1. Developing Water Quality Solutions for SF Bay
Dyan Whyte
California Regional Water Quality Control Board
San Francisco Bay Region
Dyan Whyte RMP annual meeting 5/13/2003

2. Total Maximum Daily Load
Clean Water Act §303(d) requires States to:
Identify impaired waters
Adopt plans to restore and maintain water quality standards
California:
TMDLs are adopted by incorporation into Basin Plans
Basin Planning process requires implementation plans
Dyan Whyte RMP annual meeting 5/13/2003
Dyan Whyte RMP annual meeting 5/13/2003

3. 1998 303(d) Impaired Waters List
1472 listings statewide
(400 – 800 projects)
160+ listings in SF Bay Region
(33 projects?)
Dyan Whyte RMP annual meeting 5/13/2003

4. San Francisco Bay listed as impaired by:
Copper
Nickel
Mercury
PCBs
Pesticide toxicity
Legacy pesticides
Selenium
Exotic species
Dioxins/furans
PAHs & PBDEs watch listed
Dyan Whyte RMP annual meeting 5/13/2003
Dyan Whyte RMP annual meeting 5/13/2003

5. Regulatory Action/Process Adaptive Implementation
303(d) List
TMDL Phases & Products 1
Project
Definition
Impairment assessment, conceptual model development 2
Project
Planning 3
Data Collection 4
Project
Analyses
Project Reports
5-7
Regulatory Action/Process
Basin Plan amendment
Phase 1 preliminary data compilation and analyses – evaluate basis of listing, potential sources, working hypotheses regarding causes of impairment
Phase 2 plan for addressing problem, timelines, budgets, data gaps, conceptual model of contaminant transport, fate, and effects to guide data collection and modeling needs define system inputs and outputs
Phase 4 preliminary project reports consisting of evaluation of sources, loads, propose TMDL targets defiing solution to the problem, and implementation strategy which lays out how we are going to achieve targets 8
Adaptive Implementation
WQS
Support
Dyan Whyte RMP annual meeting 5/13/2003

6. How to deal with uncertainty & complexity ???
STOP! Do not proceed until all the facts are in and we understand the system perfectly and can take actions that we know will be 100% effective.
One option is simply to stop and give up until all the information is available.
And that will take how long?
And in the mean time, the fish and birds still have too much mercury in them and nothing would get done at all while we sorted out all the complexities.
No, instead, we need to find a way to cope with this uncertainty and complexity, acknowledge it yes, but not let it paralyze us.
Dyan Whyte RMP annual meeting 5/13/2003
Dyan Whyte RMP annual meeting 5/13/2003

7. Coping with Complexity & Uncertainties
Proceed but employ:
the scientific method
A cautious approach
Flexibility
Adaptive implementation
The Theme here is this: like most of the environmental systems we must regulate, hg in sf bay is really complex and there is a lot we do not know. The presence of this uncertainty and complexity demands 3 things: caution, flexibility, and adaptability
Cautious approach: try not to overstate or overstep what you know, but begin with steps to solve the problem that are firmly rooted in what is known about the system.
Flexibility: since you know that the system is complex and variable, try to build in flexibility where you can. There is no sense in worrying about what is happening from month to month if you have your eyes set on a period of several decades for recovery.
Adaptive management: construct a plan to attack the areas of uncertainty and to incorporate the gained knowledge into the regulatory framework at some defined point in the future
Here are some of the ways in which we are adopting a cautious approach. This is certainly an art – how cautious or how bold to be. But, combined with flexibility and willingness to adapt, it can work.
Maybe the stormwater programs are doing all that they reasonably can do to control mercury load. The problem is, they have never attempted to make such a demonstration. So, we need them to go out there and quantify what they are getting from their program activities and assess the cost of that. Then, we need to explore what the options are for other sorts of activities, the likely benefit and the costs, and we will determine together when MEP has been reached. There have been virtually no efforts to date at such a quantification even though you will hear from the programs all the time that they have done everything reasonable.
For some sources – interim allocation
We also need to pay attention to areas of key uncertainty, like refining our loading estimates and coming to agreement about how these will be computed in the future, since compliance with the allocations is going to depend on this.
Also, we want to make sure that we re-visit the question as to the appropriateness of the targets – particularly the wildlife target since there is emerging information about the effects on birds that may not become available in time for the first version of the TMDL
Dyan Whyte RMP annual meeting 5/13/2003
Dyan Whyte RMP annual meeting 5/13/2003

8. Dyan Whyte RMP annual meeting 5/13/2003
TMDL Projects Updates
Dyan Whyte RMP annual meeting 5/13/2003

9. Cu/Ni in SF Bay Outcomes of the TMDL project
SSOs for South Bay calculated to fully protect beneficial uses
Assessment suggested no impairment by ambient levels of copper
Water quality protection plan that contains pollution prevention actions and ongoing monitoring to assess status
Recommended de-listing
According to USEPA procedures intended to take into account the site-specific conditions, we calculated SSOs that are fully protective of beneficial uses. They turned out to be higher than the national objectives that do not take into account the site-specific factors already mentioned. Methods and results of assessment were peer reviewed and there is stakeholder consensus as well.
a plan was developed to protect water quality when we put these SSOs in place. There has been a downward trend in both copper and nickel concentrations and loading over the last two decades, and the implementation plan should help keep us going in that direction or give us warning should the situation start to get worse for whatever reason. We will have a plan in place to address any changes for the worse as well.
In consideration of the protective proposed SSOs and implementation plan, we have already recommended that this waterbody be taken off the list of impaired waterbodies with respect to copper and nickel
Dyan Whyte RMP annual meeting 5/13/2003
Dyan Whyte RMP annual meeting 5/13/2003

10. Keys to Cu/Ni project success
Adequate Funding and data
RMP baseline monitoring provided core data set to evaluate ambient conditions
San Jose and other cities contributed > $2 million to improve scientific understanding and stakeholder involvement.
Stakeholder involvement
Consensus reached on complex technical issues.
Technical Peer Review
Ensured that the science component was sound.
Paved the way for consensus on the policy issues.
Pretty much anyone involved in this project would affirm that it was a success and a model for how this sort of project should proceed.
The money paid for good science, stakeholder involvement, and peer review of the science.
Here are the keys to success as I see it. (refer to slide)
Stakeholder involvement: the environmental groups had their own technical representation to help them fully understand the complex issues
Dyan Whyte RMP annual meeting 5/13/2003
Dyan Whyte RMP annual meeting 5/13/2003

11. Mercury transformations in the environment:
From cinnabar
to the sushi bar

12. Dyan Whyte RMP annual meeting 5/13/2003
SF Bay mercury sources
Bed Erosion
460
Central Valley Watershed
440
Urban Storm Water Runoff
160
Guadalupe River Watershed 92
Direct Atmospheric Deposition 27
Non-Urban Storm Water Runoff 25
Wastewater 19
Total
1,220
Mercury Load (kg/yr)
Dyan Whyte RMP annual meeting 5/13/2003

13. Used to Evaluate Success
Mercury Sources
WQ Standards (beneficial uses)
Sediment Target
Fish Tissue Target
Bird Egg Target
Mercury Sources
Beneficial Uses
Used to Allocate Loads
Used to Evaluate Success

14. SF Bay Mercury TMDL Implementation Plan
Reduce mercury loads to SF Bay.
Reduce production of methyl mercury.
Perform monitoring and focused studies to:
Assess progress toward targets
Refine load estimates
Evaluate appropriateness of targets
Evaluate controllability of loads.
Encourage actions that address multiple contaminants
Re-visit decisions on targets, allocations, and implementation actions every years
So, here comes the TMDL IP to the rescue. We have 4 main features of the IP (read em)
We really have to rely on trying to control methylation because there is probably only about a 20-40% reduction in sources we can hope to achieve.
We need to get better at controlling methylation and we really do not have the information right now to be able to do it so a priority for the adaptive portion of the TMDL moving forward is to figure this out.
Monitoring to see how we are doing in reaching targets and allocations
Special studies to address uncertainties
For this last bullet, many times, mercury contamination co-occurs with other sorts of contamination, say PCBs. We especially want to encourage actions that would address both of these contaminants at the same time.
e need these features
First and perhaps most importantly, a statement of our hypotheses and current understanding and assumptions about how the system works and what we are going to try, and what we do not know and need to find out.
Monitoring (targets achievement)
Studies for target appropriateness
Loading refinement
Conceptual model refinement
Studies to assess controllability of loads and methylation
Plan and time schedule to reflect on our course every 5-10 years
Dyan Whyte RMP annual meeting 5/13/2003
Dyan Whyte RMP annual meeting 5/13/2003

15. PCBs TMDL Conceptual Model
Bioturbation, Scouring,
Deposition & Resuspension,
Transport, Dredging
Atmospheric Deposition
PCBs TMDL Conceptual Model
Golden
Gate
Outflow
Point Sources
Urban Runoff
Surface
Waters
Fish eating Wildlife
Fish
Spills &
On-Land Contaminated
Sites
Biologically
Active
Sediment
Layer
Benthic &
Plant eating
Wildlife
Benthic Invertebrates
& Plants
Non-Urban Runoff & Non-Point
Sources
Buried
Sediment
Layer
Humans
Degradation,
Sorption & Desorption,
Diffusion
Delta Inflow
Dyan Whyte RMP annual meeting 5/13/2003

16. Dyan Whyte RMP annual meeting 5/13/2003
Stay tuned for …
SF Bay Hg final TMDL report
SF Bay PCBs preliminary and final TMDL reports
Guadalupe River source assessment & conceptual model report
Urban Creeks pesticide toxicity final TMDL report
Napa River sediments and nutrients preliminary project report
San Francisquito sediments preliminary project report
Sonoma Creek sediments and nutrients preliminary project report
Dyan Whyte RMP annual meeting 5/13/2003

17. Dyan Whyte RMP annual meeting 5/13/2003
Stay tuned for …
Conceptual models and SF Bay impairment assessments for:
Legacy pesticides
Selenium
Pesticide toxicity
Dioxins/furans
PAHs
PBDEs
Dyan Whyte RMP annual meeting 5/13/2003

18. Acknowledgements Thank you to the hard working TMDL staff, especially
Bill Johnson
Fred Hetzel
Richard Looker
Tom Mumley
who let me pillage their slide collections
Dyan Whyte RMP annual meeting 5/13/2003
Dyan Whyte RMP annual meeting 5/13/2003