Assessment Comments

Assessment is based on results of (1) IDNR/UHL ambient monitoring from 2004-06 upstream from Cedar Rapids, (2) monitoring of the Cedar River for nitrate by the Cedar Rapids Water Department from 2004-06, and (3) USGS ambient monitoring at Cedar Rapids from 2004-06.

Basis for Assessment

SUMMARY:  The Class A1 (primary contact recreation) uses are assessed (monitored) as “partially supported” due to levels of indicator bacteria that exceed state criteria.   The Class B(WW1) aquatic life uses are assessed (monitored) as "fully supported" based on results of ambient water quality monitoring.   The Class C (drinking water) uses are assessed (monitored) as "partially supported” due to levels of nitrate that occasionally exceed the state drinking water criterion of 10 mg/l (=U.S.  EPA’s MCL for nitrate).   Fish consumption uses are not assessed due to the lack of fish contaminant monitoring in this river segment.   The sources of data for this assessment are (1) the results of monthly monitoring from January 2004 through December 2006 at the IDNR ambient city monitoring station located at County Road E36 east of Palo (STORET station 10570002), (2) the results of ambient monitoring of the Cedar River for nitrate by the Cedar Rapids Water Department from 2004 through 2006, and (3) results of USGS chemical/physical water quality monitoring at Edgewood Road from March 2004 through December 2006.  

Note:  A TMDL for nitrate in this segment of the Cedar River was prepared by IDNR and approved by EPA in January 2007.   Because, however, the Section 303(d) impairment related to bacterial indicators (E.  coli) was not addressed in the TMDL, this waterbody remains in IR Category 5a (impaired; TMDL required) for the 2006 and 2008 assessment/listing cycles.

EXPLANATION: The Class A1 uses are assessed (monitored) as "partially supported" based on results of monitoring for indicator bacteria (E.  coli) at the IDNR/UHL ambient monitoring station on the Cedar River east of Palo.   Due to recent changes in Iowa’s Water Quality Standards, Iowa’s assessment methodology for indicator bacteria has changed.   Prior to 2003, the Iowa WQ Standards contained a high-flow exemption for the Class A criterion for indicator bacteria (fecal coliforms) designed to protect primary contact recreation uses:  the water quality criterion for fecal coliform bacteria (200 orgs/100 ml) did not apply "when the waters [were] materially affected by surface runoff."  Due to a change in the Standards in July 2003, E.  coli is now the indicator bacterium, and the high flow exemption was eliminated and replaced with language stating that the Class A criteria for E.  coli apply when Class A1, A2, or A3 uses “can reasonably be expected to occur.”  Because the IDNR Technical Advisory Committee on WQ Standards could not agree on what flow conditions would define periods when uses would not be reasonably expected to occur, all monitoring data generated for E.  coli during the assessment period, regardless of flow conditions during sample collection, will be considered for determining support of Class A uses for purposes of Section 305(b) assessments and Section 303(d) listings.  

The geometric mean level of indicator bacteria (E.  coli) in the 25 samples collected (56 orgs/100ml) is well below the Iowa Class A1 water quality criterion of 126 orgs/100ml.   Five of the 25 samples (20%), however, exceeded Iowa’s single-sample maximum criterion of 235 orgs/100 ml.   According to U.S.  EPA guidelines for Section 305(b) reporting, if levels of E.  coli exceed the single-sample maximum criterion in more than 10% of the samples, the primary contact recreation uses should be assessed as “partially supported” (see pgs 3-33 to 3-35 of U.S.  EPA 1997b).   According to IDNR’s assessment/listing methodology, these results suggest that significantly greater than 10% of the samples exceed IDNR’s single-sample maximum criterion, thus suggesting that the Class A1 uses should be assessed as “partially supported/impaired”.   Note:  one less violation of the single-sample maximum criterion for E.  coli during the 2004-2006 period would have resulted in an assessment of “fully supported” for the Class A1 uses.

The Class B(WW1) aquatic life uses are assessed (monitored) as "fully supported" based on results of water quality monitoring from (1) the IDNR ambient station near Palo and (2) the USGS station at Edgewood Road from 2004 through 2006.   Monitoring at these stations showed no violations of Class B(WW1) water quality criteria for dissolved oxygen or ammonia-nitrogen in the approximately 40 samples analyzed, or for toxic metals in the approximately 15 samples analyzed during this assessment period.   The level of pH, however, in two of the 36 samples from the IDNR/UHL station violated the Class B(WW1) criterion of 9.0 pH units.   Because these violations are more likely related to natural conditions than to a pollutant, the occurrence of the high level of pH in this river segment is not seen as a water quality impairment.   In addition, the frequency of pH violations does not suggest impairment:  according to U.S.  EPA guidelines (U.S.  EPA 1997b, page 3-17), a violation frequency of less than 10 % for conventional parameters such as pH suggest "full support" of aquatic life uses.   Thus, the percentages of violations of the pH criterion at the IDNR and USGS stations (6%) do not suggest an impairment of aquatic life uses.

Based on results of ambient monitoring conducted by IDNR and by the Cedar Rapids Water Department, the Class C (drinking water) uses are assessed as "partially supported" due to violations of the state water quality standard (= U.S.  EPA’s MCL) for nitrate.   Results of IDNR ambient monthly monitoring on the Cedar River at Palo station show four violations of the nitrate MCL in the 36 monthly samples (11% violation) collected during the 2004-2006 assessment period (mean=6.4 mg/l; maximum=11.0 mg/l).   Results from the USGS station at Edgewood Road show one violation of the nitrate MCL in the 14 samples (7% violation) collected during the 2004-2006 assessment period (mean=6.2 mg/l; maximum=12.5 mg/l).According to the IDNR assessment methodology, these results do not suggest that significantly more than 10% of the samples is greater than the Class C criterion for nitrate of 10 mg/l (=U.S.  EPA MCL) and thus do not suggest impairment of the Class C drinking water uses.   Based on DNR's Section 305(b) assessment methodology, if less than 10% of the samples exceed the nitrate MCL, the drinking water uses should be assessed as "fully supported."  None of the 35 samples analyzed for atrazine from the IDNR/UHL station, and none of the 13 samples analyzed for atrazine from the USGS station during the 2004-06 assessment period, exceeded the Iowa Class C criterion for atrazine of 3 ug/l (=U.S.  EPA’s MCL).   The average level of atrazine in the 35 IDNR/UHL samples was 0.14 ug/l (median=0.06 ug/l); the average level in the 13 USGS samples was 0.31 ug/l (median=0.09 ug/l); these results do not suggest an atrazine-related impairment of the Class C uses.  

Monitoring of the Cedar River by the Cedar Rapids Water Department (CRWD) near their water supply intake areas from January 2004 through December 2006, however, suggests that the drinking water uses of this segment of the Cedar River should remain assessed as “impaired.”  The CRWD data from the Mohawk Park monitoring station show that 94 of the 369 samples collected (25% violation) exceeded the 10 mg/l water quality standard.   At the Mohawk Park station, the mean, median, and maximum values were 8.0, 7.8, and 13.6 mg/l, respectively.   Violations tended to occur during the late spring and early summer.  

Due to over-sampling by water supply utilities during times of year when nitrate levels tend to be high, the use of a simple percentage of sample violations likely overestimates the percentage of time that nitrate levels actually exceed the MCL.   Thus, in order to determine whether the Class C uses are impaired, IDNR staff summarized nitrate data from the Cedar River Water Department as weekly averages and compared these averages to the water quality standard.   Eighteen of the 156 weekly average nitrate levels (11.5%) for the period 2004-2006 exceeded the MCL at the Mohawk Park station; three of 38 weekly average nitrate levels (8%) for the period 2004-2006 exceeded the MCL  at the Black Hawk Park station.  

According to IDNR's assessment guidelines, while the IDNR and USGS datasets show an MCL violation frequency of less than 10% and thus suggest “full support” of the Class C drinking water uses, the more robust dataset from the CRWD provides good evidence that levels of nitrate in this segment of the Cedar River exceed the nitrate MCL of 10 mg/l more than 10% of the time.   Also, information supplied by the Cedar Rapids Water Department shows evidence of increasing nitrate levels over time.   This increasing trend in nitrate also suggests less than full support of the designated drinking water uses.   Thus, the drinking water uses remain assessed as “impaired” for the current (2008) Section 303(d) listing cycle.   This assessment is consistent with previous assessment and the Section 303(d) listing history for this segment of the Cedar River.  

Fish consumption uses remain “not assessed” due to lack of recent fish tissue monitoring in this river segment.