Chapter
Aug 19, 2013
Legacy Pollutant Total Maximum Daily Loads:An Oxymoron?
Authors: E. Darby [email protected], J. Rhea [email protected], J. Benaman [email protected], S. Anghera [email protected], D. Glaser [email protected], and W. Hovel [email protected]Author Affiliations
Publication: Ports 2013: Success through Diversification
Abstract
Legacy pollutants (such as pesticides, polychlorinated biphenyls (PCBs), and other chemicals banned from use years ago) represent a major challenge to the states' total maximum daily load (TMDL) programs. However, many legacy pollutant sites are regulated under one or more existing federal programs. Therefore, legacy pollutant TMDLs often represent a form of regulatory double jeopardy as successful execution of federal program regulated cleanup does not preclude responsible parties from the TMDL provisions of the Clean Water Act. In addition, certain legacy pollutants have shown to bioaccumulate, which allows TMDLs to require reduction of fish tissue burdens for the removal of fish consumption advisories. Often, water column concentrations derived from targeted fish tissue body burdens are far below the analytical detection limit, exceed background pollutant concentrations and are not supported by site-specific data. These issues require alternative approaches for establishing legacy pollutant TMDLs.
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Ports 2013: Success through Diversification
Pages: 262 - 271
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© 2013 American Society of Civil Engineers.
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Published online: Aug 19, 2013
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Anchor QEA, 26300 La Alameda, Suite 240, Mission Viejo, CA 92691. E-mail: [email protected]
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