TMDL Issues

Meeting Summary

EPA TMDL Presentation (PDF, 392KB)
Georgia Basins, Impaired Waters, and US Military Bases

The meeting was held on January 18, 2001. EPA representatives in attendance included the following:

  • Ron Mikulak, Chief, Water Quality Assessment Section
  • Cecelia Harper, Environmental Scientist (Georgia TMDL State Coordinator)
  • Stephanie Fulton, Environmental Scientist (Tennessee TMDL State Coordinator)

EPD representatives in attendance included the following:

  • Clint Moye, TMDL Coordinator
  • Mike Creason, Industrial Wastewater Unit Manager

DoD representatives that attended the meeting are shown on Attachment I.

The main points discussed during the meeting are summarized below:

The problem with water quality

Over 40% of the waters of the United State still do not meet the water quality standards that have been set for them.  This amounts to over 20,000 individual river segments, lakes, and estuaries.  These impaired waters include 300,000 miles of rivers and shorelines and approximately 5 million lakes.

Section 303(d) of the Clean Water Act

Under Section 303(d) of the 1972 Clean Water Act, states, territories, and authorized tribes are required to develop lists of impaired waters.  These impaired waters do not meet water quality standards – even after point sources of pollution have installed the minimum required levels of pollution control technology.  The law requires that these jurisdictions establish priority rankings for waters on the lists and develop TMDLs for these waters.

What is a TMDL?

A TMDL or Total Maximum Daily Load is a calculation of the maximum amount of a pollutant that a waterbody can receive and still meet water quality standards, and an allocation of that amount to the pollutant’s sources.  In equation form,

WLA = Wasteload Allocation for permitted point sources
LA = Load Allocation for nonpoint sources
MOS = Margin of Safety

EPA Actions to Implement the TMDL Program

The New TMDL rule

EPA published the new TMDL final rule on July 13, 2000.  However, Congress added a “rider” to one of their appropriations bills that prohibits EPA from spending FY2000 and FY2001 funding to implement the new rule.

Current TMDL Program

The current rule remains in effect until 30 days after Congress permits EPA to implement the new rule.

Overview of the 1992 TMDL Regulations–Under Which the Current Program Operates

Scope of Lists of Impaired Waters

  • States must list waters that are both impaired and threatened by pollutants.
  • The list is composed of waters that need a TMDL.
  • At the state’s discretion, the waterbody may remain on the list after EPA approves the TMDL, or until water quality standards are attained.

Methodology Used to Develop Lists

  • States must consider “all existing and readily available water quality-related information” when developing their lists.
  • Monitored and evaluated data may be used.
  • The methodology must be submitted to EPA at the same time as the list is submitted.
  • At EPA’s request, the states must provide “good cause” for not including and removing a water from the list.

Priorities/Schedules for TMDL Development

  • States must establish a priority ranking of the listed waterbodies taking into account the severity of pollution and uses to be made of the water, for example, fishing, swimming, and drinking water.
  • The list must identify for each waterbody the pollutant that is causing the impairment.
  • States, territories, and authorized tribes must identify waters targeted for TMDL development within the next 2 years.

EPA Actions on Lists and TMDLs

  • EPA has 30 days in which to approve or disapprove a state’s list and the TMDLs.
    • If EPA disapproves either the state’s list or an individual TMDL, EPA has 30 days to establish the list or the TMDL. EPA must seek public comment on the list or TMDL it establishes.

Ga EPD Actions to Implement the TMDL Program

Watershed Approach

Georgia is implementing a watershed approach to water resource management through River Basin Management Planning.  River basin planning is the foundation for implementation of water protection strategies in Georgia.  In accordance with legislation passed in 1992, the Chattahoochee and Flint River Basin plans were completed in 1997, the Coosa and Oconee Basin plans were finished in 1998, and plans for the Savannah and Ogeechee Basin were completed in 2000.   The watershed plans are located at  This basin management planning approach is dynamic.

Every 5 years, additional monitoring data is collected and the plans may be updated.  Bases are encouraged to participate in the River Basin Watershed Management Planning process.  Any base personnel interested in participating in this process should contact Mork Winn of EPD at 404-165-1644.

In addition, Mr. Winn encourages DoD representatives to do the following:

  • Contact the Director’s office at 404-165-5947 or 888-373-5947 to ask to be placed on two lists:  one related to permitting and the other related to water quality standards.  Every time there is a rule change or a new permit issued, a notification will be sent to all names on the list.
  • Contact Theresa Hankerson at 404-165-6236 and request a copy of “Water Quality in Ga.”  This document includes information about all EPD programs related to water protection.

TMDL listing in Georgia

Georgia is under the most aggressive TMDL schedule in the nation.  The vast majority of waters on the list are a result of exceedances of the criteria for fecal coliform bacteria or metals, or poor fish communities due to urban runoff or nonpoint sources.  The 303(d) list for Georgia is located at  To make a determination if your facility is impacted, you must view the entire list.  This includes the following four documents on the web site: Partial Support List, Not Support List, Lake List, and Estuary List.

Schedule for listing in Georgia

  • Public notice for TMDLs for the St. Marys, Satilla, Suwannee, and Ochlocknee River Basins by June 30, 2000
  • Public notice of TMDLs for the 303(d) listed segments in the Ocmulgee, Oconee, and Altamaha River Basin by June 30, 2001
  • Public proposal of TMDLs for the Chattahoochee and Flint River Basins for the 303(d) listed segments by June 30, 2002
  • Public notice of TMDLs for the Coosa, Tallapoosa, and Tennessee River Basin 303(d) listed segments by June 30, 2003
  • Public proposal of TMDLs for the Savannah and Ogeechee River Basin 303(d) listed waters by June 30, 2004.

RDC/TMDL Implementation Plan Project

The EPD is under federal court order to come up with implementation plans for all of the established TMDLs.  The implementation plans must include timelines, measurable milestones, and a process for revising TMDLs.  EPD has contracted with all of the Regional Development Centers (RDCs) across the state to develop implementation plans for the TMDL process.  Bases are encouraged to contact their RDC so that they can participate in the development of the implementation plans.

Next steps for the workeam (subject to change as data is gathered) Determine impact of TMDLs to individual bases

  • Identify pollution prevention projects to mitigate impact at those specific bases
  • Implement projects
  • Share success stories with regulatory partners