Challenges and Solutions for Developing TMDLs for Bioaccumulative Pollutants: The California Experience

Authors: Cowan, Karen; Minton, Chris; Ashby, Karen

Source: Proceedings of the Water Environment Federation, Impaired Waters Symposium 2011 , pp. 509-528(20)

Publisher: Water Environment Federation

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Abstract:

In the current regulatory framework, bioaccumulative pollutants are very difficult to regulate. Water quality criteria/objectives for bioaccumulative pollutants are often narrative (i.e, do not have “too much” so the pollutant does not bioaccumulate to levels that are harmful to human health, aquatic life and/or wildlife). The use of narrative rather than numeric objectives reflects the site-specific nature of a bioaccumulative compound. However, narrative objectives leave significant room for subjectivity, making 303(d) listing decisions and TMDL development and implementation a complex and often contentious process. Recent TMDLs in development and/or adopted in California (e.g., PCBs in San Francisco Bay, selenium in Newport Bay, organochlorine pesticides and PCBs in Los Angeles Area Lakes) have utilized innovative approaches that account for site-specific issues yet can potentially be universally applied for the management of bioaccumulative pollutants throughout the State.
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