A TMDL Conundrum: When Adaptive Implementation is Needed
Abstract:A “conundrum” means “an intricate and difficult problem”. This is exactly what States, Tribes, EPA and Interstate Agencies are beginning to address as they try to develop TMDLs for waterbodies where extremely stringent water quality standards, complex hydrodynamic and pollutant loading situations, data limitations, and very uncertain implementation approaches make it difficult to craft a reasonable solution to meet water quality standards. This description often can be applied to TMDLs that are under development or shortly will be developed for ubiquitous pollutants with extremely low water quality standards such as PCBs, mercury and dioxin. One such current example of this type of difficult TMDL development effort is the TMDL for PCBs that the Delaware River Basin Commission is currently developing for the States of New Jersey, Pennsylvania and Delaware in the Delaware Estuary. Several of the complex issues facing the regulators, point source dischargers and non-point sources on this waterbody are:
How to develop a TMDL when the PCB water quality standard will not be met for decades because of non-point sources even if the discharge permit limits are set equal to the water quality standards.
How to establish waste load allocations resulting in permit limits that likely could not be met even when considering such factors as compliance schedule and interim permit limits
How to address the need for additional allocation in the future to enable municipal and industrial growth.
How much and how quick should PCBs be reduced.
This paper will describe the complex issues faced in this TMDL and why these make the “conventional” TMDL process not feasible for this situation. The barriers for success of adaptive implementation of a TMDL and implementation process will also be discussed The presentation will consider the need for extrapolating this approach to other similar TMDL applications across the country.
Document Type: Research Article
Publication date: January 1, 2003
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