(Table of Contents)

III.3 Water Quality Assessment

Of the information available through historic, recent, and current monitoring programs on the Nooksack River, the data collection efforts of the Department of Ecology, the NWIC, Western Washington University, and the purveyors most closely fit the review criteria outlined in Section III.1.  Figure 29 identifies sampling site locations for these studies, which will be referenced throughout the water quality assessment discussion.

Background

The Nooksack River and its tributaries are classified as Class A (excellent) from the mouth to Maple Creek at river mile 49.7. The South Fork is also Class A to Skookum Creek at river mile 14.3.  The river and tributaries above Maple Creek, the Middle Fork, and the South Fork above Skookum Creek are classified Class AA (extraordinary).

Characteristic uses of Class AA and A freshwaters include domestic, industrial, and agricultural water supply; stock watering; salmonid and other fish migration, rearing, spawning, and harvesting; wildlife habitat; primary contact recreation, sport fishing, boating, and aesthetic enjoyment; and commerce and navigation.  The emphasis of this plan is the source water supply for municipal and industrial uses.  The quality of water in terms of bacterial and chemical components is important in order to maintain a safe water supply.   Therefore, these are the elements of water quality monitoring efforts that will be emphasized in the below discussions.

III.3.1 Fecal Coliform 

Fecal coliform bacteria are normally found in the digestive tracts of warm-blooded animals.  They are closely correlated to animal fecal matter and human sewage.  Fecal coliform has been accepted as a universal indicator species for bacterial pathogens.  The presence of fecal coliform does not confirm the presence of other pathogens, yet high concentrations indicate the possibility of the presence of disease-causing pathogens (Vesilind et al. 1988).

Under Washington State’s water quality standards, fecal coliform levels in fresh water Class A waterbodies shall not exceed a geometric mean value of 100 organisms/100mL, with not more than 10% of the samples exceeding 200 organisms/100 mL.  For Class AA fresh waters, fecal coliform shall not exceed a geometric mean value of 50 organisms/100 mL, with not more than 10% of samples exceeding 100 organisms/100mL (Chapter 173-201 WAC).

Nooksack River Studies

The Department of Ecology’s ambient stations on the mainstem of the Nooksack River at North Cedarville and Brennan are most representative of trend stations due to the consistent sampling that has occurred at these sites since 1977.  Both the North Cedarville and Brennan ambient sites are located in the section of the Nooksack River characterized by Class A standards.

The North Cedarville station is located near Deming, which is down river of the confluences of the North, Middle and South Fork drainages.  The primary land use in these three drainages is commercial forestry.  In addition to commercial forestry, approximately 8% of the land area in the South Fork drainage is zoned agriculture.  Rural residences are also scattered throughout the three drainage basins. 

Fecal coliform levels at the North Cedarville ambient monitoring site have consistently met state standards for Class A fresh waters.  Although the annual geometric mean for fecal coliform has fluctuated to some extent over the 1977-1998 sampling period (Figure 26), the annual mean has not exceeded 16 cfu/100 mL, which is well below the 100 cfu/100mL standard.  There have been occasional spikes above 200 cfu/100mL, however, the number of spikes are below the 10% requirement of the Class A fresh water standard for each year (Table 44). There is minimal fecal coliform information for the individual forks of the river, which all drain to the Nooksack above the North Cedarville ambient station.  However, information collected on the Middle and South Forks, by the Department of Ecology, from October 1996 to September 1997 indicate that both waterbodies met state standards for Class AA fresh water during this sampling period.

The information reported for the North Cedarville sampling station indicates that over the past twenty years, Nooksack River water quality has not been significantly affected by land uses upriver of the North Cedarville station as it relates to fecal coliform loading.  

TABLE 44. FECAL COLIFORM CONCENTRATIONS AT NORTH CEDARVILLE FROM 1977 TO 1998.

* Annual geometric mean.  

The Brennan site has exceeded the Class A standard for fecal coliform a number of years since 1977 (Table 45).  Both the 100cfu/100mL geometric mean and the 10% limit of samples above 200cfu/100mL have been exceeded.  However, review of the geometric means in Table 45 and a graphed comparison of the data (Figure 26) illustrate a gradual decline in the level of coliform over the 21-year sampling period (1977 to 1998).  The decline has not been smooth and some years have shown high levels of fecal coliform.  

TABLE 45. FECAL COLIFORM CONCENTRATIONS AT BRENNAN FROM 1977 TO 1998.

* Annual geometric mean.  

Figure 26. Annual fecal coliform concentrations (geometric mean) at North Cedarville and Brennan ambient stations between 1977 and 1998. The trend at the Brennan site has been a decline in annual fecal coliform concentrations over time, while the North Cedarville station has remained relatively constant.

The Department of Ecology has four additional ambient sites that have been monitored for short periods.  These sites are chosen through a state rotating process that allows the regional Ecology offices to identify a site for a short-term monitoring effort.  The Ferndale, Lynden, and South Fork ambient sites are located in sections of the Nooksack River characterized by Class A standards.  The Middle Fork site is in a section characterized by the Class AA standards.  The Ferndale site was monitored for fecal coliform between February and September in 1974 and between October 1976 and September 1977.  The Lynden site was also monitored between October 1976 and September 1977.  The Ferndale and Lynden sites are located on the Class A stretch of the main stem of the river.   Both sites exceeded Class A standards for fecal coliform during the 1976-77 sampling period (Table 46).  Ambient sites were monitored at the South Fork and the Middle Fork between October 1996 and September 1997.  Both sites had low levels of fecal coliform throughout the study period.  Sampling by the City of Bellingham at the Middle Fork diversion during 1998 and 1999 also found consistently low fecal coliform concentrations.  

TABLE 46. FECAL COLIFORM CONCENTRATIONS AT DEPT. OF ECOLOGY AMBIENT SITES.

^aGeometric mean over sampling period.
^bN/A = not sampled during this time period.

The Department of Ecology also conducted a year-long Nooksack TMDL study. As part of this study, fecal coliform concentrations were measured at six main stem sites between March 1997 and February 1998.  In addition, fecal coliform was measured at four point sources along the main stem of the Nooksack River.  All of these sites are located in the Lower Nooksack Basin which is characterized by Class A fresh water standards.  The main stem TMDL monitoring included monthly collections as well as storm-event sampling at all sites except the Bertrand/Fishtrap and Everson sites.  The monthly sampling generally included two samples in a three-day period between March and August 1997.  In September and November 1997 and February 1998, monthly collection efforts generally included four consecutive days of sampling. In October and December 1997 and January 1998, storm-event sampling was conducted.  Several samples were collected during a 48-hour period.  Throughout the study, samples were taken from the right, center, and left channels of the main stem sites during different sampling events.  Not all of the stations were sampled during each sampling event and there was some variability in terms of parameters measured.

Review of the raw data from the TMDL study show that Class A standards for fecal coliform were met during this sampling period at four of the six sites (Table 47) under different sampling scenarios.  Fecal coliform standards were met at North Cedarville and Lynden during both the monthly sampling and the monthly sampling combined with storm-event sampling.  There was no storm-event sampling at the Bertrand/Fishtrap and Everson sites, but the monthly sampling met the Class A standards.  At the Marine Drive and Ferndale sites, although the geometric mean requirement was met, greater than 10 percent of the samples had fecal coliform concentrations above 200cfu/100mL.  The 10 percent limit was exceeded at both sites during the monthly sampling and the monthly sampling combined with the storm-event sampling.

In addition to the mainstem Nooksack River sites, Ecology’s TMDL study included sampling sites on tributaries draining to the river.  Site locations were typically at the mouths of the creeks.  Although a discussion of these sites is provided later, it is worth noting at this point that a review, of pollutant loads for the creeks reported in the preliminary TMDL data report, do not appear to significantly influence water quality at the main stem monitoring stations with a possible exception of the Ferndale and Marine Drive sites. This is likely due to the distance of the mainstem sampling sites from the creek mouths and the dilution that occurs when the creek drainage mixes with the river.  It is also worth noting that the annual geometric mean for the mainstem stations sampled during the TMDL assessment period are consistent with the geometric mean values for the Brennan and North Cedarville ambient stations for the same sampling year (illustrated in Figure 26).

With regard to the Ferndale and Marine Drive stations, factors that may be contributing to elevated fecal levels in addition to potential loading from sampled tributary mouths include nonpoint runoff from adjacent rural land areas (i.e., failing or improperly designed/installed septic systems or hobby farms) draining directly to the Nooksack and discharge of untreated stormwater runoff to the river via culverts.

Four point sources along the main stem of the Nooksack River were also monitored for the TMDL study.  These sites included Darigold and the Everson, Lynden, and Ferndale wastewater treatment plants.  Based on a review of the data collected by Ecology during the TMDL assessment, both Lynden and Everson experienced fecal coliform counts greater than 200 for their wastewater with Lynden experiencing elevated counts more frequently than Everson (9 samples out of 15 and 5 samples out of 15, respectively).  Since the 1997-98 TMDL sampling event, equipment upgrades have been made to the Lynden wastewater treatment plant as part of their plant expansion (discussed in Section II).  Monitoring at the plant has indicated that the equipment upgrades have been successful.  The City of Lynden has not experienced violations of fecal coliform levels in the plant’s wastewater since the upgrades took effect (Klimpel, 1999).

A special investigation included in the TMDL was a drogue study in June 1997.  A set of drogues was followed twice between Ferndale and Marine Drive.  No significant changes in the levels of fecal coliform were detected over the five-mile distance.  This suggests that fecal coliform die-off rates were low in the Nooksack River during that sampling period.  Die-off rates are easily impacted by environmental conditions such as water temperature and sunlight (Michaud, 1991).  During favorable conditions (warm water temperatures), there may be a high growth right.  On the other hand, unfavorable conditions (cold water temperature or high levels of ultra-violet light) can lead to a rapid die-off of the bacteria.  Thus, under different conditions the die-off rate in the Nooksack River may also change.

The Northwest Indian College has continued monitoring fecal coliform at five of the six TMDL main stem sites (excluding Bertrand/Fishtrap).  Geometric means and the percent of samples exceeding 200 cfu/100mL during 1998 were similar to the levels found in the TMDL study.  The Cedarville, Everson, and Lynden sites met the Class A requirements.  The Marine Drive and Ferndale sites exceeded the Class A limit of samples above 200 cfu/100mL (Table 47).  

TABLE 47. FECAL COLIFORM CONCENTRATIONS AT THE FIXED MAIN STEM SITES FOR DEPT. OF ECOLOGY TMDL STUDY (1997) AND THE NORTHWEST INDIAN COLLEGE CENTENNIAL CLEAN WATER GRANT (1998).

^a Sample number and geometric mean calculated from DOE raw data.  Final report and presentation of data was not available at this time.
^b NWIC data includes samples collected between April 1998 and March 1999.  Samples were generally collected every two weeks.  This data does not include the quality assurance data..
^c Ecology TMDL data was collected between March 1997 and February 1998.  Samples collected from right, mid, and left channels during three and four day sample events.  Samples were not consistently collected from the same number of channels during each sampling event.  During storm events, six samples were collected during a 24 or 48-hour period.
^d N/A = No storm sampling at these sites.

Tributary Studies

As previously outlined, the primary objective of the NSPP data review is to assess source water quality and trends using existing data collection efforts.  As with monitoring efforts on the Nooksack River, the collection efforts that have taken place on tributaries in the basin appear to focus on enforcement/regulatory efforts, stream restoration, and educational purposes.  Studies that have been undertaken that have the largest data set have taken place on tributaries in the Lower Nooksack Subbasin and appear to have been designed with program objectives that focus primarily on impacts from agricultural practices and which support regulatory/enforcement efforts.  A brief overview of these studies is included below.  Although several parameters were measured as part of the data collection efforts, the focus of the overviews is on fecal coliform concentrations.

The Department of Ecology conducted a TMDL study on Fishtrap Creek in 1994-1995 (Erickson 1995).  The land use in Fishtrap watershed is predominately agriculture and primarily dairy operations.  The concentration of fecal coliform varied greatly throughout the study period.  This was described in the study as an illustration of the variable loading characteristics associated with fecal coliform.  However, Class A standards for fecal coliform were exceeded at every site that was monitored along the main stem of Fishtrap Creek as well as its tributaries. The critical periods of fecal loading that were identified for Fishtrap Creek were rainfall events that occurred after prolonged dry periods.

The Institute of Watershed Studies at Western Washington University studied Kamm Creek from 1993 to 1998 (Matthews and Vandersypen 1998).    Fecal coliform levels exceeded Class A standards in three of four sites on Kamm Creek; the geometric means were above 100cfu/100mL and over 10% of the samples were above 200 cfu/100mL.  Similar to Ecology’s finding in Fishtrap Creek, fecal coliform concentrations appeared to be higher during the dry season between 1993 and 1998 at three of four sites on Kamm Creek.  No changes in concentrations were seen at the fourth site.

As discussed in Section III.2.1 and Section III.2.2, the Department of Ecology sampled a number of tributaries in the Lower Nooksack Subbasin as part of a TMDL assessment for the Nooksack River.  Generally, samples were collected at the mouth of the tributaries.  The Department of Ecology reported that fecal coliform levels found in the tributaries during the Nooksack TMDL study were not significantly different from levels found in the Fishtrap Creek TMDL, Kamm Creek study, or other studies done since the early 1990’s (Joy, unpublished draft report). 

It is important to remember that fecal coliform concentrations can vary widely due to a variety of factors including but not limited to water temperature, sunlight, rainfall, run-off, suspended materials, and deposition of bacteria in the stream sediments (Michaud 1991; Erickson 1995).  In each of the monitoring efforts previously outlined, fecal coliform concentrations have not been consistent or seasonally predictable. The draft TMDL study reports a pattern of higher levels of fecal coliform during storm events.

Fecal Coliform Summary

As discussed in Section II of the NSPP, there are a variety of land uses in the Lower Nooksack Subbasin with a potential to contribute to the elevated fecal coliform counts reported in the studies discussed above.  Primary sources of fecal coliform are animal waste (direct delivery from livestock, animal confinement areas, improper application of animal waste, and run-off from fields), human waste (failing septic systems and malfunctions in municipal sewer facilities including failing seams, pump failures, etc.), stormwater (wild and domestic animal waste), and point sources. 

There are few available studies that have been undertaken in the Nooksack Basin that have identified QAPPs, identified program objectives, and at least one year of consistent sampling.  An existing monitoring program that best fits the criteria for the NSPP data review objectives is the Department of Ecology’s ambient monitoring program.  The same stations have been sampled for over 20 years and continue to be monitored.  Establishing a long-term database such as this provides the type of database needed in order to determine water quality trends over time. 

The other program that has been undertaken on the mainstem of the Nooksack River is the TMDL assessment completed by the Department of Ecology.  From a source protection standpoint, preliminary assessment of the TMDL program indicates that the program may not be as useful to the City of Lynden and PUD as the ambient monitoring program due to the short-term nature of the study (approximately one year) and an effort to achieve multiple program objectives using a single design.

The objectives listed in the Nooksack TMDL QAPP include 1) identifying sources of bacteria loading along the lower Nooksack and its tributaries, 2) recommending waste load and load targets for point sources, tributaries, and nonpoint sources in the project area, and 3) evaluating the effectiveness of controls in watersheds with existing watershed action plans and implementation strategies (Joy, 1997).  As mentioned early on, monitoring programs are typically designed to meet specific objectives.  Monitoring programs designed to meet the objectives listed in the QAPP, if done independent of each other, would likely have different approaches.  For example, identifying specific sources of bacteria loading might be approached with an investigative monitoring design, waste load allocations (WLA) might be approached using the modeling designs outlined in the EPA technical documents for TMDLs and WLAs[1], and evaluation of watershed controls might be approached with paired samples or paired watersheds and conducted as a long-term monitoring effort (>5 years).  However, available resources (staff and finances) are often the limiting factors when designing monitoring programs.  This often leads to an effort to address a number of objectives with a single design.  The final report has not been presented so it is unknown as to whether all of the QAPP have been successfully met. 

The NWIC monitoring program was designed to overlap sampling locations used in the TMDL study.  Designing the sample locations to coincide with Ecology’s TMDL sample sites will contribute to building a database of information on both the tributaries and the lower Nooksack that can be used in assessing source water quality trends.  In addition, the NWIC monitoring program has additional sites on the tributaries including sampling sites at the confluence of tributary reaches.  This approach will help identify the reaches that are contributing higher loads of fecal coliform to the system.

III.3.2 Giardia and Cryptosporidium

Giardia and Cryptosporidium are parasitic protozoan that can lead to waterborne diseases such as gastrointestinal illnesses.  These organisms are single-celled organisms and hard to detect.  Giardia and Cryptosporidium may be found in surface waters.

Generally, in healthy people, cryptosporidiosis usually lasts a couple of weeks (Fayer, 1999).  However, in children and immune-compromised individuals cryptosporidiosis can last much longer and potentially be fatal.

Cryptosporidium parvum is the species of Cryptosporidium found to be infectious for humans.  C. parvum has been reported in a wide variety of mammals including humans.  Infection of humans results from ingestion of oocysts in contaminated water or food.  Direct or hand-to-mouth transfer of the protozoa from feces or contaminated surfaces can also cause infection.  In addition, streams or lakes may be sources when contaminated by animal feces (Fayer, 1999; WADOH, 1997).  C. parvum has been repeatedly reported to be found in domesticated animals, especially calves.  Infected calves can excrete a significant number of oocysts.  In addition to the large numbers of oocysts that can originate from agricultural sources, humans are recognized as sources of Cryptosporidium.  Oocysts have been reported in treated sewage, combined sewer overflows, and backwash water from filtration plants (Kohne, et.al.).

The presence of oocysts does not in itself indicate a health threat. They must be viable and and a genotype capable of infecting humans (Fayer, 1999).

Cryptosporidium has been shown to have high levels of resistance to disinfection levels that are usually associated with water treatment.  According to information provided through WADOH, treatment for Cryptosporidium appears to rely upon a well-operated and controlled filtration process.  Outbreaks of cryptosporidiosis that have occurred in water systems using filtration and chlorination involved situations where unusual conditions or inattentive operation failed to control the introduction of the organism into the distribution system (WADOH, 1997).

The presence of Giardia and Cryptosporidium has been correlated with high levels of turbidity and the indicator species fecal coliform.  The 1996 Safe Drinking Water Act Amendments identify Cryptosporidia as an agent that shall be regulated in the future. However, there are currently no regulations requiring monitoring of Cryptosporidium in public water systems.

At this time, there has been very little monitoring of Giardia and Cryptosporidium in the Nooksack Basin.  One thesis study from Western Washington University investigated Giardia and Cryptosporidium concentrations in three streams in Whatcom County (Smith 1997).  One of the streams was Kamm Creek.  Giardia and Cryptosporidium oocysts were present in Kamm Creek, but they were not tested for viability.  In addition, local purveyors monitor for Giardia and Cryptosporidium.  The City of Ferndale did a one-time testing of their finished water for these protozoan parasites and had no findings.

III.3.3 Chemical Contaminants

The Class A and AA fresh water criteria for toxic, radioactive, or deleterious materials are concentrations that are below those which have the potential either singularly or cumulatively to adversely affect characteristic water uses, cause acute or chronic conditions to the most sensitive biota dependent upon those waters, or adversely affect public health, as determined by the Department of Ecology (Chapter 1733-201A WAC).

Agricultural practices, forestry, stormwater runoff, and hazardous spills are potential sources of chemical contaminants to the Nooksack River and its tributaries.

Monitoring of chemical contaminants in the Nooksack Basin has been very limited.  The primary monitoring efforts of chemical contaminants include a USGS study which is part of a larger national effort, short term monitoring at the Middle Fork Diversion, groundwater studies conducted by several agencies, and compliance monitoring at the water treatment facilities.

The USGS Puget Sound Basin water quality assessment included a year-long monitoring effort at three sites along the Nooksack River (Embrey, 1999).  Pesticides, volatile organic compounds, and major ions were sampled once a month between March 1996 and May 1997 at Fishtrap Creek and Brennan and major ions were measured at North Cedarville.  Additional monitoring was conducted during storm events.  The data from this monitoring effort is still being reviewed and the report is expected to be complete in 2000.

Several agencies were involved in a series of groundwater studies in the summer of 1998.  The Department of Ecology, Environmental Protection Agency, USGS, Washington State Department of Health, and the Whatcom County Health Department investigated a large number of wells throughout the Bertrand Creek area.  A core group of key pesticides and chemical contaminants were measured and compared to the drinking water standards, at a minimum.  The Department of Ecology investigated 123 wells over a two-phase study (O’Herron, 1999).  Ecology reported that a number of wells were found with levels of 1-2 DCP which has been used as a soil fumigant but is being phased out of the marketplace.  In wells that had historically been contaminated with EDB, the levels had significantly dropped, although some still exceeded drinking water standards.  Additionally, extended tests of some wells found trace levels of several other chemical contaminants, yet the levels were well below drinking water standards.  As of the writing of the NSPP, the data and report were being reviewed and were not available.

The City of Bellingham began monitoring levels of arsenic, cadmium, chromium, copper, iron, lead, mercury, nickel, zinc, and total organic carbon in 1998 at the Middle Fork diversion.  Indications from City personnel are that this program will be ongoing (Wendling, 1999).

The City of Lynden tests levels of primary and secondary chemicals every 12 months from their surface water source.  In addition, they test for pesticides every 36 months and radionuclides every 48 months or as directed by the Washington State Department of Health.  The City of Ferndale also tests for these parameters.  A review of Lynden’s and Ferndale’s data for SOC and VOC showed no detections of the tested chemicals in the source water.

The City of Ferndale wastewater treatment facility had a Class II inspection in June 1997 (Hoyle-Dodson, 1998).  The inspection tested both effluent and receiving waters.  In the effluent sampling one VOA compound (chloroform), eight BNA compounds, and one pesticide (Lindane) were detected, but neither chronic or acute water quality criteria were exceeded by any of the compounds.  In addition, four priority pollutant metals were detected in the composite effluent.  Copper (19 ug/L) exceeded both acute and chronic criteria; lead (9.6 ug/L) and zinc (43 ug/L) exceeded chronic criteria.  Another aspect of the inspection included samples upstream and downstream of the receiving waters in the Nooksack River.  Six metal compounds were detected in the upstream and downstream receiving water samples (arsenic, chromium, copper, lead, nickel, and zinc).  In the upstream sample, lead exceeded the chronic water quality criteria while copper was within the chronic criteria.  Because the samples taken above and below the receiving waters were below the PUD intake this is not a priority concern for source water quality for the PUD or its customers.  Potential impairment of other beneficial uses associated with the river was not evaluated since it is outside of the scope of the NSPP.

III.3.4 Nutrients

Nutrients include nitrogen and phosphorus compounds, which stimulate plant growth.  Nutrients can be introduced to the water through runoff of fertilizers, manure, septic systems, erosion, detergents, and the natural decay of organic material.  High levels of nutrients can over-stimulate plant growth and cause algal blooms.  In terms of source water, impairment from high levels of nutrients may present itself in the form of taste and odor problems created by algae or bacteria in the distribution system.

Nutrient levels in the Nooksack River have been investigated through the Ecology ambient monitoring program, the Ecology TMDL study, the USGS water quality assessment, the City of Bellingham Middle Fork diversion and various tributary studies.  The USGS nutrient investigation reported that the Nooksack River had some of the largest nutrient inputs and yields when compared with other rivers in the Puget Sound Basin (Inkpen and Embrey, 1998).  The inputs were associated with the large amount of agricultural land use.  It was reported that approximately 90 percent of the nutrient inputs originate from animal and manure fertilizers.  Actual concentrations of nutrients measured in the Nooksack are not reported in the preliminary information prepared on the study.  Therefore, the extent to which nutrients exceeded suggested limits for various uses is unknown at this time.  The raw data and final report will not be available until mid summer 2000.

There currently are not standards for nutrients.  However, EPA documents suggest that total phosphorus (TP) concentrations not exceed 0.10 mg/L for streams that do not flow into reservoirs or lakes and that concentrations of PO₄^-3 above 0.10 mg/L may interfere with the coagulation process in water treatment plants (MacDonald, et.al., 1991; EPA, 1986).  Review of the TMDL study data for the mainstem Nooksack River sites indicated that with few exceptions, TP concentrations were below 0.10 mg/L.  The May 1997 and October 1997 sampling events were the occasions where total phosphorus concentrations exceeded 0.10 mg/L.  The increased concentration in October was likely the result of increased runoff since the October collection was a storm event sampling. The May sampling, however, was not related to a rain event.  Therefore, there is not an obvious explanation for the elevated TP concentration during this collection effort.  A review of other parameters for the May 1997 sampling event indicated that other parameters measured also were elevated during this period.  The highest TP concentration measured during the TMDL study period, 0.20 mg/L, was at the Lynden/Hannegan Bridge site on May 14, 1997.

The geometric annual means were calculated for Ecology’s North Cedarville and Brennan ambient stations for TP for the period of 1977-1998.  As shown in Figure 27, the annual geometric means have been below the recommended TP concentration of 0.10 mg/L.  An interesting occurrence illustrated in the Annual Geometric Mean Total Phosphorus chart is that for a period of about ten years (1978-1988) the TP concentrations were relatively flat.  In 1989, the Brennan station jumped from a geometric mean of 0.038 mg/L to an annual mean of 0.061 mg/L.  There was also a less dramatic increase at North Cedarville; from 0.026 mg/L to 0.038 mg/L.  Since 1989, the TP annual geometric means have experienced greater fluctuations than in the period of 1978- 1988; although still well below the recommended 0.10 mg/L of TP.  The number of samples collected each of year, precipitation levels, and surrounding land uses are all possible factors in the TP variations after 1988.  Since suggested levels for TP concentrations were not being exceeded, an effort was not made to correlate changes in TP after 1989 with rainfall or other influencing factors.

Water purveyors interviewed for the NSPP have not experienced problems with taste and odor.  Taste and odor complaints would be an indication of nutrient impacts to source water for potable use.  However, other beneficial uses may be impacted by nutrient levels in the river.

III.4 Identification of Data Gaps and/or Additional Monitoring Needs  

As discussed early in Section III.2, there have been a number of monitoring efforts undertaken in the Nooksack Basin.  However, there are still gaps in the database for a number of reasons:  

• Monitoring programs are generally not being designed as long-term programs with the exception of the Department of Ecology’s ambient monitoring program (two stations consistently monitored since 1977).  Establishing trend stations and maintaining a monitoring program that supports those stations is a major financial commitment, which is likely the reason most collection efforts have not been designed as long-term programs. 
  
• Several of the collection efforts being done on the tributaries and some of the forks of the Nooksack are associated with educational or restoration programs.  These programs are often not set up for purposes of assessing trends or land use impacts on water quality.  In addition, since these programs have a limited focus and objective QAPP are not typically prepared for the program. 
  
• Programs being pursued by different entities do not generally take into consideration previous monitoring efforts.  Therefore, there is not an overlap in selection of monitoring stations, methodologies, and parameters measured.  Programs designed to have some of these elements in common with other programs will help build on existing databases providing greater opportunity for assessing water quality trends.

Based on preparation of the NSPP, a review of historic and current monitoring programs, the assessment for why data gaps exist, and the need for adequate information for purposes of evaluating trends in source water quality, a list of additional monitoring needs that should be pursued follows.  Modifications and additions to existing monitoring programs should be considered as part of the implementation of the NSPP recommendation for a Comprehensive and Collaborative Basin-Wide Monitoring Program (Section V).  Additional suggestions such as developing a QAPP-shell for basin programs are included in the NSPP recommendation. 

• Design and implement a long-term monitoring program for the Nooksack Basin.  As mentioned on a number of occasions, the ambient monitoring program carried out by the Department of Ecology is the only program that has been in place on the Nooksack River for >10 years (recommended for trend stations) and which has been consistently sampled for the same parameters.  The number of ambient stations should be increased on the mainstem of the Nooksack.  The distance between the North Cedarville and Brennan stations is significant and there is a notable difference in water quality parameters between the two stations.  Additional stations on the lower Nooksack will help with source identification when water quality standards are being exceeded.  In addition, at least one ambient station should be established on each of the forks.  This will serve two purposes: 1) it provides information on water quality draining into the Nooksack and 2) it can potentially serve as a control watershed for purposes of evaluating effectiveness of watershed control measures; especially the Middle Fork where land use is primarily commercial forestry and the human population is relatively low.  
  
  The strategy and database established for a comprehensive, long-term monitoring program on the Nooksack should incorporate the data from water samples collected by the Cities of Lynden and Ferndale on source water as part of their DOH monitoring requirements (WAC 246-290-300).  
  
• Expansion of Monitoring Programs to Include Chemical Contaminants.  There is limited information available on chemical contaminants in the Nooksack River and the South, Middle, and North Forks.  Water purveyors currently sample source water for VOCs and SOCs.  However, the sampling is for purposes of compliance with drinking water requirements and therefore is limited in scope.  The potential sources of chemical contamination are varied and include but are not limited to forest practices, chemical spills from rail or vehicular transport, stormwater runoff, and agricultural practices.  
  

(Section IV)

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