurately reflects the agencies' need to establish long-term cleanup goals
and NPDES wasteload allocations The Idaho TMDL schedule lodged with the federal court is also a
major consideration affecting TMDL scheduling throughout the state.
EPA and DEQ disagree that the TMDL is unsound. The assertion that substantive problems in a
previous draft TMDL were repeated and exaggerated is not supported by any specific examples. EPA
and DEQ have carefully considered public comments and made improvements to the draft TMDL
products based on this input. The result is a legally and scientifically sound TMDL with a supportive
administrative record.
Comment #8 Letter(s) 255,272
Concurrently implementing TMDLs while revising criteria, pending evaluations, and untested regulatory arenas to
fully understand and develop meaningful TMDLs to protect water resources is not prudent or effective Effort
should be taken to use every regulatory avenue available, allow on-going remediation to show improvements, and
develop a better scientific knowledge base far implementing the TMDL program. The evaluation of realistic water
quality criteria (sue specific, etc.) while still fully protecting the water resource should be the highest priority. In
this way, EPA/1 DEQ are meeting the objective of setting TMDLs and improving water quality as required.
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However, this means a more detailed and u|x;n process will be required with industry, municipalities, the public and
agencies exploring all available alternatives to assist Idaho in meeting the challenges faced.
Resfxmse EPA and DEQ see no banners to collaborative implementation of the TMDL and the cited regulatory
relief avenues (See Regulatory Opiums) EPA and DEQ disagree with the suggestion that the TMDL
process has not been open, particularly after holding 3 public meetings and a 120-day comment period
when the agencies were available for consultation. The agencies will continue to welcome
constructive participation from the affected parties in the basin as TMDL implementation progresses.
Comment #9 Letter(s) 84
EPA proposes to issue NPDES permits to existing NPDES facilities in the CdA river basin. Does this mean no new
permits will be issued and only renewals will be addressed?
Response. EPA is beginning to develop draft NPDES permits for the operating mines and municipalities along
the South Fork. The schedule for issuing the South Fork municipal permits will be coordinated with
any variance actions. The appropriate approach to address all inactive mine adits will be evaluated in
the RI/FS process. Decisions on next steps to implement the TMDL for these adits will be made in the
Superfund Record of Decision.
Comment #10 Letters) 272
EPA plans to refine gross allocations for waste piles and non-point sources. A phased approach to setting TMDLs
would allow this to be completed in a concurrent, cast effective manner.
Response: EPA and DEQ do not expect to complete the refinements to the gross allocations in the short term.
Given the agencies' goal of reducing metals loads to the river system, the agencies do not believe it is
appropriate to delay the TMDL and NPDES permitting for discrete sources until completion of these
refinements.
Comment # 11 Letter(s) 259
Issuance of the TMDL should not be delayed to allow for the development of site-specific criteria.
Response: EPA and DEQ agree. Hie TMDL can be modified, as needed, based on approved site-specific criteria.
Comment #12 Leiter(s) 272
Revision [of the TMDL] at a later date seems unnecessary and costly to the agencies, regulated communities, and
the general public. An extensive process will be necessary to make such a revision. Additional information could be
developed to augment data bong collected for the Rl/FS as it is focused on certain objectives not consistent with
setting TMDLs. Developing a phased TMDL, as allowed by regulations, that establishes an integrated, well planned
data collection and evaluation program to assess stream conditions and contributing loading sources.
Response: Future revision of a TMDL is a possibility based on new information and changes to water quality
standards. At this time, EPA and DEQ believe it is appropriate and reasonable to issue a TMDL based
current regulations and the best available information. The agencies note that the concept of
phased TMDLs is discussal in EPA guidance and not regulation. For further discussion of phased
TMDLs, see comment #8 under Feasibility of Allocations.
Cerumeni #1 i Letier(s) 272
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EPA recognizes thai changes can be made Co the water quality criteria based on site-specific conditions and is
willing to change the TMDL at a later date. However, this seems redundant and less efficient than using site-specific
conditions at this time to set reasonable and attainable TMDLs It is expected that initiating this effort now could
span a 24-36 month period to collect acceptable data. Recognizing that EPA is willing to consider site-specific
information later, why not develop a phased approach to establishing TMDLs. This phased approach would evaluate
site-specific conditions to set TMDL levels. In this way. State, Federal, local and industry efforts can be maximized
on one common approach and method. Setting intermediate targets, milestones and goals would help to assess
stream conditions/improvements working towards protecting the uses instead of an arbitrary number. This would
also allow all parties to participate equally tn the review program. It is expected, even under the EPA proposal, to
take many years to achieve these goals and objectives. It seems reasonable to do both concurrently while assessing
stream system improvements.
Response: The commenter's concept of a phased approach would not comply with the Clean Water Act
requirement that TMDLs achieve applicable water quality standards. A TMDL must be based on the
applicable water quality standard; therefore, EPA and DEQ cannot establish intermediate targets in the
TMDL or subsequent permits. However, EPA and DEQ can establish a reasonable schedule for
discharge improvements in a permit compliance schedule. See also previous comment.
Comment #14 LeUer(s) 272
Issuance of TMDLs at this point seems counter-productive and premature. More information is needed, as
evidenced in the document. Given that so many studies are being completed, it seems prudent to collect as much
data as possible to ensure TMDLs are appropriate and attainable. A phased approach could use data collected under
all the programs, analyses and studies being completed at this time. An integrated evaluation would significantly
improve data needed to help set appropriate TMDLs.
Response: EPA and DEQ do not believe more data is necessary to develop an appropriate TMDL and note that
this basin will continue to be studied for years to come. However, EPA and DEQ do agree with the
goal of integrating the best available information to improve the TMDL The agencies believe the
integrated process outlined herein best serves this purpose while moving forward on a reasonable
timeframe toward protective NPDES permits and reduced discharges.
Comment # 15 Letter(s) 272
'Technical data used for developing the TMDL, by EPA's own admission is limited and provides insufficient data
to setting TMDLs. EPA has determined to take a very conservative approach to allocating metal loading. Instead, a
thorough investigation of flows, hardness, natural metal levels, uses and other critical issues should be adequately
evaluated prior to setting TMDLs. For this reason, a phased approach to setting the TMDLs could incorporate
supplemental and missing data which provides further scientific information. Data collection could be coordinated
with NPDES permit monitoring and compiled into one database. Many stretches of the S. Fork of the Coeur d'Alene
River are presently monitored and would provide important data. Many of the assumptions used in the document are
dependent upon accurate characterization of the stream system and discharges (point and non-point sources). Flows
are critical to develop loading capacities. It also eliminates the need to develop multiple layers of safety factors in
the estimations."
Response: While acknowledging and describing the limitations of the available data, EPA and DEQ have not
claimed that the data is insufficient for setting TMDLs. In fact, a substantial amount of river and
source data is available for the Coeur d'Alene basin. The TMDL TSD states the following about data
sources and data limitations:
"These issues are not unusual in water quality analysis and regulation because water quality and
_ flow data are often collected using a variety of methcxls and for different purposes. Collectively, the
above sources provide for ihe development of a sound and reasonable TMDL."
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Regarding an integrated database tor the TMDL and permits, EPA continues to build a large database
system that holds metals sampling information for the Coeur d" Alene basin from a variety of sources,
including data collected by Idaho DEQ, USGS, NPDES permittees, Superfund program, and mining
companies, EPA posted a portion of this database that was used in the development of the TMDL on
the Internet during the public comment period
EPA and DEQ agree with the general supposition that a lack of data necessitates a higher margin of
safety in a TMDL.
Comment #16 Letters) 274
The Idaho Mining Association ("IMA") has challenged EPA s cold water biota desipated use for the South Pork of
the Coeur d'AIene River, Canyon Creek, and Shields Gulch. This litigation is pending in the United Slates District
Court in Idaho, and motions for summary judgment have been filed. The TMDL that EPA and DEQ have proposed
is based on the challenged designated uses (and accompanying water quality criteria) for those water bodies. If IMA
prevails in the litigation, EPA will have to revisit the appropriate designated use for these water bodies, and EPA
and DEQ will in turn have to revise the TMDL. In light of the ongoing litigation concerning the appropriate
designated use for the three water bodies in the Coeur d'AIene Basin, the State should devote its limited resources to
the development of TMDLs for those water bodies which are not covered by the IMA lawsuit.
Response: The U.S. District Court recently issued a ruling in the IMA case upholding the cold water biota use
designation for the South Pork Coeur d'AIene River and Canyon Creek. The Shields Gulch
designation was remanded to EPA for re-evaluation. Therefore, it is appropriate to issue a TMDL for
the South Park and tributaries.
Comment #17 Letters) 274
EPA and DEQ should not develop a TMDL before EPA revises its TMDL regulations. The timing of the TMDL is
especially inappropriate because the comment period will close at about the time that EPA intends to publish
revisions to the TMDL regulations themselves. See 64 Fed. Reg. 22033 (Apr. 26, 1999)(propo6ed revisions to the
TMDL regulations anticipated in July 1999). At a minimum, EPA and DEQ should defer further work on the
TMDL until after EPA's amended regulations are final. At that point, the TMDL should be modified in accordance
with the revised regulations and the public should be given an opportunity to review and comment an the revised
TMDL.
Response: As anticipated m this comment, EPA issued proposed changes to the TMDL regulations (40 CFR 130)
on August 23, 1999 and finalized the regulations on July 13, 2000 (65 PR 43585) On June 30, 2000,
the U.S. Congress passed legislative restrictions on the use of appropriated funds for the New TMDL
Regulations. The restrictions are contained in "the TMDL Rider," which was included in the FY 2000
Supplemental Appropriations provisions attached to the FY 2001 Military Construction, Family
Housing, and Base Realignment and Closure for the Department of Defense (MilCon) Appropriations
Bill. The President of the United States signed this bill, including the TMDL Rider, into law on July
13,2000. Because of the TMDL Rider, the New TMDL Regulations do not take effect until 30 days
after the dale that Congress allows EPA to implement this regulation. See 65 FR at 43586, Under
current law, therefore, the regulations would not take effect before October 30, 2001. Jd. However,
neither the TMDL Rider nor the delayed effective date of the New TMDL Regulations affects a state's
authority to develop implementation plans if they choose to do so. Numerous implementation
considerations are already introduced in the TMDL support documents and this responsiveness
document m order to provide information to the entities that will implement contrbl actions. The state
anticipates that implementation planning will be iterative, with more detailed plans being developed as
permitting and cleanup assessments proceed.
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Comment #18
Letler(s) 274
The development of site-specific criteria, which is underway by DEQ, is an essential component of the TMDL for
cadmium, lead and zinc. These criteria should account for site-specific chemistry and aquatic ecosystem sensitivity
and will be a major improvement in the TMDL. The concern is that the development of site-specific criteria may
take a long time and that the regulated dischargers will be required to implement controls in the meantime based on
an inaccurate and overly conservative TMDL study. EPA and DEQ have pressed ahead to develop a TMDL based
upon criteria that both expect will be increased in the future. EPA and DEQ should defer the TMDL until after
completion and approval of the site-specific water quality criteria.
In addition, DEQ and EPA should expeditiously complete the site-specific criteria studies and propose and adopt
such criteria where they are scientifically supported. Furthermore, all dischargers should be provided with
compliance schedules of sufficient duration to allow these site-specific criteria to be adopted and incorporated into
the calculation of their permit limits.
Response: As noted m the discussion under Regulatory Options,, the site-specific criteria development is only
proceeding far an 8 mile stretch of the South Fork above Wallace. To date, the mining companies
have elected not to fund work on a larger scale (e.g., site-specific criteria for the entire South Fork)
that might affect TMDL allocations. In addition, current information suggests that a site-specific
cadmium criterion may not be significantly higher than the Gold Bode, criterion. As a result, DEQ
does not expect to propose a site-specific criterion far cadmium.
Compliance schedules in permits can only address the lime needed to meet water quality-based permit
limits, not the time needed to develop and promulgate changes to underlying water quality standards.
If standards are changed during the term of the permit, the associated permit limits can be modified.
Comment #19 Letter(s) 274
Implementation of the TMDL may result in degradation of water quality. Adopting a TMDL prior to the
development and implementation of a plan for addressing non-point source pollution may actually cause
degradation of the water quality in parts of the Coeur d'Aleoe Basin. This could occur if current discharges to the
Coeur d'Alene Basin are substantially reduced or completely eliminated. For example, consider a point source
currently discharging metals in concentrations higher than its assigned loading but below the concentrations in the
receiving waters. If the only means of achieving its assigned load allocation is to stop the discharge altogether
through evaporation, plugging an adit, or shutting down operations, the receiving water's metals concentration
below the discharge will actually increase. In other words, elimination of a "cleaner" discharge will result in
"dirtier" flow once the "cleaner" discharge is removed from the total flow. Accordingly, it makes no sense to ratchet
down on point source discharges prior to addressing the overall non-poml source metals contributions throughout
the Coeur d'Alene Basin.
Response: EPA and DEQ acknowledge the concern that, in the short term, some control actions to reduce
flowrates of less-contaminated discharges could in theory result in worse water quality. However, in
most cases, the agencies expect both flow and concentration reductions from discrete sources. This
comment also reinforces the need to proceed with cleanup actions on large nan-discrete sources in
parallel with discrete source reductions
Comment #20 Letter(s) 255,274
EPA and DEQ should defer establishing a TMDL until completion of the Basin Ri/FS and cleanup.
Response: EPA and DEQ have coordinated the TMDL wiih ongoing data collection and analysis under the
Basin wide Rl/FS. While the cleanup activities may impact the TMDL in the future, the agencies do
not believe it is reasonable or appropriate delay the TMDL until completion of the cleanup. In fact,
the TMDL allocations will serve as one of the goals ui the Rl/FS evaulation of feasibility
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Comment #21
Letter(s) 255,272
Stale law establishes the criteria by which water quality regulations can be imposed upon those permitted sources
that contribute less than 25 percent of the load to a stream .system. The intent was to ensure excess pressure and
burden wasn't exerted on point sources when impacts were from non-point sources. For this reason, based cm state
law, EPA/EDEQ should adequately address non-point source issues and mitigation efforts prior to implementing any
plans or water quality criteria revisions which cause significant financial burden on sources which do not contribute
significantly to the overall degradation of the system.
Response: EPA and DEQ do not believe the referenced state law should be used as a basis to delay water quality
improvements from a particular category of sources. The TMDL and water quality-based permits for
this basin are long overdue. At the same time, regulatory relief may be available to some sources (see
discussion of Regulatory Options). The agencies plan to move forward with both point and n on point
controls to reduce metals contamination in basin waters.
3.3 Relative Contribution of Discrete Sources
Comment #1 Letter(s) 266
An example of how the non-point source aspect of the system functions can be shown by reviewing the McCulley,
Prick, and Gillman (MFG) high and low flow reports referenced in the TMDL Technical Support Document (TSD).
The MFG monitoring data for station SF-125 (South Fork above Wallace) and the monitoring data for the Morning
discharge (inactive mine since Nov. 1990 - daylighting of infiltrated groundwater seepage only) during both high
and low flow sampling events highlight the non-point source nature of the system. The high flow event at SF-125
showed the following increases over the low flow event at the same station: flow increased by a factor of 15.5; zinc
load increased by a factor of 83.9, lead load increased by a factor of 46.6, and cadmium increased by a factor of 7 8
However, monitoring results for the high and low flow sampling events for the Morning mine (an example of the
majority of "discrete sources" identified in the draft TMDL) showed that flow actually was higher during the low
flow event. Both zinc and lead were below detection limits for both sampling events. Cadmium loading was
marginally higher during the high flow event by a factor of 1.14. The point of this example is that the high flow
event monitoring results instream clearly responded to non-point source additions whereas the "discrete source" did
not respond in a similar fashion.
Another example of the point vs. non-point source contributions can be found based upon actual DEQ instream
sampling events. For example, DEQ monitoring for the South Fork above Wallace on April 15, 1994 (271 efs)
results in actual metal loads in the South Fork above Wallace of approximately 237 pounds/day zinc. 76 pounds/day
lead, and 1.75 pounds/day cadmium. The same load allocations for this flow tier m the TMDL (all point sources
above Wallace combined), as a percent of the actual instream load during the DEQ monitoring event, are only
0.54% for zinc, 0.05% for lead, and 1.07% for cadmium - all the rest of the loading is non-point. It is clear that the
total elimination of the "point sources" would not result in any appreciable reduction in system load.
Response: As noted in the responses to comments about effluent flow, the relationship between effluent and river
flow varies among discrete sources in the basin. Based mi the comment, it appears that the Morning
mine discharge does not "mimick" the adjacent river flow hydrograph or loading profile. While it is
important for the mine owner to recognize these characteristics of the discharge in planning controls,
these characteristics have no bearing on the calculated TMDL allocations, which derive solely from
the loading capacity of the river and the average effluent flowrate compared to other sources in the
area
The discussion of the relative loading of discrete and non-discrete loadings above Wallace is
technically flawed. The commenter is comparing current instream loads with the TMDL allocations
for discrete sources in order to argue that point sources are insignificant. The key missing information
to make this case is the current discrete source loading (the loading that occurred on April 15, 1994).
As noted m the TMDL TSD. F.PA used a dataset that included adit sampling to estimate relative
loadings and found that the zinc loading atx>ve Wallace is primarily released from discrete sources. If
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the existing discrete loadings are a significant percentage oi the instream load, then it stands to reason
that point source controls will reduce the instream load.
3 4 TMDL Implementation Issues Regarding Supertund Cleanup
Comment #1 Letter(s) 87,245
Actions surrounding the TMDL should include the cleanup of the metals in sediments of riverbed and banks.
Are there any plans to remediate the entire watershed downwind of the lead smelters and zinc plant stacks to prevent
silt-laden spring run-off?
Response: Through the Coeur d'Alene Basin-wide Remedial Investigation/Feasibility Study ("Basin-wide
RI/FS"), EPA, the State of Idaho, the Coeur d'Alene Tribe, and other governmental partners are
working to determine the impact from metals in sediments of riverbeds and banks an water quality and
ecological receptors This work may confirm a need for cleanup of metals in sediments, and identify
alternatives for conducting such cleanup activities.
Comment #2 Letter(s) 277, W13
To clean up the Coeur d'Alene River, why not go after the main source of contamination, the Bunker Hill site and
the central impoundment area tailings and mine dumps?
Response: The TMDL establishes allocations for all sources of contamination, including sources within the
Bunker Hill Complex. TMDL implementation for discrete and non-discrete sources within the Bunker
Hill complex will be addressed through the Superfund cleanup.
Comment #3 Letter(s) 234
How does EPA plan to eliminate the non-point metal load?
Response: EPA is evaluating potential cleanup alternatives for non-point sources in the Basmwide RI/FS.
Comment #4 Letter(s) 1,2,9,65,277
The accumulation of tons of tailings along the riverbanks will continue to pollute the river for years to come.
Response EPA and DEQ agree that the cleanup effort will take many years.
Comment #5 Letter(s) 258
The cleanup effort should focus on both cleaning up existing pollution and preventing recunlammation from other
potential sources of pollution
Response: EPA and DEQ agree that the potential for recontamination should be considered as cleanup proceeds.
Comment #6 Letter(s) 2,39
Has the EPA estimated the cost to treat the seeps from the Central impoundment Area (CIA) at the Bunker Hill
Suj>erfund site?
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Response: Installation at a low permeability cap on the CIA is expected lo drastically reduce infiltration of water
through the waste impoundment, from an estimated 177,000 to 1,560 cubic feet per acre on an annual
average basis EPA has evaluated the potential effectiveness and costs of collecting the remaining
seepage after cap installation. Because of the proximity of the CIA to the river, collection of seepage
would be difficult It is estimated that river water would comprise approximately 98% of the water
collected in trenches, while seepage would only constitute 2% of the collected water on average. A
screening-level study estimates the costs for a collection trench and pumping system (i.e., not
including treatment) of approximately $2 million. Given that the estimated volume of water collected
is in excess of 2 cfs, costs for a treatment plant would be significant. EPA plans to further evaluate the
CIA seepage issue after the cap has been in place for sufficient time to reduce the infiltration through
the impoundment.
Comment #30 Letter(s) 298
Under the Clean Water Act, the EPA can issue 106 orders to companies mandating cleanup wort Does EPA plan to
issue any 106 orders in the CdA Basin?
Response: EPA has authority to issue cleanup orders under Section 106 of CERCLA, not the Clean Water Act.
Exercise of EPA's authority under CERCLA Section 106 is a matter of EPA's enforcement discretion.
Before exercising this authority, EPA routinely seeks to achieve cleant^ wcrk thrcugh agreements on
consent. Such agreements may be entered in the form of Administrative Orders on Consent (AOCs)
and judicially approved am sent decrees (CDs). Both forms of agreement have been entered to
provide for limited cleanup activities in the Coeur d'Alene Basin, aid EPA remains engauged in
seeking further such agreements.
3.5 Monitoring
Comment #1 Letter(s) 267
Recently developed ultra-clean sampling and testing methods were not used throughout the data collection history,
which may prove to be problematic in assessing a source's 'reasonable potential to exceed* a given allocation. A
rationale and protocol should be developed to further data collection using only ultra-dean methods.
Response: Because the TMDL does not allow increases in current metals discharges, a "reasonable potential"
evaluation to determine whether a facility needs a permit limit for these metals is neither necessary nor
appropriate. EPA anticipates that all NPDES permits for sources identified in the TMDL will contain
effluent limits for cadmium, lead, and zinc consistent with the TMDL wasteload allocations.
For the vast majority of surface water stations and sources in the upper basin, metals concentrations
are relatively high and ultra-clean sampling techniques have not been necessary However, EPA and
DEQ agree that sources discharging at the lower concentrations associated with the wasteload
allocations may need to employ ultra-clean techniques to minimize the potential for false-positive
results from sample contamination. EPA and DEQ believe they should be used on a case-by-case
basis. EPA and DEQ can work with individual sources to evaluate the need for ultra-clean sampling.
Comment #2 Letter(s) 273
Areas that are identified as not requiring clean-up should be monitored to determine whether their status changes.
Response: EPA and DEQ would support follow-up monitoring in cases where new activities tn the watershed
could alter water quality.
Comment #3 Letter(s) 284
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There should be a re-evaluation of the TMDL after several years to address the results of identifying additional
point and non-point sources and monitor the effectiveness of the established control actions.
Response: EPA and DEQ acknowledge that re-evaluation and/or modification of the TMDL may be necessary' for
any number of reasons.
3.6 TMDL Implementation Issues Regarding NPDES Permitting
Comment #1 Lettor(s) 266,274
EPA asserts that 40 CFR 122,45 mandates that permit limits be based upon "total recoverable metal," thus requiring
the translator. This is not true, as evidenced by the intent of the regulation as explained in the Federal Register
notice accompanying the rulemaking (49 PR 37998). The proposed rule was promulgated "unchanged," identifying
the procedure for "using total recoverable metals as the general standard, unless otherwise specified in a guideline
or the permit writer determines other measures are appropriate." Although using "dissolved metals limits is being
strongly discouraged" by EPA in the rulemaking, "highly unusual cases to implement the dean Wafer Act" can
allow limits to be expressed as "dissolved" metals, but "metals limits in permits should be staled as total
recoverable." EPA's reinterpretation of "should" to "shall" has the effect of a new regulation and thus this action
violates federal APA requirements.
Response: Consistent with the letter of the applicable NPDES regulation, permit limits must be expressed as total
recoverable metals (40 CFR 122.45).
Comment #2 Letters) 266
EPA's use of the translator represents an inappropriate manipulation of data, science, mid regulatory intent
Response: The Idaho water quality standards for metals are expressed as dissolved metal concentrations.
Consistent with the letter of the applicable NPDES regulation, permit limits must be expressed as total
recoverable metals (40 CFR 122.45). Therefore, it is appropriate to translate a wasteload allocation
from dissolved metal to total recoverable metal EPA has published national guidance on translators,
and the irethod used in this TMDL is consistent with that guidance (see TMDL TSD).
Comment #3 Letters) 255
NPDES permits should be based cm concentration-based limits rather than load-based limits due to the difficulty for
treatment plant operators to respond to rapidly changing flows.
Response: Loading and concentration limits are a common requirement in NPDES permits, and the allocation
irathod for the South Fork and tributaries results in load-based allocations. EPA and DEQ believe the
use of flow-based allocations for the South Fork and tributaries (based on river flow) provides ample
flexibility for facility operators to address variability in both flow and metal concentration. This
flexibility has been a significant factor in the evaluation of alternatives for upgrade of the CTP at
Bunker Hill (See discussion of the CTP in an appendix to the TMDL TSD).
Comment #4 Letter(s) 245
The identified point sources should be required to use best available control technologies.
Response: NPDES permittees must achieve both technology-based and water quality-based limits. EPA
established a technology "level playing field" for mining sources in the 1982 effluent guidelines (40
CFR 440.103) Wliile KPA cannot prescribe the use of a particular technology, water quality-based
NPDES permitting in the Pacific Northwest has resulted in mines installing and operating technology
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more advanced than thai required by the 1982 guidelines. The use of sulfide precipitation at the Red
Dog mine is one example of the level of technology needed to achieve water quality standards. The
Coeur d'Alene TMDL, consistent with this trend, will likely require more advance technology than
that needed to meet the 1982 national effluent guidelines for this industry.
EPA has no technology-based requirements for metals in municipal discharges. Additional analysis of
the South Fork municipal discharges will be conducted as part of the permitting process.
Comment #5 Letters) 255
EPA expects dischargers to evaluate different treatment scenarios and let EPA determine what levels are reasonable.
These costs could be excessive, particularly for municipal dischargers. EPA should assist with the funding of these
studies.
Response: EPA and DEQ recognize the costs of technical evaluations and agrees that it is appropriate that EPA
assist the State of Idaho with identification of grants or other technical assistance funding for
feasibility studies for the municipalities that are located within the taker Hill NPL site.
Comment #6 Letters) 267
The TMDL states that the Conversion Factor (translator) for determining chronic dissolved criteria is 0.986. This is
confusing when viewing Table 6-12. The TMDL should present a table of translators for the various reaches and/or
point source dischargers where applicable, A data set showing any and all relationships between total recoverable
and dissolved should be included as an appendix.
Response: EPA and DEQ could not locate the statement regarding a conversion factor of 0.986 in the draft
TMDL documents. The difference between "conversion factors" and "translators" can be confusing.
A conversion factor con verts a total recoverable water quality criterion to a dissolved criterion (i.e.,
they are built into the dissolved water quality criteria equations). A translator converts a dissolved
wastetoad allocation into a total recoverable wasteload allocation. Translators are based on site-
specific data, where available.
For the Coeur d'Alene River and tributaries, dissolved wasteload allocations are translated into total
recoverable wasteload allocations based on actual river monitoring. The TMDL TSD presents a table
of the translators by reach. In response to the above comment, EPA and DEQ have included the
translator dataset in an appendix to the final TMDL TSD.
For the Spokane River, to implement the effluent criterion approach for lead, EPA and DEQ have used
the default conversion factor to convert the dissolved water quality criterion equation to a total
recoverable equation.
Comment #7 Letter(s) 267
The TMDL should consider a number of recommendations to address concerns by Publicly Owned Treatment
Works (POTW) operators along the Spokane River including*
1. A seasonal TMDL for the Spokane River
2 Recognizing the benefit to the river of the dischargers'effluent;
3 Establishing a clear and detailed sampling regime for NPDES permit writers;
4. Recognizing the inability of POTWs to implement source-control over domestic customers,
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5. Adding language for use by permit writers to provide additional flexibility such as "There could be
reasons why either a discharger or the state agency may want to have a [reasonable-potential-to exceed
(RPTE)J determination and possibly even a permit limit that was more directly tied to the hardness
based formula that is the standard. Such an approach would require that the discharger concurrently
monitor both the metals concentrations and the hardness and interpret the results in terms of the
hardness standard. Therefore a discharger may propose and demonstrate a method for a hardness-
based RPTE and limit derivation to the agency for consideration. Another important consideration is
when a discharger actually uses some of the river water, in which case, it should be allowed intake
credits.
Response: 1) The type of seasonal limits envisioned is not supplied in the comment. The effluent-criterion and
performance-based allocations are valid regardless of seasonal conditions in the river and result in
concentration-based allocations for the Spokane River fatalities.
2) The Spokane River dischargers are a benefit only in the context of (1) high metals levels in the river
from upstream sources and (2) providing additional loading capacity for other sources. It should be
noted thai if the Spokane River contained zero metals, the metals in these municipal discharges would
be degrading water quality (albeit not to a level exceeding standards).
3) EPA and DEQ do not believe a detailed monitoring plan for the NPDES permits is necessary in the
TMDL, though the agencies agree that the anticipated translation of TMDL wasteload allocations to
the permits should be considered in the TMDL development. These concerns have been addressed in
numerous elements of the TMDL, such as the NPDES translators and language pertaining to the
required averaging period for the wasteload allocations (monthly average).
4) EPA and DEQ acknowledge that the alternatives far reducing metals inputs from domestic users
maybe limited toeducauon programs.
5) The "reasonable potential" concept in NPDES permitting does not apply under the TMDL
allocation approach for the Spokane River, which will result in each facility receiving permit limits. If
a facility's metals discharge is below the effluent-based criterion, a performance-based allocation must
be established. If it is not, the effluent-based criterion is established as the allocation. EPA and DEQ
believe it is appropriate and necessary to include Limits in all permits for facilities discharging metals
in the Coeur d'Alene basin.
Comment #8 Letters) 267
The TMDL incorrectly states that EPA will begin developing and reissuing expired NPDES permits after the TMDL
has been adopted. Pre-certification draft permits were issued on April 19, 1999 and included mass loading limits for
metals that did not always include the 3 metals of concern. Public comment draft NPDES permits were issued on
June 18,1999 with the comment period closing on July 23, 1999 There should be greater
axxxlination/commumcation within the Region's Office of Water.
Response: EPA's Office of Water has coordinated NPDES permitting and TMDL development in the basin, but
the commenter is correct that the TMDL TSD did not note that the Spokane River permits were under
development at the time of the TMDL proposal. The NPDES permits for these facilities, issued in
October 1999, will be revised to incorporate the wasteload allocations in this TMDL.
Comment #9 Letter(s) 284
Renewal or initiation of NPDES permits far all point source discharges need to include appropriate monitoring and
compliance schedules.
Resjjonse: EPA and DEQ agree
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Comment #10
Letter(s) 272
Toxicity of metals is based on bioavailability. Using Total Recoverable analyses to ensure compliance assumes
physical changes in the water column will cxxur adversely to stream water quality. Given the conservative hardness
used to set TMDLs, it is not reasonable to expect toxicity to increase because hardness numbers are much higher
than set in the TMDLs. This ultra-conservative method continues to drive the discharge concentration to levels a
fraction of the Gold Book Criteria. This is neither necessary, reasonable nor attainable.
Response. EPA and DEQ have promulgated dissolved metals criteria based on analysis of metals bioavailability
However, EPA must express metals limits as total recoverable in NPDES permits pursuant to a long-
standing regulation (40 CFR 122 45). For this reason, metals translators were calculated to translate
dissolved wastdoed allocations into total recoverable wasteload allocations.
EPA has revised the hardness values in the TMDL (see comments/responses under Hardness
Assumptions).
Comment #11 Letter(s) 270
"Page 46 of the TSD indicates that the TMDL could be modified in the future pending adoption of site-specific
water quality criteria for the CdA River. If NPDES discharge permits are issued based an this TMDL and this
TMDL is later modified to better reflect the naturally mineralized conditions present in the CdA basin, how will
NPDES permits be adjusted accordingly? The anti-baclcsliding provisions outlined in Section 402 (o) of the Clean
Water Act seem to prohibit the issuance of NPDES permit limits with less stringent effluent limitations than those
contained in previous permits. EPA has not adequately addressed how effluent limits in NPDES permits issued
under this TMDL could change if the TMDL is later modified as specified in the TSD."
Response: Section 402(o) addresses anti-backsliding with respect to technology-based limitation. Section
303(dX4XA) of the Clean Water Act addresses the commenter's concern about modification of
effluent limits based on revised water quality standards. This section provides that, when there is a
TMDL in place, an effluent limitation may be relaxed if the TMDL itself is revised to (1) reflect the
changed wasteload allocation and (2) demonstrate that the new allocations will meet water quality
standards.
Comment #12 Letter(s) 284
Will each discharger be permitted to exceed the water quality criteria in the mixing zone? If so, this may not be
protective of the bull trout.
Response: Mixing zones cannot be authorized when ihe receiving water exceeds the criteria. It would not be
appropriate for dischargers in the Coeur d'Alene basin to receive mixing zone authorizations for
cadmium, lead, and zinc.
Comment # 13 Lelterfs) 274
When there is one discharger of a specific pollutant, the probability that it will simultaneously discharge at its
maximum monthly average flow and maximum monthly average effluent concentration is low. For example, if both
the maximum flow and maximum effluent concentration are assumed to occur at a 5% frequency (which is EPA's
assumption for the effluent limitations guidelines) and they are not correlated with one another; the probability of
both maximums occurring simultaneously is 0.25% (expressed as probability = 0.052)
However, for many pollutants, flows and concentrations are negatively correlated because of the dilution effect.
Thus, the probability of the maximum monthly average effluent How and the maximum monthly average effluent
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concentration occurring simultaneously may be even less than 0.25^ Region 10, by using the maximum monthly
average flow and concentration to calculate a discharger's |K>IIutant loading, has included a margin of safety thai is
[xXeniially as great as 20 (5% divided by 0 25%) tn the WLA analysis tor every individual discharger. This margin
of safety is caused by the overestimated frequency of occurrence of a maximum discharge loading of a target
pollutant that is inherent in Region 10's assumption.
It is intuitive that if the probability of the maximum effluent flow and maximum effluent concentration occurring
simultaneously in the discharge from a single point source is low, the probability of these conditions occurring al the
same time for two or more point sources is even lower. In fad, if the discharges are independent, the probabilities erf
occurrence are again multiplicative. Thus, if a single discharger has a 0.25% probability of discharging at its
maximum flow and maximum concentration of a pollutant simultaneously, the probability of this happening al the
same tm*; for two dischargers is 6.25 x 10"* (0.0625%). For 3 dischargers, the probability is 1.5 x 10"*. The
methodology used for development of the WLAs for this TMDL incorporates this overly conservative approach and
thus results in permit limits for point sources that may be technically unachievable
We recommend that instead of equating the calculated WLA values to maximum monthly averages, the TMDL
should consider these values as long-term averages. Permit limits should then be calculated by applying statistically-
based variability factors, based on the capabilities of metals removal technologies, to the long-term average
concentrations developed from the WLAs. Because it is virtually impossible for all point sources to be discharging
at their maximum monthly average loadings al the same lime, this approach will be protective of water quality.
Response: The establishment of wasteload allocations not to be exceeded on a monthly average basis has
nothing to do with the probability that the maximum effluent flow and concentration will occur on the
same day at an individual facility. The pertinent question is whether a daily discharge loading from
one facility in excess of its monthly average allocation is likely to be equally balanced by another
facility discharging a loading below the allocation. This question is then expanded to address the
problem of numerous facilities discharging simultaneously in the Coeur d'Alene basin.
The commenter provides no objective basis to conclude that meeting allocations on a long-term
average basis is more appropriate than the proposed approach of applying the allocations on a monthly
average basis. Therefore, the monthly average approach remains unchanged.
Comment #14 Letter(s) 274
The TMDL proposes to use a translate* procedure to calculate NPDES permit Limits for total recoverable metals
from the wasteload allocations for dissolved metals. According to the TMDL TSD, Region 10 has estimated the
ratios of total recoverable metals to dissolved metals using surface water samples collected at or near the target sites,
and has used the 5* percentile ratio as the translator. The resulting translators are shown in Table 6-12. The
proposed cadmium and zinc translator ratios have a value of 1.0, meaning that the permit limits for total recoverable
metals are set equal to the dissolved metals wasteload allocations. The lead translator ratios vary by target site from
1.0 to 3 2.
EPA's translators are not technically supported because the relationship between the translator and stream flows was
not examined, and the proposed TMDL is based on stream flow. The TSD does not present the actual data used in
the calculations and, more importantly, the total suspended solids concentrations that were associated with each total
recoverable: dissolved metals sample pair are not provided. Because the TMDL loading allocations vary as a
function of stream flow, it is probable that the dissolved total recoverable metals ratio will vary because suspended
solids concentrations will correlate with stream flows Al high stream flow rates, mere suspended concentrations
can be achieved by the treatment process. For example, the monthly variability factor that EPA estimated for the
metals subcategory in the proposed centralized waste treatment facility effluent guidelines and standards was 1.57
times the long-term average achievable metals am central ions (as a group), based on analysis of 20 samples per
month In this example, the target metals concentrations were about two to three orders of magnitude greater than
the target effluent concentrations tor the TMDL. It is typical for the variability factors to increase as the long-term
average concentration decreases because even acceptable analytical precision can account for concentration
variations of a factor of 2 to 3 times the true concentrations at these trace metals levels. Consequently, treatment
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systems would have to achieve long term average concentrations on the order of 0.05 ^g/1 for cadmium, 0 075-0 125
ug/l lor lead, and 3.5-5 ug/1 tor zinc.
Response* EPA and DEQ disagree that the translators are not technically supported. The method used to
calculated the translators is consistent with EPA's national guidance. The available data are provided
in an appendix to the final TMDL TSD
EPA and DEQ recognize that effluent variability is an important factor in designing treatment and
control systems to meet permit limits. However, the generalization that specific concentrations must
be met by each of the facilities in the basin is not appropriate, because flow management and recycling
would directly affect the concentration requirements at a given facility.
Comment #15 Letter(s) 274
EPA and DEQ have specifically requested comment on the proposal to set NPDES permit limits as monthly average
loads. While Asarco believes it is premature and ill-advised to develop a TMDL now far use in setting NPDES
permit limits, Asarco agrees in principle that any NPDES permit limits should be expressed as monthly average
limits. It would be impractical, if not impossible, for a permitted point source to ensure compliance with daily
maximum permit limits because those limits depend on the flow rate which can vary significantly from day-to-day,
depending on numerous uncontrollable factors, such as rainstorms, snowpack, and temperature. Often, there can be
a lag period between change in a stream's flow rate and an increase in metals loading to the stream. Accordingly,
any limits that result from a TMDL should be set based on monthly average loadings.
Response: The proposal to apply the wasteload allocations to monthly average discharges is not based on the
difficulties faced by an individual facility in meeting a daily maximum limit. The pertinent
question is whether a daily discharge loading from one facility in excess of its limit is likely to be
equally balanced by another facility discharging a loading below the limit, when both are
achieving monthly average limitations. This question is then extrapolated to the numerous
facilities discharpng simulaneously in the Coeur d'Alene basin.
EPA and DEQ believe that it is reasonable to apply the allocations on a monthly average basis,
given the number of facilities and the expected timeframe for recovery in this basin. If a more
stringent approach is needed in the future, the TMDL can be revised accordingly.
3.7 TMDL Implementation Issues Regarding Effluent Trading
Comment #1 Letter(s) 266
The TMDL slates EPA has "not issued final guidance or regulations on acceptable trading mechanisms" for
"effluent trading " There is no authority under the CWA for this activity because Congress did not intend for CWA
Sec. 303(d) to result in such an outcome.
Response: EPA and DEQ agree that the Clean Water Act does not explicitly authorize effluent trading
mechanisms. At the same time, the Act does not preclude an effluent trading mechanism. In general,
EPA and DEQ believe that the potential benefits and pitfalls of a trading mechanism should be
considered im a case-by-case basis in developing TMDL allocations or NPDES permit limits.
Comment #2 Letter(s) 262,274
The published information and the verbal discussions were silent on the exchanging of individual point source
loadings What are the EPA's thoughts cm this?
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If EPA and DBQ proceed with promulgation of a TMDL lor (he Coeur d'Alene Basin, they should allow sources to
trade allocations in order to achieve compliance. This would be consistent with EPA's recognition in the context of
watershed planning that effluent trading is an effective and useful approach to achieving water quality objectives.
Hie allocation method should provide ft* trading of load allocations among pomt sources and non-point sources,
which would be limited to the TMDL for each stream segment lo assure that water quality criteria will be met.
Trading will improve the economic efficiency of the TMDL implementation and is consistent with EPA's national
policy.
Response: EPA briefly discussed effluent trading in the TMDL TSD (see appendix to TMDL TSD on allocation
alternatives). EPA and DEQ have not received specific proposals for either a basin wide trading
mechanism or specific trades between sources. Therefore, the allocation method remains unchanged
in this respect. The agencies believe certain aspects of the pollution problem in the Coeur d'Alene
basin will represent major obstacles to effluent trading, including:
1) difficulty quantifying current loadings & expected reductions from specific acupoint source areas
2) multiple responsibilities of parties under CERCLA and CWA
3) magnitude of impairment and prospects for attaining standards in long term
4) need for a standard set of trading rules rather than case-by-case trades (and TMDL modifications)
During implementation of the TMDL, EPA and DEQ will consider trading proposals that address
these concerns and demonstrate that the trading mechanism will make significant progress toward
achievement of water quality standards.
3.3 TMDL Implementation Issues Regarding Economic Considerations
Comment #1 Letters) 56.255,302,
W6
According to reports in our newspapers, the cost of just bringing the South Fork Sewer District Treatment Plant up
to the point where the discharge would meet the Gold Book requirements would cost every patron $6400 plus $700
additional annual fees. Upgrading the Page plant to treat metals would cost S10-S20 million.
Response: EPA believes the cost figures cued in this comment are probably based on an assumption that the
most costly treatment alternative considered for the Bunker Hill CTP (evaporation technology) would
be necessary for the municipality to meet the TMDL allocations. EPA and DEQ have less
information about the options for reducing metals levels in the municipal treatment plant discharges
than it does for mining sources such as the CTP. While EPA and DEQ cannot substantiate the cost
estimates cited in the comment, the agencies remain particularly concerned about the potential costs
of the TMDL to local communities For this reason, EPA and DEQ have outlined the process for
obtaining a variance from the TMDL requirements.
Comment #2 Letter(s) 301.C2.C11,
C21, C22, W13
Request that EPA conduct an economic impact analysis regarding the proposed TMDL standards.
Response: An economic impact analysis is not required under the Clean Water Act or implementing regulations
for TMDLs However, EPA and DEQ will review individual requests for variances from the TMDL
requirements during the NPDES permitting process. In its variance application, a facility may supply
information to the agencies about the economic impact of meeting the effluent limitations based on
ihe wasteload allocations If achieving the effluent limits wnuld result m substantial and widespread
economic and social impact, j variance car, provide regulatory relief provided the facility makes
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"reasonable further progress" toward achievement of the effluent limits (see discussion under
Regulatory Options and the variance provisions in the Idaho water quality standards).
Comment #3
Letter(s)
258
The health and safely of residents and visitors to the Coeur d'Alene basin is a more important consideration than
economic well being.
Response: EPA and DEQ acknowledge the comment.
EPA and DEQ should work with dischargers to identify and obtain funding to upgrade existing treatment
operations. Further, variances and/or shifting the reduction requirements to other sources or source sectors would
be acceptable as long as reductions in overall loadings are achieved.
Response: EPA and DEQ will work with municipalities to identify funding sources far facility inqprovements.
As discussed in other responses, the agencies will consider requests from dischargers for regulatory
flexibility. EPA and DEQ have not received specific requests for variances or effluent trades to date.
Comment #5 Letter(s) 258
A "sinking fund" should be established to fund both the cleanup of the basin and the ongoing maintenance that will
be required for the foreseeable future. Punding could be obtained from the parties responsible for the pollution
over time as well as federal, state and local sources.
Response: EPA and DEQ agree that a single cleanup fund would have advantages. Until a basin wide agreement
among all public and private entities is in place, the agencies will continue to direct cleanup actions
using a variety of funding sources.
Comment #6 Letter(s) 106,018
A fund should be started to clean up the river.
Response: EPA and DEQ cleanup programs continue to pursue funding for the cleanup of the metals
contamination in the CdA Basin.
Comment #7 Letter(s) 254
Failure to improve water quality will actually discourage new businesses from mowing into the area.
Response. While the agencies cannot speculate on the affect of not cleaning up the basin on business
development, EPA and DEQ believe that the TMDL and RI/FS will serve to reduce current
uncertainty about regulatory requirements for new businesses in the basin.
Comment #8 Letter(s) 250
Local, state, and congressional leadership should be seeking funding to offset the costs of implementing the
TMDL.
Response EPA and DEQ acknowledge the comment
Comment #4
Letter(s)
255,259
97
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3 9 TMDL Implementation Issues Regarding Removal Technologies
Comment # 1 Letter(s) 87
How do you recover the metals from the CdA River and lake, and is the yield then recycled through a smelter?
Response: EPA and DEQ do not anticipate the re-milling of tailings wastes to recover metals. Metals loadings
to the water column in the liver can be reduced through a variety of actions including physical
removal to capped waste repositories (such as the Central Impoundment Area in Kellogg) and
wastewater treatment of mining and municipal wastewaters.
Comment #2 Letters) 132,138
EPA should physically remove contaminated sediments from the lakes and rivers.
Response: Removal of contaminated sediments from the floodplain is ongoing. EPA and DEQ continue to
analyze the feasibility of sediment removal from the lateral lakes.
Comment #3 Letter(s) 143
New mining methods should be developed to reduce the amount of pollutants and environmental impacts.
Response: EPA and DEQ have noted that water management and wastewater treatment measures appear to be
options for achieving reductions in metals loadings. EPA and DEQ also encourage the mining
industry to consider different mining and milling methods where feasible. The mines in the CdA
basin have not provided any information to the agencies about the potential for adjusting mining and
milling methods to reduce loadings.
Comment #4 Letter(s) 145
Plugging the discharges from existing mines and covering contaminated soils with impermeable material would
reduce pollutant loadings.
Response: EPA and DEQ agree that these actions would reduce metals loadings.
Comment #5 Letter(s) 205
The TMDL Technical Support Document does not indicate any analysis or consideration given to the effects of
ongoing remediation activities or natural attenuation.
Response: EPA and DEQ solicited public comment on attenuation, and the subject is discussed in an appendix
to the TMDL TSD. The effects of specific remediation actions on water quality are difficult to
quantify with confidence, but it stands to reason that actions such as removing tailings wastes from
the floodplain will improve water quality over time.
Comment #6 Leuer(s) 132
EPA should reroute the stream channel to gel the stream away from the contaminated sediments already in the
streambeds.
98
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Response: EPA and DEQ have directed some channel construction work around the Bunker Hill sue and will
continue to consider stream channel actions to reduce metals loadings.
Comment #7 Letter(s) 97, 130, 156,
162
Build temporary dams or dikes between the tailings and the river to keep the contaminated sediment out of the
river.
Response: In some cases, tailings are "cribbed" in waste piles above the rivers; in others, the tailings are
incorporated into the river sediments themselves. Replacing failing cribs with walls or retaining
structures is an option for reducing pollutant loads, as is removal of waste pile material to a more
permanent and capped waste repository.
Comment #8
Letter(s)
118, 121, 123,
131, 136. 141,
149, 158, 179,
200
Develop a filter that could remove pollutants from the river.
Response: Filtration is a relatively common method of wastewater treatment at mining facilities, because filters
can remove metals absorbed to small particles in the wastewater. EPA and DEQ are not aware of any
application of filtration technology to an entire river or creek. Even if this was economically feasible,
filtration would not remove metals that are predominantly in the dissolved phase (notably zinc and
cadmium in CdA basin waters).
Comment #9 Letter(s) 262, W14
The proposed regulations are not realistic and certainly not affordable. We are already suffering from 18 years of
economic depression. The proposed regulations will wipe out our people's savings by reducing the value of their
homes.
Response: EPA and DEQ recognize the concerns about the potential economic impact on municipalities and
their residents. See discussion under Regulatory Options. The agencies note that the TMDL is not a
regulation or a rulemaking.
Comment #10 Letter(s) 78,79,80,81,
82, 83, 84, 85,
86, 88, 89, 90,
91,92,95, 96,
98, 99, 100,
101, 103, 104,
105, 108, 116,
117, 118, 120,
121, 122, 123,
124, 125, 126,
127. 128, 129,
' 130, 131, 133,
134, 135, 136,
137, 138, 139,
140, 141, 142,
143, 146, 147,
99
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148,
149,
150,
151,
152,
153,
154,
155,
157,
158,
159,
160,
161,
162,
163,
164,
165,
166,
167,
168,
169,
170,
171,
172,
173,
174,
175,
176,
177,
178,
179,
180,
181,
182,
183,
184,
185,
186,
187,
188,
189,
190,
191,
192,
193,
194,
195,
196,
197,
198,
199,
200,201
Ranting of hybrid poplar trees along the river would be a good method far biaremediatian of metals in the river
water and soils. In addition, these trees will help keep soils in place during floods.
Response: As part of the Basin-wide RI/FS, EPA and others are evaluating various treatment options.
Bioengmeered solutions are one category of options bong considered. Although these trees may take
up and fix some trace metals, it is not expected that sufficient root mass would be developed to
significantly lower metals concentrations in-stream. Additionally, capping or sol removal may need
to accompany the planting of any vegetation so that the plants do not attract wildlife to contaminated
soils and so that the plants do not become an additional contaminant vector.
Comment #11 Letter(s) 118, 155, 170
Find a chemical to counteract the pollutants and reduce them to an acceptable level.
Response: Chemical addition (e.g., using lime and sulfide to precipitate metals) is a proven method to remove
metals from mining wastewaters.
4.0 Other Issues
Comment #1 Letter(s) 266
The TMDL states that "Flow-based allocations can be incorporated into daily maximum and monthly average
effluent limitations." We are under the impression that the wasteload allocations are based upcm the chronic
instream value Will there be an additional upward adjustment to reflect an acute value?
Response. NPDES permit limits must implement both acute and chronic criteria in the Idaho water quality
standards. The TMDL allocations, when incorporated into an NPDES permit, will implement the
chronic criteria EPA will evaluate the need for additional limits to implement the acute criteria on a
case-by-case basis in the NPDES permitting process for individual facilities.
Comment #2 Letier(s) 241
100
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The Little North Fork of the Coeur d'Alene River was not specifically mentioned and included as part of the CdA
basin. The Little North Fork should be specifically identified under the Designated Uses section for the North
Fork of the Coeur d'Alene River and identified as being "protected for one or more of the following designated
uses." Further, the document should clarify whether the Little North Fork is included in the designation as a
"Special Resource Waters."
Response. EPA and DEQ do not believe the suggested level-of-detail regarding the Little North Fork ts
warranted, because this TMDL does not address water quality issues in tributaries of the North Fork
Coeur d'Alene River. The current metals loadings from the North Fork are factored into the loading
capacity and allocations for the mainstem Coeur d'Alene River.
Comment #3 Letter(s) 266
The TMDL states that "Tables F-l through F-5 indicate approximate concentrations that would have to be
achieved to meet the assigned loadings ..." These tables do not have either concentrations or information
allowing the calculation of concentrations in a discharge.
Response: Tables F-l through F-5 in the draft TMDL TSD contained columns with loadings, concentrations,
and discharge flowrates. Revised tables are included in the final TMDL TSD that include loads and
flowrates. Concentrations can be calculated by dividing the load by the associated flowrate.
Comment #4 Letters) 266
The proposed TMDL states that "EPA and the State erf Idaho continue to fund and implement clean-up activities in
the 21 - square mile study area." It also must be mentioned here the millions of dollars being spent by industry. We
also would suggest that the above statement be modified to reflect that "Federal and state tax dollars continue to
fund.,
Response: EPA and DEQ agree that cleanup funding by industry should be noted in addition to agency funding
from tax revenue.
Comment #5 Letter(s) 266
On Table 6-6 the "total loading capacity" for dissolved cadmium on the "South Fork Above Wallace," at a 14 cfs
flow, is given as 0.0277 pounds/day. It appears that the value should be 0.02869 pounds/day. Is this simply an
error or is there an additional "margin of safety" being imposed? All of the calculations should be verified.
Response: The values cited in this comment are no longer relevant, because the TMDL has been revised. All of
the steps m the calculation of allocations are clearly set forth in the TMDL TSD. The explicit portion
of the margin of safety is 10% of the loading capacity, there are no additional subtractions. EPA has
endeavored to run checks on the calculations in the final TMDL.
Comment #6 Letter(s) 266
The TMDL (erroneously! states that "Outfall 002 into the South Fork (from a waste rock pile)" comes from the
Star/Morning mine. Tins is a NPDES permit point source discharge that (presumably) is understood by the EPA.
The source of the water is groundwater seepage from the adit and surface water runoff.
Response: The Star/Morning 002 discrete discharge emanates from the bottom of a waste rock pile prior to
discharge into the South Fork As indicated in the comment, this discharge consists of a combination
of adit drainage and surface water runoff
101
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Comment #7
Letter (s) 266
The reference list of documents in the TSD was only available in EPA Region X offices in Seattle. But all
references were not available for review, even in the Seattle location We do appreciate the assistance of EPA
Region X personnel in our review of those documents that were available, but we believe thai the basis of the
TMDL mast be available locally for review.
Response: This comment appears to be in reference to an informal request for information during the comment
period. EPA responded appropriately to this request by voluntarily making the requested references
available for review by the commenter. For the final TMDL, EPA and DEQ plan to make a copy of
the administrative record available for review at DEQ's Coeur d'Alene field office.
Comment #8 Letters) 266
It is not clear whether all sample events in Table 5-1 were included in the "n" value of Table 5-2. If they were not,
there needs to be an explanation; or if they were, it should be so stated. It is also not clear whether all the flow tiers
(7Q10, 10/50/90th %) are represented in die data set. If not, it is unclear how the "seasonal variations" can be
determined. The CWA, at Sec. 3G3(dXlXQ. is quite clear that seasonal variations "shall* be accounted for. Thus,
it is confusing how a single sample event can meet the statutory mandate. The TMDL should be clarified.
Response; Table 5-2 contains data from sources cited in the detailed footnotes to the table. This information
was the best available information during TMDL development. At some sites (including the target
sites along the South Pork Coeur d'Alene River), a significant amount of data has been collected over
a wide variety of flow conditions, while at others there is a relatively small amount of surface water
quality data. The commenter has not noted any specific problems with this reported data or the
footnotes to the table.
Seasonal variation is addressed through the application of a variable loading capacity approach using
flow tiers. The data portrayed in Table 5-2 were not used in the development of TMDL elements
addressing seasonal variation (note that the TMDL itself does not contain or reference this data).
Rather, the Table 5-2 data were provided as information about the measured metals levels in surface
waters in this area.
Comment #9 Letter(s) 266
The proposed TMDL mentions that both Granite Creek and the North Fork of the Coeur d'Alene River "are
designated as Special Resource Waters in Idaho." The statement does not appear to be relevant to the TMDL.
There are several reasons why a water may have such a designation, as clearly outlined in Idaho regulations at
IDAPA 01.02.056. If the specific reason why a water has such a designation in Idaho would be "outstanding high
quality," then perhaps the designation was in error in the first place if current conditions warrant a TMDL. It is a
fact that water quality has steadily improved in the basin since the 1960's and that there is a finite amount of
historic material in the system. Common sense dictates a continuation of water quality improvements given the
finite amount of! each able materials.
Response: The TMDL statement about the designation of these particular waters was provided as background
information
Comment #10 Letter(s) 269,270
Paragraph 2, page 44 of the TSD states "hydroxide precipitation is currently employed at the Bunker Hill Central
Treatment Plant, which is the only facility in the basin that employs metals removal technology (other than settling
ponds)," This statement is not true and demands correction Every operating mine in the valley currently utilizes
some form of metal removal technology other than settling
102
-------
Response;
EPA and DEQ acknowledge that some facilities add chemicals to waste streams and optimize the
metals-removal performance of their settling ponds. The Bunker Hill facility is the only mining
facility currently using a mechanical wastewater treatment plant designed for removal of metals.
Comment # 11 Letter(s) 273
Request that digital maps and data sets be made available on the Internet to the public, universities, schools, and
corporations.
Response; EPA made data and maps supporting the TMDL available in both hard copy and on the Internet
during the comment period, EPA will continue to share data collected as part of the RI/FS with the
public through a variety of media, including load information repositories (e.g., libraries).
Comment #12 Letter(s) 274
There are a few minor errors in the description of water quality criteria from the National Trades Rule. The
proposed TMDL gives the same general equation for all three metals as:
Criteria = 0 986(exp(a(ln(hardness))-bJ)
Table 4-1 in the TMDL gives the values of "a" and "b" in the above equation, which are different for each metal.
The value of "b" for zinc in Table 4-1 should have a minus sign in front of it. The "0.986* value in the above
equation, which is a dissolved correction factor (CF), is correct for zinc, but not for lead or cadmium. The CP for
lead and cadmium is hardness based and is given in the National Toxics Rule as:
Cadmium CF= 1.101672 - [0.041838 Inwardness)]
Lead: CF= 1.46203 - [0.145712 ln(hardness)|
If the above equations are used with the exponential part of the criteria equation above, the calculated criteria values
for lead and cadmium are slighdy different than those given in the TMDL. Our calculations result in criteria for
cadmium of 0.37 micrograms per liter (pg/1) and 0.31 ^g/1 for a hardness of 25 milligrams per liter (mg/1) and 20
mg/1. respectively (Table 4.1 values are 0.38 Mg/1 and 0 32 Mg/1). and values for lead of 0.54 Mg/1 and 0.42 Mg/1
(Table 4.1 values are 0.54 Mg/1 and 0.41 Mg/1).
Response: EPA and DEQ agree that the TMDL TSD did not list the equations correctly. The revised TMDL
TSD has been corrected. While the notation in the TMDL TSD was problematic, the calculated
criteria values listed in the TMDL TSD and used in allocation calculations were correct, as indicated
by the nearly identical values calculated by comment er
Comment #13 Letter(s) 22,60,72,204,
215, 277
Disagree with EPA's involvement in implementing the proposed TMDLs and suggest that no action be taken.
Response: The Technical Support Document outlines the basis for issuance of this TMDL by both EPA and the
State of Idaho. EPA is also obligated undo* federal law to be involved in the implementation of the
TMDL (e.g., EPA is the NPDES permitting authority in the State of Idaho)
Comment #14 Letter(s) • 203
Section 5 2 of the April 1999 Technical Support Document identifies several important data limitations that increase
the uncertainty of decisions related to establishing TMDL values. Are the available data appropriate to support
103
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establishing TMDL values? Also, what is the EPA's identified level of acceptable uncertainty that is appropriate for
proposed TMDL decisions?
Response; As stated in the Technical Support Document, EPA and DEQ believe the available data provide for
development of a sound and reasonable TMDL. EPA does not have an identified level of acceptable
uncertainty for TMDL decisions. The Clean Water Act recognizes the inherent uncertainties in TMDL
development in the requirement for a margin of safely
Comment #15 Letters) 205
Under the Federal Water Pollution Control Act, EPA was required to conduct a careful investigation" and to
cooperate with state water pollution control agencies, interstate agencies, and 'the municipalities and industries
involved" (Water Pollution Control Act Section 102(a)). What consultation occurred before ihe public meetings?"
Response: This TMDL is issued under the authorities of Section 303(d) of the Clean Water Act. EPA and DEQ
met with numerous affected parties prior to the release of the draft TMDL. It should also be noted that
there is no obligation to do so under Section 303(d).
Comment #16 Letters) 203,208,295
Based an information available to the public, it is not clear that the planning and assessment steps supporting the
proposed TMDL are documented.
Response: The final administrative record for the TMDL documents all of the information used to support this
action.
Comment #17 Letter(s) 284
The Coeur d'Alene Tribe feels that the water quality within the Coeur cfAlene basin has been greatly mismanaged
by federal and state water quality managers by not considering the basin's water as a whole, but rather as parts
which fit into different jurisdictions.
Response: EPA and DEQ agree that junsdicational lines can impede progress in the waterbody as a whole. This
TMDL has been developed with the intent of analyzing and managing the water quality problems
holisucally, across jurisdictional lines.
Comment #18 Letter(s) 115
Mining companies have been cleaning up the area and revegetating the disturbed areas, and lead levels in blood are
dropping. These things should be acknowledged.
Response: EPA and DEQ acknowledge that the mining companies have funded a number of cleanup projects in
the basin to date. Again, this TMDL is focused on aquatic life rather than human health, but EPA and
DEQ do acknowledge that blood lead levels m humans have dropped over time as cleanup and public
education projects have proceeded.
Comment #19 . Letter(s) 207
104
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To be consistent with other listings of water bodies with contaminated sediments in the state and nation, the Coeur
d'Alene Basin/Spokane River sediment issue will need to he addressed under Section 303 of the Clean Water Act
Washington's proposed metals TMDL purposely did not address the particulate fraction since it was assumed that
the Idaho metals TMDL would provide specific goals for controlling the sources of stream bed sediment loads in
the Coeur d'Alene Basin as was originally proposed before the EPA took over the TMDL development.
Response: As stated in the TMDL and supporting documents, this TMDL addresses dissolved metals
contamination of the water column. Therefore, contaminated sediments in the floodplain are treated as
a source of metals to the water column in this TMDL. A TMDL focused on floodplain sediments
themselves is a distinctly different endeavor. Contrary to the suggestion in this comment, neither EPA
nor DEQ have begun such a TMDL. Rather, DEQ is working on a "clean sediment" TMDL, focused
an physical impairments to habitat from excess sediment delivery (and not on chemical quality of
sediments).
There are a number of unresolved issues pertaining to any future TMDLs for contaminated sediments
in Idaho. Hie state of Idaho does not have sediment quality standards for metals and other
contaminants. Therefore, these waters are not currently 303(d)-listed for sediment contamination.
Even if the waters are listed as impaired in the future, characterization and quantification of the
allowable particulate load to protect downstream sediments will be a major technical challenge,
requiring significant time and resources to complete. EPA and DEQ bdierve this TMDL is
appropriately focused on the water column first, and this focus does not preclude further work in the
future (including ongoing Superfund evaluations) on other aspects of the pollution problems in this
river system.
Comment #20 Lettafs) 273
The TMDL only addresses dissolved cadmium, lead and zinc. No standards are proposed for the loading of
suspended solids. Only addressing the dissolved fraction (as opposed to the total metals level) will not adequately
reflect the true water quality parameters needed to support a healthy ecosystem TMDL criteria are needed for total
suspended solids.
Response: EPA and DEQ have determined that the dissolved fraction of these metals in the water column is the
greatest concern from a toxicity standpoint, and the focus on dissolved metals is consistent with the
requirements of the Idaho water quality standards. EPA and DEQ agree that this TMDL does not
address either "clean" or contaminated suspended solids. However, DEQ has proposed a TMDL for
sediment to address habitat concerns in the Coeur d'Alene Basin. This TMDL will likely be revised
and expanded in the coming year. In addition, contaminated sediments may be addressed in this
TMDL.
Comment #21 Letterfs) 216,218
What is the EPA doing to protect the Silver Valley Aquifer?
Response. EPA is analyzing groundwater contamination and remediation alternatives as part of the RI/FS for the
basin.
Comment #22 Letter(s) 155
Flood prevention within the basin needs to l>e addressed.
Response: EPA and DEQ recognize that water and runoff management are important elements m the cleanup
project.
105
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Comment #23 Letter(s) 167
Is it possible to give schools a chance to participate in adopting a part of the stream and plant hybrid poplar trees?
Response: If planting of trees along a segment of stream channel is selected as a remedy in the RJ/FS process,
EPA and DEQ would welcome school participation in planting and maintenance. These decisions will
be made after completion of the RI/FS.
Comment #24 Letters) 267,255,203
The derivation of proposed TMDLs for the Coeur d'Alene Basin surface waters was apparently not performed using
guidance issued by EPA's Quality Assurance Division. That guidance was prepared in response to EPA Order
5360.1 entitled Policy and Program Requirements to Implement the Quality Assurance Program. One objective of
that guidance is to support defensible decision-making.
The EPA should use all seven steps of the DQO process to identify alJ decisions that support the proposed TMDL
and make this documentation available to the public.
Response: There is no legal requirement to use DQO process steps in a TMDL, nor is it clear how the DQO
process would improve this TMDL. EPA and DEQ have identified all data sources and technical
decisions supporting the TMDL in the Technical Support Document.
Comment #25 Lelter(s) 118
Educate local businesses to encourage them to be more proactive m addressing pollution issues.
Response: EPA and DEQ will continue to meet with municipalities and industry to discuss the best ways to
reduce metals loadings.
Comment #26 Letter(s) 154
The TMDL would just be a policy to ease people's minds, but would accomplish nothing.
Response: EPA and DEQ disagree. This TMDL is one of the first attempts to hoiistically analyze metals
impairment in the CdA Basin (the RI/FS is another), and it is the first action to assign responsibility
for source cleanup in the context of a basmwide framework. The TMDL allocations will be
incorporated into NPDES permits and will therefore directly affect the amount of pollution entering
the stream from discrete sources. It also serves an important purpose of clarifying applicable water
quality standards across jurisdictions of the State of Idaho, Coeur d'Alene Tribe, and State of
Washington, and it translates these standards into loading goals for the Superfund cleanup,
Comment #28 Letter(s) 64,66,147,04.
W1
With respect to lead, the EPA should report its assay numbers regarding oxide lead separately from an assay for
total lead and an assay for sulfide lead. Oxide lead, as PbO, is the part that is harmful to animals and humans, not
the total lead as reported by the EPA.
Response: The TMDL goal is to identify controls necessary to meet Idaho water quality standards for metals
Idaho standards for protection of aquatic life from metals, including lead, are expressed as dissolved
106
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metal. The total recoverable measure is also used in the TMDL, because NPDES permit limits for
metals must be expressed as total recoverable by regulation. Neither the water quality standards nor
NPDES regulations include oxide lead as a regulatory measure for aquatic life protection
Comment #29 Leiter(s) 252,02
Don't penalize the existing mining operations ft* problems related to mining in the past (supporting 2 major wars).
Response: The TMDL must be designed to achieve water quality standards. With respeel to operating mines, the
discrete wasteload allocations for their discharges of metals, combined with reductions from other
sources, are necessary to achieve the standards. EPA and DEQ believe the mines can achieve these
allocations at costs that are consistent with pollution abatement practices in use at mining facilities in
other regions of the country.
Comment #30 Letter(s) 24,25,47,54,
55,215, 263,
017, 024, 026
If the EPA considers the Coeur d'Alene River watts- so dangerous, and in need of such restrictive regulation, why
are long-time residents not suffering any significant adverse health effects from living in the valley?
Response: This TMDL action is focused on aquatic life protection, not human health concerns. EPA and DEQ
have not portrayed metals in basm waters as "dangerous" to residents, but rather as harmful to fish and
other aquatic life.
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Appendix A: Comments Log
108
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h
Name/Org
Date
Comments
Received
#
Name/Org
Date
Comments
Received
1
John/Irma Pickard
4/26/99
2
Mary Wieman
5/5/99
20
Robin Stanley Superintendent
Mullan School District #392
5/17/99
3
Shirley Hindley
5/11/99
21
South Fork Coeur d'Alene River
Sewer District
5/17/99
4
Shoshone County Commissioners
5/12/99
22
Michael Stevenson
Silver Valley People's Action
Coalition
5/17/99
5
Doug Stiles
Lucky Riday Mine
5/13/99
23
Robert Stovem
Stovern Supply Co
5/17/99
6
Michele Nanni
The Lands Coimal
5/13/99
24
Dee Sverdsten
5/17/99
7
Sharon Waldo
Kellogg Chamber of Commerce
5/13/99
25
Jeanne Batscn
5/18/99
8
Rose Zieja
5/13/99
26
Greg Godwin, Superintendent
Joint School District #391
5/18/99
9
Vanner Hegbloom
Local 5114 USWA
5/13/99
27
South Fork Coeur d'Alene River
Sewer District
5/19/99
10
Kenneth/Joann Branstettef
5/13/99
28
Sherry Krulitz
Shoshone County Commissioner
5/19/99
11
Roger Mangum, Mayor
City of Kellogg
5/13/99
29
Walter Hadley
Kellogg Planning & Zoning
Commission
5/19/99
12
Robert (Rick) Richins
Coeur d'Alene Mines Corp
5/14/99
30
Larry Watson
Idaho House of Representatives
5/20/99
13
Bill Dire, Jr.
Wallace City Council
5/14/99
31
Roy/Nancie Burkhart
5/20/99
14
Larry Watson
Idaho House of Representatives
5/14/99
32
Roy/Nancie Burkhart
5/20/99
15
Tamra Schlittenhart
5/14/99
33
Clyde Peppin
5/20/99
16
Joe Peak
Bnaville Resort
5/14/99
34
John Amonson
5/20/99
17
Tom Fudge
Hecla Mining Co, Lucky Friday Mine
5/14/99
35
Shirley Hindley
Coeur d'Alene Assn of Realtors
5/20/99
18
Buell Hollisler
Kootenai Environmental Alliance
5/17/99
36
Doug Stiles
Hecla Mining Co
Lucky Friday Mine
5/20/99
19
Nancy Vandeventer
Wallace Schools Superintendent
5/17/99
MeJinda
109
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#
Name/Org
Date
Comments
Received
#
Name/Org
Date
Comments
Received
37
Randall Anderson
Hecla Mining Co
5/20/99
W13
Roger Mangum
Mayor of Kellogg
5/18/99
38
Roger Mangum
Mayor of Kellogg
5/20/99
W14
Duane E. Little
Shoshone County Assessor
5/18/99
39
DuaneE Little
Shoshone County Assessor
5/20/99
W15
Mike Carlson
Silver Valley Resources
5/18/99
40
Jade King
Shoshone County Commissioner
5/20/99
W16
Bill Dire
Wallace City Council
5/18/99
W17
Bret Bowers
Community Leaders for EPA
Accountability Now! (CLEAN)
5/18/99
W1
W.M. (Bill) Calhoun
W. M. Calhoun. Inc.
5/18/99
W18
Rick Richins
Coeur d'Alene Mines
Corporation
5/18/99
W2
Tom Fudge
Heel a Mining Co.
Lucky Friday Mine
5/18/99
W19
Joe Peak
Enaville Resort
5/18/99
W3
Ross Stout
South Fork Coeur d'Alene River Sewer
District
5/18/99
W20
Jack King
Shoshone County
Commissioner
5/18/99
W4
Harry Cougher
Sunshine Mining Co.
5/18/99
W21
Sherry Krulitz
Shoshone County Commissioner
5/18/99
W5
Lee Haynes
City of Smelterville
5/18/99
W22
Jim Vergobbi
Shoshone County
Commissioner
5/18/99
W6
Bill Keller
Mayor of Smelterville
5/18/99
W23
Jack Riggs
Idaho State Senator
5/18/99
W7
Shirley Hindley
Coeur d'Alene Assn. of Realtors
5/18/99
W8
Doug Stiles
Hecla Mining Co
Lucky Friday Mine
5/18/99
Ci
H. Sid ftederickson
City of Coeur d'Alene
Wastewater Utility Division
5/19/99
W9
Arthur Iverson
5/18/99
C2
Marti Callabreta
Coeur d'Alene River Basin
Commission
5/19/99
W10
Pat Kmsey
5/18/99
C3
Steve Judy
Mayor of City of Coeur d'Alene
5/19/99
Wll
Randy Anderson
Hecla Mining Co,
5/18/99
C4
Anne Walsh
Coeur d'Alene Mines Corp.
5/19/99
W12
Eric Klepfer
Coeur d'Alene Mines Corporation
5/18/99 -
C5
Joe Guardipee
5/19/99
no
-------
• *
#
Name/Org
Date
Comments
Received
#
Name/Org
Date
Comments
Received
C6
Greg Godwin Superintendent
Joint School District #391
5/19/99
Oi
John Hull
Wallace School District
5/25/99
C7
Ed Kerwin
Cocur d'Alene Mines Corp.
5/19/99
02
Robin Stanley Superintendent
Mullan School District #392
5/25/99
C8
Mkv Cricky
Save Our River Environment
5/19/99
03
Connie Fudge
5/25/99
C9
John Amonson
5/19/99
04
W. M. (Bill) Calhoun
W. M. Calhoun, toe.
5/25/99
CIO
Michele Nanm
The Lands Council
5/19/99
05
Tan Fudge
Hecla Lucky Fttday Mine
5/25/99
Cll
Ron Krusemark
5/19/99
06
Randy Anderson
Hecla Mining Co.
5/25/99
C12
Sue Hollister
5/19/99
07
Mary Wieman
Silver Valley People's Action
Coalition
5/25/99
CI3
Dean Jamison
Caeur d'Alene Area Chamber of
Commerce
5/19/99
OS
Barbara Miller
Silver Valley People's Action
Coaliticn
5/25/99
CI4
Larry Watson
Idaho House of Representatives
5/19/99
09
Greg Godwin Superintendent
Joint School District #391
5/25/99
C15
Mike Lee
Silver Valley Resources
5/19/99
010
fted W. Brackebusch
Mine Systems Design, Inc.
5/25/99
C16
Jim Duff
5/19/99
Oil
Doug Stiles
Lucky Friday Mine
5/25/99
CI?
Bill Madigan
Post Falls WWTP
5/19/99
012
John Lang
5/25/99
CIS
Jerry Boyd
5/19/99
013
Michele Nanru
The Lands Council
5/25/99
C19
Robert Hopper
Bunker Hill Mining Co.
5/19/99
014
Bill Hollister
5/25/99
C20
Jack Riggs
Idaho State Senator
5/19/99
015
Joe Peak
Enaville Resort
5/25/99
C21
Shirley Hindley
Coeur d'Alene Assn. of Realtors
5/19/99
016
Larry Watson
Idaho House of Representatives
5/25/99
C22
Larry Drew
Heel a Mining Co.
5/19/99
017
Jean Vasberg
5/25/99
C23
Ross Stout
5/19/99
018
Frank Seats
5/25/99
C24
Tom Fudge
Hecla Lucky Friday Mine
5/19/99
019
Dale Leaf
5/25/99
C25
Bret Bowers Community Leaders for
EPA Accountability Now" (CLEAN)
5/19/99
020
Cathy Zinetti
5/25/99
-------
#
Name/Org
Date
Comments
Received
#
Name/Org
Date
Comments
Received
02I
Bill Keller
Mayor of Smelterville
5/25/99
55
Larry Watson
Idaho House of Representatives
Duplicate of
#30 5/20/99
022
Mike Lee
Silver Valley Resources
5/25/99
56
D.F, Zabel
Phoenix Home Life Mutual Ins.
5/21/99
023
Anne Walsh
Coeur d'Alene Mines Corp.
5/25/99
57
Joint School District 391
5/24/99
024
Gtne Duffy
5/25/99
58
Dwight Morgan
5/24/99
025
Robert Hopper
Bunker Hill Mining Co.
5/25/99
59
Michael Crapo, US Senator
5/26/99
026
lack King
Shoshone County Commissioner
5/25/99
60
Art Barrett
smm
027
Art Barrett
5/25/99
61
Larry Yergler
smm
028
Larry Yergler
5/25/99
62
Jack King
Shoshone County Commissioner
smm
VOLUME 2 BEGINS HERE
63
R-ed W. Brackebusch
Mine Systems Design, Inc.
5/26/99
41
Lee Haynes
City of Smelterville
5/20/99
64
W. M. Calhoun
W. M. Calhoun, Inc.
5/26/99
42
Ran Krusemark
5/20/99
65
John Hull
Wallace School District
5/26/99
43
Mike Carlson
smm
66
W. M. Calhoun
W. M. Calhoun, Inc.
5/26/99.
44
Darrick/Qxmie Holmquist
5/20/99
67
Michael J. Murray
5/26/99
45
Marilyn Hinsz
5/20/99
68
Keith Dahlberg, MD
smm
46
Tern Wild
5/20/99
69
Steve Pritchett
smm
47
W.M.Calhoun
W. M. Calhoun, Inc.
5/20/99
70
Clyde Peppin
5/27/99
48
ioe Guar di pee
5/20/99
71
Shauna Hillman
Indelible Tidbits
5/28/99
49
Larry Watson, Idaho House of
Repsentatives
5/20/99
72
Dorothy Thielman
smm
50
(No Name)
5/20/99
73
Edith Smith
smm
51
John Amonson
5/20/99
74
Steve Pritchett
6/1/99
52
Roger Mangurn
Mayor of Kellogg
5/20/99
75
Dee Ann Sverdsten
6/1/99
53
Coeur d'Alene Chamber of Commerce
5/20/99
76
Darrell Jerome
6/1/99
54
Larry Watson
Idaho House of Representatives
5/21/99
77
Randall Anderson
Hecla Mining Co.
6/1/99
112
-------
»
Name/Org
Date
Comments
Received
#
Name/Org
Date
Comments
Received
78
Andy Warren
Horizon Jr. High School Student
6/2/99
98
Bryan Blackburn
Horizon Jr. High School Student
6/4/99
79
Justin Rose
Hcnzon Jr. High School Student
6/23/99
99
Tyler Jeffries
Horizon Jr. High School Student
6/4/99
80
Jessica Tenney
Horizon Jr. High School Student
6/2/99
100
David Dames
Horizon Jr. High School Student
6/4/99
30a
Katie Stone
Horizon Jr. High School Student
6/2/99
Beginning Vol 4
81
Ashley Guimocd
Horizon Jr. High School Student
6/2/99
101
Kendra Black
Horizon Jr. High School Student
6/4/99
82
Robin Ann Silvey
6/2/99
102
Janet Vollolmi
6/4/99
83
Amanda Golden
6/2/99
103
Jane! Davisson
Horizon Jr. High School Student
6/4/99
84
Nicholas Woolf
Horizon Jr. High School Student
6/2/99
104
Mark Tarbuttcu
Horizon Jr. High School Student
6/4/99
85
Jenny Giesea
Horizon Jr. High School Student
6/2/99
105
Elijah Dcryle
Horizon Jr. High School Student
6/4/99
86
Gina Pfau
Horizon Jr. High School Student
6/2/99
106
Rachelle Langdon
Horizon Jr. High School Student
6/4/99
87
Keith Dahlberg, MD
6/2/99
107
Harry Voltolini
6/4/99
88
Cory Degenstein
6/2/99
108
Brian McGaugh
Horizon Jr. High School Student
6/4/99
89
Kalen Hotlinberger
Horizon Jr. High School Student
6/2/99
109
Clarence Chnslman
6/8/99
90
Bryce Anderson
Horizon Jr. High School Student
6/2/99
110
Richard Shaffer
Best Western Wallace Inn
6/8/99
9!
Jeremy Redding
Hcnzon Jr. High School Student
6/2/99
111
Arthur Iverson
6/9/99
92
Katie Lallier
Horizon Jr. High School Student
6/4/99
112
Edward Peterson
6/10/99
93
Arthur Iverson
6/4/99
113
Dante Bisaro
6/10/99
94
Connie Sue Fudge
6/4/99
114
James Berry
6/10/99
95
Whitney Rollins
Horizon Jr. High School Student
6/4/99
115
Terry/Catherine Linmger
6/11/99
96
Lexie Gulden
Horizon Jr. High School Student
6/4/99
116
Lacy O'Connell
Horizon Jr High School Student
6/14/99
97
Tony Honorof
6/4/99
117
Patrick Kaczmarek
Horizon Jr, High School Student
6/14/99
-------
#
Name/Org
Date
Comments
Received
#
Name/Org
Date
Comments
Received
118
Christina Gulden
Horizon Jr. High School Student
6/14/99
135
Lisa Munts
Horizon Jr. High School Student
6/14/99
119
Craig/Dianna Mast
(illegible)
Tim KjHebrew
Joanne White
Dick Clark
Steve Anderson
Jan Turbak
Fred Fossberg(7)
6/14/99
136
Courtney Massey
Horizon Jr. High Schod Student
6/14/99
120
Heather Douglas
Horizon Jr. High Schod Student
6/14/99
137
Michael Pentieo
Horizon Jr. High Schod Student
6/14/99
121
Ranae Nelson
Horizon Jr. High Schod Student
6/14/99
138
Lisa Schuldt
Horizon Jr. High Schod Student
6/14/99
122
John D'Addabbo
Horizon Jr. High School Student
6/14/99
139
Colin Fulton
Horizon Jr. High Schod Student
6/14/99
123
Ashley Dill
Horizon Jr. High Schod Student
6/14/99
140
Bnttney Pence
Horizon Jr. High School Student
6/14/99
124
Joshua Wilson
Horizon Jr. High School Student
6/14/99
141
Larry Brick
Horizon Jr. High Schod Student
6/14/99
125
Jennifer Numata
Horizon Jr. High School Student
6/14/99
142
Paula Silinger
Horizon Jr. High Schod Student
6/14/99
126
Mike Livingbston
Horizon Jr. High Schod Student
6/14/99
143
Leann Muller
Horizon Jr. High Schod Student
6/14/99
127
Morgan Paupst
Horizon Jr. High School Student
6/14/99
144
Kenneth Clark
6/14/99
128
Kyle Jones
Horizon Jr. High Schod Student
6/14/99
145
John Hams
Horizon Jr. High Schod Student
6/14/99
129
Aaron Bertoni
Horizon Jr. High Schod Student
6/14/99
146
Mitch Lykins
Horizon Jr. High Schod Student
6/14/99
130
Justin Gottlob
Horizon Jr. High Schod Student
6/14/99
147
Nicole Lovinger
Horizon Jr. High School Student
6/14/99
Beginning Vol 5
148
Matt Unger
Horizon Jr. High Schod Student
6/14/99
131
Kellie Spurgeon
Horizon Jr. High School Student
6/14/99
149
Teagan MacDonald
Horizon Jr. High Sch(x>l Student
6/14/99
132
Meegan Buege
Horizon Jr High School Student
6/14/99
150
Blair Holbrook
Horizon Jr. High School Student
6/14/99
133
Chad Flaherty
Horizon Jr. High School Student
6/14/99
151
Taylor Hall
Horizon Jr High School Student
6/14/99
134
Jo Ellen Schmidt
Horizon Jr. High Schcx)! Student
6/14/99
114
-------
#
Name/Org
Date
Comments
Received
#
Name/Org
Date
Comments
Received
152
Heidi Odeen
Horizon Jr. High School Student
6/14/99
170
Chris Ralston
Horizon Jr. High School Student
6/14/99
153
Kyle Lynden
Horizon Jr. High School Student
6/14/99
171
Tyler Ormsby
Horizon Jr. High School Student
6/14/99
154
Carl Niggemyer
Horizon Jr. High School Student
6/14/99
172
Billy Belknap
Horizon Jr. High School Student
6/14/99
155
Tiffany Nichols
Horizon Jr. High School Student
6/14/99
173
Kara Christen
Horizon Ir. High School Student
6/14/99
156
Lauralee McMillan
Horizon Jr. High School Student
6/14/99
174
April Kawamoto
Horizon Jr. High School Student
6/14/99
157
Rachel Cortez
Horizon Jr. High School Student
6/14/99
175
Teasha Barfuss
Horizon Jr. High School Student
6/14/99
Beginning Vol 6
176
Jonathan Sol berg
Horizon Jr. High School Student
6/14/99
158
Tyler Wmningham
Horizon Jr. High School Student
6/14/99
177
Mara Kindsvogel
Horizon Jr. High School Student
6/14/99
159
Ben Sanders
Honzcu Jr. High School Student
6/14/99
178
Sean Nowliag
Horizon Jr. High Schod Student
6/14/99
160
Jessica Herman
Horizon Jr. High School Student.
6/14^9
179
Shelby Nerd
Horizon Jr. High School Student
6/14/99
161
Ryan Hue
Horizon Jr. High School Student
6/14/99
180
Tyler Guilhault
Horizon Jr. High School Student
6/14/99
162
Amanda Span
Horizon Jr. High School Student
6/14/99
131
Timber Roden . '
Horizon Jr. High School Student
6/14/99
163
Lauren Leavitt
Horizon Jr. High School Student
6/14/99
182
Megan Barney
Horizon Jr. High School Student
6/14/99
164
Luke Jensen
Horizon Jr. High School Student
6/14/99
183
Jenniephier Rise
Horizon Jr. High School Student
6/14/99
165
Jessica DeRouen
Horizon Jr. High School Student
6/14/99
184
Ashley Steward
Horizon Jr. High School Student
6/14/99
166
Uyen Bui-Nguyen
Horizon Jr. High School Student
6/14/99
185
Megan Dormaier
Horizon Jr. High School Student
6/14/99
16?
Tessa Mali on ey
Horizon Jr. High School Student
6/14/99
Beginning Vol 7
168
Jacob Radke
Horizon Jr High School Student
6/14/99
186
Kris Fischer
Horizon Jr. High School Student
6/14/99
169
Alexa Smith
Horizon Jr. High School Student
6/14/99
187
Allen Greaves
Horizon Jr. High School Student
6/14/99
"
-------
#
Name/Org
Date
Comments
Received
#
Name/Org
Date
Comments
Received
138
Lmdsey Poole
Horizon Jr. High School Student
6/14/99
208
R. Meml Coomes
Coomes Associates
6/25/99
189
Brent Cabot
Horizon Jr. High School Student
6/14/99
209
A petition with 484 signatures on
it, 64 pages long
6/21/99
190
Jennifer Jewell
Horizon Jr. High School Student
6/14/99
Beginning Vol 8
191
Sean Ness
Horizon Jr. High School Student
6/14799
210
Robert Werner
6mm
192
Bailee Brown
Horizon Jr. High School Student
6/14/99
211
Bill Osebold
6/29/99
193
Skip Jewett
Horizon Jr. High School Student
6/14/99
212 .
Cecelia/Prank Walls
6/30/99
194
Brian Eik
Horizon Jr. High School Student
6/14/99
213
Susan Grampian, MD
7/1/99
195
Jessica Pillsbury
Horizon Jr. High School Student
6/14/99
214
Mary Souchik
7/2/99
196
Kelsey Nord
Horizon Jr. High School Student
6/14/99
215
Keaneth/Joaim Branstetter
7/2/99
197
Tyson Shelly
Horizon Jr. High School Student
6/14m
216
Sy Thompson
mm
198
Christina Ralston
Horizon Jr. High School Student
6/14/99
217
CShulz
7/7/99
199
Lucas Chane
Horizon Jr High School Student
6/14/99
218
Sy Thompson
7/7/99
200
Rose Mattana
Horizon Jr. High School Student
6/14/99
219
Jean Stout
7/8/99
201
Alex Cross
Horizon Jr. High School Student
6/15/99
220
Larry/Gina Schrock
7/12/99
202
Art Barrett
5/26/99
221
Michael Boyd
7/12/99
203
R. Meml Coomes
Coomes Associates
6/15/99
222
Warren/Ruth Peterson
7/12/99
204
Kenneth Clark
6/15/99
223
Don/Thea Tager
7/13/99
205
Jerry Boyd
6/16/99
224
Robert McFarland
7/13/99
206
Mary Wieman
6/18/99
225
Gregory Nickel
7/19/99
207
Megan White
Washington Dept of Ecology
6/21/99
226
Jim Cronin
Megan Schmall
7/19/99
227
Carol Bieschke Small
mum
228
Gregory Nickel
7/22/99
229
Harve/Tina Paddock
mum
116
-------
#
Name/Org
Date
Comments
Received
#
Name/Org
Date
Comments
Received
230
Harry Cougher
Sunshine Mining Co,
7/27/99
250
Mary Lou Reed
8/U/99
231
Scott Brown
Idaho Conservation League
7/29/99
251
Jack Domit
Spokane R. Prop. Owner's Assn.
8/11/99
232
C. S. Anderson
8/2/99
252
Gordon Canterbury
8/11/99
233
W. C. Rust
8/3/99
253
Lup6 Eckenrode
8/11/99
234
Jerry Jayne
8/4/99
254
David Brown
8/11/99
235
Paul De Pal ma
8/4/99
255
Ross Stout
SF Coeur d'Alene R. Sewer Dist,
8/12/99
236
Eunice Cunningham
8/4/99
256
Steve Doyle
8/12/99
237
Margaret Hafey
8/4/99
257
Lola Palmer
MLarlm Palmer
Candice Cameron
Bob Cameron
Karen DuPuis
Bill DuPuis
Katby Cameron
Gail Haynes
John Nearing
8/12/99
238
Eileen Stanley
8/5/99
258
George Brabb
8/13/99
239
J aims Thomas
8/5/99
259
Michele Nanni
The Lands Council
8/13/99
240
Jack Roylance
8/5/99
260
Guadalupe Flores
8/13/99
241
Mike Mihelich
Kootenai Environmental Alliance
8/6/99
261
MarceUe/Art Barrett
8/13/99
242
Anne Solomon
mm
262
John Siddle
Sunshine Mining Co.
8/13/99
243
Michael Clary
8/9/99
263
Anne Hite
8/13/99
244
Lisa Carney
8/10/99
264
Gina Brooks
8/13/99
245
Guy Bailey
Amen can Wildlands
8/10/99
265
Clyde Peppin
8/13/99
246
Marion Grosvenor
8/10W
266
William Booth
Hecla Mining Co.
8/13/99
247
Mitchell Grant
8/11/99
267
H. Sid Fredericks on
City of Coeur d'Alene
8/13/99
248
Cheryl Grant
8/11/99
268
(27 Geologists/ Engineers)
(Petition Style letter)
8/13/99
249
Valerie Palmer
8/11/99
269
Shoshone Natural Resources
Coalition
8/13/99
117
-------
§
Name/Org
Date
Comments
Received
#
Name/Org
Date
Comments
Received
270
Tom Fudge
Hecta Mining Co.
Lucky Friday Mine
8/13/99
292
James Geyer
8/17/99
271
(544 petition type forms)
8/13/99
293
Eileen Stanley
8/17/99
272
Robert (Rick) Richins
Coeur d'Alene Mines Corp
8/13/99
294
James Thomas
8/16/99
in
Esther Larsen
WA Citizens Advisory Committee
8/13/99
295
Lisa Carney
8/13/99
274
Douglas Parker
Asarco
8/16/99
2%
Jack Roylance
8/18/99
275
Judy Johnson
8/16/99
297
2 packets of form letters/
petitions.
Seat July 9,
1999
276
Sharon Broadhead
8/16/99
298
Bret Bowers
Communty Leaders for EPA
Accountability Now! (CLEAN)
5/13/99
(approx)
277
Norman Graham
8/16/99
299
John Woodwcrth
WA State Public Works Board
5/14/99
278
Micheie Nanni
Lands Council
8/16/99
300
Joe Peak
Enaviile Rttcrt
5/17/99
279
Ken Bright
8/16/99
301
Shirley Hindley
Coeur d'Alene Assoc.of Realtors
5/20/99
280
Michael Lee
Silver Valley Resources
8/16/99
302
SF Coeur d'Alene R. Sewer Dist.
5/20/99
281
Esther Larsen
WA Citizens Advisory Committee
8/16/99
303
SF Coeur d'Alene R. Sewer Dist
5/20/99
282
Jack Roylance
8/16/99
304
Michael Crapo
U. S. Senator
5/25/99
283
(petition type with 66 signatures)
8/16/99
305
Nancy Vandeventer
5/26/99
284
Phillip Cernera
Coeur d'Alene Tribe
8/16/99
306
Silver Valley People's Action
Coalition
7/7/99
285
Robert Hallock
US Fish & Wildlife Service
8/16/99
307
Bill Osebold
7/26/99
286
Lola Frederick
8/16/99
308
Gary Stanley
8/16/99
287
Jarru Fernette
8/16/99
309
Arline Stanley
8/16/99
288
Enc Williams
8/16/99
310
John "Jack" Roylance, Jr.
8/16/99
289
Burton Gosling
8/16/99
290
Jennifer Leinart
8/16/99
291
Mike Paulson, WA State Farm Bureau
Natural Resources Committee
8/16/99
118
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