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The Status of the TMDL

Current Status

November 2, 2009

The extended public comment period for the September 2009 revised version of the draft Spokane River and Lake Spokane Dissolved Oxygen TMDL: Water Quality Improvement Report ended on October 30, 2009.  Twenty-five comments were received.

October 20, 2009

The comment period for the September 2009 revised version of the draft Spokane River and Lake Spokane Dissolved Oxygen TMDL: Water Quality Improvement Report has been extended 15 days.  Comments are accepted until October 30, 2009.

September 15, 2009

The September 2009 revised version of the draft Spokane River and Lake Spokane Dissolved Oxygen TMDL: Water Quality Improvement Report is available for review and comment.   September 15 - October 15, 2009.

The final Spokane River Modeling Scenarios Report 2009 is now available. (This revised version replaces the one made available on this website on 09/14/09.)

April 21, 2009

Modeling for the revised TMDL is scheduled to begin in May and be completed by June. A revised project schedule and updated scenario table is provided below. A technical report will be developed based on the results of the modeling.

• Updated project schedule
• Updated draft scenario table

December 3, 2008

Draft dissolved oxygen scenarios currently being considered by Ecology, Idaho DEQ, the Spokane Tribe, and EPA for assessment of Lake Spokane dissolved oxygen impacts

November 21, 2008

• Memo developed by Ecology describing issues of consideration for pursuing a Use Attainability Analysis (UAA) and Site Specific Criteria changes in Lake Spokane
• Letters from the dischargers and Ecology's replies:
  • Andresen,Wayne - ECTS 7272 - INSYSTEM
  • IEP Letter 11/17/08
  • Stakeholder Modeling Letter10/09/08
  • Spokane River WQ Modeling for TMDL NPDES Processes

November 10, 2008

The Environmental Protection Agency (EPA), working with Ecology, the Idaho Department of Environmental Quality (IDEQ), and the Spokane Tribe of Indians, developed a work plan and schedule to run additional modeling scenarios on the Spokane River. The modeling will determine the impact on dissolved oxygen in Long Lake from point and nonpoint sources as well as dams. Modeling results will be used to complete Washington State's dissolved oxygen TMDL and NPDES permits in both Washington and Idaho. The following documents include the work plan, work plan schedule, and a letter from Ecology to EPA concerning interpretation of dissolved oxygen water quality standards at Long Lake.

The following documents are available in Adobe Acrobat (.PDF file) format. To view and/or print PDF files, you first will need to download and install Adobe Acrobat Reader:

• Spokane TMDL NPDES Workplan
• Spokane TMDL NPDES Schedule
• Standards Clarification Letter to EPA

September 26, 2008

EPA’s written statement for why they reversed course on the TMDL.

September 8, 2008

The latest draft TMDL is on hold. EPA announced that their interpretation of Washington State water quality standards for dissolved oxygen, which established the baseline for phosphorus allocations to Washington dischargers, was in error. The two agencies will meet in the coming weeks to determine an appropriate path forward to issue the TMDL and discharger permits.

May 20, 2008

As a result of the concerns and issues raised by the comments, Ecology modified the report and provided an additional 30-day public comment period on the revised draft. The comment period ran from May 20 - June 24, 2008. Ecology considered all comments,  but focused on those that addressed the following changes:

Topic	Changes in current Revision
Avista Dams	Additional language to describe the 401 certification requirements for the hydroelectric dams on pages 4 and 5.
Spokane Tribe of Indians Water Quality Standards	Spokane Tribe water quality standards are recognized and discussed on pages 7, 10, and 33 through 34.
Modeling	New language and updates to Table 3 on page 15 to describe how net groundwater phosphorus values are derived for Lake Spokane and the Spokane River. Additional bullets to describe modeling runs for ammonia in 2007 and the use of corrected flows for Hangman Creek on page 19.
Implementation Timeframe for TMDL, Permits and Ten Year Assessment	A new table (Table 8) and additional language to describe the schedule sequence for the TMDL, NPDES permits, and associated target pursuit actions and wasteload allocations on pages 46 and 47. Language has been added on page 35 to clarify that to the extent the Foundational Concepts document suggested no enforceable limits during the first ten years, the NPDES permits will contain enforceable limits in their ten-year compliance schedules. Language has been added to page 48 to specify how final wasteload allocations may change (but still be protective of water quality) based on data collected in advance of the ten-year assessment. Language has also been added on pages 48 and 50 to clarify that monitoring will be conducted on a biennial basis and will be assessed in advance of ten years in order to determine compliance with the NPDES permits and whether dissolved oxygen is being improved in Lake Spokane for the ten-year assessment.
Load and Wasteload Allocations	Revised wasteload allocations for Table 5 on page 29. Ammonia values have also been revised following the 2007 modeling (see fourth bullet above). The 10 µg/L target remains in the Managed Implementation Plan per the Foundational Concepts and as described with new language on page 46. An equation to convert concentrations to lbs/day on page 30 in place of Table 6 in the previous draft (tables are re-numbered after 5). The lbs/day wasteload allocations are provided in Table 9 in the Managed Implementation Plan on page 49, based on the 10 µg/L concentration.
Language Changes	Clarifying language to describe the water quality standards on pages 9 through 11. Additional language and a graph (Figure 5) have been added to describe loading capacity in Lake Spokane on pages 24 through 26. Additional language to clarify that nonpoint source reductions can be made to the mainstem of the Spokane River or the tributaries on pages 27 and 40. The language describes how only tributary nonpoint loads are identified and assigned load allocations but that the Dischargers can and should pursue actions to reduce nonpoint pollution to the mainstem in order to improve dissolved oxygen in Lake Spokane. Additional language to clarify the interim , technology-based, and final wasteload allocations (page 39) and the activities of the ten year assessment (pages 49-51) in the Managed Implementation Plan. Additional bullet points in the Reasonable Assurances section on pages 31 through 34 including the Coeur d’ Alene Lake Management Plan, the Liberty phosphorus fertilizer no-use policy, and the Spokane County phosphate dishwasher detergent ban. Groundwater monitoring has been added as an activity to the Managed Implementation Plan on page 51.
New Sections	New section on stormwater discharges on pages 42 through 44. A responsiveness summary is included as Appendix G which describes Ecology’s approach to issues such as background water quality, implementation timeframe, and other issues in more detail. A November 2004 modelers agreement has been added as Appendix H.

Background

Ecology began working on a Dissolved Oxygen Water Quality Improvement Project (TMDL) in 1998. In the fall of 2000, Ecology contracted with the U.S. Army Corps of Engineers (USACE) to apply the CE-QUAL-W2 model to the Spokane River and Lake Spokane system. The USACE collaborated with Portland State University. A report (Cusimano, 2004) on the water quality study and modeling effort was completed in 2004 (see Technical Information page for a link to the report).

In October 2004, Ecology released a draft TMDL for public comment. Prior to the release, entities that discharge to the Spokane River (the Dischargers) developed a Use Attainability Analysis and submitted a petition for rule making to revise the dissolved oxygen water quality criteria for the Spokane River and Lake Spokane. Shortly thereafter, Ecology and the Dischargers agreed to withdraw the petition, put the draft TMDL on hold and develop an implementation plan for the TMDL. This led to the creation of the Spokane River TMDL Collaboration (Collaboration).

The Collaboration included Ecology, the Dischargers, local governments, Idaho Department of Environmental Quality (IDEQ), the U.S. Environmental Protection Agency (EPA), the Spokane Tribe of Indians, environmental groups, and power companies. The Collaboration developed the Foundational Concepts for the Spokane River TMDL Managed Implementation Plan. The Collaboration agreed that the TMDL’s Managed Implementation Plan will be consistent with the principles described in the Foundational Concepts. The agreement was formalized through a Memorandum of Agreement signed on March 7, 2007.

During 2007, Ecology worked with Portland State University to run some additional model scenarios to incorporate modifications to the modeling approach as a result of the Collaboration. The dissolved oxygen TMDL has been revised to reflect the Foundational Concepts and the new modeling.  The draft report, Spokane River and Lake Spokane Dissolved Oxygen Total Maximum Daily Load, Water Quality Improvement Report was distributed for a 45-day public comment period in September 2007.

Ecology appreciates the effort made by all the individuals and organizations that provided comments to address the critical issues in the previous draft plan. Use this link to get an electronic copy of the revised draft.

Please direct any questions or comments to:

David Moore

Water Quality Program - Eastern Regional Office

Washington State Department of Ecology

4601 N. Monroe Street

Spokane, WA 99205-1295

Phone:  (509) 329-3514

Email:  dmoo461@ecy.wa.gov

 

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