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Assigning Load
and Waste Load Allocations
This section deals especially with the allocation of loads to various
polluters – perhaps the most
scientifically and politically challenging aspect of TMDLs. Setting
and policing TMDLs requires
an understanding of the difference between concentration and load, so
we will first examine that
key pair of values.
The first step in writing a TMDL is determining the maximum allowable
load: the amount of a
pollutant that the water body can tolerate without degradation. Then
background loads (BLs),
waste load allocations (WLAs), load allocations (LAs), and margins of
safety (MOSs) must be
allocated as fairly as possible.
This is the place where time invested in stakeholder development
really pays off! Stakeholders
should be involved through all stages of the process to assure that
they accept, as much as pos-sible,
the nature of the problems and the potential solutions. With the
support of the stakeholders,
a TMDL process can yield excellent results. On the other hand,
without stakeholder involvement
and buy-in, writing and enforcing a TMDL can be a frustrating,
fractious undertaking.
Concentrations vs. Loads
The TMDL program is oriented toward controlling loads
–
measured in mass/time increments
such as pounds per day – so it works especially well for
concentrated point sources. The quality
of the water itself – the way it directly affects organisms,
including humans – depends on the
concentration of
pollutants, which is measured in mass/volume units, such as mg/L. Though
the
law regulates in terms of load (e.g., 56 pounds of phosphorus/day),
assessing nonpoint sources
and monitoring in-stream water quality are typically handled by
concentration (0.07 mg/L total
P).
The connecting factor is flow,
which is not directly regulated in the TMDL process in most cases.
As noted earlier, the relationship
Load
= Concentration x Flow defines
the links among the three
variables.
By assuming a given flow rate, the resultant concentration is
determined by dividing the load by
the flow rate. For example, in the Tualatin River, midsummer flow
rates average 150 cubic feet
per second (cfs), which corresponds to about 100 million gallons per
day, or about 800 million
lbs. of water. 70-ppb total phosphorus (TP) is the maximum
concentration at which beneficial
uses of the river are not impaired by excess algal growth. A
concentration of 70 ppb TP at 150
cfs flow corresponds to 56 lbs TP per day.
A major tributary during this time may have flow rates of 10 cfs--at
a target concentration of 50
ppb TP for agricultural systems, this represents about 2.7 lb. of TP
passing that point per day.
Compared with simply collecting a water sample and analyzing
concentrations, determining flow
rates in open channel systems is time-consuming. By monitoring flow
at a minimum of ten
evenly spaced points across the stream, total flow can be determined.
This may be done on every
visit to a site. Or, after these direct flow measurements have been
taken over a wide range of
flow conditions, a relationship between depth at one point in the
stream and the flow for the
whole stream can be developed. This relationship is called the
"rating curve," and is generally
useful over the range of flows with which it was developed, as long
as the channel shape doesn’t
change. Once a valid rating curve is available for a reach of stream,
only one depth measurement
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YSI Incorporated 40
needs to be taken to calculate flow.
Controlling loads can be accomplished in one of two ways: lowering
concentrations, or lowering
flow rates. For point sources, either approach is useful, because the
flow is typically a small
fraction of the total input into the system. Excluding this small
point source flow, basically all
the rest of the flow is from nonpoint sources. In contrast,
eliminating nonpoint source load by
eliminating flow will dry up the stream or lake. So the best option
is to maintain or even increase
flow, but focus on lowering concentrations in that water.
Increasing flow can be achieved with stored water, timing reservoir
releases to meet flow goals,
establishing or restoring wetlands, and managing riparian buffers. In
the Pacific Northwest,
innovative water rights easements have been designed which allow
water trusts to lease water
rights and direct them to instream use rather than irrigation (Landry
and Peck, 1998). Instream
water rights could provide another valuable flow management tool,
especially where the prior
appropriation doctrine of water law prevails.
Maximum Allowable Loads
Maximum allowable loads are determined based on the concentrations or
amounts of pollutants
that will not degrade the quality of the
water body, adversely affecting its benefi-cial
uses.
In many cases, research is required to
determine what these concentrations or
amounts are. A report is also available
which allows the user to determine specifi-cally
the types of algal or higher plant
species that are most likely to occur in a
given water body (NRCS/EPA, in press).
Based on the fundamental properties of the
stream or lake, the likely plant types or
responses can be predicted. In addition,
this publication indicates the relative
sensitivity of water bodies to changes in
two important TMDL parameters, phospho-rus
and nitrogen.
Waste Load Allocations - Point Sources
Each major point source in a TMDL-affected watershed is allocated a
quantity of additional
pollutant it can add to the water body – a waste load allocation,
or WLA. In most instances these
systems are already regulated by the National Pollution Discharge
Elimination System (NPDES
permits), which requires monitoring effluent flow rates and
concentrations. Monitoring the
stream above and below a point source outfall is important for
determining the actual impact of
the source on both the regulated parameter and other stream water
quality parameters.
It is important to note that waters coming from point sources differ
from waters derived from
nonpoint sources in several ways:
1. They often contain higher concentrations of pollutants
2. Flow rates are relatively constant and predictable
Experimentation Yields
Maximum Allowable Load
To determine the critical concentration of total
phosphorus (TP) in Oregon’s Tualatin River,
experiments were conducted with native algal
populations at different total P concentrations.
It was found that there was some limitation to
algal growth below 70 micrograms TP/L. The
product of total flow and concentration gives
the total load of TP that the river can tolerate
without exceeding 70 micrograms TP/L,
which results in excessive algal growth.
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YSI Incorporated 41
3. The form of the pollutants is often different, with more soluble
forms and less
particulate/sediment forms
4. Because it is concentrated in one point, and regulated by other
programs (e.g.,
NPDES, the National Pollution Discharge Elimination System), the
loads are easily
calculated very accurately
As a result of these characteristics, in most cases, point sources
cause the biggest problems
during dry season, low-flow periods, because the flow of the
receiving water (the water the
point source empties into) is less and so there is less dilution of
the concentrated point
source.
Load Allocations - Nonpoint Sources
A total load allocation (LA) is established to cover all nonpoint
sources in a watershed
covered by a TMDL. This total LA is divided into individual
allocations.
The basis for this allocation rests on a wide range of factors,
including estimates of sources,
expected ability to meet the TMDL limits, and overall economics.
There’s no question that
some cleanup strategies are cost-prohibitive. The TMDL process allows
TMDL managers
and stakeholders to consider whether it is cheaper and more effective
to clean up discharge
from one source, or to prevent further pollution from other sources.
In many cases, a Designated Management Agency is chosen to represent
each land use type –
such as a conservation district for agriculture, and a state
department of forestry covering
woodlands – helping negotiate the level of allocation and institute
best management prac-tices.
Load allocation requires active participation of stakeholders in the
watershed (see Section II).
For example, in the Tualatin River Valley, the allocation of
phosphorus was roughly based on
expected concentrations coming out of stream reaches dominated by
those land management
types: forestry at 20 micrograms of total phosphorus (TP)/L,
agriculture at 50 micrograms
TP/L, and urban at 70 micrograms/L. Therefore, the load allocations
were equivalent to 20,
30, and 20 microgram TP/L changes in concentration for forestry,
agriculture, and urban,
respectively.
There are some general statements that apply to most nonpoint
sources:
1. Nonpoint sources often contain low concentrations of pollutants,
but still too high for
aquatic health. In some cases, however, nonpoint sources can have
very high concen-trations
– for instance, large livestock feedlots.
2. Flow is often much higher during rainy periods than dry periods
because of its connec-tion
to runoff.
3. Nonpoint sources have not been monitored as intensively as point
sources and have not
been regulated nearly as much or as consistently as point sources in
the past. Rela-tively
speaking, little baseline data are available.
4. Because of their erratic nature, capturing the storm events that
lead to large nonpoint
source pollution inputs is difficult in most monitoring programs,
especially those that
rely on grab sampling.
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YSI Incorporated 42
5. There is great uncertainty in predicting the amount of pollution
from nonpoint
sources because they are so dispersed and generally have low
concentrations.
Given the many unknowns, it’s no surprise that modeling sources,
transport, and sinks of
nonpoint source pollutants – and assigning reasonable loads
comparable to point sources – is
difficult.
Background
Every natural water body contains most of the parameters managed with
TMDLs. Nutrients and
sediments, in particular, are always present, although in some
aquatic systems their natural
concentrations are very low.
Thus, setting the TMDL for a given body of water generally assumes
that there is a difference
between the natural background and the TMDL for a given beneficial
use. This difference is
caused by human-related inputs, which can be then assigned LAs and
WLAs.
In a few cases, where backgrounds are naturally high or the water
body is particularly sensitive,
there may be little or no difference between background loading from
natural sources and the
TMDL. Any increase above the background conditions results in
significant degradation of water
quality. In those cases, there is no flexibility to allow for
enrichment above the background, and
the LAs and WLAs must be zero. Monitoring must be done to assure that
there are no increases
above the background.
Margin of Safety
This is "insurance" based upon the certainty of the
response of the system to the parameter in
question. As noted above, this depends on how well the water body is
understood. If best
available science suggests that a given concentration of a nutrient
will be low enough to limit
algal growth to acceptable levels, the MOS may dictate that the TMDL
be set at 70% of that
concentration as a target, because of the uncertainty in that number.
For example, as concentra-tions
decrease, other algal species may become dominant that require less
nutrient for maximum
growth. So setting a margin of safety makes sense where the response
of the water body is
uncertain.
TMDLs and Lakes
The TMDL approach is well suited to regulation of pollutants entering
lakes. Of course, because
of long residence times, flow is less important than the amount of a
pollutant that enters the
system. Most lakes have residence times of months to years, meaning
that any pollutant entering
the system can remain in the system for a long time before it is
flushed out, which can cause
many long-term problems.
Any streams, pipes, or groundwater flows that enter the lake and
bring pollutants can continue to
degrade lake health over the long term. Also, in contrast to flowing
water systems, fine, nutrient-rich
sediments are likely to settle and accumulate in polluted lakes. In
many cases these sedi-ments
become important long-term, internal sources of pollutants, which are
difficult to eliminate
and keep cycling phosphorus into the water year after year. Such fine
sediments rarely settle to
the bottom in streams, unless the streams are stagnant during part of
the year. It’s important to
note that phosphorus – and, to a lesser extent, nitrogen – are
often associated with sediments and
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YSI Incorporated 43
accumulated organic matter in lakes.
As with TMDLs written for streams, TMDLs for lakes assign a load to
the lake, then assign
portions of that load to the contributing sources of pollution: point
sources, tributaries, groundwa-ter
and sediments.
© 1999,
YSI Incorporated
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