-IR- Database Guide
-IR- Database: Indiana Register

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

Indiana Department of Environmental Management
Office of Water Quality
Notice of Public Comment Period for the Draft 2012 List of Impaired Waters
and Consolidated Assessment and Listing Methodology
under Section 303(d) of the Clean Water Act


PURPOSE OF NOTICE
The Indiana Department of Environmental Management (IDEM) is soliciting public comment for the development of its draft 2012 303(d) List of Impaired Waters and the Consolidated Assessment and Listing Methodology (CALM) used to develop it. The draft 303(d) list will be submitted to the United States Environmental Protection Agency (U.S. EPA) on April 1, 2012. Any person having water quality data to support or refute the listing of a specific waterbody or to add a waterbody to the list will be able to provide that information to IDEM during the public comment period. Comments and suggestions regarding the CALM will also be accepted during this period. IDEM will review and respond to all comments received and will work with U.S. EPA after the comment period ends to finalize the list for U.S. EPA approval.
The draft 303(d) list and the CALM will also be available on IDEM's website at:
http://www.in.gov/idem/programs/water/303d/index.html

AUTHORITY: IC 13-18-2-3.

SUBJECT MATTER
Basic Purpose and Background
The IDEM Office of Water Quality (OWQ) is preparing to update its List of Impaired Waters, as required by Section 303(d) of the federal Clean Water Act (CWA) and the Water Quality Planning and Management regulation at 40 CFR Part 130. Under the CWA, each state is required to assemble all existing and readily available water quality related data and information for use in assessing its waters for compliance with the state's water quality standards (WQS). WQS are developed to protect beneficial uses for which the waters are designated (fishing, swimming, and drinking, etc.). The state is then required to prepare and make public a list of those waters not meeting WQS and the methodology used to evaluate the data and determine impairment status. The 303(d) List of Impaired Waters will identify the portion of the waterbody that is impaired; the pollutant or pollutants not meeting WQS thus causing the impairment; and a schedule for development of a total maximum daily load (TMDL). The list must be submitted to U.S. EPA by April 1, 2012.
A TMDL evaluation is a process that quantifies the amount of a specific pollutant that a waterbody can assimilate and still meet WQS. What constitutes a pollutant is described in Section 502(6) of the CWA, and includes materials such as sewage, chemical wastes, biological materials, and wastes from industrial, municipal, and agricultural operations. The definition also encompasses drinking water contaminants that are regulated under Section 1412 of the Safe Drinking Water Act (SDWA). A TMDL is a written, quantitative assessment that identifies how much of the pollutant is coming from point sources and nonpoint sources, specifies the amount of pollutant reduction necessary from each source in order to meet the WQS set for that pollutant, and lays the groundwork for developing and implementing a plan to reduce the amount of the pollutant coming from each source. As part of IDEM's TMDL process, the public is invited to participate in the plan to develop and implement the TMDL.
At this time, IDEM is still awaiting approval of the 303(d) list submitted to U.S. EPA for the 2010 cycle. This delay is due to issues raised by U.S. EPA regarding changes IDEM made to its 303(d) list in response to public comments received prior to IDEM's submission of the 2010 303(d) list to U.S. EPA. The issues raised by U.S. EPA, which are discussed later in this notice, were formally addressed to IDEM after submission of its 2010 303(d) list for approval and have yet to be resolved.
This situation has illustrated that any issues U.S. EPA may have regarding revisions to a state's assessment methodologies and corresponding changes to its 303(d) list can be complex, and their resolution can impose significant delays in approval. Given the potential for such delays in the future, IDEM has determined that reviewing all public comments and those provided by U.S. EPA together will allow IDEM to more effectively evaluate all the available information and will allow IDEM to work through any issues and receive timely approval from U.S. EPA. IDEM will consider the 2012 303(d) list finalized once U.S. EPA approval is received.

Applicable Federal Law
The 303(d) List of Impaired Waters is developed pursuant to Section 303(d) of the federal CWA. This notice serves as a solicitation for any additional water quality related information that may be used to further develop and refine the 2012 draft 303(d) list and satisfies the federal Water Quality Planning and Management regulation at 40 CFR Part 130, which requires states to provide public notice and opportunity for public comment on the state's 303(d) list and the methodology used to develop it.

Public Participation
IDEM will present the 2012 Draft 303(d) List of Impaired Waters at the Water Pollution Control Board meeting, which will be open to the public and will provide the public an opportunity to discuss the list. This meeting will be held on the following date:
Wednesday, April 11, 2012, 1:30 p.m. EDT
Indiana Government Center South
302 West Washington Street, Conference Center Room A
Indianapolis, Indiana 46206

REQUEST FOR PUBLIC COMMENTS
At this time, IDEM solicits the following:
(1) Water quality data or water quality related information to support or refute the listing of a specific waterbody or to add a waterbody to the 303(d) list.
(2) Comments and suggestions regarding the CALM.
Comments may be submitted in one of the following ways:
(1) By mail or common carrier to the following address:
2012 Draft 303(d) List of Impaired Waters
Betsy Rouse, Administrative Assistant
Rules Development Branch
Office of Legal Counsel
Indiana Department of Environmental Management
100 North Senate Avenue
MC 65-45
Indianapolis, IN 46204-2251
(2) By facsimile to (317) 233-5970. Please confirm the timely receipt of your faxed comments by calling the Rules Development Branch at (317) 233-8903.
(3) By electronic mail to brouse@idem.in.gov. To confirm timely delivery of your comments, please request a document receipt when you send the electronic mail. PLEASE NOTE: Electronic mail comments will NOT be considered part of the official written comment period unless they are sent to the address indicated in this notice.
(4) Hand delivered to the receptionist on duty at the thirteenth floor reception desk, Office of Legal Counsel, Indiana Government Center North, 100 North Senate Avenue, Indianapolis, Indiana.

COMMENT PERIOD DEADLINE
All comments must be postmarked, faxed, or time stamped no later than May 8, 2012. Hand-delivered comments must be delivered to the appropriate office by 4:45 p.m. on the above-listed deadline date.
Additional information regarding this notice may be obtained from Jody Arthur, Watershed Assessment and Planning Branch, Office of Water Quality, (317) 308-3179 or (800) 451-6027 (in Indiana).

INDIANA'S 2012 CONSOLIDATED ASSESSMENT AND LISTING METHODOLOGY
For the development of the 2012 Draft 303(d) List of Impaired Waters, IDEM has followed, to the degree possible, the 305(b) and 303(d) reporting methods outlined in the U.S. EPA's Guidance for 2006 Assessment, Listing and Reporting Requirements Pursuant to Sections 303(d), 305(b) and 314 of the Clean Water Act (U.S. EPA, 2005) and the additional guidance provided in the U.S. EPA memorandums Information Concerning 2012 Clean Water Act Sections 303(d), 305(b), and 314 Integrated Reporting and Listing Decisions (U.S. EPA, 2009). The 303(d) list was developed using IDEM's 305(b) Assessment Database (ADB). Interpretation of the data and listing decisions take into account U.S. EPA's guidance and IDEM's current CALM.
One aspect of U.S. EPA's guidance calls for a comprehensive listing of all monitored or assessed waterbodies in the state, based on the state's assessment and listing methodology. Each waterbody assessment unit (AU), which may consist of an entire waterbody or a segment of a larger waterbody, is to be placed in one or more of five categories depending on the degree to which it supports designated uses. U.S. EPA guidance encourages states to place a waterbody AU in additional categories as appropriate in order to more clearly illustrate where progress has been made in TMDL development and other restoration efforts. A detailed explanation of the five categories is provided in IDEM's CALM in Attachment 1. The following is a summary of the five categories:
  Category 1  Attaining the WQS for all designated uses and no use is threatened. 
  Category 2  Attaining some of the designated uses; no use is threatened; and insufficient data and information are available to determine if the remaining uses are attained or threatened. 
  Category 3  Insufficient data and information to determine if any designated use is attained. 
  Category 4  Impaired or threatened for one or more designated uses but does not require the development of a TMDL. 
    A. TMDL has been completed that is expected to result in attainment of all applicable WQS and has been approved by U.S. EPA. 
    B. Other pollution control requirements are reasonably expected to result in the attainment of the WQS in a reasonable period of time. 
    C. Impairment is not caused by a pollutant. 
  Category 5  The WQS is not attained. 
    A. The waters are impaired or threatened for one or more designated uses by a pollutant or pollutants, and require a TMDL. 
    B. The waters are impaired due to the presence of mercury or PCBs, or both in the edible tissue of fish collected from them at levels exceeding Indiana's human health criteria for these contaminants. 
The 303(d) List of Impaired Waters will consist of all impairments listed in Category 5. This category includes waters where the WQS is not attained because the waterbody AU is impaired or threatened by one or more pollutants for each of which a TMDL is required. It should be noted that the U.S. EPA's most recent guidance does not change existing rules for listing and delisting waterbody impairments from Category 5. The existing regulations still require states, at the request of the U. S. EPA's Regional Administrator, to demonstrate good cause for not including waterbody impairments on the 303(d) list that were included on previous 303(d) lists (pursuant to 40 CFR 130.7(b)(6)(iv)).

DEVELOPMENT OF DRAFT 2012 303(d) LIST
Organization of Indiana's 303(d) List
Each lake, stream or reach of stream in IDEM's ADB, which stores water quality assessment information for CWA 305(b) reporting and 303(d) listing purposes, is assigned a unique assessment unit ID (AUID). IDEM's methods for defining representative units of assessment are described in detail in IDEM's CALM (Attachment 1). The sizes of AUs in the ADB vary based on a number of factors. Given this, a single AU may or may not represent the entire river or stream to which it is associated. IDEM's methods for defining representative AUs are discussed in detail in the CALM.
Each impairment is listed individually on Indiana's 303(d) list to achieve consistency in how U.S. EPA tracks TMDL development and to facilitate more effective planning by IDEM. Therefore, a single AU may appear on the 303(d) list for one or more impairments.

Changes in Segmentation and Their Effect on Indiana's 303(d) List
The geographical extent and location of each AU within a given 12 or 14 digit hydrologic unit code (HUC) is defined for mapping purposes through a process called reach indexing. Reach indexing uses a software tool developed by U.S. EPA that works with geographical information systems (GIS) software to "key" the AU defined by IDEM to the National Hydrography Dataset (NHD). This "key" is called the Reach Index. IDEM used these tools with the medium resolution (1:100,000 scale) NHD to create its first statewide Reach Index in 2002, which facilitates mapping of Indiana's 305(b) assessments and 303(d) listings in GIS applications and incorporation of this information into IDEM's ADB and U.S. EPA's national databases.
In these databases, Indiana lakes and reservoirs, including Lake Michigan, are assigned a single AUID with sizes reported in acres. Indiana's Lake Michigan shoreline is assigned AUIDs in accordance with the eight digit HUC in which they are located and is reported in miles. Rivers and streams are assigned AUIDs in accordance with the 12 or 14 digit HUC in which they are located and are reported in miles. For large rivers with more than 1,000 square miles of drainage area, the AUIDs for mainstem nonwadeable reaches within their 12 to 14 digit HUCs are distinguished from those smaller, wadeable streams so that issues such as sampling techniques, which might bias results, can be considered within a class of streams. With regard to Indiana's flowing waters, AU sizes vary widely and a single segment may or may not represent the entire river or stream to which it is associated.
In 2006, IDEM developed an administrative process for splitting an AU into smaller units to allow more accurate application of assessment data. This process was employed through the 2010 assessment and listing cycle. The NHD is now available in high resolution (1:24,000 scale) for the entire state of Indiana. Given this, IDEM implemented a "moratorium" on segmentation changes for the 2012 cycle in order to reallocate staff resources to the work of reach indexing at high resolution instead. Resegmentations are now done on a very limited basis when needed to support National Pollutant Discharge Elimination System (NPDES) permit development or other OWQ program needs.
The rationale for IDEM's decision to revise the Indiana Reach Index using the high-resolution NHD along with a detailed discussion of high-resolution indexing process is provided in IDEM's CALM (Attachment 1). This decision better supports IDEM's 305(b) assessment and 303(d) listing processes and TMDL development than resegmentation on a case-by-case basis, and will accomplish the following:
• Reduce the effort required to track segmentation changes, and;
• Result in a statewide reach index with assessment units that allow more thorough and representative water quality assessments
At this time, it is anticipated that IDEM will complete its high resolution Reach Index prior to the submission of its 2014 Integrated Report. In the meantime, IDEM has prioritized its high resolution indexing work to stay ahead of TMDL development, focusing indexing efforts in those watersheds (at the eight digit HUC scale) in which one or more TMDLs will be developed for the next 303(d) listing cycle. Once Indiana's high resolution reach index is completed, the need to split segments using the segmentation process will be virtually eliminated.
As in previous cycles, any change in segmentation, whether done on a case-by-case basis or for the purposes of incorporating high resolution NHD data, must be accurately tracked so that 305(b) assessment and 303(d) listing information associated with the original AU is not lost. To this end, IDEM has refined its original methods for tracking segmentation changes in order to deal with the complexities associated with tracking changes as a result of high resolution indexing and to track resulting changes to the 303(d) list. As before, per U.S. EPA's request, IDEM still retires the original AUID for any AU that has been reindexed. IDEM also uses the same reassessment process to evaluate existing assessments and listing information on each AU reindexed to ensure that no valuable information is lost and that assessment information is appropriately applied to the new AU or AUs.
All AUIDs that have been retired due to segmentation changes during the 2012 cycle are identified in Attachment 2.

IDEM's Use of External Data
Section 303(d) of the CWA requires that states consider all readily available data sources in the preparation of their 303(d) lists and 305(b) assessment process. In addition to the water quality data collected by its staff, IDEM also has cooperative agreements with the United States Geological Survey (USGS) to collect water quality data at the same sites sampled by IDEM to provide data for additional parameters not sampled by IDEM. The data collected by the USGS through this partnership were reviewed as part of IDEM's rotating basin assessments for the 2012 cycle.
IDEM also reviews data generated and submitted by external parties that is obtained in three different ways:
• Provided to IDEM through 319(h) and 205(j) grant agreements;
• Provided to IDEM through the TMDL development process;
• Provided to IDEM in response to 305(b)/303(d) solicitations.
Although these data are collected by organizations external to IDEM, most of these data sets are submitted to IDEM and housed internally making them easily obtainable through program staff within IDEM. All data received are reviewed for usability in accordance with IDEM's Assessment Branch, Quality Assurance Project Plan (QAPP).
In 2006, IDEM began working to develop a more formal process for soliciting and reviewing water quality data from external organizations for potential use in its 305(b)/303(d) processes. Since that time, IDEM has conducted two formal solicitations, one in 2007 and 2009, both of which resulted in a large number of data sets. In addition to a great deal of new water quality data, these solicitations provided good information to help IDEM develop its External Data Framework. Under development, the voluntary External Data Framework will provide guidelines and technical assistance to help organizations that collect water quality data to become more involved with IDEM in working toward the shared goals of protecting and restoring Indiana's water resources.
The organizations and individuals that submitted data to IDEM in response to the 305(b)/303(d) solicitations in 2007 and 2009 are shown in Table 1. Note that Table 1 does not include those data sets required to be submitted to IDEM in fulfillment of 319(h) and 205(j) grant project requirements or those submitted through the TMDL development process.
IDEM expected the External Data Framework to be finalized in time for the 2012 cycle. However, staff resource constraints delayed its full implementation. IDEM completed its review of the data sets submitted by external organizations to determine their usability in 305(b) assessments and 303(d) listing and identified the usable data sets, but did not have time to organize the data to facilitate the assessment process.
The external data sets shown in Table 2 meet the necessary data quality requirements as outlined in IDEM's QAPP for 305(b) assessment purposes. IDEM is still in the process of evaluating these data for assessment purposes. If IDEM is able to complete these assessments prior to receiving U.S. EPA approval of the 2012 303(d) list, any resulting changes to the list will be proposed to U.S. EPA for consideration in its approval process. If assessments cannot be completed prior to receiving U.S. EPA approval, any resulting changes will be incorporated into the draft 2014 303(d) list.

Table 1: Sources of external data sets received in response to IDEM's 305(b)/303(d) solicitations in 2007 and 2009. This table does not include external data sets submitted to IDEM in fulfillment of 319(h) and 205(j) grant project requirement or those submitted through the TMDL development process.
Source 
AMERICAN WATER COMPANY 
ANCILLA COLLEGE 
CITY OF ANDERSON 
CITY OF ANGOLA AND TRINE UNIVERSITY 
CITY OF DECATUR 
CITY OF ELKHART 
CITY OF INDIANAPOLIS 
CITY OF KOKOMO 
CITY OF LAFAYETTE 
CITY OF PERU 
CITY OF RICHMOND 
CITY OF SEYMOUR 
CITY OF SHELBYVILLE 
CITY OF SOUTH BEND 
CITY OF VALPARAISO 
CITY OF ELKHART 
EMILY TALLO AND SAVE MAUMEE GRASSROOTS ORGANIZATION 
HAMILTON COUNTY HEALTH DEPARTMENT 
HOWARD COUNTY HEALTH DEPARTMENT 
JOHNSON COUNTY HEALTH DEPARTMENT 
MADISON COUNTY MS4 
MARION COUNTY HEALTH DEPARTMENT 
MICHIGAN CITY 
MONROE COUNTY PARKS AND RECREATION 
CITY OF MUNCIE 
SARAH SKELTON AND LAKE OF THE WOODS PROPERTY OWNER'S ASSOCIATION 
ST. JOSEPH WATERSHED AND THE NATURE CONSERVANCY 
STEUBEN COUNTY LAKES COUNCIL 
TOWN OF BROWNSBURG 
TOWN OF FORTVILLE 
TOWN OF MCCORDSVILLE 
TOWN OF SPEEDWAY 
WHITE COUNTY DEPARTMENT OF HEALTH 

Table 2: Sources of External data sets determined by IDEM to meet the necessary data quality requirements as outlined in IDEM's Assessment Branch QAPP for 305(b) assessment purposes.
Source 
American Water Company 
City of Elkhart 
City of Indianapolis 
City of Muncie 
City of South Bend 
City of Valparaiso 
Marion County Health Department 
Status of U.S. EPA approval of IDEM's 2010 303(d) List
IDEM has not received U.S. EPA approval for Indiana's 2010 303(d). U.S. EPA has raised concerns regarding two decisions that IDEM made when finalizing its 2010 303(d) list for submission. The information in this section is intended to provide a summary of the issues related to these concerns and their impact on the development of IDEM's draft 2012 303(d) list. More detailed information on these issues and the specific waters in question can be found in Attachment 3, which contains U.S. EPA's letter to IDEM articulating its concerns regarding the changes IDEM has made to its CALM with respect to metals assessments and its decision to not use derived criteria in assessment and listing decisions. IDEM's letter to U.S. EPA in response to these concerns is also included.

IDEM's Decision to Use Dissolved as Opposed to Total Metals Results when Making Aquatic Life Use Assessments

Based on public comments received, IDEM changed the methods by which metals data are evaluated for assessment purposes to bring them closer in line with Indiana's WQS. In 2005, U.S. EPA approved a change in Indiana's WQS to the aquatic life criteria for metals in waters outside of the Great Lakes basin, changing from total recoverable metals criteria to dissolved metals criteria1. This change was made because the dissolved fraction is a more accurate representation of the biologically active portion of the metal than is the total or total recoverable fraction and is thus more appropriate for the protection of aquatic life.
In the WQS, criteria for total recoverable metals are provided for certain metals2 along with conversion factors that are used to obtain a dissolved criterion. Until now, all of IDEM's metals assessments have been based on total recoverable metals results because most of the available water quality data is for the total metals as opposed to the dissolved fraction. However, IDEM has determined that using the total recoverable criteria expressed in Indiana's WQS for 305(b) assessments and 303(d) listing decisions is not appropriate because doing so may result in an overestimation of toxicity. Given this and U.S. EPA's recommendation that dissolved metal concentrations be used for the application of metals aquatic life criteria (U.S. EPA, 1996), IDEM revised its assessment methodology to require that water quality assessments for metals be based on dissolved metals concentrations instead of total metals concentrations. Based on this change, IDEM had removed all impairments from the 303(d) list submitted for 2010 that were previously listed based on total metal concentrations for which there are no applicable criteria. IDEM had also proposed to add a number of metals impairments to the draft 2010 303(d) list based on routine assessments and resegmentations. These additional impairments were not incorporated into the 2010 303(d) list submitted to U.S. EPA because they were also based on total metals results. IDEM maintains that these waters should remain in Category 3 of Indiana's Consolidated List for these parameters until IDEM can obtain the dissolved metals data necessary to accurately assess the impacts that metals may be having on water quality conditions. It should be noted that IDEM has since revised its monitoring strategy to collect dissolved metals data at all probabilistic monitoring locations to support these and future assessments.

IDEM's Position Regarding the Use of Derived Criteria (Tier I Criteria and Tier II Values) in 305(b) Assessments and 303(d) Listing Decisions

Indiana's WQS provide methods for the calculation of derived criteria for substances for which numeric criteria are not specifically articulated in the standards to ensure that the concentration of a substance or combination of substances does not become acutely toxic to aquatic organisms or produce chronic effects on them3. These methods are critical when IDEM receives requests proposing discharges of potentially toxic substances that do not have a specified numeric standard. The methods are used by IDEM's National Pollutant Discharge Elimination System (NPDES) Program in order to help develop appropriate permit limits to ensure that discharges do not cause or contribute to a water quality impairment. Thus, IDEM's calculation of derived criteria is a permit-driven process.
Although they have not been promulgated with a public process into Indiana's Administrative Code, both Tier I criteria and Tier II values are scientifically defensible for use in developing NPDES permit limits if calculated in accordance with the methods outlined in Indiana's WQS. However, according to the legal determination made by IDEM's Office of Legal Counsel, until these criteria go through the full public rulemaking process described in IC 13-14-9 and IC 4-22-2, they cannot also be used to make 305(b) assessment and 303(d) listing decisions nor be used to develop TMDLs that might affect NPDES permitted facilities.
Based on this decision, those waters originally identified in the draft 2010 303(d) list as impaired based on the use of derived criteria are no longer considered by IDEM to be impaired. A total of 138 impairments were proposed for listing based on IDEM's use of derived criteria. These waters were not added by IDEM to the 2010 303(d) list submitted to U.S. EPA for the 2010 cycle. In addition, a total of 18 impairments based on derived criteria were proposed for Category 4A of IDEM's Consolidated List based on completion of a TMDL. Likewise, these were not added to the 2010 303(d) list submitted to U.S. EPA. It remains IDEM's position that all of the waters originally assessed as impaired based on derived criteria should remain in Category 3 of Indiana's Consolidated List for these parameters until applicable water quality criteria are available with which to make assessments. More information on the issues surrounding IDEM's initial use of derived criteria and the rationale behind IDEM's subsequent decision to discontinue their use in these processes can be found in the public comments received and IDEM's responses, which are available online at:
http://www.in.gov/idem/nps/2647.htm.

Moving Forward with the Development of Indiana's 2012 Draft 303(d) List

IDEM is actively working with U.S. EPA to resolve the issues related to listing based on total metals data or derived criteria. In the meantime, IDEM has proceeded with development of its draft 2012 list based on the assumption that the issues that have delayed U.S. EPA's approval of the 2010 303(d) list will either be resolved or that U.S. EPA will issue a partial approval of the 2010 303(d) list prior to IDEM's formal submission of its draft 2012 303(d) list.
Based on communications with U.S. EPA staff4, if these issues cannot be resolved, U.S. EPA will issue a partial approval in the form of a letter accompanied by a preliminary decision document. The preliminary decision document will indicate specifically the 2010-cycle listings that were approved and will identify any additional impairments that U.S. EPA determines must be added to Indiana's 2010 303(d) list to receive full approval. Upon issuing its preliminary decision document, U.S. EPA will publish it in the Federal Register for a 30-day public comment period. After the 30-day public comment period ends, U.S. EPA will develop its responses to the comments received and will issue its final decision document regarding Indiana's 2010 303(d) list. If U.S. EPA's final decision results in changes to Indiana's 303(d) list, in accordance with IC 13-18-2-3(a) IDEM will publish the changes in the Indiana Register and conduct a public hearing within 90 days of receiving them.
Each 303(d) list builds upon the previously approved list. Beginning with a 303(d) list that may yet change as a result of negotiations with U.S. EPA has added to the challenges associated with developing a 303(d) list that accurately conveys the status of impairment of Indiana waters.
However, IDEM continues to make progress in its water quality assessments and remains committed to move forward in its reporting of results to the public despite the unresolved issues associated with the 2010 303(d) list. Therefore, in order to develop the draft 2012 303(d) list, IDEM segregated the impairments still in question from the rest of the 2010 303(d) list and has made a number of revisions based on comments provided U.S. EPA.
IDEM has agreed to add back to Category 5 those impairments that were previously listed for total metals on the 2008 303(d) list pending collection of dissolved metals data and reassessment of the results in accordance with IDEM's current methodology. Some of these reaches have since been resegmented. IDEM applied the original impairments to their new AUIDs resulting in the addition of a total of 10 impairments for total metals. IDEM has also added a total of 24 impairments back to Category 5 based on comments received from U.S. EPA unrelated to the issues associated with metals assessments and IDEM's use of derived criteria in assessment and listing decisions. These comments and IDEM's response are also included in Attachment 3.
Until U.S. EPA provides IDEM with its formal decision regarding the approval of IDEM's 2010 303(d) list, IDEM believes that this approach provides the most accurate foundation possible upon which to build the draft 2012 303(d) list.

WATERBODY IMPAIRMENTS PROPOSED TO BE REMOVED FROM INDIANA'S 303(d) LIST OF IMPAIRED WATERS
Waterbody Impairments Proposed to be Removed from Category 5A as a Result of TMDL Development
The CWA does not clearly define the timeline for TMDL development. However, in response to the 1998 Federal Advisory Committee Act (FACA) committee's recommendations, U.S. EPA has issued guidance for states to develop expeditious schedules of not more than eight to 15 years. In accordance with the CWA, the 303(d) list guides TMDL development. IDEM works with U.S. EPA every 305(b)/303(d) assessment and listing cycle to determine the number of TMDLs that must be developed in order to keep pace with the number of new impairments identified each cycle and to meet the goal of completing TMDLs for impairments within 15 years of their listing.
This short-term (two-year) schedule for TMDL development is currently under development and will be submitted to U.S. EPA with IDEM's formal submission of its draft 303(d) list later in 2012. IDEM will also provide with its submission a long-term TMDL development schedule that will identify a timeline for TMDL development for all impairments identified on the draft 2012 303(d).
To develop both schedules, IDEM generally prioritizes TMDL development to address impairments identified on its earliest 303(d) lists. However, because IDEM employs a watershed approach that considers all the known impairments in a given watershed, the resulting TMDL reports commonly include additional impairments identified in subsequent 303(d) lists and impairments newly identified as a result of the additional water quality monitoring conducted for TMDL development.
IDEM focuses its TMDL development on bacteria and impaired biotic communities with nutrient-related sources because these are the types of impairments most commonly identified in Indiana waters. Most of these impairments have been found through TMDL development to be nonpoint source driven and their sources are relatively well understood. Given this, the resulting TMDLs readily lend themselves to effective management through locally led watershed management planning and implementation efforts.
IDEM continues to make significant progress in TMDL development. In 2012, IDEM proposes to place a total of 355 impairments in Category 4A for one or more impairments. A total of 145 of these impairments were previously listed in Category 5A of the 2010 303(d) List of Impaired Waters. These impairments include additional impairments to waters previously placed on the 303(d) list for other parameters and impairments to waters previously placed in Category 2 or 3 of Indiana's Consolidated List. The impairments proposed to be added to Category 4A are identified in Attachment 4 and are keyed to the TMDL in which they are addressed (Table 4). The TMDL documents listed below along with information on TMDL development and scheduled public meetings can be found online at:
http://www.in.gov/idem/nps/2347.htm

Table 3: TMDLs completed with U.S. EPA approval received or anticipated prior to formal submission of its draft 2012 303(d) list on April 1, 2012.
Key  TMDL Document 
Total Maximum Daily Load for Escherichia coli (E. coli) for the Upper Wildcat Creek Watershed, Howard, Tipton, Grant, and Madison Counties 
Total Maximum Daily Load for Escherichia coli (E. coli) for the Middle Fork Wildcat Creek Watershed, Clinton, Carroll, Tippecanoe, and Howard Counties 
Total Maximum Daily Load for Escherichia coli (E. coli) for the Lower Wildcat Creek Watershed, Carroll, Clinton, Howard, Tippecanoe, and Tipton Counties 
Total Maximum Daily Load for Escherichia coli (E. coli) for the Galena River Watershed, La Porte and St. Joseph Counties 
Total Maximum Daily Load for Escherichia coli (E. coli) in the Highland-Pigeon Creek Watershed and Total Phosphorous for Hurricane Creek, Gibson, Pike, Vanderburgh, Posey, and Warrick Counties 
Total Maximum Daily Load for Escherichia coli (E. coli) in the Cicero Creek Watershed, Hamilton, Tipton, Boone and Clinton Counties 
Total Maximum Daily Load for Escherichia coli (E. coli) in the Upper White River Headwaters Watershed in Randolph, Delaware, and Henry Counties 
Busseron Creek Watershed TMDL Development* 
Pigeon River TMDL* 
*These TMDLs are currently in draft but are expected to be approved prior to IDEM's formal submission of its draft 2012 303(d) List of Impaired Waters to U.S. EPA. If any of these TMDLs are not yet approved at the time of submission, their corresponding AUs, presently proposed to be placed in Category 4A, will remain in Category 5A.

Waterbody Impairments Proposed to be Removed from Category 5 Due to Resegmentation.
In accordance with IDEM procedure and U.S. EPA policy, impairments may not be removed from the 303(d) list solely on the basis of resegmentation. All impairments on a resegmented AU must be reevaluated to determine their applicability to the resulting new AU or AUs. Therefore, all impairments that were delisted based on resegmentation are identified in Attachment 5 and those that were added back to the list under their new AUIDs are identified in Attachment 7. For the 2012 cycle, IDEM proposes removing a total of 914 impairments from Category 5 as a result of resegmentation.

Waterbody Impairments Proposed to be Removed from Category 5 on the Basis of Information Received Since the 2010 303(d) List was Submitted to U. S. EPA
This section includes waterbody impairments removed from Category 5 on the basis of new or revised assessments. The waterbody impairments proposed to be removed from Indiana's 303(d) list are located primarily in the Upper Wabash River basin, which was sampled by IDEM in 2008, and the Lower Wabash and Kankakee River basins sampled in 2009. Assessments for the Ohio River were also revised this cycle based on data and information provided by the Ohio River Valley Sanitation Commission (ORSANCO). Detailed information on how IDEM incorporates ORSANCO's data and assessments into the state's 303(d) listing processes is provided in IDEM's CALM (Attachment 1).
As a result of these assessments, IDEM proposes to remove a total of 48 impairments from Category 5A (Attachment 6).

PROPOSED ADDITIONS TO INDIANA'S 303(D) LIST OF IMPAIRED WATERS
Waterbody Impairments Proposed to be Added to Category 5 Based on Reassessments Conducted for Resegmentation Purposes
In accordance with IDEM procedure and U.S. EPA policy, impairments may not be removed from the 303(d) list solely on the basis of resegmentation. All impairments on a resegmented AU must be reevaluated to determine their applicability to the resulting new AU or AUs. All impairments delisted based on resegmentation are identified in Attachment 5. Those impairments that were added back to the list under their new AUIDs until their reassessment can be completed are identified in Attachment 7. For the 2012 cycle, IDEM proposes adding a total of 1,111 impairments to Category 5 as a result of resegmentation.

Waterbody Impairments Proposed to be Added to Category 5 on the Basis of Information Received Since the 2010 303(d) List was Submitted to U.S. EPA
For the 2012 cycle, IDEM proposes to add a number of impairments to Category 5A. For a lake or stream to be listed, IDEM must have sampling data that is representative of that waterbody and the data collected must support 303(d) listing in accordance with IDEM's CALM. The waterbody impairments proposed to be added to the 303(d) list on the basis of new or revised assessments are located primarily in the Upper Wabash River basin, which was sampled by IDEM in 2008, and the Lower Wabash and Kankakee River basins sampled in 2009. Assessments for the Ohio River were also revised this cycle based on data and information provided by the Ohio River Valley Sanitation Commission (ORSANCO). Detailed information on how IDEM incorporates ORSANCO's data and assessments into the state's 303(d) listing processes is provided in IDEM's CALM (Attachment 1). Based on these assessments, IDEM proposes to add a total of 220 impairments to Category 5 (Attachment 7).

Summary of Changes
Table 4 summarizes the proposed removals from and additions to Indiana's 303(d) list and their impact on the total number of AUs listed by waterbody type and their associated stream miles and lake acres. Table 5 and Table 6 provide a comparison of the 2010 and 2012 303(d) lists in terms of the total number of AUs listed and the total number of impairments listed, respectively. Table 7 summarizes the proposed changes to Indiana's 303(d) List of Impaired Waters in terms of the types of impairments that appeared on the 303(d) list in 2010 versus those that appear on the 2012 draft 303(d) list. The proposed changes will result in the draft 2012 303(d) list containing a total of three 3,430 individual impairments compared to 3,146 individual impairments for the 2010 303(d) list (AUs with multiple impairments are listed once for each impairment).
Attachment 9 consists of the proposed Category 5A and Category 5B impairments that together comprise the draft 2012 303(d) list of Impaired Waters for Indiana. The 303(d) list is a subset of Indiana's Consolidated List to be submitted as part of Indiana's Integrated Water Quality Monitoring and Assessment Report to U.S. EPA in 2012.

Table 4: Proposed changes to Indiana's 303(d) List of Impaired Waters in terms of total number of AUs listed by waterbody type and their associated stream miles or lake acres.
Nature of Proposed changes to 2010 303(d) List  Number of Stream Assessment Units  Total Stream Miles  Number of Lake Assessment Units  Total Lake Acres 
Waterbody impairments removed from Category 5 based on changes in segmentation  636  3,836  NA  NA 
Waterbody impairments removed from Category 5 based on information received since the 2010 303(d) list was submitted to U.S. EPA  28  186 
Waterbody impairments removed from Category 5 to Category 4A based on TMDL development  134  926 
Waterbody impairments added back to Category 5 based on changes in segmentation  791  7,034  NA  NA 
Waterbody impairments added to Category 5 based on information received since the 2010 303(d) list was submitted to U.S. EPA  164  1,828 
Waterbody impairments added to Category 5 based on U.S. EPA comments regarding IDEM's 2010 303(d) list  28  145 
*These numbers do not reflect the 156 unique waterbodies totaling 987 miles with impairments newly identified through the TMDL process and for which the TMDL has been completed. These waters were placed directly in Category 4A.

Table 5: Comparison of the 2010 303(d) List of Impaired Waters submitted to U.S. EPA and the Draft 2012 303(d) List of Impaired Waters in terms of the total number of individual AUs listed by waterbody type and their associated stream miles or lake acres.
303(d) List  Total Number of Assessment Units  Number of Stream Assessment Units  Total Stream Miles  Number of Lake Assessment Units  Total Lake Acres 
2010 303(d) List submitted to U.S. EPA**  2,020  1,880  12,029  140  73,056* 
Draft 2012 303(d) List  2,205  2,065  16,088  140  73,076* 
*For the purposes of accurate year-to-year comparisons, the 2012 totals do not include Lake Michigan.
**Includes revisions identified in Attachment 2.

Table 6: Proposed changes to Indiana's 303(d) List of Impaired Waters in terms of the total number of impairments added or removed from the 2010 303(d) list submitted to U.S. EPA.
Total Number of Impairments on the 2010 303(d) List Submitted to U.S. EPA  3,146 
Waterbody impairments removed from Category 5 based on changes in segmentation  (914) 
Waterbody impairments removed from Category 5 based on information received since the 2010 303(d) list was submitted to U.S. EPA  (48) 
Waterbody impairments removed from Category 5 to Category 4A based on TMDL development  (145) 
DELISTINGS TOTAL  (1,107) 
Waterbody impairments added back to Category 5 based on changes in segmentation  1,111 
Waterbody impairments added to Category 5 based on information received since the 2010 303(d) list was submitted to U.S. EPA  220 
Waterbody impairments added to Category 5 based on U.S. EPA comments regarding IDEM's 2010 303(d) list  34 
ADDITIONS TOTAL  1,365 
Total Number of Impairments on Draft 2012 303(d) List  3,404 
*This number does not include the 210 individual impairments newly identified through the TMDL process and for which the TMDL has been completed. These impairments were placed directly in Category 4A.

Table 7: Comparison of the 2010 303(d) list and proposed 2012 303(d) list by impairment type.
Cause of Impairment  Number of Impairments on the 2010 303(d) List Submitted to U.S. EPA  Number of Impairments on the Draft 2012 303(d) List 
ALGAE  20  20 
AMMONIA  10 
CHLORIDE  16  17 
FREE CYANIDE  27  30 
DIOXIN (WATER)  69  69 
DISSOLVED OXYGEN  163  169 
E. COLI  976  1,136 
IMPAIRED BIOTIC COMMUNITIES  570  615 
NUTRIENTS  110  133 
OIL AND GREASE 
PESTICIDES 
PH  18  22 
PHOSPHORUS  50  50 
SILTATION 
SULFATE 
TASTE AND ODOR  12  12 
TEMPERATURE  14 
PCBs (FISH TISSUE)  612  618 
PCBs (WATER)  69  69 
TOTAL MERCURY (FISH TISSUE)  355  348 
TOTAL MERCURY (WATER)  47  66 
TOTAL COPPER 
TOTAL LEAD 
TOTAL NICKEL 
TOTAL ZINC 
Total  3,146  3,404 

MAP INFORMATION SOURCES
All information used to create the maps in this report was obtained from IDEM databases and Geographical Information Systems Libraries, and the State of Indiana Geographical Information Office.

REFERENCES CITED
Indiana Administrative Code (IAC):
http://www.in.gov/legislative/iac/title327.html
Indiana Department of Environmental Management (IDEM). 2004. Quality Assurance Project Plan for Indiana Surface Water Quality Monitoring and Total Maximum Daily Load (TMDL) Program. Office of Water Management, Assessment Branch, Environmental Toxicology and Chemistry Section. Indianapolis, IN.
Indiana Department of Environmental Management (IDEM). 2005. Indiana Water Quality Monitoring Strategy (draft). Office of Water Management, Assessment Branch. Indianapolis, IN. B-001-OWQ-A-00-06-0-R3.
U. S. Environmental Protection Agency. 1997a. Guidelines for Preparation of the State Water Quality Assessments (305[b] Reports) and Electronic Updates: Report Contents. Washington, D.C.: U. S. Environmental Protection Agency. EPA-841-B-97-002A.
U. S. Environmental Protection Agency. 1997b. Guidelines for Preparation of the State Water Quality Assessments (305[b] Reports) and Electronic Updates: Supplement. Washington, D.C.: U. S. Environmental Protection Agency. EPA-841-B-97-002B.
U. S. Environmental Protection Agency. 2005. Guidance for 2006 Assessment, Listing and Reporting Requirements Pursuant to Sections 303(d), 305(b) and 314 of the Clean Water Act: Public Review Draft. Washington, D.C.: U.S. Environmental Protection Agency.
U. S. Environmental Protection Agency. 2006. Memorandum to Regions 1-10 Water Division Directors Regarding Information Concerning 2008 Clean Water Act Sections 303(d), 305(b), and 314 Integrated Reporting and Listing Decisions. Washington, D.C.: U.S. Environmental Protection Agency.
U. S. Environmental Protection Agency. 2009. Memorandum to Regions 1-10 Water Division Directors Regarding Information Concerning 2010 Clean Water Act Sections 303(d), 305(b), and 314 Integrated Reporting and Listing Decisions. Washington, D.C.: U.S. Environmental Protection Agency.
U. S. Environmental Protection Agency. 2001. 2002 Integrated Water Quality Monitoring and Assessment Report Guidance. November 19, 2001 Memorandum from U.S. EPA Office of Wetlands, Oceans and Watershed to U.S. EPA Regional Water Management Directors, Regional Science and Technology Directors, and State, Territory and Authorized Tribal Water Quality Program Directors.

CONTACT INFORMATION
Marylou Poppa Renshaw
Chief – Watershed Assessment and Planning Branch
Indiana Department of Environmental Management
100 North Senate Avenue
MC65-44 SHADELAND
Indianapolis, IN 46204-2251
(317) 308-3235; or toll free (800) 451-6027
mrenshaw@idem.in.gov

Jody Arthur
Technical Environmental Specialist
Watershed Assessment and Planning Branch
Indiana Department of Environmental Management
100 North Senate Avenue
MC65-44 SHADELAND
Indianapolis, IN 46204-2251
(317) 308-3179; or toll free (800) 451-6027
jarthur@idem.in.gov

Attachment 1
Indiana Department of Environmental Management's 2012 Consolidated Assessment and Listing Methodology

REGULATORY BACKGROUND
Section 303(d) of the 1972 Federal CWA requires each state to identify those waters that do not meet the state's WQS for designated uses. For these impaired waters, states are required to establish TMDLs to meet the state WQS. In addition, the U.S. EPA has released guidance recommending that states, territories, and authorized tribes submit an Integrated Water Quality Monitoring and Assessment Report (IR) that will satisfy CWA requirements for both the Section 305(b) water quality report and Section 303(d) list of impaired waters. IDEM has integrated this guidance into its CALM.

IDEM's SURFACE WATER QUALITY MONITORING STRATEGY
IDEM has developed a water quality monitoring strategy (WQMS) to guide its monitoring activities aimed at assessing the quality of Indiana's surface waters. Specific goals of the WQMS include:
• Measure the physical, chemical, bacteriological, and biological quality of the aquatic environment in all river basins and identify factors responsible for impairment.
• Assess the impact of human and other activities on the surface water resource.
• Identify trends through the analysis of environmental data, and
• Provide environmental quality assessment to support water quality management programs.
To achieve these goals, IDEM has divided the state into five major water management basins. The WQMS describes a rotating basin approach that allows IDEM to focus its monitoring resources in a different basin each year. IDEM's 305(b) assessment and 303(d) listing processes also follow the rotating basin. With this approach, Indiana's rivers and streams in each major basin are monitored and assessed every five years (Figure 1-A). Lakes and reservoirs in Indiana are monitored for IDEM by the Indiana Clean Lakes Program (CLP) administered by Indiana University's School of Public and Environmental Affairs. This monitoring does not follow the rotating basin due to the unequal distribution of lakes across the Indiana landscape. Using an approach similar to rotating basins, lakes throughout the state are divided into five regions that are defined in a way that maximizes monitoring resources. The following monitoring programs provide water quality data in support of IDEM's CWA programs:
• Watershed Monitoring Program
• Fixed Station Monitoring Program
• E. coli Monitoring Program
• Fish Community Monitoring Program
• Fish Tissue Contaminant Monitoring Program
• Macroinvertebrate Community Monitoring Program
• Special Projects
• Clean Lakes Program
318120053ONA01.jpg
Figure 1-A: The five major water management basins in Indiana as defined by IDEM to support the Agency's rotating basin monitoring, assessment, reporting and listing schedule.

DESIGNATED USES
The CWA provides the underpinning for Indiana's WQS (327 IAC 2), which are designed to ensure that all waters of the state, unless specifically exempted, are safe for full body contact recreation and are protective of aquatic life, wildlife, and human health. These beneficial uses are described in the state's WQS as "designated" uses. IDEM monitors and assesses Indiana's surface waters to determine the extent to which they meet WQS; and thus support their designated uses and to identify where possible the sources of impairment for those waters that do not support one or more of these uses.

WATER QUALITY ASSESSMENT METHODOLOGY
Use Support status is determined for each waterbody using the assessment guidelines provided in the U.S. EPA documents Guidelines for Preparation of the State Water Quality Assessments (305[b] Reports) and Electronic Updates: Report Contents (EPA-841-B-97-002A), Guidance for 2006 Assessment, Listing and Reporting Requirements Pursuant to Sections 303(d), 305(b) and 314 of the CWA (U.S. EPA, 2005), and the additional guidance provided in the U.S. EPA memorandum Information Concerning 2010 CWA Sections 303(d), 305(b), and 314 Integrated Reporting and Listing Decisions (U.S. EPA, 2009). Available results from six types of monitoring data listed below are integrated to provide an assessment for each stream waterbody for 305(b) reporting and 303(d) listing purposes:
• Physical or chemical water results
• Fish community assessment
• Benthic aquatic macroinvertebrate community assessments
• Fish tissue and surficial aquatic sediment contaminant results
• Habitat evaluation
• E. coli monitoring results

WATERBODY ASSESSMENT UNITS AND THE ASSESSMENT DATABASE
IDEM maintains its CWA Section 305(b) assessment and 303(d) listing information in the Assessment Database ADB). Each waterbody assessment unit (AU) is assigned a unique identifier in the ADB to which all assessment information for that waterbody is associated. This identifier is called an assessment unit ID (AUID).
In general, each AUID corresponds to the watershed in which it is located as defined by the United State Geological Survey (USGS) hydrologic unit code (HUC) system, a hierarchical system that divides and then subdivides the United States successively smaller geographic areas based on surface hydrologic features, or drainages. Under this system, the average size of an 8-digit hydrologic unit area in Indiana, commonly known as a subbasin, is about 448,000 acres (700 square miles). The 12-digit and 14-digit hydrologic unit areas, or subwatersheds, within an 8-digit hydrologic unit area are much smaller. The 12-digit and 14-digit hydrologic unit areas in Indiana range in size from less than five acres (less than one square mile) to about 28,000 acres (almost 44 square miles).

WATERBODY ASSESSMENT UNITS AND IDEM's REACH INDEX
The geographical extent and location of each AU within a given 12-digit or 14-digit HUC are defined for mapping purposes through a process called reach indexing. Reach indexing uses a software tool developed by U.S. EPA that works with geographical information systems (GIS) applications to delineate for a waterbody one or more units of assessment and to "key" these AU (as defined by IDEM) to the National Hydrography Dataset (NHD)5. This "key" is called the Reach Index. IDEM used these tools to create its first statewide Reach Index in 2002, which facilitates mapping of Indiana's 305(b) assessments and 303(d) listings in GIS applications and incorporation of this information into IDEM's ADB and U.S. EPA's national databases.
In these databases, Indiana lakes and reservoirs, including Lake Michigan, are assigned a single AUID with sizes reported in acres. Indiana's Lake Michigan shoreline is divided and assigned AUIDs in accordance with the 8-digit HUC in which they are located and are reported in miles. Rivers and streams are assigned AUIDs in accordance with the 12-digit or 14-digit HUC in which they are located and are reported in miles. For large rivers with more than 1,000 square miles of drainage area, the AUIDs for mainstem nonwadeable reaches within their 12-14 digit HUCs are distinguished from those smaller, wadeable streams so that issues such as sampling techniques, which might bias results, can be considered within a class of streams. With regard to Indiana's flowing waters, AU sizes vary widely and a single segment may or may not represent the entire river or stream to which it is associated.

Revisions to IDEM's Reach Index
In 2006, IDEM developed an administrative process for splitting AUs into smaller units to allow for more accurate application of assessment data. When Indiana created its Reach Index, most waterbodies in the state were assigned an AUID based on the 14-digit watershed in which they were located. In most cases, each 14-digit watershed was assigned a single AUID regardless of how many individual streams were located in the watershed. Therefore, an assessment of any stream would be applied to all the streams in the watershed regardless of where the sample was located or its relative representativeness to each stream. This problem was not preventable at the time because, while the reach indexing tool had the capability to split "watershed" AUs into smaller AUs, the software had no built-in means for tracking changes in segmentation.
Changes in segmentation were considered on a case-by-case basis and were generally made either to accommodate a more accurate assessment or to correct an earlier assessment in which the data were inappropriately applied. When AUs were split, IDEM reevaluated previous assessments of the original AU along with any recent data that were available at the time of resegmentation. This reassessment process ensured that the original assessment information was properly applied to the resulting new AUs. In most cases, the original assessment was applied to only one or two of the resulting AUs with the remaining units unassessed. IDEM continued using resegmentation through the 2008 cycle to more accurately apply assessment data. However, when the NHD became available for the entire state at the high resolution, it was found that a significantly higher number of first and second order streams6 appear at the 1:24,000 scale than IDEM's 1:100,000 scale Reach Index contained. These small streams and stream networks are an important component of the hydrology in their watersheds and can have significant effects on water quality in larger streams. Given this, IDEM decided that revising the Reach Index as a whole at 1:24,000 scale instead of continuing with resegementation on a case-by-case basis at 1:100,000 scale would do the following:
• Reduce the effort required to track segmentation changes, and;
• Result in a statewide reach index with AUs that allow more thorough and representative water quality assessments
This decision to revise the Reach Index using the high resolution NHD better supports IDEM's 305(b) assessment and 303(d) listing processes and TMDL development than resegmentation on a case-by-case basis. However, it requires significant staff resources. Given this, in 2009, IDEM decided to implement a "moratorium" on segmentation changes for the 2010 assessment and listing cycle and to reallocate staff resources to the work of Reach Indexing at high resolution instead. Resegmentations are now done on a very limited basis when needed to support NPDES permit development or other OWQ program needs.
At this time, it is anticipated that IDEM will complete its high resolution Reach Index prior to the 2012 integrated report cycle. In the meantime, IDEM has prioritized its high resolution indexing work to stay ahead of TMDL development, focusing indexing efforts in those watersheds (at the 8-digit hydrologic unit, or HUC scale) in which one or more TMDLs will be developed for the next 303(d) listing cycle. Once Indiana's high resolution reach index is completed, the need to split segments using the segmentation process will be virtually eliminated.
Similar to IDEM's original resegmentation process, the high resolution indexing process also involves splitting the original AU into smaller more representative units considering a combination of factors including hydrology, similarities in land use and potential sources of impairment. However, IDEM's high resolution indexing process defines new AU based on small catchment basins (very small watersheds) and then adds the new streams that appear on the map at the 1:24,000 scale NHD to these new AU.
The result is a far more accurate representation of Indiana's hydrology and AU that are more homogeneous and thus more representative for the purposes of water quality assessment and TMDL development. For the 2010 cycle, IDEM also began incorporating the new USGS 12-digit hydrologic units into the indexing process to better support the Nonpoint Source Section 319 program, which has adopted this scale for watershed management planning and implementation purposes.
Any change in segmentation, whether from resegmentation done on a case-by-case basis or for the purposes of incorporating high resolution NHD data, must be accurately tracked so that 305(b) assessment and 303(d) listing information associated with the original AU is not lost. To this end, IDEM's has refined its original methods developed to track segmentation changes to track changes now being made to the Reach Index as a result of high resolution indexing. As before, per U.S. EPA's request, IDEM still retires the original AUID for any AU that has been reindexed. And, IDEM also uses the same reassessment process to evaluate existing assessments and listing information on each AU reindexed to ensure that no valuable information is lost and that assessment information is appropriately applied to the new AU resulting from the reindexing effort.

IDEM's Process for Indexing at High Resolution Using a Catchment Basin Approach
The goal of the high resolution indexing process is to identify all streams and stream reaches that are representative for the purposes of assessment. In practice, this process leads to grouping tributary streams into smaller catchment basins of similar hydrology, land use, and other characteristics such that all tributaries within the catchment basin can be expected to have similar potential impacts. Catchment basins, as defined by the aforementioned factors are typically very small, which significantly reduces the variability in the water quality we might expect from one stream or stream reach to another. Given this, all tributaries within a catchment basin are assigned a single AUID. Grouping tributary systems into smaller catchment basins also allows for better characterization of the larger watershed. Variability within the larger watershed will be accounted for by the differing AUIDs assigned to the different catchment basins.
Using the catchment basin approach, indexing at high resolution is guided in large part by the hydrology of a system. This is because the mechanisms of large streams and river are very different from those of small streams and tributary system, making it logical to separate these into separate AUIDs. However, other factors are also considered when deciding how to define a water quality AU:
• Varying land uses within a watershed are also considered because rural development is expected to have different impacts on a stream than urban areas, which in turn, have different impacts to a stream segment than forested areas.
• The presence and locations of any permitted facilities are considered due to their potential impact on the hydrology of a given stream and their potential to impact water quality, depending on the type of facility and whether the facility is operating efficiently.
• Any other known factors that might reasonably be expected to impact hydrology or water quality, or both (for example, dams, channelization, wetlands, etc.).
Aerial photography is particularly important in determining appropriate segmentation within a watershed because it provides very recent and accurate information about the presence and thickness of riparian buffers, the presence and spatial extent of rural development, and the types of land use practices in the watershed, all of which help to determine where we might expect to see differences in water quality resulting from one or more of these factors. Due to the potential impacts these factors can have on stream water quality, they are all considered when determining whether segmentation should occur and where it should occur along the stream reach.

The Reassessment Process associated with Reach Indexing
On each AU indexed, IDEM conducts a reassessment to evaluate any existing information in the ADB for all designated uses assessed to ensure that no valuable information is lost and that assessment information is appropriately applied to the resulting new AU.
Because IDEM prioritizes its high resolution indexing based on TMDL development, the reassessments conducted for the purposes of TMDL development consider only those designated use impairments for which the TMDL is being developed. However, IDEM's reassessment must also consider any existing information in the ADB associated with other designated uses that are not considered in the TMDL.
This process is particularly complicated in cases where there are two or more previously assessed AUs that were combined through the indexing process. For each new AU to be entered into the ADB, a report or reports must be generated from the database for the original AU or AUs from which the new AU was derived. These reports must then be compared to determine, for each designated use, whether there is any existing assessment information for the original AU or AUs and to identify any conflicting assessment information. Any conflicting information must be resolved prior to entering the new AU into the ADB. This requires a reevaluation of all the data used to make the use assessments on the original AU to determine which, if any are applicable to each new AU.
The reassessment process is conducted as time allows, preferably prior to entering the data into the ADB. However, if the reassessment cannot be accomplished prior to ADB data entry, all information from the original AU or AUs is carried over and any conflicting assessment information is noted for later resolution ensuring that no valuable assessment information is lost.

WATER QUALITY ASSESSMENT DECISIONS
The designated uses outlined in Indiana's WQS and the narrative and numeric criteria to protect them provide the underpinning for IDEM's 305(b) assessment process and 303(d) listing decisions. Water quality assessments are made by compiling existing and readily available data from site-specific chemical (water, sediment, and fish tissue), physical (habitat, flow data), and biological (fish community, macroinvertebrates, and E. coli) monitoring of Indiana's rivers, streams, and lakes and evaluating those data against Indiana's WQS. Waters identified as not meeting one or more of their designated uses are then placed on the Indiana's 303(d) List of Impaired waters. IDEM's decision making criteria are a combination of the narrative and numeric criteria expressed in Indiana's WQS in IAC 327, Article 2. More detailed information regarding IDEM's WQS-based approach to evaluating fish tissue data and IDEM's use of site-specific water quality criteria in the 305(b) assessment process is also provided.
Chemical data for toxicants [dissolved metals, polynuclear aromatic hydrocarbons (PAHs), pesticides, ammonia, and free cyanide], conventional water chemistry parameters (dissolved oxygen, pH, temperature, and anions), and bacteria (E. coli) were evaluated for compliance with Indiana's WQS (327 IAC 2-1-6 and 327 IAC 2-1.5-8). U.S. EPA 305(b) guidelines were applied to chemical and biological data as indicated in Guidelines for Preparation of the State Water Quality Assessments (305[b] Reports) and Electronic Updates: Supplement (EPA-841-B-97-002B).
Table 1-A shows the minimum data required for 305(b) assessments. For each AU with sufficient data to make one or more designated use assessments, IDEM applies the 305(b) assessment process described in Table 1-B. Assessment data are integrated for the purposes of making water quality assessments, meaning that all data for a given waterbody are considered together. In accordance with U.S. EPA policy, IDEM generally treats each type of data as independently applicable.

Table 1-A: Minimum data requirements for CWA 305(b) assessments.
Parameter Type  Minimum Information Required for Assessment 
Aquatic Life Use Support – Rivers and Streams 
Toxicants  Minimum of three measurements 
Conventional Inorganics  Minimum of three measurements 
Nutrient Parameters  Minimum of three measurements and two or more of parameters must have been exceeded on same date in order to classify a waterbody as impaired. 
Benthic aquatic macroinvertebrate Index of Biotic Integrity (mIBI)  Minimum of one measurement, preferably with corresponding qualitative habitat use evaluation (QHEI) score* 
Fish community (IBI)  Minimum of one measurement, preferably with corresponding qualitative habitat use evaluation (QHEI) score* 
*The Qualitative Habitat Evaluation Index (QHEI) is not required to determine aquatic life use support but is used, when available in conjunction with macroinvertebrate community scores (mIBI) or fish community scores (IBI) or both to evaluate the role that habitat plays in waterbodies where impaired biotic communities (IBC) have been identified. 
Aquatic Life Use Support – Lakes and Reservoirs 
Indiana Dept. of Natural Resources (IDNR) surveys of the status of sport fish communities in lakes  No minimum sample requirement; Assessments are revised with most recent plans published by IDNR. 
IDNR Trout Stocking Plans  No minimum sample requirement; Assessments are revised with most recent plans published by IDNR. 
IDNR information on pH levels in lakes and reservoirs  No minimum sample requirement; Assessments based on narrative reports and communication from IDNR staff. 
Temperature  No minimum sample requirement; Assessments for lake temperatures are not a regular part of IDEM's assessment process. All data are reviewed when readily available and adequacy of the data set as a whole is determined on a case-by-case basis. 
Fish Consumption Use Support (Human Health) 
Mercury and polychlorinated biphenyls (PCBs) in Fish Tissue  One actual concentration value (including estimated values above the method detection limits) 
Recreational Use Support (Human Health) – All waters 
Bacteria (E. coli Minimum of ten grab samples or one geometric mean result calculated from five equally spaced samples over thirty days. 
Recreational Use Support (Aesthetics) – Lakes and Reservoirs 
Natural Lakes and Reservoirs  Minimum of three total phosphorus results with corresponding Chlorophyll a results collected over three years (consecutive or nonconsecutive). 
Drinking Water Use Support – Rivers and Streams 
Toxicants  Minimum of three measurements 
Conventional Inorganics  Minimum of three measurements 
Taste and odor producing substances  No minimum sample requirement; Weight of evidence approach is used; typically requires numerous public complaints regarding taste and odor such that water utility must employ additional treatment to remedy the problem. 
Drinking Water Use Support – Lakes and Reservoirs 
Applications for permits to apply algaecides  One permit application 

Table 1-B: Water quality assessment methodology for determining designated use support for all waters except the Ohio River.
Aquatic Life Use Support - Rivers and Streams 
Toxicants  Dissolved metals, pesticides, polyaromatic hydrocarbons (PAH), free cyanide, ammonia were evaluated on a site-by-site basis and judged according to the magnitude of the exceedance or exceedances of Indiana's WQS and the number of times the exceedance or exceedances occurred. For any one pollutant (grab or composite samples), the following assessment criteria are applied to data sets consisting of three or more measurements. 
Fully Supporting  Not Supporting 
<1 exceedance of the acute criteria within a three-year period, and <1 exceedance of the chronic criteria for aquatic life within a three-year period.  >1 exceedance of the acute or chronic criteria for aquatic life within a three-year period. 
Conventional inorganics  Dissolved oxygen, pH, sulfates, chlorides were evaluated for the exceedance or exceedances of Indiana's WQS. For any one pollutant, the following assessment criteria are applied to data sets consisting of three or more measurements. 
Fully Supporting  Not Supporting 
For dissolved oxygen, one or more samples may be <4mg/L, but no more than 10% of all measurements are <5mg/L. For other conventional inorganics, criteria are exceeded in <10% of measurements.  For dissolved oxygen, one or more samples <4mg/L and more than 10% of all measurements are <5mg/L. For other conventional inorganics, criteria are exceeded in >10% of measurements. 
Nutrients  Nutrient conditions were evaluated on a site-by-site basis using the benchmarks described below. In most cases, two or more of these conditions must be met on the same date in order to classify a waterbody as impaired. This methodology assumes a minimum of three sampling events. 
  • Total Phosphorus: One or more measurements >0.3 mg/l 
  • Nitrogen (measured as NO3 + NO2) – One or more measurements >10.0 mg/l 
  • Dissolved Oxygen (DO) – Measurements below the WQS of 4.0 mg/l or measurements that are consistently at/close to the standard, in the range of 4.0-5.0 mg/l or values >12.0 mg/l 
  • pH measurements – Measurements above the WQS of 9.0 or measurements that are consistently at/close to the standard, in the range of 8.7-9.0 
  • Algal Conditions – Algae are described as "excessive" based on field observations by IDEM scientists. 
Benthic aquatic macroinvertebrate Index of Biotic Integrity (mIBI) Scores (Range of possible scores is 12-60)  Fully Supporting  Not Supporting 
mIBI >36  mIBI <36 
Fish community (IBI) Scores (Range of possible scores is 6-60)  IBI >36  IBI <36 
Qualitative habitat use evaluation (QHEI) (Range of possible scores is 0-100)  The Qualitative Habitat Evaluation Index (QHEI) is not used to determine aquatic life use support. Rather, the QHEI is an index designed to evaluate the lotic habitat quality important to aquatic communities and is used in conjunction with mIBI or IBI data, or both to evaluate the role that habitat plays in waterbodies where impaired biotic communities (IBC) have been identified. QHEI scores are calculated using six metrics: substrate, instream cover, channel morphology, riparian zone, pool/riffle quality, and gradient. A higher QHEI score represents a more diverse habitat for colonization of aquatic organisms. IDEM has determined that a QHEI total score of <51 indicates poor habitat. For streams where the macroinvertebrate community (mIBI or mHab) or fish community (IBI) scores indicate IBC, QHEI scores are evaluated to determine if habitat is the primary stressor on the aquatic communities or if there may be other stressors/pollutants causing the IBC. 
Aquatic Life Use Support – Lakes and Reservoirs 
Indiana Department of Natural Resources surveys of the status of sport fish communities in lakes and information on trout stocking.  Fully Supporting  Not Supporting 
Supports cold water fishery, including native Cisco and stocked trout, or both.  Native Cisco population is gone or lake unable to support stocked trout and lake attributes, or both, appear to contribute to warm water fishery condition. 
Temperature and pH  Lakes in which thermal modifications have caused an adverse effect on aquatic life and lakes that do not meet Indiana's WQS for pH have been assessed as not supporting of aquatic life use. 
Fish Consumption Use Support (Human Health) 
All samples from a given sampling reach must have results below the benchmarks for mercury and polychlorinated biphenyls (PCBs) in order to be assessed as fully supporting, and all waters with a sample result exceeding the benchmark for either mercury or PCBs, or both are classified as impaired. 
Mercury in Fish Tissue  Fully Supporting  Not Supporting 
Actual concentration values (including estimated values above the method detection limits) for all samples collected from sampling reach are <0.3 mg/kg  One or more actual concentration values (including estimated values above the method detection limits) for samples collected from sampling reach are >0.3 mg/kg 
PCBs in Fish Tissue  Fully Supporting  Not Supporting 
Actual concentration values (including estimated values above the method detection limits) for all samples collected from sampling reach are <0.02 mg/kg  One or more actual concentration values (including estimated values above the method detection limits) for samples collected from sampling reach are >0.02 mg/kg 
Recreational Use Support (Human Health) – All waters 
IDEM has two different criteria for recreational use assessments depending on the type of data set being used in making the assessment. For data sets consisting of five equally spaced samples over a 30-day period, we apply two tests, both of which are based on U.S. EPA's Ambient Water Quality Criteria for Bacteria - 1986 (EPA440/5-84-002), which provides the foundation for Indiana's WQS for recreational use. For data sets consisting of 10 or more grab samples where no five of which are equally spaced over a 30-day period, the 10% rule is applied. Specific criteria are provided below. 
  Fully Supporting  Not Supporting 
Bacteria (E. coli): at least five equally spaced samples over 30 days. (cfu = colony forming units)  Geometric mean does not exceed 125 cfu/100ml and no more than one sample >576 cfu/100ml.  Geometric mean exceeds 125 cfu/100mL. 
Bacteria (E. coli): grab samples (cfu = colony forming units)  No more than 10% of measurements >576 cfu/100ml and not more than one sample >2,400 cfu/100ml.  More than 10% of samples >576 cfu/100ml or more than one sample >2,400 cfu/100ml. 
Drinking Water Use Support – Rivers and Streams 
Rivers are designated for drinking water uses if a community water supply has a drinking water intake somewhere along the segment. When IDEM has data for a segment with a drinking water intake, those data are compared to the applicable ambient water quality criteria in Indiana's WQS to determine if the drinking water use is met. The appropriate water quality criteria are applied for specific substances identified in the WQS. Information regarding non-naturally occurring taste and odor producing substances not specifically identified in the WQS are reviewed within the context of a water treatment facility's ability to meet Indiana's drinking WQS using conventional treatment. 
Toxicants  Dissolved metals, pesticides, PCBs, free cyanide were evaluated on a site by site basis and judged according to magnitude of the exceedance or exceedances of Indiana's WQS for point of water intake and the number of times the exceedance or exceedances occurred. For any one pollutant (grab or composite samples), the following assessment criteria are applied. 
  Fully Supporting  Not Supporting 
  No more than one exceedance of the acute or chronic criteria for human health within a three-year period.  More than one exceedance of the acute or chronic criteria for human health within a three-year period. 
Conventional inorganics  Total dissolved solids, specific conductance, sulfate, chloride, nitrite-N and nitrogen (measured as NO3 + NO2) were evaluated for the exceedance or exceedances of Indiana's WQS for point of water intake and the number of times the exceedance or exceedances occurred. For any single pollutant (grab or composite samples), the following assessment criteria are applied to data sets consisting of three or more measurements. 
Fully Supporting  Not Supporting 
No more than one exceedance of the acute or chronic criteria for human health within a three-year period.  More than one exceedance of the acute or chronic criteria for human health within a three-year period. 
Taste and odor producing substances  Fully Supporting  Not Supporting 
Taste and odor substances not present in quantities sufficient to interfere with production of drinking water by conventional treatment  Taste and odor substances present in quantities requiring additional treatment by the public water supply to prevent taste and odor problems 
Recreational Use Support (Aesthetics) – Lakes and Reservoirs 
Natural Lakes  Fully Supporting  Not Supporting 
No more than 10% of all TP values >54 ug/L and their associated Chla values are <20ug/L  Less than 10% of all TP values are >54 ug/L but their associated Chla values are >20ug/L, and the TSI score for the lake indicates eutrophic (32-46) or hypereutrophic (>47) conditions 
Or 
More than 10% of all TP values are >54 ug/L with associated Chla values <4ug/L, but the TSI score for the lake indicates eutrophic (32-46) or hypereutrophic (>47) conditions 
Or 
More than 10% of all TP values are >54 ug/L with associated Chla values >4ug/L 
Reservoirs  Fully Supporting  Not Supporting 
No more than 10% of all TP values >51 ug/L and their associated Chla values are <25ug/L  Less than 10% of all TP values are >51 ug/L but their associated Chla values are >25 ug/L and the TSI score for the lake indicates eutrophic (32-46) or hypereutrophic (>47) conditions 
Or 
More than 10% of all TP values are >51 ug/L with associated Chla values <2ug/L, but the TSI score for the lake indicates eutrophic (32-46) or hypereutrophic (>47) conditions 
Or 
More than 10% of all TP values are >51 ug/L with associated Chla values >2ug/L 
Drinking Water Use Support – Lakes and Reservoirs 
Information on the application of pesticides to surface drinking water reservoirs  Reservoirs or lakes that serve as source water for public water supplies that received pesticide (algaecide) application permits for algae were classified as not supporting because additional treatment by the public water supply was required to prevent taste and odor problems. 
Other Assessments – Lakes and Reservoirs 
Indiana Trophic State Index (TSI)  Nutrients, ammonia, dissolved oxygen, light transmission and light penetration in the water column turbidity, and algae growth were used to determine TSI scores. Trophic scores were used to classify lakes according to their trophic state. Lake trends were also assessed for lakes with two or more trophic scores if at least one of the scores was less than five years old. Trophic scores and lake trends are not used to determine use support status. These assessments are conducted to fulfill CWA Section 314 reporting requirements for publicly owned lakes and reservoirs. 

IDEM's Use of Site-Specific Criteria
Indiana's WQS contain provisions for the calculation of site-specific criteria (SSC) for the protection of aquatic life and human health in order to provide 1) an additional level of protection, or 2) a less stringent criteria in cases where it can be shown that site-specific conditions indicate the criterion contained in Indiana's WQS for the pollutant in question is unnecessarily stringent7. SSC are typically developed for the NPDES program on a case-by-case basis to ensure that the specific pollutant or pollutants contained in a permitted discharge do not impair aquatic life or human health use support.
The SSC expressed in Indiana's WQS apply only to the stream or stream reach and the pollutant for which they were calculated. Until now, IDEM has been generally unable to apply SSC in its assessment processes because of the way AUs are defined. Few SSC are broadly applicable to the basin in which they are located. Therefore, in order to apply SSC, the AU must match the reach to which the criterion applies both in terms of its location and length. In most cases, the AU as a whole is larger than the reach to which the SSC applies. Given this, applying a SSC to the entire AU would result in the criterion being used to assess the water quality condition for the entire waterbody as opposed to the specific reach to which it applies. In the past, IDEM's policy in these cases has been to give precedence to the ambient water quality criterion expressed in the state's WQS.
IDEM has put the necessary internal processes in place to conduct the resegmentations that are needed to more accurately apply SSC. Such resegmentations require close coordination between IDEM's NPDES, WQS, and 305(b)/303(d) programs. Given the scientific and regulatory complexities involved, these resegmentations are rare and must necessarily be considered on a case-by-case basis. In the future, IDEM plans to coordinate this work with NPDES permit renewals for those facilities discharging to waters with applicable SSC.

OHIO RIVER ASSESSMENTS
IDEM collaborates with the Ohio River Valley Water Sanitation Commission (ORSANCO) to conduct water quality assessments of the Ohio River reaches that border Indiana. ORSANCO is an interstate water pollution control agency for the Ohio River established through a compact agreement between member states and approved by Congress. Under the terms of the compact, member states cooperate in the control of water pollution in the Ohio River Basin.
ORSANCO monitors the Ohio River on behalf of the compact states under CWA Section 305(b) and produces a water quality assessment report of its water quality condition every two years. Although this report identifies water quality issues on the Ohio River, unlike its compact states, ORSANCO is not required to develop a 303(d) List of Impaired Waters. Identifying Ohio River impairments on a 303(d) list for the purposes of TMDL development is the responsibility of each compact state.

Development of Assessment Methodologies for the Ohio River
Every two years, ORSANCO prepares a description of the proposed assessment methodology for review by the 305(b) workgroup made up of state agency personnel responsible for preparing the Integrated Reports in each state and one or more U.S. EPA representatives responsible for reviewing state reports. When the 305(d) Work Group reaches agreement on the methodology, it is submitted to ORSANCO's Technical Committee for review and approval. Once approved, ORSANCO applies the methodology to the available information to make its preliminary assessments that are then distributed to the 305(b) Work Group for review. When the 305(b) Work Group reaches agreement on the assessment, each state incorporates the results into its Integrated Report and 303(d) List of Impaired Waters, and ORSANCO completes its 305(b) report for submission to U.S. EPA.
ORSANCO's role in completing Ohio River use attainment assessments and developing a biennial report on Ohio River water quality conditions is primarily to facilitate interstate consistency in CWA 305(b) assessments and how impairments are identified on states' 303(d) lists for the purposes of TMDL development. However, such consistency is not always possible given the differences in states' WQS. Given these differences, member states are not obligated to incorporate any or all of ORSANCO's water quality assessments into their own reports. Specifically, U. S. EPA guidance states that "data and information in an interstate commission 305(b) report should be considered by the states as one source of readily available data and information when they prepare their Integrated Report and make decisions on segments to be placed in Category 5; however, data in a 305(b) Interstate Commission Report should not be automatically entered in a state Integrated Report or 303(d) list without consideration by the state about whether such inclusion is appropriate." (U.S. EPA, 2005)
For the 2010 cycle, IDEM has completed a thorough review of ORSANCO's methodology for the assessment of aquatic life use support, recreational use support and support of fish consumption uses. This review included a comparison of the relative stringencies of applicable criteria in ORSANCO's Pollution Control Standards (PCS) and Indiana's WQS (CALM Appendix A) and the different ways in which these criteria are used to make each type of use support assessment.
In order to achieve consistency with other member states, IDEM generally defers to ORSANCO's methods for evaluating the available data for assessment purposes. And, where there are no significant differences between ORSANCO's criteria and those expressed in Indiana's WQS, IDEM incorporates ORSANCO's assessments directly into its Integrated Report and 303(d) List applying them to the corresponding reaches defined in IDEM's ADB. However, in cases where the water quality criteria ORSANCO use are less stringent than the water quality criteria expressed in Indiana's WQS and or its methods for applying them are significantly inconsistent with IDEM's assessment methodology, IDEM uses the data collected by ORSANCO directly. In these cases, IDEM evaluates the data against IDEM's assessment methodology and compares results to Indiana's WQS to make the assessment. IDEM's methods for applying ORSANCO's assessments and/or data for the purposes of Integrated Reporting is described below and summarized in Table 1-C.

Aquatic Life Use Assessments for the Ohio River
ORSANCO uses both water chemistry results and biological monitoring results to determine the degree to which the Ohio River supports aquatic life. ORSANCO's fish community assessments of the Ohio River use the Ohio River Fish Index (ORFIn) developed based on the nationally used Index of Biotic Integrity (IBI) designed to assess smaller streams. The ORFIn has been customized to assess the Ohio River, with expected values developed for the different habitats found in this large river system. The ORFIn combines various attributes of the fish community to give a score to the river based on its biology. The total score is compared to an expected score, which varies depending on the habitat type and location. IDEM defers to ORSANCO's assessments based on biological data. IDEM also defers to ORSANCO's approach to evaluating water chemistry data. However, assessments may differ somewhat depending on the parameter in question and whose criterion, ORSANCO's or Indiana's, is more stringent. Tables containing WQS comparisons are provided near the end of this methodology document immediately after the contact information.

Recreational Use Assessments for the Ohio River
Indiana's E. coli criteria are slightly more stringent than ORSANCO's. However, unlike Indiana's WQS, ORSANCO's criteria do not allow exceptions for exceedances that are incidental and attributable solely to E. coli resulting from the discharge of treated wastewater from a wastewater treatment plant. ORSANCO's assessment methodology also directly applies its single sample maximum criterion to individual results, which provides a more robust assessment than Indiana's combined criteria and assessment methodology can. Indiana therefore defers to ORSANCO's assessments of recreational use support for the Ohio River.

Fish Consumption Assessments for the Ohio River
In addition to assessments of aquatic life use support and recreational use support, ORSANCO also makes assessments of the degree to which the Ohio River supports fish consumption. In applying these assessments to Indiana reaches of the Ohio River, IDEM emphasizes that this information is not intended to be a public health advisory and recommends that the public refer to the most current Indiana Fish Consumption Advisory (FCA) or contact the Indiana State Department of Health (ISDH), or both with any specific questions or concerns regarding the health risks associated with consuming fish caught from the Ohio River. Important differences between fish consumption use impairments identified as a result of these assessments and the health advisories provided in the FCA are discussed in more detail in the section of this methodology describing Indiana's assessment methodology for fish consumption for other Indiana waters and Lake Michigan.
ORSANCO uses both fish tissue data and water sample results to make its fish consumption use assessments, and its methods for evaluating the data differ somewhat from IDEM's methods for similar assessments on other Indiana waters. Unlike ORSANCO's methodology, IDEM's assessment methodology relies on fish tissue data only and requires only one exceedance of the applicable criterion to assess impairment. IDEM's methods are intended to result in a more conservative estimate of conditions in smaller rivers and streams for which there is commonly less available data. In contrast, the Ohio River is a large and complex river system, and the ORSANCO monitoring programs that provide data for the assessment of fish consumption use support result in a far more robust data set than those available for similar assessments of other Indiana waters. Therefore, IDEM defers to ORSANCO's assessment methodology for fish consumption use support for the Ohio River and applies its methodology to all data considered usable for these assessments, regardless of the matrix sampled.
ORSANCO's criterion for methylmercury in fish tissue is equivalent to Indiana's criterion for mercury in fish tissue (0.3 mg/kg). ORSANCO's assessment methodology does not include a similar criterion for PCBs in fish tissue. Therefore, in cases where IDEM has results for PCBs in fish tissue from Ohio River fish, IDEM evaluates the results using ORSANCO's methods and the criterion applicable to other Indiana waters (0.02 mg/kg).
In addition to fish tissue data, ORSANCO's monitoring programs provide results for PCBs and dioxin and total mercury in the water column. IDEM defers to ORSANCO's approach to evaluating water column results for PCBs and dioxin results. However, assessments may differ somewhat depending on the parameter in question and whose criterion, ORSANCO's or Indiana's, is more stringent. With regard to mercury in the water column, ORSANCO's chronic aquatic life use criterion for total mercury in ambient waters is equivalent to Indiana's chronic aquatic life use criterion for total mercury (0.012 ug/L). ORSANCO applies this criterion in its assessments of fish consumption use support as opposed to aquatic life use support results, because ORSANCO considers bioaccumulation of mercury in fish tissue more of a human health issue than a threat to aquatic life. IDEM concurs with ORSANCO's use of water column results for mercury in assessments of fish consumption use based on this rationale and defers to ORSANCO on its fish consumption use assessments for the Ohio River. However, unlike ORSANCO, IDEM also applies the chronic criterion for total mercury in its assessments of aquatic life use support on the Ohio River.
For sites where the results for total mercury and/or PCBs in water conflict with the fish tissue results for that same contaminant, the fish tissue results are given precedence. Biological data are given more weight in the assessment decision because fish tissue levels of these contaminants are an indicator of more direct potential impacts to individuals consuming fish from the Ohio River while their concentrations in the water column are more an indicator of potential bioaccumulation than direct impacts from consumption. IDEM concurs with this approach.

Table 1-C: Water quality assessment criteria for determining designated use support for the Ohio River.
Aquatic Life Use Support – Ohio River 
Toxicants  Results for dissolved metals, total mercury, total selenium, free cyanide, and ammonia were evaluated on a site-by-site basis and judged according to the magnitude of the exceedance or exceedances of the applicable criteria in Indiana's WQS or ORSANCO's PCS, whichever is more stringent and the number of times the exceedance or exceedances occurred. 
Fully Supporting  Not Supporting 
No more than 10% of all samples exceed applicable criterion for a given pollutant.  More than 10% of all samples exceed applicable criterion for a given pollutant. 
Dissolved Oxygen (DO) and Temperature  Daily averages from hourly DO measurements and period averages from hourly temperature measurements were evaluated for the exceedance or exceedances of the applicable criteria in Indiana's WQS or ORSANCO's Pollution Control Standards, whichever is more stringent and the number of times the exceedance or exceedances occurred. Where exceedances are sufficient to impair, results are reviewed against any available biological data, Ohio River Fish Index (ORFin) scores, for the site to determine impairment. 
Fully Supporting  Not Supporting 
For DO, the daily averages for 10% or less of days fall below 5mg/L.  For DO, the daily averages for more than 10% of days fall below 5 mg/L 
And  And 
Biological data for the same reach indicates full support (more than 25% of sites in a pool receive passing ORFin scores.  Biological data for the same reach indicates impairment (25% or more of sites in a pool receive failing ORFin scores. 
Or  Or 
No biological data are available for the site but the daily averages for 10% or less of days fall below 5mg/L.  No biological data are available for the site but the daily averages for more than 10% of days fall below 5 mg/L. 
For temperature, no more than 10% of the periods exceed the period average  For temperature, more than 10% of the periods exceed the period average 
And  And 
Biological data for the same reach indicates full support (No more than 25% of sites in a pool receive failing ORFin scores)  Biological data for the same reach indicates impairment (More than 25% of sites in a pool receive failing ORFin scores) 
Or  Or 
No biological data are available for the site but 10% or less of the periods exceed the applicable period average.  No biological data are available for the site but more than 10% of the periods exceed the applicable period average. 
Conventional Inorganics  Results for pH, sulfates, and chlorides were evaluated for the exceedance or exceedances of the applicable criteria in Indiana's WQS or ORSANCO's PCS, whichever is more stringent and the number of times the exceedance or exceedances occurred. 
Fully Supporting  Not Supporting 
No more than 10% of all samples exceed applicable criterion for a given pollutant.  More than 10% of all samples exceed applicable criterion for a given pollutant. 
Ohio River Fish Index (ORFin) scores  ORFin scores are compared to expected scores for the location sampled. Expected scores vary depending on the habitat type and location. 
Fully Supporting  Not Supporting 
No more than 25% of sites in a pool receive failing ORFin scores  More than 25% of sites in a pool receive failing ORFin scores 
Fish Consumption Use Support (Human Health) – Ohio River 
Results for total mercury, PCBs and dioxin in water samples were evaluated for the exceedance or exceedances of the applicable criteria in Indiana's WQS or ORSANCO's PCS, whichever is more stringent and the number of times the exceedance or exceedances occurred. Results for methylmercury and PCBs in fish tissue samples were evaluated for the exceedance or exceedances of the applicable criteria in Indiana's WQS or ORSANCO's Pollution Control Standards, whichever is more stringent and the number of times the exceedance or exceedances occurred. Generally, for sites where water sample results conflict with fish tissue results for the same pollutant, the fish tissue results are given precedence. 
Total mercury and polychlorinated biphenyls (PCBs) in Fish Tissue and Water Samples  Fully Supporting  Not Supporting 
For reaches with results from both water and fish tissue samples, more than 10% of water sample results exceed the applicable water quality criterion  For reaches with results from both water and fish tissue samples, more than 10% of water sample results exceed the applicable water quality criterion 
And  And 
No more than 10% of results from composited fish tissue samples exceed the applicable fish tissue criterion  More than 10% of results from composited fish tissue samples exceed the applicable fish tissue criterion 
Or  Or 
More than 10% of water sample results exceed the applicable water quality criterion but 10% or less of results from composited fish tissue samples exceed applicable fish tissue criterion  Less than 10% of water sample results exceed the applicable water quality criterion but more than 10% of results from composited fish tissue samples exceed applicable fish tissue criterion 
For reaches with results from either water samples or fish tissue samples but not both, no more than 10% of results from all samples exceed the applicable criterion  For reaches with results from either water samples or fish tissue samples but not both, more than 10% of results from all samples exceed the applicable criterion 
Dioxin in Water Samples  No more than 10% of results from all samples exceed the applicable criterion  More than 10% of results from all samples exceed the applicable criterion 
Recreational Use Support (Human Health) – Ohio River 
Available data are evaluated in two ways. Both individual results and monthly geometric mean results calculated from five samples, one collected each week for five consecutive weeks are evaluated for exceedances of the applicable criteria in ORSANCO's PCS and the number of times exceedances occurred. 
Bacteria (E. coli)  Fully Supporting  Not Supporting 
No more than 10% of the monthly geometric mean results exceed the geometric mean criterion  More than 10% of the monthly geometric mean results exceed the geometric mean criterion 
And  Or 
No more than 10% of all single sample results exceed the instantaneous maximum criterion  More than 10% of all single sample results exceed the instantaneous maximum criterion 

LAKES ASSESSMENTS

IDEM's CWA Section 305(b) Assessment Criteria for Recreational Use Support in Lakes

IDEM's lakes assessments have largely been limited to CWA Section 314 assessments of lake trends and trophic state. This has been due to the absence of water quality criteria in the state's WQS. Indiana's WQS contain narrative criteria for all waters of the state. The few designated use assessments made on lakes and reservoirs to date are based primarily on narrative criteria.
On a national scale the number one impairment of lakes and reservoirs has long been identified as nutrients. Given this, U.S. EPA has mandated that states develop and adopt nutrient criteria their WQS. In 2001, EPA published recommended criteria for both causal (total nitrogen and phosphorus) and response (chlorophyll a and turbidity or water clarity) variables in the federal register (66 FR 1671). These criteria were developed for waterbodies in "aggregated" ecoregions based on the work of Omernik and Gallant (1988). U.S. EPA's ecoregional approach uses lake data from a number of states. The analyses used to derive the criteria applicable to Indiana included only nine Indiana lakes, one natural lake and eight reservoirs. Given this, U.S. EPA's published criteria are not as Indiana-specific as IDEM believes is necessary to provide for accurate assessments of water quality conditions in lakes throughout the state. U.S. EPA recognizes these concerns and encourages states to modify or refine their criteria to reflect conditions on a smaller geographic scale (U.S. EPA, 2000c).
In 2007, IDEM developed additional criteria for assessing recreational use support in lakes and reservoirs within the context of aesthetics in order to more fully assess the water quality condition of Indiana's lakes and reservoirs. It should be noted that the assessment criteria described here does not replace any assessment criteria currently in place for lakes and reservoirs. The assessment criteria for recreational use support with respect to human health remains unchanged, as do those used to determine drinking water and aquatic life use support (Table 1-B).
These criteria used to determine recreational use support within the context of aesthetics are based on the results of a study conducted by of Limno-Tech, Inc. (LTI). In 2004, IDEM contracted with LTI to recommend potential nutrient water quality criteria for Indiana's lakes based on data collected throughout Indiana over several decades. Under this project, a comprehensive database of lakes data was developed for use in analyzing nutrient relationships for Indiana's lakes. The final report for this study was submitted to IDEM in 2007. For the purposes of this notice, a summary of the data and analytical methods used and the resulting recommendations are provided here.

Phosphorus thresholds for recreational use assessments and the data used to develop them.

The LTI study used both agency data and volunteer data collected by the Indiana CLP from 321 natural lakes and 113 reservoirs from 1989 to 2005. Of the 13,063 individual samples with water quality data, 70% of the samples were collected under the volunteer monitoring program. In order to have sufficient data for robust analyses, it was important to use volunteer data if its reliability could be verified. The Indiana CLP is funded by IDEM's Section 319 grant program and operates under an IDEM-approved Quality Assurance Project Plan (QAPP) that documents the data quality of all data collected under the program.
Given the importance of volunteer data to this study, data were examined to determine if there was a significant difference depending on whether the data were collected by volunteers or by the agencies. LTI first plotted raw data values against each other. However, it became apparent that averaged data provided a much better representation of potential relationships. For example, Figure 1-B shows the growing season (June to August) average of Secchi depth and chlorophyll a (Chla) values for lakes where at least three different sample years of Chla existed. This analysis shows that volunteer data are indistinguishable from agency data, and, therefore, no bias should exist if all datasets are combined. Similar conclusions were reached when LTI made additional comparisons between Secchi depth and total phosphorus (TP) and between Chla and TP. The absence of bias between volunteer and agency data was also confirmed by evaluating lakes where agency and volunteer data were used to calculate summer medians versus lakes where only agency data were available.
318120053ONA02.jpg
Figure 1-B: Comparison of volunteer and agency data (Source: LTI, 2007).
Data from all sources were reviewed for quality assurance and evaluated to identify spatial and temporal patterns. Suitable models for developing criteria were evaluated and statistical analyses were applied to establish the recommended total phosphorus thresholds shown in Table 1-D.

Table 1-D: Recommended phosphorus thresholds.
Lake Type  Total Phosphorus (ug/L)  Associated Range in Chlorophyll a (ug/L) 
Natural Lakes  54  4 to 20 
Reservoirs  51  2 to 25 
Source: Modified from LTI (2007).

The associated range of Chla represents the range of concentrations that based on LTI's analysis of natural lakes and reservoirs in Indiana that can be expected when TP concentrations are at or below 54 ug/L or 51 ug/L, respectively.

How the thresholds were determined

Multiple linear regression analyses were conducted on total phosphorus (as a response variable) for each data set (natural lakes and reservoirs) using regression tree analysis (RTA) methods developed by Soranno, et.al, (personal communication). RTA was used to determine appropriate TP thresholds.
Once the TP thresholds were established, median values above and below the threshold for each lake type were calculated for two biological response variables, Secchi depth and Chla. The median values above and below represent the range of expected values for each response variable associated with its corresponding TP threshold. For example, in Figure 1-C, the median below line represents the median of all Chla concentration values that fall to the left of the calculated TP threshold whereas the median above line represents all of the Chla values that fall to the right of the threshold (that is, correspond to TP "exceedances"). A simplified model of how the median values calculated for a given TP threshold are used to determine recreational use support is provided in the discussion regarding IDEM's assessment methodology for this use (Figure 1-D).
318120053ONA03.jpg
Figure 1-C: Relationship of Chlorophyll a concentrations to the TP threshold for natural lakes (Source: LTI, 2007).

A biological response factor for Chla was then calculated as the median of the biological response above the threshold divided by the median of the biological response below the threshold. The biological response factor for Secchi depth was calculated as the median of the biological response below the threshold divided by the median of the biological response above the threshold. Based on the work of Soranno, et al., a biological response factor of 2 or greater is considered significant and could reasonably be designated as a relevant TP threshold above which action should be taken.
Table 1-E shows that the thresholds calculated are very significant for Chla in both reservoirs and natural lakes. The threshold for Secchi depth in reservoirs, while still significant, is not nearly as strong as the threshold for Chla as indicated by their biological response factors (3.6 for Secchi depth vs. 13.2 for Chla). The same holds true for natural lakes (1.9 for Secchi depth and 5.6 for Chla), and the biological response factor for Secchi depth falls below that which is considered significant for the purposes of setting an appropriate TP threshold.

Table 1-E: TP thresholds and median values above and below the thresholds for natural lakes and reservoirs.
Response Variable  Secchi Depth  Chlorophyll a 
Natural Lakes 
TP Threshold (ug/L)  36  54 
Median of values above TP threshold  1.2 meters  20 ug/L 
Median of values below TP threshold  2.4 meters  4 ug/L 
Biological response factor  1.9  5.6 
Reservoirs 
TP Threshold (ug/L)  31  51 
Median of values above TP threshold  0.8 meters  25 ug/L 
Median of values below TP threshold  2.7 meters  2 ug/L 
Biological response factor  3.6  13.2 
Source: Modified from LTI (2007).

Because the TP thresholds for Chla are much stronger than those for Secchi depth, IDEM's assessment methodology incorporates the TP thresholds developed for Chla. Other reasons for this decision are that Secchi depth measurements are inherently more subjective than Chla measurements, and IDEM does not have survey data regarding aesthetics necessary to adequately translate secchi depth information into use support status. While there is similarly little analogous information available for Chla, IDEM considers Chla data obtained through laboratory analyses of water samples a more reliable indicator of phosphorus enrichment than secchi depth for the purposes of 305(b) assessment and 303(d) listing decisions.
In some cases, the Chla data were not consistent with expectations given the TP levels measured for a given lake (for example, low Chla values associated with high TP values or vice versa). For these situations, IDEM's methodology used the TSI score as a surrogate response variable (in addition to Chla) to determine impairment status. The TSI score can be affected by a number of variables in addition to phosphorus (see Table 7). However, the index places additional weight on algal concentration, adding significantly more points where concentrations are high. While the TSI does not provide a direct response variable for TP, it can be a useful indicator in cases where Chla results are mixed.
In addition to providing a surrogate measure for Chla, the TSI score also provides a good measure of overall trophic condition of a given lake. Recognizing the connection between trophic status and nutrient enrichment, U.S. EPA generally considers hypereutrophic conditions as measured by the TSI indicative of impairment (U.S. EPA, 2000c). IDEM does not believe that the TSI score alone is sufficient information for making designated use assessments because it can be affected by a number of variables in addition to nutrient loading. However, in cases where the Chla results are mixed, IDEM used the most recent TSI score to determine impairment. If the TSI score indicates eutrophic or hypereutrophic conditions, the lake was assessed as impaired. It should be noted that TSI scores were not used in absence of Chla results. TSI scores were only reviewed in cases where there were sufficient TP and Chla data but where those data showed conflicting results.
The benchmarks from the LTI study were used to make assessments for recreational uses (as opposed to other designated uses), specifically within the context of aesthetics. Because IDEM does not have sufficient information regarding the response of aquatic communities to nutrient enrichment, these criteria are used to make recreational use support determinations only. These assessments are made within the context of aesthetics as opposed to health risk. Recreational use support assessments for human health are based on pathogen data and are made in the same manner as for rivers and streams when adequate data are available. All impairments identified based on this methodology were assessed as impaired for phosphorus as opposed to nutrients because the LTI study did not include analyses of other nutrient-related parameters.
Figure 1-D provides a simplified model of how the median values calculated for a given TP threshold are used to determine recreational use support. A more detailed discussion is provided in following section.
318120053ONA04.jpg
Figure 1-D: Simplified model of IDEM's assessment methodology using TP data in conjunction with Chla data.

IDEM's assessment methodology using the Total Phosphorus (TP) thresholds

Step 1. Determine the available data to be used for assessment
Indiana's CLP samples 70-80 lakes each year in accordance with a rotating sampling strategy similar to the rotating basin strategy employed by IDEM for monitoring streams. However, the basin rotation IDEM employs for Indiana's rivers and streams does not work well for lakes given their unequal distribution across the Indiana landscape. While some basins contain very few lakes, others contain more than can feasibly be sampled in a given year. Instead, the Indiana's CLP monitoring rotation for lakes is designed to analyze all public access lakes once every five years. Through this rotation, a given lake is monitored approximately once every five years in July and August with approximately 80 lakes sampled each year. About 400 lakes are thus monitored in a given five-year rotation. In general, only public lakes having an accessible boat launching area were sampled. The July-August period is used because this is the time of year when worst-case scenario and stable conditions (warm temperatures, thermal stratification, hypolimnetic anoxia, and algal blooms are expected).
All available data for a given lake were used for assessment purposes. U.S. EPA guidance suggests that, while all readily available data should be reviewed, 305(b) assessment decisions should be based on data five years old or less. The use of historical data is necessary because the sampling conducted by IDEM's CLP program is designed specifically to support CWA Section 314 assessments of trophic state and lake trends, not to make designated use assessments. As a result, while IDEM's CLP sampling strategy ensures sufficient samples for determining trophic state and trends, a given CLP sampling rotation does not guarantee sufficient data for making designated use assessments (see Table 1-A for minimum data requirements). IDEM's benchmark criteria were developed using data from 1989 forward. U.S. EPA recommends that, in general, the method of data gathering for determining compliance (in this case, designated use support) for lakes and reservoirs should be similar to that used to establish the criteria (U.S. EPA, 2000c). CLP data used for designated use assessments includes results from the following:
• One-time samples collected from public access lakes by SPEA students and analyzed in the CLP laboratory, and
• Monthly TP and Chla samples collected from public and private lakes by trained volunteers and sent to the CLP laboratory for analysis.
Step 2. Determine adequate data for assessment
For purposes of determining recreational use support within the context of aesthetics, the following general rules were applied:
• Only TP and Chla data, including volunteer-collected data, analyzed in the CLP laboratory in accordance with the CLP QAPP were used for assessment purposes.
• A minimum of three years' worth of data was considered sufficient for assessment purposes, provided each TP value had a corresponding Chla value.
• Multiple results within a given year for each parameter (TP and Chla) were averaged to provide a single value for that year.
• For consistency in assessments, all samples used in attainment decisions must have been collected during the summer season.
Step 3: Apply benchmark criteria to determine use support
The thresholds shown in Table 1-F were applied to all natural lakes and reservoirs for which sufficient data were available. IDEM's methods for applying these criteria are summarized in Table 1-H and are illustrated in Figure 1-E. All waters found to be not supporting of recreational use (aesthetics) were categorized as impaired and placed in Category 5A of Indiana's 303(d) list.

Table 1-F: Summary of IDEM's assessment methodology for recreational use support within the context of aesthetics.
Recreational Use Support (Aesthetics) – Lakes and Reservoirs 
Natural Lakes  Fully Supporting  Not Supporting 
No more than 10% of all TP values >54 ug/L and their associated Chla values are <20ug/L  Less than 10% of all TP values are >54 ug/L but their associated Chla values are >20ug/L, and the TSI score for the lake indicates eutrophic (32-46) or hypereutrophic (>47) conditions 
Or 
More than 10% of all TP values are >54 ug/L with associated Chla values <4ug/L, but the TSI score for the lake indicates eutrophic (32-46) or hypereutrophic (>47) conditions 
Or 
More than 10% of all TP values are >54 ug/L with associated Chla values >4ug/L 
Reservoirs  Fully Supporting  Not Supporting 
No more than 10% of all TP values >51 ug/L and their associated Chla values are <25ug/L  Less than 10% of all TP values are >51 ug/L but their associated Chla values are >25 ug/L and the TSI score for the lake indicates eutrophic (32-46) or hypereutrophic (>47) conditions 
Or 
More than 10% of all TP values are >51 ug/L with associated Chla values <2ug/L, but the TSI score for the lake indicates eutrophic (32-46) or hypereutrophic (>47) conditions 
Or 
More than 10% of all TP values are >51 ug/L with associated Chla values >2ug/L 
318120053ONA05.jpg
Figure 1-E: IDEM's assessment process for determining recreational use support for lakes within the context of aesthetics.

Given the robust, Indiana-specific dataset upon which the thresholds recommended in the LTI study were developed, IDEM believes they are appropriate for making designated use assessments and will likely provide the basis for rulemaking to establish nutrient criteria for Indiana's lakes in the future. When IDEM finalizes its nutrient criteria and incorporates them into the state's WQS, IDEM will review all lakes assessments made with the present methodology to determine their consistency with the revised WQS.

IDEM's CWA Section 314 Lakes Assessments
CWA Section 314 lakes assessments were based on the Indiana Trophic State (or eutrophication) Index, a modified version of the BonHomme Index developed for Indiana lakes in 1972. This multi-metric index combines chemical, physical, and biological data into one overall trophic score for each public lake and reservoir sampled (Table 1-G). Scores range from zero to 75. Lower values reflect lower concentrations of nutrients (Table 1-F). This information is useful in evaluating watershed impacts on lakes. Declining or extirpated cisco populations and the presence of exotic and potentially toxic blue-green algae species were also considered when evaluating lake water quality for aquatic life use. For drinking water reservoirs, taste and odor were also considered as potential indicators of other water quality problems within the waterbody.

Table 1-G: The Indiana Trophic State Index
Parameter  Range  Eutrophy Points 
Total Phosphorus (mg/L)  <0.03 
0.03-0.039 
0.04-0.059 
0.06-0.199 
0.20-0.99 
>1.0 
 
Soluble Phosphorus (mg/L)  <0.03 
0.03-0.039 
0.04-0.059 
0.06-0.199 
0.2-0.99 
>1.0 
 
Organic Nitrogen (mg/L)  <0.5 
0.5-0.59 
0.6-0.89 
0.9-1.9 
>2.0 
 
Nitrate (mg/L)  <0.3 
0.3-0.39 
0.4-0.89 
0.9-1.9 
>2.0 
 
Ammonia (mg/L)  <0.3 
0.3-0.39 
0.4-0.59 
0.6-0.99 
>1.0 
 
Dissolved Oxygen (% saturation at a depth of five feet)  <114 
115 to 119 
120 to 129 
130 to 149 
>150 
 
Dissolved Oxygen (% of measured water column with at least 0.1 ppm dissolved oxygen)  <28 
29-49 
50-65 
66-75 
76-100 
 
Light Penetration (depth in feet measured with a Secchi disk)  <
>5 
 
Light Transmission (% at a depth of three feet as measured with a photocell)  0-30 
31-50 
51-70 
>71 
 
Total Plankton (organisms/L as measured in a sample collected from a single vertical tow between the surface and the 1% light level)  <3,000 
3,000-6,000 
6,001-16,000 
16,001-26,000 
26,001-36,000 
36,001-60,000 
60,001-95,000  10 
95,001-150,000  15 
150,001-500,000  20 
>500,000  25 
Dominance of blue-green algae (>50%)  10 additional points 

Table 1-H: Indiana's lake classification in terms of trophic condition.
Trophic State  Indiana TSI Score 
Increasing TSI scores indicate increasing eutrophication  Oligotrophic  <15 TSI points 
Mesotrophic  16-31 TSI points 
Eutrophic  32-46 TSI points 
Hypereutrophic  >47 TSI points 
Dystrophic  Lakes with little plant growth despite the presence of nutrients; usually due to high humic conditions 

INDIANA'S ASSESSMENT METHODOLOGY FOR FISH CONSUMPTION
U.S. EPA "generally believes that fish and shellfish consumption advisories....based on segment specific information demonstrate impairment of CWA section 101(s) 'fishable' uses" and continues to require that IDEM make water quality assessments for fish consumption and place waters with fish consumption advisories on its 303(d) list of impaired waters (U.S. EPA, 2000a). However, Indiana's WQS (WQS) do not contain numeric criteria for the concentration of mercury or polychlorinated biphenyls (PCBs) in fish tissue. IDEM's past and present fish consumption use assessments are a translation of the narrative portion of Indiana's WQS, which states that surface waters "... shall be free from substances in concentrations that on the basis of available scientific data are believed to be sufficient to injure, be chronically toxic to, or be carcinogenic...to humans, animals, aquatic life or plants." (327 IAC 2-1-6 (a)(2)).
In the absence of numeric criteria for mercury and PCBs in fish tissue, Indiana's 305(b) assessment and 303(d) listing methodology relied primarily on the state's Fish Consumption Advisory (FCA) published by the Indiana State Department of Health (ISDH). The approach proved to be problematic for the following reasons:
• Concentrations for assigning FCA groupings, as well as other variables for calculating these concentrations, can change with new scientific information. The advisory groupings shown in the FCA do not include the contaminant concentrations associated with them making it very difficult to determine whether a previous assessment is still valid when such changes occur. Using fish tissue concentration data is more straightforward, making it easier to reevaluate previous assessments as new information becomes available.
• Indiana's FCA was never intended to be used to make designated use assessments under CWA Sections 305(b) and 303(d). There is nothing mandatory or regulatory about the advice itself. Rather, the FCA is intended to provide the public with important public health information. In contrast, the 303(d) list is a list of waterbodies that do not meet WQS, and for which a TMDL is required. The groupings shown in the advisory are not designed to and do not translate into WQS. In the interest of achieving greater consistency with goals of CWA Sections 305(b) and 303(d), IDEM believes this change in its methodology for making water quality assessments for fish consumption is in order.
In 2007, IDEM revised its methods for determining Fish Consumption use support to address these and other issues associated with using FCAs for making CWA assessments.

IDEM's Assessment Criteria for Mercury and PCB Concentrations in Fish Tissue

Mercury

In 2001, U.S. EPA issued a revised human health-based water quality criterion for methylmercury (U.S. EPA 2001). The new criterion is unique among all U.S. EPA (CWA 304(a)) water quality criteria in that it identifies an acceptable mercury concentration in fish tissue rather than water. A fish tissue criterion is logical because it is fish that are the main source of methylmercury exposure to both humans and wildlife. Also, a tissue-based criterion eliminates the need for a bioaccumulation factor in the criterion calculation, which can be a significant source of uncertainty. The U.S. EPA criterion (U.S. EPA 2001) is 0.3 mg/kg methylmercury in fish muscle tissue. Since nearly 100% of the mercury in fish muscle is methylmercury, the criterion can reasonably be considered a total mercury criterion.

Polychlorinated Biphenyls (PCBs)

U.S. EPA has not issued a human health-based criterion for PCBs in fish tissue nor do Indiana's WQS contain a numeric concentration criterion for PCBs in the edible portion of fish tissue. However, Indiana has adopted human health WQS to protect the public from adverse impacts due to the following:
• Exposure through public drinking water supplies withdrawn from surface waters;
• Nondrinking water exposures such as consumption of fish caught in Indiana lakes, rivers, and streams.
Although human consumption of sport fish is not explicitly described in Indiana's WQS, criteria for fish consumption are included as part of the calculation of the human health criteria IDEM plans to propose in the future. The fish consumption values in the human health criteria calculation are intended to ensure that the levels of a carcinogenic chemical in fish are not at levels harmful to people who consume them.
Absent a U.S. EPA criterion derived specifically for fish tissue concentration of PCBs, using U.S. EPA's methodology for deriving ambient water quality criteria for the protection of human health (U.S. EPA 2006a) to calculate a concentration value for PCBs is a reasonable alternative that results in a criterion that is more readily applicable to Sections 305(b) and 303(d) water quality assessments than using FCA grouping levels.
IDEM's benchmark criterion for mercury and PCBs in fish tissue is shown in Table 9.

Table 1-I: WQS-based assessment thresholds for mercury and PCBs.
Mercury (Hg) 
Concentration in Fish Tissue  Fully Supporting  Not Supporting 
<0.3 mg/kg  > 0.3 mg/kg 
Polychlorinated Biphenyls (PCBs) 
Concentration in Fish Tissue  Fully Supporting  Not Supporting 
<0.02 mg/kg  > 0.02 mg/kg 

Relationship of IDEM's WQS-Based Criteria to the FCA

A fish consumption advisory is determined based on the quantity of a chemical in fish, such as milligrams of chemical per kilogram of the edible portion of fish tissue (mg/kg), commonly expressed as parts per million (ppm). WQS, on the other hand, are expressed as the quantity of the chemical in water, such as micrograms of a chemical per liter of water (ug/L). The exposure assumptions upon which the human health criteria are based can be used to calculate a maximum safe fish concentration. That fish concentration value can then be directly compared to the values used to issue fish consumption advisories to determine whether the advisory is less or more protective than the WQS.
The levels of fish tissue contaminants that trigger a FCA have little relation to the levels of fish tissue contaminants on which the WQS criteria are based. This discrepancy exists because different assumptions about fish consumption rates and body weight are made in calculating water quality criteria than in issuing FCA. FCAs are intended to provide for protection of human health over a lifetime of exposure, maximizing benefits of eating fish while minimizing the risk. The calculations used to determine if an FCA should be issued are based on contaminant concentration found in fish, which is treated as a constant while consumption rates are allowed to vary. Allowing for different consumption rates makes it possible to safely consume fish that have different levels of contamination. The recommended consumption rate is reduced as fish tissue concentrations increase. To determine a Group 2 advisory, the FCA uses a higher consumption rate (32 g/day) and a lower body mass (22 kg) than the WQS-based criteria calculation, which results in a higher effective exposure in terms of contaminant concentration per unit body mass. These values for consumption and body mass differ because FCA is intended to advise at-risk populations (women who are pregnant or breastfeeding, women who plan to have children, and children less than 15 years of age) about how much fish they can safely eat.
In contrast, WQS criteria calculations start with an assumed level of fish consumption and derive a criterion for a safe level given the exposure. Because the consumption rate is held constant, the resulting criterion can be applied consistently to all waters. FCAs are expressed for a given waterbody in terms of certain species within certain size ranges; very few FCAs apply to all fish in a given waterbody, which limits their utility for water quality assessment purposes.
IDEM's assessment methodology for evaluating fish tissue data directly is applicable to all waters and uses the revised human health-based water quality criterion for methylmercury (U.S. EPA 2001) and a criterion for PCBs derived from U.S. EPA's (2000b) human health methodology.
While mindful of the differences in purpose and function of the FCA and the 303(d) list, IDEM's methodology maintains as much consistency as possible between the protocols ISDH uses to assess data for the FCA and the protocols IDEM uses to assess data for the determination of impairment. For PCBs, the WQS-based threshold is consistent with the one meal per week advice in the FCA, which is equivalent to a Group 2 advisory. However, the threshold for mercury is higher than that which would trigger a Group 2 advisory (Table 1-J). For mercury, given the existing exposure assumptions upon which the water quality criteria are based, issuance of a FCA does not necessarily indicate an exceedance of WQS.

Table 1-J: Fish tissue concentrations for levels of consumption advice established by ISDH for mercury and total PCBs and its correspondence to an impairment condition as determine by the WQS-criteria.
Mercury  Fish Tissue Concentration (mg/kg) 
<0.05  <0.05 – 0.2  0.2 – 1.0  1.0 – 1.9  >1.9 
FCA Groups  Group 1  Group 2  Group 3  Group 4  Group 5 
Consumption Advice (FCA)  Unlimited  1 meal/week  1 meal/month  1 meal/2 months  No consumption 
PCBs  Fish Tissue Concentration (mg/kg) 
<0.05  <0.05 – 0.2  0.2 – 1.0  1.0 – 1.9  >1.9 
FCA Groups  Group 1  Group 2  Group 3  Group 4  Group 5 
Consumption Advice (FCA)  Unlimited  1 meal/week  1 meal/month  1 meal/2 months  No consumption 
*Shaded cells indicate consumption advice that corresponds to nonsupport and an impaired condition using the WQS-based criteria.

IDEM's benchmark criteria do not reflect any determination by IDEM of what an appropriate fish consumption rate should be. The consumption rates expressed in Indiana's WQS for human health are 15.0 g/day for waters in the Great Lakes basin (327 IAC 2-1.5-14) and 6.5 g/day for downstate waters (327 IAC 2-1-8.6). However, the most recent consumption studies available suggest consumption rates in Indiana are much closer to the 17.5 g/day national consumption rate (Sheaffer et al., 1999; Williams et al., 2000).
For mercury, IDEM defaulted to the U.S. EPA water quality criterion for water quality criterion for mercury in fish tissue (U.S. EPA, 2001), which corresponds to one meal per month, or a Group 3 advisory.
For calculating the criterion for PCB in fish tissue, IDEM used the same consumption rate U.S. EPA used to calculate its criterion for mercury in fish tissue for the general population, which is 17.5 g/day national consumption rate. The use of a higher consumption rate in the PCB calculation is consistent with that used by U.S. EPA and results in a more protective criterion than applying the consumption rate expressed for either the Great Lakes basin or downstate waters. The same holds true for mercury. IDEM's decision to use U.S. EPA's criterion value for mercury in fish tissue was a policy decision based on the fact that U.S. EPA's criterion is more protective. Calculations for both criteria are provided at the end of this of this methodology.

Assessment method using the WQS-based criteria

IDEM's assessment methodology for evaluating fish tissue data reflects a conservative approach intended to both identify waters in which the data indicate impairment for mercury or PCBs, or both and to provide for the protection of human health. Using this approach, all samples from a given sampling reach must have results below the benchmarks for mercury and PCBs in order to be assessed as fully supporting, and all waters with a sample result exceeding the benchmark for mercury or PCBs, or both are classified as impaired.

Table 1-K: Methods for determining fish consumption use support in Indiana waters.
Determining Use Support 
  Fully Supporting  Not Supporting 
Mercury in Fish Tissue  Actual concentration values (including estimated values above the method detection limits) for all samples collected from sampling reach are <0.3 mg/kg  One or more actual concentration values (including estimated values above the method detection limits) for samples collected from sampling reach are > 0.3 mg/kg 
PCBs in Fish Tissue  Actual concentration values (including estimated values above the method detection limits) for all samples collected from sampling reach are <0.02 mg/kg  One or more actual concentration values (including estimated values above the method detection limits) for samples collected from sampling reach are > 0.02 mg/kg 
In order to ensure accuracy in Indiana's 303(d) list, it was necessary to reevaluate all of the data used in all previous assessments using the new methodology. In 2008, IDEM conducted a statewide reassessment of all IDEM fish tissue data. The data set reviewed for reassessment was comprised of results from sampling conducted from 1994-2005 and is IDEM's longest ranging and most complete fish tissue data set to date. IDEM emphasizes that in completing its statewide reassessment, no waterbody impairment previously identified on Indiana's 303(d) list was delisted due to the age of the data available for assessment.
The following describes in detail the steps in IDEM's assessment process for assessing fish consumption use support for Indiana waters, which are illustrated in Figure 1-F.

Step 1. Determine adequate data for assessment
U.S. EPA guidance suggests that, while all readily available data should be reviewed, 305(b) assessment decisions should be based on data five years old or less. Therefore, each year assessments are conducted using the most recent five years' worth of fish tissue data. For purposes of determining fish tissue contaminant concentrations for assessment, the following general rules were applied:
• In order to ensure the most representative data were used for assessment, only samples prepared from the edible portion of fish were utilized.
• One year of sampling was considered sufficient for assessment purposes.
• For waterbodies with data collected in multiple years, species size classes were determined for each year of sampling and treated as individual samples.
• Concentration values less than the analytical method detection limit were considered insufficient for assessment purposes due to the uncertainty associated with such results. It should be noted that for PCBs and mercury, values below the analytical method detection limits do not commonly occur because both contaminants are bioaccumulative in fish tissue.
• Estimated values that are lower than the required quantitation limit8, which for PCBs is greater than 0.02 mg/kg, were considered valid for assessment purposes.
• Waterbodies were assessed as fully supporting only if all samples have actual quantitations (i.e., values above the method detection limits) and all were equal to or less than 0.02 mg/kg for PCBs and 0.3 mg/kg for mercury.
• One sample exceeding either criterion with an actual reported concentration was sufficient for the purposes of assessing impairment. This conservative approach is intended to provide greater protection of human health.
Step 2: Apply WQS-based concentration thresholds to determine use support
The WQS-based assessment thresholds shown in Table 1-I were applied to all lakes and streams for which sufficient fish tissue data were available. IDEM's methods for applying these criteria are summarized in Table 1-K. All waters found to be not supporting due to either mercury or PCBs or both were categorized as impaired and placed in Category 5B of Indiana's 303(d) list.
Step 3: Determine the appropriate geographical extent to which the assessment applies
In some cases fish can be very mobile and difficult to attribute to a discrete portion of a lake or river reach. For 305(b)/303(d) assessments, all fish tissue data for a given lake or reservoir were aggregated into a lakewide assessment unless there was evidence that fish from certain parts of a lake are isolated and may have been exposed to different levels of contamination. In determining the appropriate geographical extent to which results can be confidently applied to rivers and streams, a number of factors were considered in a weight-of-evidence approach to the decision making process, including the following:
• The size and complexity of watershed relative to the amount of data available for decision making and differences in stream orders within a given watershed;
• The spatial continuity of sampling results across watershed boundaries for a larger streams and rivers;
• Contaminant concentrations and information regarding known sources;
• The types of species sampled (bottom-feeder versus predator, considered in cases where the data were very limited);
• The relative amount and age of data (in cases where there were conflicting results from different sites along the same AU).
318120053ONA06.jpg
Figure 1-F: IDEM's assessment process for mercury or PCBs, or both in fish tissue.

Additional Advantages to Using a WQS-Based Approach for Fish Consumption Assessments

Presently, IDEM assesses for mercury and PCBs in fish tissue. Because IDEM's methodology for fish tissue assessments is based on human health criteria, it allows for the calculation of additional criteria for other potentially harmful substances (for example, dieldrin, DDT, chlordane, and other organochlorine pesticides) that might be found in fish tissue and can be used to identify waters in which fishable uses are impacted by such substances. IDEM has been collecting fish tissue data since the 1970s and has contaminant concentration information for a number of substances in addition to mercury and PCBs. However, because past assessments were based on the FCA, IDEM's ability to assess this information for 305(b)/303(d) purposes was limited to those constituents addressed in the advisory. In future 305(b)/303(d) cycles, IDEM expects to calculate criteria for the additional substances for which the agency has fish tissue data in order to more fully characterize the fishable uses in Indiana's waters and identify those waters that do not support fish consumption.

How to interpret impairments for fish consumption identified on Indiana's 303(d) List of Impaired Waters

IDEM emphasizes that the purpose of the 303(d) list is not to provide the public with a list of waters in which they should or should not swim, or from which they should or should not catch and eat fish. Section 303(d) of the CWA requires that states develop a list identifying impairments to water quality for which a TMDL is required. The 303(d) list is not and was never intended to be a public health advisory. IDEM continues to defer to the Indiana FCA on questions regarding the relative risks of consuming fish caught from Indiana waters and recommends that the public refer to the current FCA or contact the ISDH, or both with any specific questions or concerns in this respect. The current fish consumption advisory can be found online at:
http://www.in.gov/isdh/files/2010_FCA_May28.pdf
and contains more specific information than the 303(d) list does regarding the sizes and species of fish that can be safely consumed and how often.
Because IDEM uses the similar methods in determining unsafe levels of mercury and PCBs that ISDH uses in determining fish consumption advice, the concentrations of these contaminants used to determine impairment correspond closely to the meal frequency recommendations published in the FCA. However, it is important to emphasize that one cannot assume, because a particular waterbody does not appear on the 303(d) list for fish consumption that the fish in that waterbody are safe for consumption of more than one meal per week. Likewise, due to the statewide fish consumption advisory for carp, it should not be assumed that carp greater than 15" in length from waters assessed as fully supporting are safe for consumption of more than one meal per month for the general population, or at all by at-risk populations. The 303(d) list is not intended to communicate health risk information.
At present, adequate translators do not exist for applying concentrations of mercury or PCBs in fish tissue to concentrations in the water column. Toxicants may be present in fish at levels that have no ill effects on aquatic life but due to bioaccumulation may make them unsafe to eat. The concentrations shown in Table 10 apply only to fish tissue, not water. Therefore, it also should not be assumed that if a waterbody is impaired for fish consumption that mercury or PCBs, or both are present in the water column in amounts harmful to human health.
IDEM's fish consumption use assessments are required by U.S. EPA and are a translation of the narrative portion of Indiana's WQS, which states that surface waters "¼shall be free from substances in concentrations that on the basis of available scientific data are believed to be sufficient to injure, be chronically toxic to, or be carcinogenic¼to humans, animals, aquatic life or plants." (327 IAC 2-1-6 (a)(2)). In addition to resolving the issues associated with using the FCA for assessments, IDEM believes this assessment methodology is consistent with this standard, achieves consistency with the decision making criteria used in developing the FCA, and is consistent with U.S. EPA 305(b) and 303(d) policy guidance.

AQUATIC LIFE USE ASSESSMENTS

Use Support Criteria for Biological Data
Biological assessments for streams are based on the sampling and evaluation of either the fish communities or benthic aquatic macroinvertebrate communities, or both. Indices of Biotic Integrity (IBI) for fish and macroinvertebrate IBI (mIBI) assessment scores, or both, were calculated and compared to regionally calibrated models. In evaluating fish communities, streams rating as "fair" or worse are classified as nonsupporting for aquatic life uses. For benthic aquatic macroinvertebrate communities, individual sites are compared to a statewide calibration at the lowest practical level of identification for Indiana. All sites at or above background for the calibration are considered to be supporting aquatic life uses. Those sites rated as moderately or severely impaired in the calibration are considered to be nonsupporting. Waters with identified impairments to one/more biological communities are considered not supporting aquatic life use. The biological thresholds Indiana uses to make use attainment decisions are shown in Table 1-L to provide greater context for understanding the range of biological condition that is considered either fully supporting or impaired.
IDEM's aquatic life use assessments are never based solely on habitat evaluations. However, habitat evaluations are used as supporting information in conjunction with biological data to determine aquatic life use support. Such evaluations that take into consideration a variety of habitat characteristics as well as stream size help IDEM to determine the extent to which habitat conditions may be influencing the ability of biological communities to thrive. If habitat is determined to be driving a biological community impairment (IBC) and if no other pollutants that might be contributing the impairment have been identified, the IBC is not considered for inclusion on IDEM's 303(d) List of Impaired Waters (Category 5). In such cases, the waterbody is instead placed in Category 4C for the biological impairment.

Table 1-L: Biological thresholds used to determine aquatic life use support.
Biotic Index Score and Associated Assessment Decision  Integrity Class  Corresponding Integrity Class Score  Attributes 
Macroinvertebrate community data collected with artificial samplers (used in assessments prior to 2010 cycle) 
mIBI >1.8 (artificial substrate sampler) indicates full support  Excellent  6.0-8.0  NA 
Good  4.0-5.9  NA 
Fair  1.8-3.9  NA 
mIBI <1.8 (artificial substrate sampler) indicates impairment  Poor  1.0-1.7  NA 
Very Poor  0-0.9  NA 
Macroinvertebrate community data collected using KICK methods (used in assessments prior to 2010 cycle) 
mIBI >2.2 (kick methods) indicates full support  Excellent  6.0-8.0  NA 
Good  4.0-5.9  NA 
Fair  2.2-3.9  NA 
mIBI <2.2 (kick methods) indicates impairment  Poor  1.0-2.1  NA 
Very Poor  0-0.9  NA 
Macroinvertebrate community data collected using multihabitat (MHAB) methods (used in assessments for 2010 cycle) 
mIBI >36 indicates full support  Excellent  53-60  Comparable to "least impacted" conditions, exceptional assemblage of species. 
Good  45-52  Decreased species richness (intolerant species in particular), sensitive species present. 
Fair  36-44  Intolerant and sensitive species absent, skewed trophic structure. 
mIBI <36 indicates impairment  Poor  23-35  Many expected species absent or rare, tolerant species dominant. 
Very Poor  12-22  Few species and individuals present, tolerant species dominant 
No Organisms  <12  No macroinvertebrates captured during sampling. 
Fish community data 
IBI >36 indicates full support  Excellent  53-60  Comparable to "least impacted" conditions, exceptional assemblage of species. 
Good  45-52  Decreased species richness (intolerant species in particular), sensitive species present. 
Fair  36-44  Intolerant and sensitive species absent, skewed trophic structure. 
IBI <36 indicates impairment  Poor  23-35  Top carnivores and many expected species absent or rare, omnivores and tolerant species dominant. 
Very Poor  12-22  Few species and individuals present, tolerant species dominant, diseased fish frequent. 
No Organisms  <12  No fish captured during sampling. 

Revisions to IDEM's Use Support Criteria for Biological Data

IDEM's use support criteria for fish community and macroinvertebrate community data have undergone significant changes since they were first adopted in 1996. Table 1-M summarizes the evolution of IDEM's criteria for making assessments with biological data. The criteria developed for the 2004 305(b)/303(d) assessment and listing cycle are calibrated to reference conditions in Indiana and remain in effect today. However, with these changes and each change prior to that time, resulting criteria were applied only to the basins being assessed at the time. For the 2008 cycle, IDEM completed its review of all aquatic life use support assessments made prior to 2002 to identify any waterbodies that may now be considered fully supporting.
For the 2010 cycle, IDEM revised its assessment methods for evaluating macroinvertebrate data. The statewide mIBI was developed and calibrated using riffle/run samples collected throughout the state from 1990-1994. The riffle/run method was subsequently used by the OWQ from 1996 to 2003 to collect samples at some of the same sites sampled for the original calibration of the index randomly selected for follow-up sampling. Beginning in 1998, samples were also collected at probabilistic sites chosen for the Watershed Monitoring Program where a suitable riffle/run habitat was present. Unfortunately, less than half of the probabilistic sites sampled during this time had riffle/run type habitats within the allowed distance, which reduced the effectiveness of the riffle/run method as a monitoring tool. This necessitated the need to develop a macroinvertebrate sampling method that could be used at all probabilistic sites, regardless of habitat.
The new multi-habitat method (MHAB) differs primarily from the riffle/run method in that it samples all habitats available at a stream site using a D-frame net instead of the kick screen used in the riffle/run method. In 2004, 62 sites (a subset selected from all sites previously sampled with the riffle/run method between 1990 and 2003) were resampled with the new MHAB method. The idea was to develop an index calibrated, not on the best possible reference conditions, but on a normal distribution of stream conditions based on mIBI scores obtained at previously sampled sites. It was later determined that this was too few samples to develop an efficient statewide index; these samples were combined with probabilistic samples collected in 2005, 2006 and 2007 (a total of 247 samples) to develop the index currently in use.
Twelve metrics were chosen from a pool of more than 100 possible metrics in the development of the new mIBI. These 12 metrics provided the best correlation to the data and describe a diversity of features that characterize the quality of a stream or river. The scores for each individual metric are totaled and can range from 12 to 60. As with the fish community IBI, mIBI scores less than 36 are considered nonsupporting of aquatic life use while those equal to or greater than 36 are supporting of aquatic life use.
IDEM incorporated the mHAB methods into it monitoring programs in 2004 and began using the mIBI scores derived with the mHab methods beginning with the 2010-cycle assessments of aquatic life use support. At this time, IDEM is considering whether a reevaluation of waters previously assessed using the original mIBI is now in order. However, due to the differences in sampling methods used to obtain the data for the original mIBI and the new index now in place, such a reassessment may not be necessary or appropriate.

Table 1-M: Evolution of the criteria used in making aquatic life use assessments with biological data.
Cycle  Criteria Development and Changes 
1998  IDEM used Karr's 1986 Index of Biotic Integrity (IBI) Classification and Attributes Table to establish criteria to apply to fish community (IBI) data for use support assessments: 
  • IBI >44 = Fully supporting (Excellent/Good) 
  • IBI < 44 and >22 = Partially supporting (Fair/Poor) 
  • IBI < 22 = Not supporting (Very Poor/No Fish) 
IDEM's criteria for macroinvertebrate community (mIBI) data collected using kick methods: 
  • mIBI >4 = Fully supporting 
  • mIBI < 4 and >2 = Partially supporting 
  • mIBI < 2 = Not supporting 
2000  IDEM reviewed fish community data from 1990-1995 (n=831) to determine new, more accurate limits reflective of Indiana fish communities by subtracting ½ standard deviation from the statewide mean to calculate the following criteria: 
  • IBI > 34 = Fully supporting 
  • IBI < 34 and > 32 = Partially supporting 
  • IBI < 32 = Not supporting 
Criteria for macroinvertebrate community data were unchanged. 
2002  Based on IDEM's adoption of U.S. EPA's integrated reporting format, the category for partially supporting was eliminated for both fish community data and macroinvertebrate community data: 
  • IBI >32 = Fully supporting 
  • IBI < 32 = Not supporting 
Criteria for macroinvertebrate community data were unchanged. 
2004 to 2008  IDEM completes its first five-year basin monitoring rotation. After reviewing the narrative biological criteria [327 IAC 2-1-3(2)] and WQS definition [327 IAC 2-1-9(49)] of a well balanced aquatic community, IDEM determined that IBI values previously considered partially supporting are reflective of poorer conditions and should be classified as not supporting. The resulting criteria are now applied to all basins in Indiana: 
  • IBI >36 = Fully supporting 
  • IBI < 36 = Not supporting 
With a more robust set of macroinvertebrate community data, IDEM was also able to calibrate its criteria for this type of data, developing specific criteria applicable to all basins in the state. 
For samples collected with an artificial substrate sampler: 
  • mIBI >1.8 = Fully supporting 
  • mIBI < 1.8 = Not supporting 
For samples collected using kick methods: 
  • mIBI >2.2 = Fully supporting 
  • mIBI < 2.2 = Not supporting 
2010  Criteria for fish community data remain unchanged. 
IDEM developed a new mIBI using mHAB sampling methods that accounts for all habitat types available at a given site and which is applicable in all basins in the state. 
All samples are collected using a D-frame net, and mIBI scores range from 12-60: 
  • mIBI >36 = Fully supporting 
  • mIBI < 36 = Not supporting 

CONSOLIDATED LISTING METHODOLOGY

For the development of the 2010 Draft 303(d) List of Impaired Waters, IDEM has followed, to the degree possible, the 305(b) and 303(d) reporting methods outlined in the U.S. EPA's Guidance for 2006 Assessment, Listing and Reporting Requirements Pursuant to Sections 303(d), 305(b) and 314 of the Clean Water Act (U.S. EPA, 2005) and the additional guidance provided in the U.S. EPA memorandums Information Concerning 2010 Clean Water Act Sections 303(d), 305(b), and 314 Integrated Reporting and Listing Decisions (U.S. EPA, 2009). The 303(d) list was developed using IDEM's 305(b) Assessment Database (ADB). Interpretation of the data and listing decisions take into account IDEM's assessment methodologies, U.S. EPA's guidance.
Waterbody AU were classified as monitored if surface water quality data used for assessments were not more than five years old or were still considered representative of current conditions. Data from a given monitoring site are considered representative of the waterbody for that distance upstream and downstream in which there are no significant influences to the waterbody that might cause a change in water quality. Using this same rationale, data may also be extrapolated to some distance into tributaries upstream of a given sampling location. Waterbody AU with monitoring site or sites upstream and downstream and those for which reliable assessments can be made based on extrapolation of representative data are classified as monitored. Only monitored waterbodies are considered for 303(d) listing purposes. Any waters identified as "Not Supporting" of one or more designated uses in accordance with the criteria described in previous sections of this methodology are placed on Indiana's 303(d) List of Impaired Waters.
Interpretation of the data through the 305(b) assessment process and the subsequent 303(d) listing decisions are based in large part on U.S. EPA guidance. U.S. EPA's guidance calls for a comprehensive listing of all monitored or assessed waterbodies in the state. Prior to 2006, U.S. EPA required that states place each waterbody into only one category. U.S. EPA now encourages states to place waterbody AU in additional categories as appropriate in order to more clearly illustrate where progress has been made in TMDL development and other restoration efforts. Given this, IDEM places each waterbody into one of five categories of the Consolidated List depending on the degree to which it supports the designated beneficial use in question. Therefore, because IDEM makes use support assessments for three to four of the beneficial uses designated for each waterbody, a single waterbody may appear in one or more categories of the Consolidated List for different uses.

LISTING OF WATERBODY IMPAIRMENTS BY CATEGORY
Category 1  Attaining the WQS for all designated uses and no use is threatened. Waters should be listed in this category if there are data and information that meet the requirements of the state's assessment and listing methodology and support a determination that all WQS are attained and no designated use is threatened. 
Category 2  Attaining some of the designated uses; no use is threatened; and insufficient or no data and information are available to determine if the remaining uses are attained or threatened. Waters should be listed in this category if there are data and information that meet the requirements of the state's assessment and listing methodology to support a determination that some, but not all, designated uses are attained and none are threatened. 
Category 3  Insufficient data and information to determine if any designated use is attained. Little or no information is available with which to make an assessment. Waters should be listed in this category where the data or information to support an attainment determination for any designated use are not available or are not consistent with the requirements of the state's assessment and listing methodology. States should schedule monitoring on a priority basis to obtain data and information necessary to classify these waters as Category 1, Category 2, Category 4, or Category 5. 
Category 4  Impaired or threatened for one or more designated uses but does not require the development of a TMDL. 
  A. TMDL has been completed that results in attainment of all applicable WQS, and has been approved by U.S. EPA. Monitoring should be scheduled for these waters to verify that the WQS are met when the water quality management actions needed to achieve all TMDLs are implemented. 
  B. Other pollution control requirements are reasonably expected to result in the attainment of the WQS a reasonable period of time. Consistent with the regulation under 130.7(b)(i),(ii), and (iii), waters should be listed in this subcategory where other pollution control requirements required by local, state, or federal authority are stringent enough to achieve any WQS applicable to such waters. Monitoring should be scheduled for these waters to verify that the WQS are attained as expected. 
  C. Impairment is not caused by a pollutant. Waters should be listed in this subcategory if the impairment is not caused by a pollutant but is attributed to other types of pollution for which a TMDL cannot be calculated. 
Category 5  The WQS is not attained. Waters may be listed in both 5A and 5B depending on the parameters causing the impairment 
  A. The waters are impaired or threatened for one or more designated uses by a pollutant or pollutants and require a TMDL. This category constitutes the Section 303(d) list of waters impaired or threatened by a pollutant or pollutants for which one or more TMDLs are needed. Waters should be listed in this category if it is determined in accordance with the state's assessment and listing methodology that a pollutant has caused, is suspected of causing, or is projected to cause impairment. Where more than one pollutant is associated with the impairment of a single AU, the AU will remain in Category 5 until TMDLs for all pollutants have been completed and approved by U.S. EPA. 
  B. The waterbody AU are impaired due to the presence of mercury or PCBs, or both in the edible tissue of fish collected from them at levels exceeding Indiana's human health criteria for these contaminants. This category also composes a portion of the Section 303(d) list of impaired waters, but the state believes that a conventional TMDL is not the appropriate approach. The state will continue to work with the general public and U.S. EPA on actual steps needed ultimately to address these impairments. 
Because each situation is unique, resources, and data sets are sometimes limited, the 303(d) listing process may at times require IDEM staff to apply rational professional discretion. Any waterbody AU assessed differently than indicated in the water quality assessment methodology outlined above will be accompanied by written justification, so that stakeholders will understand how each decision was made.
The current 303(d) list includes impairments identified on previous 303(d) lists that still require TMDL development. For an AU to be listed, it must have been assessed using representative data, and the data must support listing. Any data, both internal or from outside sources, that is used for listing decisions must meet IDEM's quality assurance and quality control (QAQC) requirements as outlined in IDEM's surface water quality monitoring Quality Assurance Project Plan.

DELISTING OF IMPAIRMENTS
The U.S. EPA's new guidance does not change existing rules for listing and delisting. The existing regulations require states, at the request of the U.S. EPA's Regional Administrator, to demonstrate good cause for not including impairments on the 303(d) list that were included on previous 303(d) lists (pursuant to 40 CFR 130.7(b)(6)(iv)). In general IDEM will only consider delisting an AU if one of the following is true:
• New data indicate that WQS are now being met for the AU under consideration. This would typically occur during IDEM's scheduled assessments when reviewing data collected through our 5-year basin rotation.
• The assessment or listing methodology, or both, has changed and the AU under consideration would not be considered impaired under the new methodology.
• An error is discovered in the sampling, testing, or reporting of data that led to an inappropriate listing. IDEM will review previous assessments and 303(d) listings when there is there is reason to believe that the original assessment was not valid. Reassessment (review of previous assessment or 303(d) listing decisions) typically occurs as a result of ongoing QA/QC of IDEM's Assessment Database (ADB) or through inquiry by IDEM staff or external parties. Under these circumstances, the 305(b)/303(d) coordinator works with the IDEM staff initiating the question or receiving it from the external party to gather the necessary information and consult with other staff as needed to resolve the question. During reassessment, several types of information are considered, including data quality issues, past assessment methodologies, land use data, historical information from the public, etc. Regardless of the situation, no assessment is dismissed as invalid based solely on the age of the data.
• If it is determined that another program, besides the TMDL program, is better suited to address the water quality problem, or the problem is determined not to be caused by a pollutant (see Categories 4B9 and 4C above).
• A TMDL has been completed, and the waterbody AU is expected to meet WQS after implementation of the TMDL (see Category 4A above).

TMDL DEVELOPMENT AND PRIORITIZATION FOR OHIO RIVER IMPAIRMENTS
Because the Ohio River is a boundary between states and US EPA Regions, the development of and TMDL for the river will involve more than one state. To date, no TMDLs have been completed for the reaches of the Ohio River that border Indiana. However, ORSANCO is working with Ohio, West Virginia, Kentucky, Illinois, and Indiana (IDEM) to assist U.S. EPA Region 5 complete a bacteria TMDL for the entire river.

TMDL DEVELOPMENT AND PRIORITIZATION FOR ALL OTHER INDIANA WATERS
IDEM prioritizes impaired waters for TMDL development in order to meet its TMDL goals. IDEM's rotating basin water quality monitoring schedule continues to be a factor in determining where TMDL development will occur to the extent that it provides data for use in the TMDL. For example, if IDEM is monitoring in a given basin in one year, the data collected will usually be available the following year for incorporation into a TMDL. To take advantage of all available resources for TMDL development, the following additional factors are considered when determining when impairments on the 303(d) list (Category 5) will be scheduled for TMDL development:
• The quantity and age of available data – AU for which the most current and robust data available will receive greater priority than AU for which data are scarce or nonexistent.
• The nature of impairment – The three leading causes of impairment to Indiana's waters are impairments due to the presence of mercury or PCBs, or both in fish tissue, E. coli, and impaired biotic communities (IBC). To date, states have received little guidance from U.S. EPA regarding how to develop a TMDL to restore a waterbody with elevated levels of mercury or PCBs, or both in fish tissue. IDEM has placed all fish tissue impairments in a separate category of the list (5B) because it does not believe that, at this point in time, a conventional TMDL is the appropriate approach for addressing these impairments. Until adequate guidance is available, IDEM believes it to be more prudent to focus its limited resources on developing TMDLs on impairments for which appropriate methods have been established.
• Other activities occurring in the watershed that may improve water quality if given sufficient time – TMDL development for impairments to waterbody AU where other interested parties, such as local watershed groups, may be working to alleviate the water quality problem may be delayed to give these other actions time to have a positive impact on the waterbody. If WQS still are not met, then the TMDL process will be initiated.
In keeping with the need to make the best possible use of limited resources, IDEM's primary focus in the short-term is on E. coli. IDEM has established an effective method for developing E. coli TMDLs and will continue to use this method to address the second leading cause of impairment to Indiana's surface waters. IBC, which is the third leading cause of impairment of surface waters is more difficult to address because IBC are actually a symptom of other unidentified stressors in the environment that may include a combination of pollution, for which no TMDL would be required, and one or more pollutants. IDEM continues to explore different methods of source identification through its second-year studies program and has plans to complete additional TMDLs over the next two years for a number of IBC and other impairments, including nutrients, sulfates, total dissolved solids, dissolved oxygen, pH, nickel, zinc, and copper.
Waterbodies on the 303(d) list are scheduled to complete the TMDL development process within 15 years. Since the CWA does not clearly define the timeline for TMDL development, U.S. EPA, in response to the Federal Advisory Committee Act (FACA) Committee's recommendations, issued guidance for states to develop expeditious schedules of not more than eight to 15 years. 40 CFR section 130.7 also dictates that the 303(d) list specifically include the identification of waters targeted for TMDL development in the next two years. This list was submitted to U.S. EPA with Indiana's 303(d) List of Impaired Waters in October 2010.

REFERENCES CITED
Barbour, M.T., J. Gerritsen, B.D. Snyder, and J.B. Stribling. 1999. Rapid Bioassessment Protocols for Use in Streams and Wadeable Rivers: Periphyton, Benthic Macroinvertebrates and Fish, Second Edition. EPA 841-B-99-002. U.S. Environmental Protection Agency; Office of Water; Washington, D.C.
Indiana Administrative Code (IAC):
http://www.in.gov/legislative/iac/title327.html
Indiana Department of Environmental Management (IDEM). 1992. Biological Studies Section Standard Operating Procedures. Office of Water Management, Assessment Branch, Biological Studies Section. Indianapolis, IN.
Indiana Department of Environmental Management (IDEM). 2004. Quality Assurance Project Plan for Indiana Surface Water Quality Monitoring and Total Maximum Daily Load (TMDL) Program. Office of Water Management, Assessment Branch, Environmental Toxicology and Chemistry Section. Indianapolis, IN.
Indiana Department of Environmental Management (IDEM). 2005. Indiana Water Quality Monitoring Strategy (draft). Office of Water Management, Assessment Branch. Indianapolis, IN. B-001-OWQ-A-00-06-0-R3.
Indiana Department of Environmental Management (IDEM). 2005. Indiana Water Quality Monitoring Strategy (draft). Office of Water Management, Assessment Branch. Indianapolis, IN. B-001-OWQ-A-00-06-0-R3.
Karr, J.R.; K.D. Fausch; P.L. Angermeier; P.R. Yant; and I.J. Schlosser 1986. Assessing Biological Integrity in Running Waters: A method and its rationale. Special publication 5. Illinois Natural History Survey, Champaign, IL.
LTI. 2007. Spatial Data Analysis for Developing Lake Nutrient Standards: Draft Report to Indiana Department of Environmental Management. Ann Arbor, Michigan: LTI Incorporated.
Sheaffer, A.L., O'Leary, J.T., Williams, R.L. and Mason, D.M. 1999. Consumption of Indiana sport caught fish: Mail survey of resident license holders. Purdue University: West Lafayette, Indiana. Technical Report 99-D-HDFW-1.
Omernik, J.M. and A.L. Gallant. 1988. Ecoregions of the Upper Midwest States. Environmental Research Laboratory. Corvallis, Oregon. EPA-600-3-88-037.
Ohio River Valley Sanitation Commission. 2006. Ohio River Valley Sanitation Commission Pollution Control Standards for discharges to the Ohio River, 2006 Revision. Cincinnati, Ohio: Ohio River Valley Sanitation Commission.
Plafkin, J.L., M.T. Barbour, K.D. Porter, S.K. Gross, and R.M. Hughes. 1989. Rapid bioassessment protocols for use in streams and rivers: Benthic macroinvertebrates and fish. U.S. Environmental Protection Agency, Office of Water Regulations and Standards, Washington, D.C. EPA 440-4-89-001.
Soranno, P. A. and K. Spence Chervuli, et al. Michigan State University, Department of Fisheries and Wildlife. Personal communication to LTI Inc.
U. S. Environmental Protection Agency. 1986. Ambient Water Quality Criteria for Bacteria. Washington, D.C.: U. S. Environmental Protection Agency. EPA440/5-84-002.
U. S. Environmental Protection Agency. 1997a. Guidelines for Preparation of the State Water Quality Assessments (305[b] Reports) and Electronic Updates: Report Contents. Washington, D.C.: U. S. Environmental Protection Agency. EPA-841-B-97-002A.
U. S. Environmental Protection Agency. 1997b. Guidelines for Preparation of the State Water Quality Assessments (305[b] Reports) and Electronic Updates: Supplement. Washington, D.C.: U. S. Environmental Protection Agency. EPA-841-B-97-002B.
U.S. Environmental Protection Agency. 2000a. Office of Water Memorandum: Guidance to Promote Consistency in the Use of Fish and Shellfish Tissue Data by States, Territories, Authorized Tribes and EPA Regional Offices in Clean Water Act Section 303(d) Decision-making. Office of Water. WQSP-00-03.
U.S. Environmental Protection Agency. 2000b. Methodology for Deriving Ambient Water Quality Criteria for the Protection of Human Health. Office of Water. EPA-822-B-00-004.
U.S. Environmental Protection Agency. 2000c. Nutrient Criteria Technical Guidance Manual: Lakes and Reservoirs, First Edition. Office of Water. EPA-822-B00-001.
U.S. Environmental Protection Agency. 2001. Water Quality Criterion for the Protection of Human Health: Methylmercury. Office of Water. EPA-823-R-01-001.
U. S. Environmental Protection Agency. 2001. 2002 Integrated Water Quality Monitoring and Assessment Report Guidance. November 19, 2001 Memorandum from U.S. EPA Office of Wetlands, Oceans and Watershed to U.S. EPA Regional Water Management Directors, Regional Science and Technology Directors, and State, Territory and Authorized Tribal Water Quality Program Directors.
U. S. Environmental Protection Agency. 2005. Guidance for 2006 Assessment, Listing and Reporting Requirements Pursuant to Sections 303(d), 305(b) and 314 of the Clean Water Act: Public Review Draft. Washington, D.C.: U.S. Environmental Protection Agency.
U. S. Environmental Protection Agency. 2006. Memorandum to Regions 1-10 Water Division Directors Regarding Information Concerning 2008 Clean Water Act Sections 303(d), 305(b), and 314 Integrated Reporting and Listing Decisions. Washington, D.C.: U.S. Environmental Protection Agency.
U. S. Environmental Protection Agency. 2009. Memorandum to Regions 1-10 Water Division Directors Regarding Information Concerning 2010 Clean Water Act Sections 303(d), 305(b), and 314 Integrated Reporting and Listing Decisions. Washington, D.C.: U.S. Environmental Protection Agency.
Williams, R. L., O'Leary, J.T., Sheaffer, A.L., and Mason, D.M. 2000. An Examination of Fish Consumption by Indiana Recreational Anglers: An On-site Survey. Purdue University: West Lafayette, Indiana. Technical Report 99-D-HDFW-2.

CONTACT INFORMATION
Marylou Poppa Renshaw
Chief – Watershed Assessment and Planning Branch
Indiana Department of Environmental Management
100 North Senate Avenue
MC65-44 SHADELAND
Indianapolis, IN 46204-2251
(317) 308-3235; or toll free (800) 451-6027
mrenshaw@idem.in.gov

Jody Arthur
Technical Environmental Specialist
Watershed Assessment and Planning Branch
Indiana Department of Environmental Management
100 North Senate Avenue
MC65-44 SHADELAND
Indianapolis, IN 46204-2251
(317) 308-3179; or toll free (800) 451-6027
jarthur@idem.in.gov

COMPARISONS OF WATER QUALITY CRITERIA CONTAINED IN INDIANA'S WATER QUALITY STANDARDS AND ORSANCO'S POLLUTION CONTROL STANDARDS AND OTHER CRITERIA FOR MAKING DESIGNATED USE ASSESSMENTS OF THE OHIO RIVER.

Table 1-N: Comparison of criteria used to determine recreational use support.
Indicator  Type of Criterion  ORSANCO's RECR Criterion  Indiana's RECR Criterion  Most Stringent Criterion[1] 
E. coli  Geometric Mean  Applicable May-October (Recreational Season); May not exceed 130 cfu/100 mL based on no less than five samples per month  Applicable April-October (Recreational Season); May not exceed 125 cfu/100 mL based on no less than five equally spaced samples over a 30-day period. Must apply the single sample maximum criteria if five equally spaced samples are not available for the calculation of a geometric mean.  Indiana 
E. coli  Single Sample Maximum  Applicable May-October (Recreational Season); May not exceed 240 cfu/100 mL in any sample  Applicable April-October (Recreational Season); May not exceed 235 cfu/100 mL in any one sample in a thirty day period EXCEPT in cases where there are at least ten samples at a given site, up to 10% may exceed the single sample maximum IF E. coli exceedances are incidental and attributable solely to E. coli resulting from the discharge of treated wastewater from a wastewater treatment plan as defined in Indiana Code AND the geometric mean criteria are met.  Indiana 
[1]Although Indiana's E. coli numeric criteria are slightly more stringent than ORSANCO's, unlike Indiana's WQS, ORSANCO's criteria do not allow exceptions. ORSANCO's assessment methodology also incorporates analysis of single sample results, which provides a more robust assessment than Indiana's combined criteria and assessment methodology can. Indiana therefore defers to ORSANCO's assessments of recreational use support for the Ohio River. ORSANCO conducts bacterial sampling from May to October, one month shorter than the recreational season defined in Indiana's WQS. Given this, data are not available for Indiana's full recreational season. 

Table 1-O: Comparison of criteria used to determine fish consumption use support.
Indicator  Type/Source of Criterion  ORSANCO Criterion  Indiana Criterion  Most Stringent Criterion 
Methylmercury in Fish Tissue (ug/L)  Human Health Criterion for Methylmercury (U.S. EPA, 2001)  0.3  0.3  Equally Stringent 
Total Mercury in Water (ug/L)  Aquatic Life CAC (4-day average) Outside the Mixing Zone (Indiana); Not to exceed (ORSANCO)  0.012  0.012  Equally Stringent 
Dioxin (2, 3, 7, 8-TCDD) in Water (ug/L)  CCC Human Health (30-day average) Outside the Mixing Zone (Indiana); CWA Section 304(a) Human Health Criterion for Priority Pollutants (ORSANCO)  0.000000005  0.0000001  ORSANCO 
Polychlorinated Biphenyls (PCBs) in Water (ug/L)[1]  CCC Human Health (30-day average) Outside the Mixing Zone (Indiana)/Aquatic Life CAC (4-day average) Outside the Mixing Zone; CWA Section 304(a) Human Health Criterion for Priority Pollutants (ORSANCO)  0.000064[2]  0.00079  ORSANCO 
[1] Indiana has two criteria for PCBs that could be used to make fish consumption use assessments because they both address different ways of preventing exposure through consumption of fish, one by preventing bioaccumulation of the contaminant in the fish and the other to protect against exposure through the consumption of contaminated fish. The criterion shown in the table is the CCC Human Health criterion for waters outside the mixing zone. Human health criteria are calculated for and intended to protect from exposure through public drinking water supplies withdrawn from surface waters and nondrinking water exposures such as consumption of fish. Therefore, the human health criteria (both ORSANCO's and Indiana's are appropriate for use in fish consumption assessments. The Aquatic Life CAC of 0.014 ug/L for PCBs could be used in a similar manner as the Aquatic Life CAC for total mercury to prevent bioaccumulation of PCBs in fish. However, the Human Health CCC for PCBs is far more protective and is used instead to make fishable use assessments for the Ohio River. The opposite is true for total mercury, which is why the Aquatic Life CAC of 0.012 ug/L is used instead of the Human Health CCC of 0.15 ug/L. 
[2] This criterion applies to total PCBs (e.g. the sum of all congener or all isomer or homolog or Arochlor analyses). 

Table 1-P: Comparison of metals criteria used to determine aquatic life use support.
Metal  Fraction  Acute or Chronic  ORSANCO's Criterion Concentration (ug/L)  ORSANCO's Dissolved Criterion Conversion Factors  Indiana's Criterion Concentration (ug/L)  Indiana's Dissolved Criterion Conversion Factors  Most Stringent Criterion 
Cyanide[1]  Free  Chronic  5.2  NA  5.2  NA  Equally stringent 
Mercury[1]  Dissolved (ORSANCO); Total Recoverable (Indiana)  Chronic  0.91  0.85 (dissolved)  0.012 (total recoverable)  NA  Indiana 
Arsenic[1]  Dissolved[2]  Chronic  150  -190  ORSANCO 
Cadmium  Dissolved[2]  Chronic  e(0.7409(ln hardness)-4.719)  1.101672 - [ln(hardness) * 0.041838]  e(0.7852[ln (hardness)]-3.490)  1.101672 -[(ln(hardness) (0.041838)]  ORSANCO 
Chromium III  Dissolved[2]  Chronic  e(0.819(ln hardness)+0.6848)  0.86  e(0.8190[ln (hardness)]+1.561)  0.86  ORSANCO 
Copper  Dissolved[2]  Chronic  e(0.8545(ln hardness)-1.702)  0.962  e(0.8545[ln (hardness)]-1.465)  0.96  ORSANCO 
Lead  Dissolved[2]  Chronic  e(1.273(ln hardness)-4.705)  1.46203 - [ln(hardness) * 0.145712]  e(1.273[ln (hardness)]-4.705)  1.46203 –[(ln hardness) (0.145712)]  Equally stringent 
Nickel  Dissolved[2]  Chronic  e(0.846(ln hardness)+0.0584)  0.997  e(0.846[ln (hardness)]+1.1645)  0.997  ORSANCO 
Zinc  Dissolved[2]  Chronic  e(0.8473(ln hardness)+0.884)  0.986  e(0.8473[ln (hardness)]+0.7614)  0.986  Indiana 
[1] This criterion is expressed in ORSANCO's Pollution Control Standards as "Not to Exceed" and in Indiana's WQS as a 4-day average. 
[2] Unless otherwise shown, dissolved metals criteria are calculated as the total recoverable criterion multiplied by the dissolved criterion conversion factor. Assessments are made by comparing dissolved results against the established or calculated criterion. 

Table 1-Q: Comparison of sulfate and cyanide criteria used to determine aquatic life use support.
Indicator  Type of Criterion  ORSANCO's ALUS Criterion  Indiana's ALUS Criterion  Most Stringent Criterion 
Cyanide[1] (ug/L)  Chronic  5.2  5.2  Equally stringent 
Chloride[2] mg/L)  Chronic  No criterion  230  Indiana 
Sulfate[3] (mg/L): Hardness (mg/L as CaCO3) > or = 100 mg/L but < or = 500 mg/L AND Chloride (mg/L) > or = 5 mg/L but < 25 mg/L  Not to Exceed  No criterion  [-7.478+(5.79*hardness) + (54.163*chloride)] * 0.65  Indiana 
Sulfate[3] (mg/L): Hardness (mg/L as CaCO3) > or = 100 mg/L but < or = 500 mg/L AND Chloride (mg/L) > or = 25 mg/L but < or = 500 mg/L  Not to Exceed  No criterion  [1.276+(5.508*hardness) - (1.457*chloride)] * 0.65  Indiana 
Sulfate[3] (mg/L): Hardness (mg/L as CaCO3) < 100 mg/L AND Chloride (mg/L) < or = 500 mg/L  Not to Exceed  No criterion  500  Indiana 
Sulfate[3] (mg/L): Hardness (mg/L as CaCO3) > 500 mg/L AND Chloride (mg/L) > or = 5 mg/L but < 25 mg/L  Not to Exceed  No criterion  [57.478+(5.79*500) + (54.163*chloride)] * 0.65  Indiana 
Sulfate[3] (mg/L): Hardness (mg/L as CaCO3) > 500 mg/L AND Chloride (mg/L) > or = 25 mg/L but < or = 500 mg/L  Not to Exceed  No criterion  [1.276+(5.508*500) - (1.457*chloride)] * 0.65  Indiana 
[1] This criterion is expressed in ORSANCO's Pollution Control Standards as "Not to Exceed" and in Indiana's WQS as a 4-day average. 
[2] ORSANCO's Pollution Control Standards do not contain a chloride criterion for the protection of aquatic life. Therefore, IDEM uses the data collected by ORSANCO for the purposes of making its aquatic life use assessments for the Ohio River. 
[3] Indiana's criterion for sulfate is a calculated criterion that requires both pH and hardness values and is rounded to nearest whole number for the purposes of assessment. ORSANCO's Pollution Control Standards do not contain a sulfate criterion for the protection of aquatic life. Therefore, IDEM uses the data collected by ORSANCO to calculate the applicable criteria for the purposes of making its aquatic life use assessments for the Ohio River. 

Table 1-R: Comparison of ammonia, dissolved oxygen, pH and temperature criteria used to determine aquatic life use support.
Indicator  Type of Criterion  ORSANCO's ALUS Criterion  Indiana's ALUS Criterion  Most Stringent Criterion 
Ammonia (mg/L) applicable March 1 to October 31  Not to Exceed  [((0.0577/(1+10(7.688-pH)))) + (2.487/(1-10(pH-7.688)))] * Minimum of (2.85 or (1.45*100.028*(25-T)))  [((0.0577/(1+10(7.688-pH)))) + (2.487/(1-10(pH-7.688)))] * (1.45*100.028*(25-(MAX [T OR 7])) Equally stringent 
Where: T = Temperature, °C  Where: T = Temperature, °C 
Note:  For the  above equation,  multiply the   parenthetical   equation by 2.85 when  T < or = 14.51°C. When  T > 14.51°C, multiply the  parenthetical equation by (1.45 * 10(0.028*(25-T)).  Note:  For the above  equation,   the last  term  should be 10(0.028*(25-T)) for  all  T > 7°C. When T = 7°C or less,   the last  term in   the equation  should  be   10(0.028*(25-7)) or 10(0.504) 
Ammonia (mg/L) applicable November 1 to last day of February  Not to Exceed  [((0.0577/(1+10(7.688-pH)))) + (2.487/(1-10(pH-7.688)))] * (1.45*100.028 * (25-(MAX [T OR 7])) Same criteria year round  Equally stringent 
Where: T = Temperature, °C 
Note: For the above equation, the last term should be 10(0.028*(25-T)) for all T > 7°C. When T = 7°C or less, the last term in the equation should be 10(0.028*(25-7)) or 10(0.504) 
Dissolved Oxygen (mg/L) applicable April 15 to June 15  Not to Exceed  Minimum concentration at least 5 at all times  Avg concentration at least 5.0 per calendar day; minimum concentration not < 4 at any time  ORSANCO 
Dissolved Oxygen (mg/L) applicable June 16 to April 14  Not to Exceed  Avg concentration at least 5.0 per calendar day; minimum concentration not <4  Avg concentration at least 5.0 per calendar day; minimum concentration not <4 at any time  Equally stringent 
pH (standard units)  Not to Exceed  Avg concentration at least 5.0 for each calendar day; minimum concentration not <4 at any time  No value <6.0 nor >9.0  ORSANCO 
Temperature (expressed in degrees C and F)  Not to exceed  Allowable values expressed as Period Averages and Maximum Temperatures  Allowable values expressed as Maximum Temperatures  ORSANCO[4] 
[4] Both ORSANCO's Pollution Control Standards and Indiana's WQS articulate maximum allowable temperatures. ORSANCO's standards also include allowable period average temperatures that are more stringent than the maximum allowable temperatures in either set of standards. 

DERIVATION OF CRITERIA VALUES FOR CONCENTRATIONS OF MERCURY AND PCBS IN FISH TISSUE

U.S. EPA stipulates that the risk assessment parameters used to categorize fish tissue contaminant data must be at least as protective as those used in the WQS-based fish concentrations. The equation for calculating a fish tissue criterion for PCBs utilizes the guidance provided by U.S. EPA for calculating screening values for target analytes (http://www.epa.gov/waterscience/fishadvice/volume1/v1ch5.pdf). EPA's Office of Water recommends the use of this calculation method because it is the basis for developing current water quality criteria for the protection of human health. The general equation used for calculating Screening Values (SVs) for carcinogens in fish tissue is derived from this guidance and is as follows:
SVc = [(RL / CSF) • BW] / CR  Equation 1 
where:     
SVc  Screening value for a carcinogen (mg/kg; ppm) 
RL  Maximum acceptable risk level (dimensionless) 
CSF  Oral cancer slope factor (mg/kg-d)-1 
BW  Mean body weight of the general population (kg) 
CR  Mean daily consumption rate of species of interest (kg/d) 

In determining a screening value or fish tissue criterion for PCBs, the same assumptions and parameters used for calculating human health water quality criteria were applied. These parameters include a BW of 70 kg, CSF (of 2.0 (mg/kg-d)-1, RL of 10-5, and CR of 17.5 (g/d).
The general equation for calculating a fish tissue screening value for PCBs is:
318120053ONA07.jpg  Equation 2 
Therefore, 
Cancer risk level (the RL value from equation 1) = 10-5 
q1 (the CSF from equation 1) = of 2.0 (mg/kg-d)-1 
BW (same in both equations) = 70 kg 
Fish Consumption (CR in equation 1) = 17.5 (g/d) or 0.0175 (kg/d) 
318120053ONA08.jpg 
A tissue-based criterion eliminates the need for a bioaccumulation factor in the criterion calculation while PCB exposure from drinking water is negligible (http://www.great-lakes.net/humanhealth/lake/superior.html).

Attachment 2
Assessment Unit IDs Retired as a Result of Segmentation
ASSESSMENT UNIT IDS RETIRED 
INB0112_00  INB0161_T1026  INB01B1_T1034  INB01G3_T1003  INB0214_03  INB0221_T1013 
INB0113_00  INB0162_00  INB01B2_00  INB01G3_T1004  INB0214_T1001  INB0221_T1014 
INB0141_00  INB0162_T1001  INB01B3_00  INB01G3_T1005  INB0214_T1002  INB0222_01 
INB0141_T1023  INB0162_T1002  INB01B4_T1028  INB01G3_T1006  INB0214_T1003  INB0222_02 
INB0142_00  INB0162_T1003  INB01C1_00  INB01G4_M1020  INB0214_T1004  INB0222_T1001 
INB0153_00  INB0162_T1004  INB01C3_00  INB01H1_00  INB0214_T1005  INB0222_T1002 
INB0153_T1001  INB0162_T1006  INB01C4_00  INB01H2_00  INB0214_T1006  INB0222_T1003 
INB0153_T1005  INB0162_T1007  INB01C4_T1031  INB01H3_00  INB0214_T1007  INB0222_T1004 
INB0155_00  INB0163_00  INB01C5_00  INB01H4_00  INB0214_T1008  INB0222_T1005 
INB0155_01  INB0164_00  INB01D3_00  INB01H5_00  INB0214_T1009  INB0222_T1006 
INB0155_02  INB0164_T1001  INB01D4_00  INB01H6_00  INB0214_T1011  INB0222_T1007 
INB0155_T1001  INB0165_00  INB01E1_00  INB01H7_00  INB0216_00  INB0222_T1008 
INB0155_T1002  INB0166_00  INB01E1_M1010  INB01H8_00  INB0218_01  INB0223_00 
INB0155_T1003  INB0171_00  INB01E3_00  INB01H9_00  INB0218_T1001  INB0224_00 
INB0155_T1004  INB0171_T1002  INB01E3_M1011  INB01HA_00  INB0218_T1002  INB0231_00 
INB0155_T1005  INB0172_00  INB01E3_M1029  INB01HB_T1030  INB0218_T1003  INB0232_00 
INB0155_T1006  INB0172_T1003  INB01F1_M1012  INB01HD_00  INB0218_T1004  INB0233_00 
INB0155_T1007  INB0173_00  INB01F2_M1013  INB01HD_T1001  INB0218_T1005  INB0233_T1001 
INB0155_T1008  INB0173_T1004  INB01F3_00  INB01HD_T1002  INB0218_T1006  INB0234_00 
INB0155_T1009  INB0174_00  INB01F4_00  INB01J2_M1021  INB0218_T1007  INB0234_T1003 
INB0155_T1010  INB0174_T1005  INB01F5_M1014  INB01J4_M1022  INB0219_00  INB0235_00 
INB0155_T1011  INB0175_T1006  INB01F6_00  INB0213_00  INB0221_01  INB0236_00 
INB0155_T1012  INB0176_00  INB01F7_00  INB0213_01  INB0221_02  INB0237_00 
INB0156_00  INB0176_T1007  INB01F8_M1015  INB0213_T1001  INB0221_03  INB0238_01 
INB0156_01  INB0181_00  INB01F9_00  INB0213_T1002  INB0221_T1001  INB0238_02 
INB0156_02  INB0184_00  INB01F9_M1016  INB0213_T1003  INB0221_T1002  INB0238_T1001 
INB0156_T1002  INB0186_00  INB01FA_M1017  INB0213_T1004  INB0221_T1003  INB0238_T1002 
INB0156_T1003  INB0187_00  INB01G1_M1018  INB0213_T1005  INB0221_T1004  INB0238_T1003 
INB0156_T1004  INB0187_T1001  INB01G2_00  INB0213_T1006  INB0221_T1005  INB0238_T1004 
INB0156_T1005  INB0192_T1009  INB01G2_01  INB0213_T1007  INB0221_T1006  INB0238_T1005 
INB0156_T1007  INB01A1_00  INB01G2_T1001  INB0213_T1008  INB0221_T1007  INB0239_00 
INB0156_T1008  INB01A6_00  INB01G2_T1002  INB0213_T1009  INB0221_T1008  INB0241_01 
INB0156_T1009  INB01A6_T1025  INB01G3_00  INB0213_T1010  INB0221_T1009  INB0241_02 
INB0156_T1010  INB01A6_T1026  INB01G3_M1019  INB0214_00  INB0221_T1010  INB0241_T1001 
INB0161_00  INB01A6_T1027  INB01G3_T1001  INB0214_01  INB0221_T1011  INB0241_T1002 
INB0161_T1025  INB01B1_00  INB01G3_T1002  INB0214_02  INB0221_T1012  INB0241_T1003 
INB0241_T1004  INB0316_T1005  INB035D_00  INB0414_02  INB0424_T1027  INB0434_T1007 
INB0241_T1005  INB0317_00  INB035D_T1019  INB0414_T1000  INB0431_00  INB0435_00 
INB0241_T1006  INB0317_T1006  INB0361_00  INB0414_T1001  INB0431_01  INB0435_01 
INB0241_T1007  INB0321_00  INB0361_T1020  INB0414_T1002  INB0431_02  INB0435_T1001 
INB0241_T1009  INB0321_T1007  INB0363_00  INB0415_00  INB0431_T1000  INB0435_T1002 
INB0241_T1010  INB0322_00  INB0364_00  INB0415_T1001  INB0431_T1001  INB0435_T1003 
INB0241_T1011  INB0333_00  INB0365_00  INB0415_T1002  INB0431_T1002  INB0436_00 
INB0241_T1012  INB0334_T1013  INB0366_00  INB0415_T1003  INB0431_T1003  INB0436_01 
INB0241_T1013  INB0335_00  INB0369_P1022  INB0421_00  INB0432_03  INB0436_T1001 
INB0242_00  INB0335_T1014  INB036A_00  INB0422_00  INB0432_04  INB0436_T1002 
INB0242_01  INB0341_00  INB036A_T1001  INB0422_01  INB0432_05  INB0437_00 
INB0242_T1001  INB0342_00  INB036A_T1002  INB0422_P1001  INB0432_T1001  INB0437_T1001 
INB0242_T1002  INB0343_00  INB0411_00  INB0422_T1022  INB0432_T1002  INB0437_T1002 
INB0242_T1003  INB0344_00  INB0411_01  INB0422_T1023  INB0432_T1004  INB0437_T1003 
INB0242_T1004  INB0344_T1001  INB0411_02  INB0422_T1024  INB0433_00  INB0437_T1004 
INB0242_T1005  INB0345_00  INB0411_T1001  INB0422_T1025  INB0433_01  INB0437_T1005 
INB0242_T1006  INB0351_00  INB0411_T1002  INB0422_T1026  INB0433_02  INB0441_00 
INB0242_T1007  INB0351_T1015  INB0412_00  INB0423_00  INB0433_P1001  INB0441_T1006 
INB0242_T1008  INB0352_T1001  INB0412_01  INB0423_T1001  INB0433_P1003  INB0442_00 
INB0242_T1009  INB0352_T1016  INB0412_02  INB0423_T1002  INB0433_T1001  INB0442_T1007 
INB0242_T1010  INB0353_00  INB0412_03  INB0423_T1003  INB0433_T1002  INB0442_T1026 
INB0243_00  INB0354_T1017  INB0412_T1000  INB0423_T1004  INB0433_T1003  INB0443_00 
INB0244_00  INB0354_T1018  INB0412_T1001  INB0423_T1005  INB0433_T1006  INB0443_T1008 
INB0248_00  INB0355_00  INB0412_T1002  INB0423_T1006  INB0433_T1007  INB0444_00 
INB0248_T1001  INB0356_00  INB0412_T1003  INB0423_T1007  INB0433_T1008  INB0444_T1009 
INB0248_T1002  INB0356_T1001  INB0412_T1004  INB0423_T1008  INB0433_T1009  INB0445_00 
INB0311_00  INB0356_T1002  INB0412_T1005  INB0423_T1009  INB0434_00  INB0445_T1010 
INB0311_T1001  INB0357_00  INB0413_T1001  INB0424_02  INB0434_01  INB0446_00 
INB0312_00  INB0357_01  INB0413_T1002  INB0424_03  INB0434_02  INB0447_00 
INB0312_T1002  INB0357_T1001  INB0413_T1003  INB0424_T1020  INB0434_03  INB0447_T1011 
INB0313_00  INB0358_00  INB0413_T1004  INB0424_T1021  INB0434_T1001  INB0448_00 
INB0313_T1003  INB0359_00  INB0413_T1005  INB0424_T1022  INB0434_T1002  INB0448_T1012 
INB0314_01  INB035A_00  INB0413_T1006  INB0424_T1023  INB0434_T1003  INB0451_00 
INB0315_00  INB035A_T1018  INB0413_T1007  INB0424_T1024  INB0434_T1004  INB0451_T1013 
INB0315_T1004  INB035B_00  INB0414_00  INB0424_T1025  INB0434_T1005  INB0452_00 
INB0316_00  INB035C_00  INB0414_01  INB0424_T1026  INB0434_T1006  INB0453_00 
INB0453_T1014  INB0514_01  INB0532_T1005  INB0561_M1010  INB0617_P1050  INB0636_00 
INB0454_00  INB0514_T1001  INB0533_00  INB0562_00  INB0617_P1058  INB0636_P1076 
INB0455_00  INB0514_T1002  INB0533_M1004  INB0562_M1011  INB0617_P1066  INB0636_T1001 
INB0456_00  INB0514_T1003  INB0534_00  INB0571_00  INB0617_T1036  INB0636_T1002 
INB0457_00  INB0514_T1004  INB0534_M1005  INB0572_00  INB0618_00  INB0637_00 
INB0457_T1015  INB0514_T1005  INB0541_00  INB0572_T1001  INB0618_P1002  INB0638_00 
INB0458_00  INB0514_T1006  INB0542_00  INB0572_T1002  INB0618_P1056  INB0638_T1012 
INB0459_00  INB0521_00  INB0543_00  INB0572_T1003  INB0621_00  INB0641_00 
INB045A_00  INB0521_M1002  INB0544_00  INB0573_00  INB0621_T1004  INB0641_T1013 
INB0461_T1001  INB0521_T1013  INB0545_00  INB0573_M1012  INB0622_00  INB0642_00 
INB0461_T1016  INB0522_00  INB0551_00  INB0611_00  INB0623_00  INB0643_01 
INB0462_00  INB0522_T1001  INB0552_00  INB0611_P1001  INB0623_P1070  INB0644_00 
INB0462_T1017  INB0522_T1002  INB0553_T1005  INB0611_P1060  INB0623_P1071  INB0644_T1041 
INB0463_00  INB0522_T1003  INB0553_T1006  INB0611_T1002  INB0623_T1038  INB0645_00 
INB0464_00  INB0522_T1004  INB0553_T1013  INB0611_T1003  INB0624_00  INB0645_P1078 
INB0464_T1018  INB0522_T1005  INB0553_T1014  INB0611_T1005  INB0624_P1005  INB0645_P1079 
INB0471_T1019  INB0522_T1006  INB0553_T1015  INB0611_T1006  INB0624_T1006  INB0645_P1080 
INB0472_00  INB0522_T1007  INB0553_T1016  INB0612_00  INB0625_00  INB0645_P1081 
INB0473_00  INB0523_00  INB0553_T1017  INB0612_P1060  INB0625_P1045  INB0645_P1083 
INB0474_00  INB0524_00  INB0554_00  INB0612_P1061  INB0626_00  INB0646_00 
INB0474_01  INB0525_00  INB0555_00  INB0612_P1062  INB0626_P1007  INB0647_00 
INB0474_T1001  INB0526_00  INB0556_00  INB0613_00  INB0626_T1039  INB0648_00 
INB0474_T1002  INB0526_T1001  INB0556_T1016  INB0613_01  INB0627_00  INB0648_T1014 
INB0474_T1003  INB0526_T1002  INB0557_00  INB0613_P1054  INB0628_00  INB0649_00 
INB0475_00  INB0526_T1003  INB0557_T1001  INB0613_P1068  INB0628_01  INB0649_T1015 
INB0475_T1020  INB0526_T1004  INB0557_T1002  INB0613_T1001  INB0628_P1008  INB064A_00 
INB0476_00  INB0526_T1005  INB0558_T1007  INB0613_T1005  INB0628_T1003  INB064B_00 
INB0476_T1021  INB0526_T1006  INB0558_T1009  INB0614_00  INB0628_T1004  INB064B_T1043 
INB0476_T1028  INB0526_T1007  INB0559_00  INB0614_P1034  INB0631_00  INB064C_00 
INB0477_T1022  INB0531_00  INB055A_00  INB0614_T1001  INB0631_T1009  INB0651_00 
INB0477_T1023  INB0532_01  INB055B_00  INB0614_T1004  INB0632_00  INB0652_00 
INB0511_00  INB0532_M1003  INB055B_T1008  INB0615_00  INB0632_T1010  INB0653_00 
INB0511_M1001  INB0532_T1001  INB055B_T1017  INB0616_00  INB0633_00  INB0653_T1017 
INB0512_00  INB0532_T1002  INB055C_00  INB0616_P1064  INB0634_00  INB0653_T1044 
INB0513_00  INB0532_T1003  INB055C_T1009  INB0616_P1065  INB0634_P1077  INB0654_00 
INB0514_00  INB0532_T1004  INB0561_00  INB0617_00  INB0635_00  INB0655_00 
INB0655_P1085  INB0671_T1001  INB0691_00  INB06BD_T1002  INB0814_M1002  INB0835_T1003 
INB0655_P1086  INB0671_T1002  INB0692_00  INB06BD_T1003  INB0814_T1001  INB0836_00 
INB0656_00  INB0671_T1003  INB0692_T1001  INB06BD_T1006  INB0814_T1002  INB0836_T1057 
INB0657_00  INB0671_T1004  INB0692_T1002  INB06BD_T1007  INB0814_T1003  INB0837_00 
INB0657_01  INB0671_T1005  INB0693_00  INB06C2_00  INB0821_00  INB0838_00 
INB0657_T1003  INB0671_T1006  INB0694_00  INB06C3_00  INB0822_00  INB0839_00 
INB0657_T1004  INB0672_00  INB0695_00  INB06C4_00  INB0823_00  INB0839_M1006 
INB0657_T1005  INB0672_T1001  INB0696_00  INB06C6_00  INB0823_T1044  INB083A_00 
INB0657_T1006  INB0672_T1002  INB0697_00  INB06C7_00  INB0824_00  INB083B_00 
INB0657_T1007  INB0672_T1003  INB06A1_00  INB06C8_00  INB0825_00  INB083B_M1007 
INB0657_T1008  INB0672_T1004  INB06A2_02  INB06C9_00  INB0826_00  INB0842_01 
INB0657_T1009  INB0672_T1005  INB06A2_M1095  INB06CA_00  INB0826_T1045  INB0842_T1001 
INB0658_00  INB0672_T1006  INB06A2_T1002  INB06D1_00  INB0827_T1013  INB0842_T1002A 
INB0659_00  INB0673_00  INB06A3_00  INB06D1_T1005  INB0828_00  INB0842_T1002B 
INB065A_T1002  INB0673_01  INB06B1_00  INB06D1_T1006  INB0828-00  INB0843_00 
INB065A_T1003  INB0673_T1001  INB06B2_00  INB06D2_00  INB0829_00  INB0844_01 
INB065B_00  INB0673_T1002  INB06B3_00  INB06E1_00  INB0829_T1039  INB0845_01 
INB065C_00  INB0673_T1003  INB06B4_00  INB06E2_00  INB0831_00  INB0845_T1001 
INB0661_00  INB0673_T1004  INB06B5_00  INB06E2_M1093  INB0831_M1003  INB0845_T1001A 
INB0662_00  INB0673_T1005  INB06B6_00  INB06F1_00  INB0832_00  INB0845_T1002 
INB0662_T1020  INB0673_T1006  INB06B7_00  INB06F2_00  INB0833_00  INB0846_01 
INB0663_00  INB0674_00  INB06B8_00  INB06F3_00  INB0833_M1004  INB0846_T1001 
INB0663_T1021  INB0675_00  INB06B9_00  INB06F4_00  INB0834_00  INB0847_01 
INB0664_00  INB0675_T1001  INB06BA_00  INB06F4_T1001  INB0834_01  INB0847_T1001 
INB0665_00  INB0675_T1002  INB06BA_T1001  INB06F4_T1003  INB0834_T1001  INB0847_T1002 
INB0666_00  INB0675_T1003  INB06BA_T1002  INB06F5_M1094  INB0834_T1002  INB0847_T1003 
INB0666_T1022  INB0675_T1004  INB06BA_T1003  INB06F6_00  INB0834_T1003  INB0847_T1003A 
INB0667_00  INB0681_00  INB06BB_00  INB06F6_02  INB0834_T1004  INB0847_T1003B 
INB0667_T1023  INB0682_00  INB06BB_T1001  INB06F7_00  INB0834_T1005  INB0847_T1003C 
INB0668_00  INB0682_M1026  INB06BB_T1003  INB06F8_00  INB0835_00  INB0848_01 
INB0668_P1090  INB0683_00  INB06BB_T1004  INB0811_00  INB0835_01  INB0848_T1001 
INB0669_00  INB0684_00  INB06BB_T1005  INB0812_00  INB0835_02  INB0848_T1001A 
INB066A_00  INB0684_M1027  INB06BC_00  INB0813_01  INB0835_03  INB0848_T1002 
INB066B_00  INB0685_00  INB06BD_00  INB0813_02  INB0835_04  INB0848_T1003 
INB066B_T1025  INB0686_00  INB06BD_01  INB0813_M1001  INB0835_M1005  INB0849_00 
INB0671_00  INB0686_M1028  INB06BD_02  INB0813_T1002  INB0835_T1002  INB0849_T1008 
INB084A_00  INB0892_00  INB08C2_T1009  INB08H3_T1002  INB08J6_01  INB08M3_00 
INB084B_00  INB0893_00  INB08C2_T1010  INB08H3_T1003  INB08J6_02  INB08M3_M1032 
INB084B_T1009  INB0894_00  INB08E1_01  INB08H3_T1004  INB08J6_P1002  INB08M4_00 
INB084B_T1046  INB0894_M1020  INB08E1_M1050A  INB08H3_T1005  INB08J6_T1001  INB08M4_M1033 
INB084C_00  INB08A1_00  INB08E1_M1050B  INB08H3_T1006  INB08J6_T1002  INB0981_00 
INB084C_T1010  INB08A2_00  INB08E1_T1001  INB08H3_T1006A  INB08J6_T1003  INB0982_01 
INB0851_00  INB08A3_01  INB08E1_T1002  INB08H3_T1006B  INB08J6_T1004  INB0982_T1001 
INB0852_00  INB08A3_02  INB08E4_00  INB08H3_T1006C  INB08J7_00  INB0982_T1002 
INB0853_00  INB08A3_T1001  INB08E5_00  INB08H3_T1006D  INB08J8_00  INB0982_T1002A 
INB0854_00  INB08A3_T1002  INB08E6_00  INB08H3_T1006E  INB08K1_01  INB0982_T1002B 
INB0854_T1053  INB08A3_T1003  INB08E6_M1022  INB08H4_00  INB08K1_02  INB0982_T1002C 
INB0861_00  INB08A4_00  INB08F1_00  INB08H4_T1027  INB08K1_03  INB0983_00 
INB0861_T1011  INB08A5_00  INB08F1_M1023  INB08J1_00  INB08K1_T1002  INB0985_00 
INB0862_00  INB08A6_00  INB08F2_00  INB08J2_00  INB08K1_T1003  INB0991_00 
INB0862_T1054  INB08A7_00  INB08F2_M1024  INB08J3_01  INB08K1_T1004  INB0992_00 
INB0863_00  INB08A8_00  INB08G2_T1035  INB08J3_02  INB08K1_T1005  INB09A1_00 
INB0863_T1012  INB08B1_00  INB08G3_00  INB08J3_03  INB08K1_T1005A  INB09A2_00 
INB0863_T1047  INB08B2_00  INB08G3_T1036  INB08J3_T1001  INB08K1_T1006  INB09A5_00 
INB0871_00  INB08B3_01  INB08G4_00  INB08J3_T1002  INB08K2_00  INB09A6_00 
INB0871_M1014  INB08B3_02  INB08G5_01  INB08J3_T1003  INB08K2_T1029  INB09A7_01 
INB0871_T1048  INB08B3_T1001  INB08G5_02  INB08J3_T1004  INB08K3_00  INB09A7_T1001 
INB0872_00  INB08B3_T1002  INB08G6_01  INB08J3_T1005  INB08K4_00  INB09A7_T1001A 
INB0873_00  INB08B3_T1003  INB08G6_T1001  INB08J3_T1006  INB08K5_00  INB09A7_T1002 
INB0881_00  INB08B3_T1004  INB08G6_T1002  INB08J3_T1007  INB08K5_T1030  INB09A7_T1003 
INB0881_M1015  INB08B3_T1005  INB08G7_T1040  INB08J3_T1008  INB08M1_00  INB09A7_T1003A 
INB0882_00  INB08B3_T1006  INB08G8_T1041  INB08J3_T1010  INB08M1_M1031  INB09A7_T1004 
INB0882_M1016  INB08B4_00  INB08G9_01  INB08J4_00  INB08M2_01  INB09A7_T1005 
INB0882_T1052  INB08C1_00  INB08G9_T1001  INB08J5_01  INB08M2_T1001  INB1011_01 
INB0883_00  INB08C2_01  INB08GA_00  INB08J5_T1001  INB08M2_T1002  INB1011_T1001 
INB0884_00  INB08C2_T1001  INB08GA_T1043  INB08J5_T1002  INB08M2_T1003  INB1011_T1002 
INB0884_M1017  INB08C2_T1003  INB08GB_00  INB08J5_T1002A  INB08M2_T1004  INB1011_T1003 
INB0885_00  INB08C2_T1004  INB08H1_00  INB08J5_T1002B  INB08M2_T1004A  INB1011_T1004 
INB0886_00  INB08C2_T1005  INB08H1_T1025  INB08J5_T1003  INB08M2_T1004B  INB1011_T1004A 
INB0886_M1018  INB08C2_T1006  INB08H2_00  INB08J5_T1004A  INB08M2_T1004C  INB1012_T1001 
INB0891_00  INB08C2_T1007  INB08H3_01  INB08J5_T1004B  INB08M2_T1005  INB1012_T1001A 
INB0891_M1019  INB08C2_T1008  INB08H3_T1001  INB08J5_T1004C  INB08M2_T1006  INB1012_T1002 
INB1012_T1003  INB101C_T1001A  INB1054_T1007  INB1122_01  INB1145_M1003  INB11F3_M1011 
INB1013_01  INB1021_00  INB1055_01  INB1122_T1004  INB1153_00  INB11F4_M1012 
INB1013_T1002  INB1022_00  INB1055_T1001  INB1122_T1006  INB1154_00  INB11F5_00 
INB1013_T1003  INB1023_00  INB1055_T1002  INB1123_00  INB1154_T1026  INB11G1_03A 
INB1014_02  INB1024_00  INB1056_00  INB1124_00  INB1155_00  INB11G1_T1006 
INB1014_T1001  INB1025_00  INB1056_T1008  INB1125_00  INB1155_T1027  INB11G1_T1007 
INB1014_T1002  INB1026_01  INB1057_00  INB1131_02  INB1156_M1004  INB11G2_01 
INB1015_01  INB1026_T1002  INB1057_T1009  INB1131_T1001  INB1161_00  INB11G2_02 
INB1015_02  INB1026_T1003  INB1058_01  INB1131_T1002  INB1162_00  INB11G2_04 
INB1015_T1001  INB1026_T1004  INB1058_02  INB1132_T1021  INB1164_00  INB11G2_T1003 
INB1015_T1002  INB1027_00  INB1058_T1001  INB1134_02  INB1165_01  INB11G3_03 
INB1015_T1003  INB1027_T1002  INB1058_T1002  INB1134_T1003  INB1166_00  INB11G3_04 
INB1015_T1004  INB1031_01  INB1058_T1003  INB1134_T1004  INB1173_00  INB11G3_04A 
INB1016_01  INB1031_T1001  INB1059_00  INB1134_T1006  INB1174_00  INB11G3_T1001 
INB1016_02  INB1031_T1002  INB1059_T1010  INB1135_01  INB1174_M1005  INB11G3_T1002 
INB1016_T1002  INB1032_00  INB105A_00  INB1135_02  INB1175_00  INB11G3_T1003 
INB1016_T1003  INB1033_00  INB105A_T1011  INB1135_P1001  INB1191_00  INB11G3_T1004 
INB1016_T1004  INB1034_00  INB1061_00  INB1135_T1001  INB1194_00  INB11G3_T1005 
INB1016_T1005  INB1035_01  INB1062_00  INB1135_T1001A  INB1194_M1007  INB11G3_T1006 
INB1017_01  INB1035_T1001  INB1063_00  INB1135_T1002  INB11A1_00  INB11G3_T1007 
INB1017_T1001  INB1035_T1002  INB1064_00  INB1135_T1003  INB11A2_00  INB11G3_T1008 
INB1018_02  INB1041_00  INB1065_00  INB1135_T1004  INB11A3_00  INB11G3_T1009 
INB1019_01  INB1041_T1003  INB1066_01  INB1135_T1005  INB11A4_00  INB11G3_T1010 
INB1019_02  INB1042_00  INB1066_02  INB1135_T1006  INB11A5_M1008  INB11G3_T1011 
INB1019_T1001  INB1042_T1004  INB1066_03  INB1136_00  INB11C4_00  INB11G3_T1012 
INB1019_T1002  INB1043_00  INB1066_T1001  INB1136_T1033  INB11C4_M1009  INB11G4_01 
INB1019_T1003  INB1043_T1005  INB1066_T1002  INB1137_00  INB11D1_01  INB11G4_02 
INB1019_T1005  INB1044_00  INB1066_T1003  INB1138_00  INB11D1_P1001  INB11G4_02A 
INB101A_00  INB1045_00  INB1067_00  INB1138_M1001  INB11D2_00  INB11G4_02B 
INB101B_01  INB1046_00  INB1067_T1012  INB1138_T1023  INB11D3_00  INB11G4_T1001 
INB101B_T1001  INB1046_T1014  INB1068_00  INB1141_00  INB11D4_00  INB11G4_T1002 
INB101B_T1002  INB1051_00  INB1069_00  INB1142_00  INB11D5_00  INB11G4_T1003 
INB101B_T1002A  INB1051_T1006  INB1069_T1013  INB1142_M1002  INB11F1_00  INB11G4_T1004 
INB101B_T1002B  INB1052_00  INB111B_00  INB1143_00  INB11F2_00  INB11G4_T1004B 
INB101C_01  INB1053_00  INB111C_00  INB1144_00  INB11F2_P1028  INB11G4_T1005 
INB101C_T1001  INB1054_00  INB1121_00  INB1145_00  INB11F3_00  INB11G5_02 
INB11G5_02A  INB11G8_T1001  INB11GC_T1006  INB1333_M1005  INB13B8_00  INE0227_T1030 
INB11G5_02B  INB11G8_T1001H  INB11GD_01  INB1341_M1006  INB13B9_01  INE0231_00 
INB11G5_02C  INB11G9_01  INB11GD_01A  INB1351_00  INB13B9_02  INE0232_01 
INB11G5_02D  INB11G9_01A  INB11GD_01C  INB1352_00  INB13B9_T1001  INE0232_T1001 
INB11G5_03C  INB11G9_01B  INB11GD_01D  INB1353_00  INB13B9_T1002  INE0233_00 
INB11G5_P1005  INB11G9_02  INB11GD_01E  INB1354_00  INB13B9_T1003  INE0234_00 
INB11G5_P1010  INB11G9_02B  INB11GD_T1001  INB1361_00  INB13B9_T1004  INE0235_00 
INB11G5_T1001  INB11G9_P1001  INB11GD_T1002  INB1361_M1008  INB13BA_00  INE0236_00 
INB11G5_T1002  INB11GA_01  INB11GD_T1003  INB1381_00  INB13BB_00  INE0237_00 
INB11G5_T1003  INB11GA_01A  INB11H1_M1014  INB1381_M1009  INB13BC_00  INE0237_T1028 
INB11G6_01  INB11GA_02A  INB11H2_M1015  INB1382_00  INB13BD_00  INE0241_00 
INB11G6_03  INB11GA_02C  INB11J1_00  INB1391_00  INB13BE_00  INE0241_T1001 
INB11G6_03A  INB11GA_03  INB11J1_M1017  INB1391_T1019  INB13BF_00  INE0242_00 
INB11G6_03C  INB11GA_P1001  INB11J2_00  INB1392_00  INB13BG_00  INE0243_00 
INB11G6_04  INB11GA_T1001  INB11K1_01  INB1393_00  INB13C1_00  INE0244_00 
INB11G6_T1001  INB11GA_T1002  INB11K1_02  INB1394_00  INB13C1_M1015  INE0245_00 
INB11G6_T1002  INB11GB_01  INB11K1_T1001  INB1395_00  INB13C2_00  INE0246_00 
INB11G7_01  INB11GB_01A  INB11K1_T1002  INB1396_00  INB13C2_M1016  INE0247_00 
INB11G7_01A  INB11GB_02  INB11K1_T1003  INB1397_00  INB13D1_00  INE0248_T1002 
INB11G7_01B  INB11GB_03  INB11K1_T1004  INB13A1_00  INB13D1_M1017  INE0249_00 
INB11G7_01C  INB11GB_T1001  INB11K2_00  INB13A1_M1011  INB13D2_00  INE024A_T1003 
INB11G7_01D  INB11GB_T1002  INB11K3_00  INB13A3_M1012  INB13D2_M1018  INE024B_00 
INB11G7_P1001  INB11GB_T1003  INB11K4_00  INB13A3_M1012A  INE0212_00  INE024C_00 
INB11G7_T1001  INB11GB_T1004  INB11K4_M1018  INB13A3_T1001  INE0221_00  INE0251_00 
INB11G7_T1001B  INB11GB_T1005  INB11M1_00  INB13A3_T1001A  INE0222_00  INE0252_00 
INB11G7_T1002  INB11GC_01  INB11M1_M1019  INB13A3_T1001B  INE0222_T1032  INE0271_00 
INB11G7_T1002A  INB11GC_02A  INB11M2_00  INB13A4_00  INE0223_01  INE0272_00 
INB11G7_T1003  INB11GC_02B  INB11M3_M1020  INB13A4_M1013  INE0223_02  INE0273_00 
INB11G7_T1003A  INB11GC_02C  INB1311_M1001  INB13A5_M1014  INE0223_T1001  INE0274_00 
INB11G7_T1003B  INB11GC_03  INB1315_M1002  INB13B1_00  INE0223_T1002  INE0275_00 
INB11G7_T1004  INB11GC_04  INB1321_00  INB13B2_00  INE0224_00  INE0276_00 
INB11G8_01  INB11GC_T1001A  INB1322_00  INB13B3_00  INE0225_00  INE0278_00 
INB11G8_01A  INB11GC_T1002  INB1323_00  INB13B4_00  INE0225_T1029  INJ0191_00 
INB11G8_01B  INB11GC_T1003  INB1331_00  INB13B5_00  INE0225_T1031  INJ0192_00 
INB11G8_01C  INB11GC_T1004  INB1331_M1004  INB13B6_00  INE0226_00  INJ0192_P1036 
INB11G8_P1001  INB11GC_T1005  INB1333_00  INB13B7_00  INE0227_00  INJ0192_P1037 
INJ0193_00  INJ01BB_T1005  INJ01E6_00  INJ01J2_T1004  INJ01M5_00  INJ01R1_T1001 
INJ0193_P1038  INJ01BB_T1006  INJ01E6_T1021  INJ01J2_T1005  INJ01M5_T1318  INJ01R1_T1002 
INJ0194_00  INJ01BC_00  INJ01E6_T1303  INJ01J2_T1006  INJ01M6_00  INJ01R1_T1003 
INJ0195_00  INJ01BC_T1298  INJ01E6_T1329  INJ01J3_00  INJ01M6_02  INJ01R1_T1004 
INJ0196_00  INJ01C1_01  INJ01E7_00  INJ01J4_00  INJ01M6_03  INJ01R1_T1005 
INJ019A_00  INJ01C1_02  INJ01E7_T1310  INJ01J5_00  INJ01M7_02  INJ01R1_T1006 
INJ019C_00  INJ01C1_P1001  INJ01E7_T1311  INJ01J6_00  INJ01M7_03  INJ01R1_T1006A 
INJ01B1_T1035  INJ01C1_P1002  INJ01F1_00  INJ01K1_00  INJ01M7_T1002  INJ01R1_T1006B 
INJ01B2_00  INJ01C1_T1001  INJ01F1_M1011  INJ01K1_T1019  INJ01M7_T1003  INJ01R1_T1008 
INJ01B3_00  INJ01C1_T1003  INJ01F2_00  INJ01K2_T1002  INJ01M8_01  INJ01R2_01 
INJ01B3_T1032  INJ01C1_T1004  INJ01F2_M1010  INJ01K2_T1018  INJ01M8_T1001  INJ01R2_02 
INJ01B3_T1033  INJ01C2_00  INJ01F3_00  INJ01K3_01  INJ01M8_T1002  INJ01R2_T1001 
INJ01B4_00  INJ01C3_00  INJ01F4_00  INJ01K3_T1001  INJ01M9_00  INJ01R2_T1002 
INJ01B4_T1031  INJ01C4_01  INJ01F5_00  INJ01K3_T1001B  INJ01MA_00  INJ01R2_T1003 
INJ01B4_T1297  INJ01C4_02  INJ01F5_M1009  INJ01K3_T1003  INJ01MA_T1321  INJ01R2_T1004 
INJ01B5_00  INJ01C4_T1002  INJ01G6_00  INJ01K3_T1004  INJ01N1_T1015  INJ01R2_T1005 
INJ01B5_T1030  INJ01C4_T1003  INJ01H1_00  INJ01K3_T1006  INJ01N2_02  INJ01R2_T1006 
INJ01B6_00  INJ01C5_01  INJ01H1_T1326  INJ01K4_00  INJ01N2_T1001  INJ01R2_T1007 
INJ01B6_T1029  INJ01C5_P1002  INJ01H2_00  INJ01K4_T1017  INJ01N2_T1001B  INJ01R2_T1008 
INJ01B7_00  INJ01C5_P1003  INJ01H3_00  INJ01K5_00  INJ01N2_T1001C  INJ01R3_00 
INJ01B7_T1028  INJ01C5_T1001  INJ01H3_P1025  INJ01K6_00  INJ01N2_T1002  INJ01R3_T1306 
INJ01B8_00  INJ01C6_01  INJ01H4_00  INJ01K6_02  INJ01N2_T1002A  INJ01R4_01 
INJ01B8_T1027  INJ01C6_02  INJ01H5_00  INJ01K6_T1001  INJ01N2_T1003  INJ01R4_02 
INJ01B9_00  INJ01C6_T1001  INJ01H6_00  INJ01K6_T1003  INJ01N2_T1003A  INJ01R4_T1001 
INJ01BA_00  INJ01C7_00  INJ01H7_00  INJ01K6_T1004  INJ01N3_00  INJ01R4_T1002 
INJ01BA_T1309  INJ01C7_P1022  INJ01H7_01  INJ01K7_00  INJ01N3_T1322  INJ01R4_T1003 
INJ01BB_01  INJ01C8_00  INJ01H7_03  INJ01K7_T1016  INJ01N4_00  INJ01R4_T1005 
INJ01BB_P1001  INJ01D2_00  INJ01H7_P1002  INJ01M1_00  INJ01N4_T1014  INJ01R4_T1005A 
INJ01BB_P1002  INJ01D3_00  INJ01H7_P1003  INJ01M2_02  INJ01N5_00  INJ01R4_T1006 
INJ01BB_P1003  INJ01D3_M1012  INJ01H8_00  INJ01M2_P1022  INJ01N6_00  INJ01R4_T1007 
INJ01BB_P1004  INJ01E1_00  INJ01H8_T1312  INJ01M2_P1023  INJ01N6_T1013  INJ01R4_T1008 
INJ01BB_P1005  INJ01E2_00  INJ01J1_00  INJ01M2_P1025  INJ01N6_T1304  INJ01T1_M1006 
INJ01BB_T1001  INJ01E3_00  INJ01J2_P1001  INJ01M3_00  INJ01P1_00  INJ01T1_P1001 
INJ01BB_T1002  INJ01E4_00  INJ01J2_P1002  INJ01M4_00  INJ01P1_M1007  INJ01T1_T1001 
INJ01BB_T1003  INJ01E4_T1302  INJ01J2_T1001  INJ01M4_P1024  INJ01P2_00  INJ01T1_T1002 
INJ01BB_T1004  INJ01E5_00  INJ01J2_T1002  INJ01M4_P1180  INJ01R1_02  INJ01T2_00 
INJ01T2_M1005  INW0126_T1012  INW0165_00  INW0193_00  INW01C2_T1065  INW01E4_00 
INJ01T2_T1324  INW0131_00  INW0166_T1031  INW0194_00  INW01C3_00  INW01E4_M1080 
INJ01T3_00  INW0131_T1013  INW0166_T1227  INW0194_M1053  INW01C4_00  INW01E5_00 
INJ01T3_M1004  INW0132_00  INW0171_T1027  INW0195_M1054  INW01C5_00  INW01E6_00 
INJ01T4_M1003  INW0132_T1014  INW0172_00  INW0196_00  INW01C5_T1067  INW01E6_M1081 
INJ01T5_T1002  INW0133_T1015  INW0172_T1032  INW0197_00  INW01C6_00  INW01E7_01 
INJ01T6_M1001  INW0141_00  INW0173_00  INW0198_M1055  INW01C7_00  INW01E7_T1115 
INJ01T6_T1308  INW0141_T1223  INW0173_T1033  INW0198_T1056  INW01C8_00  INW01E8_00 
INW0111_T1221  INW0142_00  INW0174_00  INW01A1_00  INW01C8_T1068  INW01E8_T1121 
INW0111_T1222  INW0143_00  INW0175_00  INW01A2_00  INW01C9_00  INW01E9_00 
INW0112_00  INW0144_00  INW0175_T1039  INW01A3_00  INW01CA_00  INW01EA_00 
INW0112_T1002  INW0145_T1016  INW0176_00  INW01A4_00  INW01CA_P1069  INW01EA_T1122 
INW0113_00  INW0146_00  INW0176_T1040  INW01A5_T1043  INW01CB_T1071  INW01EB_00 
INW0113_T1003  INW0147_T1017  INW0177_00  INW01A6_00  INW01CC_00  INW01EB_T1123 
INW0114_00  INW0148_T1018  INW0177_T1041  INW01A6_T1044  INW01CD_00  INW01EC_00 
INW0114_T1004  INW0149_00  INW0181_00  INW01A7_00  INW01CE_T1072  INW01ED_M1082 
INW0115_00  INW014A_T1019  INW0182_00  INW01A8_00  INW01D1_T1061  INW01EE_00 
INW0115_T1005  INW0151_00  INW0183_00  INW01A9_T1045  INW01D2_M1059  INW01F1_00 
INW0116_00  INW0152_T1020  INW0184_00  INW01AA_00  INW01D2_T1058  INW01F1_T1083 
INW0117_00  INW0153_00  INW0184_T1110  INW01AB_00  INW01D3_T1062  INW01F2_00 
INW0118_00  INW0153_T1021  INW0185_00  INW01AC_00  INW01D4_M1060  INW01F2_T1084 
INW0119_00  INW0154_00  INW0186_00  INW01AC_T1046  INW01D4_T1063  INW01F3_00 
INW0119_T1006  INW0154_T1022  INW0186_T1116  INW01AD_00  INW01D4_T1119  INW01F4_00 
INW011A_00  INW0155_T1113  INW0187_00  INW01AE_00  INW01D5_00  INW01F4_T1085 
INW011A_T1007  INW0156_00  INW0188_00  INW01AF_00  INW01D6_00  INW01F5_00 
INW011B_00  INW0156_T1023  INW0188_T1034  INW01AF_P1048  INW01D7_T1073  INW01F5_T1086 
INW011C_00  INW0157_T1024  INW0189_00  INW01AF_T1047  INW01D8_M1076  INW01F6_00 
INW011C_T1008  INW0158_00  INW0189_T1035  INW01B1_00  INW01D8_T1074  INW01F7_T1087 
INW011D_00  INW0158_T1025  INW018A_00  INW01B2_00  INW01D9_00  INW01F8_00 
INW011D_T1009  INW0159_T1026  INW018B_00  INW01B2_T1049  INW01DA_M1077  INW01F9_00 
INW0121_00  INW0161_00  INW018B_P1036  INW01B3_00  INW01DB_00  INW01FA_T1223 
INW0122_T1011  INW0162_00  INW018C_00  INW01B4_00  INW01E1_00  INW01FA_T1224 
INW0123_00  INW0162_T1228  INW018C_T1037  INW01B5_T1050  INW01E1_T1078  INW01FB_00 
INW0124_00  INW0163_00  INW0191_M1038  INW01B6_T1051  INW01E2_00  INW01FC_00 
INW0125_00  INW0163_T1029  INW0192_00  INW01C1_T1064  INW01E3_00  INW01FD_T1089 
INW0126_T1010  INW0164_00  INW0192_M1052  INW01C2_00  INW01E3_M1079  INW01FE_00 
INW01FE_T1107  INW01FJ_00  INW01G4_P1125  INW01H2_T1097  INW01H6_T1102  INW01J7_00 
INW01FF_00  INW01FJ_T1091  INW01G4_T1095  INW01H3_T1099  INW01H7_00  INW01J8_00 
INW01FF_T1108  INW01G1_00  INW01G5_00  INW01H4_00  INW01H7_T1103  INW01J9_M1106 
INW01FG_00  INW01G1_M1092  INW01G5_T1096  INW01H4_T1101  INW01J1_00   
INW01FG_T1109  INW01G2_00  INW01G6_M1094  INW01H5_00  INW01J2_00   
INW01FH_00  INW01G3_00  INW01H1_T1097  INW01H5_P1001  INW01J6_00   
INW01FH_T1090  INW01G3_M1093  INW01H2_00  INW01H5_P1002  INW01J6_M1105   

Attachment 3
U.S. EPA Comments on Indiana's 2010 303(d) and IDEM's Response and
Subsequent Changes to Category 5 for the 2012 Cycle

U.S. EPA Comments Received by IDEM via E-mail Correspondence on April 20, 2011 and IDEM's Responses

U.S. EPA Comment: The following proposed delisted segments/impairments (previously listed in the 2008 cycle) either require a formal delisting reason or some clarifications.

IDEM Response: For this response, IDEM has divided the delistings in question into two tables. Table 3-Aincludes just the Ohio River mainstem delistings, and Table 3-B includes all the remaining delistings in question. IDEM organized its response in this way because all of U.S. EPA's questions regarding the Ohio River delistings stem at least in part from resegmentations, while the reasons for other delistings in question vary.

The following is excerpted from IDEM's finalized 303(d) list for the 2010 cycle submitted to U.S. EPA on November 16, 2010 (pp. 11-12):

IDEM collaborates with the Ohio River Valley Water Sanitation Commission (ORSANCO) to conduct water quality assessments of the Ohio River reaches that border Indiana. ORSANCO monitors the Ohio River on behalf of the compact states under CWA Section 305(b), produces a water quality assessment for report of its water quality condition every two years. Although this report identifies water quality issues on the Ohio River, unlike its compact states, ORSANCO is not required to develop a 303(d) List of Impaired Waters. Identifying Ohio River impairments on a 303(d) list for the purposes of TMDL development is the responsibility of each individual state.

For the purposes of assessment, ORSANCO divides the Ohio River into 21 "pools" defined by the location of navigational dams and their associated mile points along the river. The reach of the Ohio River that borders Indiana begins at mile point 491.1 and ends at mile point 848. ORSANCO assessments for the following Ohio River pools were incorporated into Indiana's finalized 2010 303(d) list. . . While these pools are analogous to IDEM's assessment units, ORSANCO reports its assessments based on mile points, which may or may not comprise an entire pool. Furthermore, the reaches assessed by ORSANCO do not remain static in length within a given pool. For example, in one cycle, the Meldahl-Markland Pool, which extends from Ohio River Mile (ORM) point 436.2-531.1, might be assessed as impaired for a given use only between mile points 506.0-515.5 with the remaining miles fully supporting for that use. Therefore, IDEM resegmented the Ohio River to define smaller reaches, which allow more accurate application of the assessment information provided by ORSANCO. All previously identified impairments were reevaluated against the most current assessment information available from ORSANCO to determine their applicability to the new AUIDs.

As noted in the previous excerpt, all previously identified impairments were reevaluated against the most current assessment information from ORSANCO. As such each delisting identified by U.S. EPA in Table 1 are based on recent water quality data indicating that the reach is now meeting the applicable water quality criteria. Additional detail is provided in the table.

Table 3-A: IDEM responses to U.S. EPA questions regarding IDEM's rationale for removal of previously listed Ohio River impairments from IDEM's finalized 2010 draft 303(d) list.
ASSESSMENT UNIT ID  ASSESSMENT UNIT NAME  CAUSE OF IMPAIRMENT  DELISTING REASON  EPA REVIEWER COMMENT  IDEM RESPONSE 
INH1_00  OHIO RIVER - OHIO STATE LINE TO MARKLAND DAM  E. COLI  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Recent data indicates applicable water quality standards attained"  No formal reason provided for delisting only that delisting was a result of data reassessment. According to segmentation tracking, the delisted AU was resegmented into INH1_01, INH1_02, INH1_03, INH1_04, INH1_05, INH1_06, INH1_07, INH1_08 and these AUs have E. coli in Cat2. Please clarify if delisting reason assumption is correct.  INH1_01 originally spanned ORM 491.1-531.6. ORSANCO's most recent report indicates that the Ohio River is fully supporting of recreational use from ORM 488.0-603.3, which includes all the reaches resulting from this resegmentation. 
INH1_00  OHIO RIVER - OHIO STATE LINE TO MARKLAND DAM  PCBs in FISH TISSUE  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INH1_01, INH1_02, INH1_03, INH1_04, INH1_05, INH1_06, INH1_07, INH1_08".  INH1_01, INH1_02, INH1_03, INH1_04, INH1_05, INH1_06, INH1_07, INH1_08 were not listed in the submitted Cat5 but according to the segmentation tracking file it should be in Cat5. Plus that's the only delisting explanation provided. ???  ORSANCO has assessed the entire Ohio River as impaired for PCBs based on water column results. IDEM concurs with ORSANCO's assessment of PCB impairment. However, because most of IDEM's fishable use assessments are based on fish tissue data, all PCB impairments on the Ohio River based on water column results now appear on Indiana's 303(d) list as "PCBs in Water" instead of "PCBs in Fish Tissue". This change was made to clearly differentiate between water column impairments and those found in fish tissue. All of the Ohio River impairments previously identified as "PCBs in Fish Tissue" have been reapplied as "PCBs in Water" to all of the new reaches resulting from resegmentation. 
INH2_00  OHIO RIVER - MARKLAND TO KENTUCKY RIVER  E. COLI  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Recent data indicates applicable water quality standards attained"  No formal reason provided for delisting only that delisting was a result of data reassessment. According to segmentation tracking, the delisted AU was resegmented into INH2_01, INH2_02, INH2_03 and these AUs have E. coli in Cat2. Please clarify if delisting reason assumption is correct.  INH2_00 originally spanned ORM 531.6-545.3. ORSANCO's most recent report indicates that the Ohio River is fully supporting of recreational use from ORM 488.0-603.3, which includes all the reaches resulting from this resegmentation. 
INH2_00  OHIO RIVER - MARKLAND TO KENTUCKY RIVER  PCBs in FISH TISSUE  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INH2_01, INH2_02, INH2_03".  INH2_01, INH2_02, INH2_03 were not listed in the submitted Cat5 but according to the segmentation tracking file these AUs should be in Cat5 for "PCBs in Fish Tissue". Please clarify if delisting reason assumption is correct.  IDEM's response regarding the delisting of INH1_00 for PCBs in Fish Tissue applies to this impairment. 
INH3_00  OHIO RIVER - KENTUCKY R TO BATTLE CR  E. COLI  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Recent data indicates applicable water quality standards attained"  No formal reason provided for delisting only that delisting was a result of data reassessment. According to segmentation tracking, the delisted AU was resegmented into INH3_01, INH3_02, INH3_03, INH3_04, INH3_05, INH3_06, INH3_07, INH3_08, INH3_09, INH3_10 have E. coli in Cat2. Please clarify if delisting reason assumption is correct.  INH2_00 originally spanned ORM 545.3-613.0. ORSANCO's most recent report indicates that the Ohio River is fully supporting of recreational use from ORM 488.0-603.3, which includes all the reaches resulting from this resegmentation except INH3_12, and INH3_13, which together span ORM 605.7-613.0. These two reaches appear in Category 5A for E. coli. 
INH3_00  OHIO RIVER - KENTUCKY R TO BATTLE CR  PCBs in FISH TISSUE  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INH3_01, INH3_02, INH3_03, INH3_04, INH3_05, INH3_06, INH3_07, INH3_08, INH3_09, INH3_10".  INH3_01, INH3_02, INH3_03, INH3_04, INH3_05, INH3_06, INH3_07, INH3_08, INH3_09, INH3_10 were not listed in the submitted Cat5 but according to the segmentation tracking file these AUs should be in Cat5 for "PCBs in Fish Tissue". Please clarify if delisting reason assumption is correct.  IDEM's response regarding the delisting of INH1_00 for PCBs in Fish Tissue applies to this impairment. 
INH3_M01  OHIO RIVER - BATTLE CR TO McALPINE DAM  PCBs in FISH TISSUE  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INH3_11, INH3_12, INH3_13".  INH3_11, INH3_12, INH3_13 were not listed in the submitted Cat5 but according to the segmentation tracking file these AUs should be in Cat5 for "PCBs in Fish Tissue". Please clarify if delisting reason assumption is correct.  IDEM's response regarding the delisting of INH1_00 for PCBs in Fish Tissue applies to this impairment. 
INH4_00  OHIO RIVER - MCALPINE TO GREENWOOD, KY  PCBs in FISH TISSUE  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INH4_01, INH4_02".  INH4_01, INH4_02 were not listed in the submitted Cat5 but according to the segmentation tracking file these AUs should be in Cat5 for "PCBs in Fish Tissue". Please clarify if delisting reason assumption is correct.  IDEM's response regarding the delisting of INH1_00 for PCBs in Fish Tissue applies to this impairment. 
INH4_M01  OHIO RIVER - GREENWOOD, KY TO SALT CR  PCBs in FISH TISSUE  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INH4_02, INH4_03, INH4_04, INH4_05"  INH4_02, INH4_03, INH4_04, INH4_05 were not listed in the submitted Cat5 but according to the segmentation tracking file these AUs should be in Cat5 for "PCBs in Fish Tissue". Please clarify if delisting reason assumption is correct.  IDEM's response regarding the delisting of INH1_00 for PCBs in Fish Tissue applies to this impairment. 
INH5_00  OHIO RIVER - SALT CR TO CANNELTON  PCBs in FISH TISSUE  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INH5_01, INH5_02, INH5_03, INH5_04, INH5_05, INH5_06, INH5_07, INH5_08, INH5_09, INH5_10, INH5_11, INH5_12, INH5_13, INH5_14, INH5_15".  INH5_01, INH5_02, INH5_03, INH5_04, INH5_05, INH5_06, INH5_07, INH5_08, INH5_09, INH5_10, INH5_11, INH5_12, INH5_13, INH5_14, INH5_15 were not listed in the submitted Cat5 but according to the segmentation tracking file these AUs should be in Cat5 for "PCBs in Fish Tissue". Please clarify if delisting reason assumption is correct.  IDEM's response regarding the delisting of INH1_00 for PCBs in Fish Tissue applies to this impairment. 
INH6_00  OHIO RIVER - CANNELTON TO NEWBURGH  PCBs in FISH TISSUE  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INH5_16, INH6_01, INH6_02, INH6_03, INH6_04, INH6_05, INH6_06, INH6_07, INH6_08, INH6_08, INH6_09, INH6_10".  INH5_16, INH6_01, INH6_02, INH6_03, INH6_04, INH6_05, INH6_06, INH6_07, INH6_08, INH6_08, INH6_09, INH6_10 were not listed in the submitted Cat5 but according to the segmentation tracking file these AUs should be in Cat5 for "PCBs in Fish Tissue". Please clarify if delisting reason assumption is correct.  IDEM's response regarding the delisting of INH1_00 for PCBs in Fish Tissue applies to this impairment. 
INH7_00  OHIO RIVER - NEWBURGH TO GREEN R  PCBs in FISH TISSUE  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INH7_01".  INH7_01 was not listed in the submitted Cat5 but according to the segmentation tracking file these AUs should be in Cat5 for "PCBs in Fish Tissue". Please clarify if delisting reason assumption is correct.  IDEM's response regarding the delisting of INH1_00 for PCBs in Fish Tissue applies to this impairment. 
INH8_00  OHIO RIVER - GREEN RIVER TO EVANSVILLE  PCBs in FISH TISSUE  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INH8_01, INH8_02".  INH8_01, INH8_02 were not listed in the submitted Cat5 but according to the segmentation tracking file these AUs should be in Cat5 for "PCBs in Fish Tissue". Please clarify if delisting reason assumption is correct.  IDEM's response regarding the delisting of INH1_00 for PCBs in Fish Tissue applies to this impairment. 
INH8_M01  OHIO RIVER - EVANSVILLE TO UNIONTOWN  PCBs in FISH TISSUE  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INH8_03, INH8_04, INH8_05, INH8_06, INH8_07, INH8_08, INH8_09, INH8_10, INH8_11, INH8_12".  INH8_03, INH8_04, INH8_05, INH8_06, INH8_07, INH8_08, INH8_09, INH8_10, INH8_11, INH8_12 were not listed in the submitted Cat5 but according to the segmentation tracking file these AUs should be in Cat5 for "PCBs in Fish Tissue". Please clarify if delisting reason assumption is correct.  IDEM's response regarding the delisting of INH1_00 for PCBs in Fish Tissue applies to this impairment. 
INH9_00  OHIO RIVER - UNIONTOWN TO WABASH RIVER  E. COLI  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Recent data indicates applicable water quality standards attained"  No formal reason provided for delisting only that delisting was a result of data reassessment. According to segmentation tracking, the delisted AU was resegmented into INH9_01 and this AU has E. coli in Cat2. Please clarify if delisting reason assumption is correct. Please clarify if delisting reason assumption is correct.  INH9_01 originally spanned ORM 853.5-855.5. ORSANCO's most recent report indicates that the Ohio River is fully supporting of recreational use from ORM 847.3-853.4, which includes INH9_01 resulting from this resegmentation. ORSANCO data indicates that the Ohio River reach immediately upstream from this in Illinois also meets Indiana's criteria for full support. 
INH9_00  OHIO RIVER - UNIONTOWN TO WABASH R  PCBs in FISH TISSUE  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INH9_01"  INH9_01 was not listed in the submitted Cat5 but according to the segmentation tracking file these AUs should be in Cat5 for "PCBs in Fish Tissue". Please clarify if delisting reason assumption is correct.  IDEM's response regarding the delisting of INH1_00 for PCBs in Fish Tissue applies to this impairment. 

Table 3-B: IDEM responses to U.S. EPA questions regarding IDEM's rationale for removal of previously listed impairments from IDEM's finalized 2010 draft 303(d) list.
ASSESSMENT UNIT ID  ASSESSMENT UNIT NAME  CAUSE OF IMPAIRMENT  DELISTING REASON  EPA REVIEWER COMMENT  IDEM RESPONSE 
INB11G4_T1024  SULPHER CREEK  IMPAIRED BIOTIC COMMUNITIES  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INB11G4_T1003 and INB11G4_T1005"  INB11G4_T1005 was not listed in the submitted Cat5 but according to the segmentation tracking file this AU should be in Cat5 for IBC. Please clarify if delisting reason assumption is correct.  This delisting was addressed in IDEM's response to U.S. EPA comments on Indiana's draft 303(d) list in which IDEM stated that the IBC on INB11G4_T1024 would be applied to the new reaches resulting from resegmentation. In finalizing its 303(d) list, IDEM verified that the IBC applies only to INB11G4_T1003 but not to INB11G4_T1005. IDEM has no biological data to support listing INB11G4_T1005 for IBC. IDEM will add INB11G4_T1004 to its 303(d) list for IBC. 
INB11G4_T1024  SULPHER CREEK  DISSOLVED OXYGEN  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INB11G4_T1003".  INB11G4_T1003 was not listed in the submitted Cat5 for DO but according to the segmentation tracking file this AU should be in Cat5 for DO. Please clarify if delisting reason assumption is correct.  INB11G4_T1024 was correctly delisted for dissolved oxygen (DO) based on changes in segmentation. Recent data for both of the reaches resulting from this resegmentation (INB11G4_T1003 and INB11G4_T1005) indicate that applicable water quality criteria are met. 
INC0143_T1002  WILLOW CREEK (UPSTREAM OF CHRISMAN DITCH)  DISSOLVED OXYGEN  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INC0159_T1001".  INC0159_T1001 was not listed for DO in the submitted Cat5 but according to the segmentation tracking file this AU should be in Cat5 for DO. Please clarify if delisting reason assumption is correct.  INC0143_T1002 was correctly delisted for dissolved oxygen (DO) based on changes in segmentation. IDEM has verified that the DO impairment applies to the new reach resulting from this resegmentation (INC0159_T1001). This impairment was correctly added to IDEM's segmentation tracking spreadsheet but inadvertently omitted in the finalized 303(d) list. IDEM will add this impairment back to Indiana's 303(d) list. 
INC0151_00  SALT CREEK TRIBUTARIES  IMPAIRED BIOTIC COMMUNITIES  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INC0131_01, INC0131_02, INC0131_T1001, INC0131_T1002".  INC0131_01, INC0131_02, INC0131_T1001, INC0131_T1002 were not listed for IBC in the submitted Cat5, but according to the segmentation tracking file these AUs should be in Cat5 for IBC. Please clarify if delisting reason assumption is correct.  INC0151_00 was correctly delisted for IBC based on changes in segmentation. IDEM has verified that the IBC applies to each of the new reaches resulting from this resegmentation (INC0131_01, INC0131_02, INC0131_T1001, and INC0131_T1002). These impairments were correctly added to IDEM's segmentation tracking spreadsheet but were inadvertently omitted in the finalized 303(d) list. IDEM will add these impairments back to Indiana's 303(d) list. 
INC0151_T1012  SALT CREEK  IMPAIRED BIOTIC COMMUNITIES  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INC0131_01, INC0131_02".  INC0131_01, INC0131_02 were not listed for IBC in the submitted Cat5 but according to the segmentation tracking file these AUs should be in Cat5 for IBC. Please clarify if delisting reason assumption is correct.  INC0151_T1012 was correctly delisted for IBC based on changes in segmentation. IDEM has verified that the IBC applies to each of the new reaches resulting from resegmentation: INC0131_01; INC0131_02. These impairments were correctly added to IDEM's segmentation tracking spreadsheet but inadvertently omitted in the finalized 303(d) list. IDEM will add these impairments back to Indiana's 303(d) list. 
INC0152_01  SALT CREEK (VALPARAISO, IN)  IMPAIRED BIOTIC COMMUNITIES  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INC0132_01".  INC0132_01 is not listed for IBC in the submitted Cat5 but according to the segmentation tracking file this AU should be in Cat5 for IBC. Please clarify if delisting reason assumption is correct.  INC0152_01 was correctly delisted for IBC based on changes in segmentation. IDEM has verified that the IBC applies to the new reach resulting from this resegmentation (INC0132_01). This impairment was correctly added to IDEM's segmentation tracking spreadsheet but inadvertently omitted in the finalized 303(d) list. IDEM will add this impairment back to Indiana's 303(d) list. 
INC0152_02  SALT CREEK (UPSTREAM OF CLARK DITCH)  IMPAIRED BIOTIC COMMUNITIES  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INC0132_02".  INC0132_02 is not listed for IBC in the submitted Cat5 but according to the segmentation tracking file this AU should be in Cat5 for IBC. Please clarify if delisting reason assumption is correct.  INC0152_02 was correctly delisted for IBC based on changes in segmentation. IDEM has verified that the IBC applies to the new reach resulting from this resegmentation (INC0132_02). This impairment was correctly added to IDEM's segmentation tracking spreadsheet but inadvertently omitted in the finalized 303(d) list. IDEM will add this impairment back to Indiana's 303(d) list. 
INC0152_T1001  BEAUTY CREEK  IMPAIRED BIOTIC COMMUNITIES  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INC0132_T1007".  INC0132_T1007 is not listed for IBC in the submitted Cat5 but according to the segmentation tracking file this AU should be in Cat5 for IBC. Please clarify if delisting reason assumption is correct.  INC0152_T1001 was correctly delisted for IBC based on changes in segmentation. IDEM has verified that the IBC applies to the new reach resulting from this resegmentation (INC0132_T1007). This impairment was correctly added to IDEM's segmentation tracking spreadsheet but inadvertently omitted in the finalized 303(d) list. IDEM will add this impairment back to Indiana's 303(d) list. 
INC0155_T1017  SALT CREEK  IMPAIRED BIOTIC COMMUNITIES  No reason provided  Please provide delisting reason.  INC0155_T1017 was correctly delisted for IBC based on changes in segmentation. IDEM has verified that the IBC applies to the new reach resulting from this resegementation (INC0133_T1031). This impairment was inadvertently omitted from the segmentation tracking spreadsheet and the finalized 303(d) list. IDEM will add this impairment back to Indiana's 303(d) list. 
INC0191G_ G1092  LAKE MICHIGAN SHORELINE - LAPORTE  MERCURY in FISH TISSUE  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INC0112G_G1092".  INC0112G_G1092 was not listed in the submitted Cat5 but according to the segmentation tracking file this AU should be in Cat5 for "Mercury in Fish Tissue". Please clarify if delisting reason assumption is correct.  INC0191G_G1092 was correctly delisted for Mercury in Fish Tissue based on changes in segmentation. IDEM has verified that the impairment for Mercury in Fish Tissue applies to the new reach resulting from this resegmentation (INC0112G_G1092). This impairment was correctly added to IDEM's segmentation tracking spreadsheet but inadvertently omitted in the finalized 303(d) list. IDEM will add this impairment back to Indiana's 303(d) list. 
INC0191G_ G1092  LAKE MICHIGAN SHORELINE - LAPORTE  PCBs in FISH TISSUE  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INC0112G_G1092".  INC0112G_G1092 was not listed in the submitted Cat5 but according to the segmentation tracking file this AU should be in Cat5 for "PCBs in Fish Tissue". Please clarify if delisting reason assumption is correct.  INC0191G_G1092 was correctly delisted for PCBs in Fish Tissue based on changes in segmentation. IDEM has verified that the impairment for PCBs in Fish Tissue applies to the new reach resulting from this resegmentation (INC0112G_G1092). This impairment was correctly added to IDEM's segmentation tracking spreadsheet but inadvertently omitted in the finalized 303(d) list. IDEM will add this impairment back to Indiana's 303(d) list. 
INC01P1002_ T1085  MARQUETTE PARK LAGOONS (WEST)  PCBs in FISH TISSUE  No reason provided  Please provide delisting reason.  This impairment was inadvertently omitted from Indiana's 303(d) list through an error in segmentation tracking. IDEM will add this impairment back to Indiana's 303(d) list. 
INC01P1083_ T1084  MARQUETTE PARK LAGOONS (EAST)  PCBs in FISH TISSUE  No reason provided  Please provide delisting reason.  This impairment was inadvertently omitted from Indiana's 303(d) list through an error in segmentation tracking. IDEM will add this impairment back to Indiana's 303(d) list. 
ING0362_01  WHITEWATER CANAL  E. COLI  No formal delisting reason was provided.  No reason provided for delisting. According to segmentation tracking file, the delisted AU was resegmented into ING0365_02 and this AU has E. coli in Cat2. But there is a contradiction related to resegmentation because AU ING0362_01 is still listed in Cat5 for other impairments. Please clarify and fix these inconsistencies.  This impairment was correctly delisted for E. coli based on changes in segmentation. IDEM has verified that the E. coli impairment applies to the new reach resulting from this resegmentation (ING0365_02). ING0362_01, which should have been retired, also appears on the finalized list for PCBs in Fish Tissue. In order to correctly retire NG0362_01, IDEM will add the E. coli impairment back to Indiana's 303(d) list and will apply the impairment for PCBs in Fish Tissue to ING0365_02. 
INK013B_03  MILL CREEK (DOWNSTREAM OF UNION MILLS, IN)  E. COLI  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Recent data indicates applicable water quality standards attained"  No formal reason provided for delisting. According to segmentation tracking, the delisted AU was resegmented into INK0147_01 and this AU has E. coli in Cat2. Please clarify if delisting reason assumption is correct.  This reach was identified as a result of an interim resegmentation effort, which was finalized after IDEM published its draft 303(d) list. This reach of Mill Creek is now represented by INK0147_01. Recent data indicate waterbody is meeting applicable water quality criteria. 
INK013C_T1007  KANKAKEE RIVER - MAINSTEM  PCBs in FISH TISSUE  No reason provided  No formal reason provided for delisting, only that delisting was a result of data reassessment. Also according to segmentation tracking file, both original AU and resegmentation into INK0148_M1003 don't show any category listings for PCBs for 2008 or 2010 respectively. Please clarify.  This impairment was inadvertently omitted from Indiana's 303(d) list through an error in segmentation tracking. IDEM will add this impairment back to Indiana's 303(d) list. 
INK0146_T1008  KANKAKEE RIVER  PCBs in FISH TISSUE  No reason provided  No formal reason provided for delisting, only that delisting was a result of data reassessment. Also according to segmentation tracking file, both original AU and resegmentation into INK0174_M1004 don't show any category listings for PCBs for 2008 or 2010 respectively. Please clarify.  This impairment was inadvertently omitted from Indiana's 303(d) list through an error in segmentation tracking. IDEM will add this impairment back to Indiana's 303(d) list. 
INK0147_T1009  KANKAKEE RIVER  PCBs in FISH TISSUE  No reason provided  No formal reason provided for delisting, only that delisting was a result of data reassessment. Also according to segmentation tracking file, both original AU and resegmentation into INK0175_M1005 don't show any category listings for PCBs for 2008 nor 2010 respectively. Please clarify.  This impairment was inadvertently omitted from Indiana's 303(d) list through an error in segmentation tracking. IDEM will add this impairment back to Indiana's 303(d) list. 
INK0183_M1011  KANKAKEE RIVER - ENGLISH LAKE  PCBs in FISH TISSUE  No reason provided  No formal reason provided for delisting. Also according to segmentation tracking file, both original AU and resegmentation into INK0186_M1006 don't show any category listings for PCBs for 2008 nor 2010 respectively. Please clarify.  This impairment was inadvertently omitted from Indiana's 303(d) list through an error in segmentation tracking. IDEM will add this impairment back to Indiana's 303(d) list. 
INK015A_T1002  LAKE ARM  E. COLI  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Resegmentation into INK0136_T1001".  INK0136_T1001 was not listed in the submitted Cat5 but according to the segmentation tracking file it should be in Cat5. Please clarify if delisting reason assumption is correct.  This reach was identified as a result of an interim resegmentation effort, which was finalized after IDEM published its draft 303(d) list. IDEM has verified that the E. coli impairment applies to the new reach resulting from this resegmentation (INK0136_T1001). This impairment was correctly added to IDEM's segmentation tracking spreadsheet but inadvertently omitted in the finalized 303(d) list. IDEM will add this impairment back to Indiana's 303(d) list. 
INK019A_02  COBB DITCH (DOWNSTREAM OF SELVERS DITCH)  E. COLI  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Recent data indicates applicable water quality standards attained"  No formal reason provided for delisting. According to segmentation tracking, the delisted AU was resegmented into INK01A7_01 and this AU has E. coli in Cat2. Please clarify if delisting reason assumption is correct.  This reach was identified as a result of an interim resegmentation effort, which was finalized after IDEM published its draft 303(d) list. This reach of Cobb Ditch is now represented by INK01A7_01 and INK01A7_02. Recent data indicate these waterbodies are meeting applicable water quality criteria. 
INK019B_02  LUDINGTON DITCH  E. COLI  No formal delisting reason was provided. But based on other provided info (see EPA reviewer comment) it is believed to be "Recent data indicates applicable water quality standards attained"  No formal reason provided for delisting. According to segmentation tracking, the delisted AU was resegmented into INK01A7_03 and this AU has E. coli in Cat2. Please clarify if delisting reason assumption is correct.  This reach was identified as a result of an interim resegmentation effort, which was finalized after IDEM published its draft 303(d) list. Ludington Ditch is now represented by INK01A7_03. Recent data indicate this waterbody is meeting applicable water quality criteria. 
INK0277_T1001  MINIER LATERAL  E. COLI  Moved to Cat4A; Approved TMDL  The formal reason provided for delisting was "Approved TMDL". Also according to segmentation tracking, the delisted AU was resegmented into INK0274_T1001 and this AU has E. coli in Cat 4A. But Not found in Table A4 of Attachment 1 of Appendix G. Please identify what is the approved TMDL report that addresses this AU.  This impairment was mistakenly listed in IDEM's finalized 303(d) submission materials as having been included in the Kankakee/Iroquois TMDL, which was approved by U.S. EPA. IDEM has since verified that this reach was not addressed by this TMDL and that the agency has no data to support delisting. IDEM will add this impairment back to its 303(d) list. 
INK0334_01  CADY MARSH DITCH  E. COLI  No reason provided  Please provide delisting reason.  This impairment was inadvertently dropped from Indiana's 303(d) list through an error in segmentation tracking. IDEM will add this impairment back to Indiana's 303(d) list. 

*"Cat" means Category on Indiana's Consolidated Listing.

In addition to taking the follow-up actions described in the preceding tables, IDEM would like to remove an additional six impairments which were inadvertently left on the 303(d) list submitted for approval (Table 3-C). These waters correspond to IDEM Nonpoint Source Success Stories, which identify waters that have been restored as a result of activities funded either in part or whole by CWA Section 319 nonpoint source funding. These delistings are needed to ensure consistency between the information published on U.S. EPA's NPS Success Stories website (http://water.epa.gov/polwaste/nps/success319/in_walnut.cfm) and Indiana's 303(d) list of Impaired Waters.

Table 3-C: Additional impairments identified by IDEM to be removed from Category 5 based on water quality improvements.
ASSESSMENT UNIT ID  ASSESSMENT UNIT NAME  CAUSE OF IMPAIRMENT  DELISTING REASON 
INW0311_00  UPPER WEST FORK BIG WALNUT CREEK  E. COLI  Recent data indicates applicable water quality criteria are met. 
INW0312_00  EDLIN DITCH – SMITH DITCH  E. COLI  Recent data indicates applicable water quality criteria are met. 
INW0313_00  EDLIN DITCH – GRASSY BRANCH  E. COLI  Recent data indicates applicable water quality criteria are met. 
INW0314_00  LOWER WEST FORK BIG WALNUT CREEK  E. COLI  Recent data indicates applicable water quality criteria are met. 
INW0316_00  ROSS CREEK – EAST FORK BIG WALNUT CREEK  E. COLI  Recent data indicates applicable water quality criteria are met. 
INW0317_00  LOWER EAST FORK BIG WALNUT CREEK  E. COLI  Recent data indicates applicable water quality criteria are met. 

U.S. EPA Comment: The following proposed delisted segments/impairments (not previously listed in the 2008 cycle) either require a formal delisting reason or some clarifications (Table 3-D).

Table 3-D: IDEM responses to U.S. EPA questions regarding removals of impairments not previously listed but provisionally placed on the 2010 draft 303(d) list.
ASSESSMENT UNIT ID  ASSESSMENT UNIT NAME  CAUSE OF IMPAIRMENT  DELISTING REASON  EPA REVIEWER COMMENT  IDEM RESPONSE 
INB11G4_T1004  SULPHER CREEK  DISSOLVED OXYGEN  No formal delisting reason was provided.  Proposed new listing in PN, delisted in the final submittal. According to the segmentation tracking file, AU was originally identified under AU ID INB11G4. No info for DO delisting provided. Please clarify.  Recent data indicates applicable water quality criteria are met. 
INB11G7_02C  KETTLE CREEK (BETWEEN GOOSE AND MOHAWK LAKES)  MERCURY in FISH TISSUE  No reason provided  Proposed new listing in PN, delisted in the final submittal. No info for "Mercury in Fish Tissue" delisting provided. Please clarify.  This reach was identified as a result of an interim resegmentation effort, which was finalized after IDEM published its draft 303(d) list. IDEM has verified that the impairment for Mercury in Fish Tissue applies to the new reach resulting from this resegmentation (INB11G7_T1003). This impairment was inadvertently omitted from the segmentation tracking spreadsheet and the finalized 303(d) list. IDEM will add this impairment back to Indiana's 303(d) list. 
INB11GA_02  BUCK CREEK - UNNAMED TRIBUTARY  NUTRIENTS  No reason provided  Proposed new listing in PN, delisted in the final submittal. No info for nutrient delisting provided. Please clarify.  This reach was identified as a result of an interim resegmentation effort, which was finalized after IDEM published its draft 303(d) list. This unnamed tributary to Buck Creek is now represented by INB11GA_T1001 and INB11GA_T1002, both of which correctly appear on Indiana's finalized 303(d) list for nutrients. 
INB11GA_T1003  BUCK CREEK  NUTRIENTS  No reason provided  Proposed new listing in PN, delisted in the final submittal. No info for nutrient delisting provided. Please clarify.  This reach was identified as a result of an interim resegmentation effort, which was finalized after IDEM published its draft 303(d) list. Buck Creek is now represented by INB11GA_02A, INB11GA_02B, and INB11GA_02C, all of which correctly appear on Indiana's finalized 303(d) list for nutrients. 
INB11G6_02  BIG BRANCH  pH  No reason provided  Proposed new listing in PN, delisted in the final submittal. No info for pH delisting provided. Please clarify.  Recent data indicates applicable water quality criteria are met. 
INB11G6_03  MUD CREEK  pH  No reason provided  Proposed new listing in PN, delisted in the final submittal. No info for pH delisting provided. Please clarify.  Recent data indicates applicable water quality criteria are met. 
INK0153_T1001  CLIFTON BRANCH  pH  No reason provided  Proposed new listing in PN, delisted in the final submittal. No info for pH delisting provided. Please clarify.  INK0153_T1001 is a new reach resulting from the resegmentation of INK0165_00. In finalizing its 303(d) list for submission, IDEM verified that INK0165_00 is fully supporting of aquatic life use. This reach was not been previously listed for pH nor does the agency have any data to indicate a pH impairment. 
INC0158_01  DEEP RIVER  SILTATION  No reason provided  Proposed new listing in PN, delisted in the final submittal. No info for siltation delisting provided. Please clarify.  INC0158_01 is a new reach resulting from the resegmentation of INKC0142_T1008. In finalizing its 303(d) list for submission, IDEM verified that INC0158_01 was not previously listed for siltation nor does the agency have any data to indicate impairment for siltation. 
INC0114_01  TRAIL CREEK, EAST BRANCH  SULFATES  No reason provided  Proposed new listing in PN, delisted in the final submittal. No info for sulfate delisting provided. Please clarify.  During its statewide reassessment of sulfate data, which was finalized after the PN of Indiana's draft 2010 303(d) list, IDEM found that the agency has no sulfate data with which to make an assessment for this reach of Trail Creek. 

U.S. EPA Comment: Proposed delisted segments/impairments on the basis of derived criteria (Tier I and Tier II) and/or total recoverable metals:
Placeholder: These issues are currently under discussion. EPA will follow up with formal comments. 

IDEM's Response: IDEM is currently working on its response to U.S. EPA's comments on the finalized 303(d) list regarding IDEM's decisions on the use of derived criteria and total recoverable metals in 305(b)/303(d) assessment and listing decisions, which were received in a letter from U.S. EPA dated June 30, 2011. IDEM will send its response via a separate letter to U.S. EPA.

U.S. EPA's June 30, 2011 letter containing comments regarding IDEM's Use of Derived Criteria and Total Metals Data in CWA Section 305(b) and 303(d) Assessment and Listing Processes
318120053ONA09.gif
318120053ONA10.gif
318120053ONA11.gif
318120053ONA12.gif
318120053ONA13.gif
318120053ONA14.gif
318120053ONA15.gif
318120053ONA16.gif
318120053ONA17.gif
IDEM LETTER TO U.S. EPA MAILED IN RESPONSE TO COMMENTS RECEIVED ON JUNE 30, 2011
318120053ONA18.gif
318120053ONA19.gif
318120053ONA20.gif
318120053ONA21.gif
318120053ONA22.gif

ADDITIONAL CHANGES BY IDEM TO CATEGORY 5 BASED ON U.S. EPA COMMENTS RECEIVED

Table 3-E: Explanations keyed to the additions to Category 5 shown in Table 3B, all of which were based on U.S. EPA comments regarding Indiana's finalized 2010 303(d) list.
KEY  REASON 
Added back under originally listed AUID; See IDEM response to EPA comments on 2010 finalized list 
Added back under new AUID resulting from resegmentation; See IDEM response to EPA comments on 2010 finalized list 
Added back under new AUID resulting from segmentation pending collection of dissolved metals data and reassessment of this reach in accordance with IDEM's current methodology 
Added back under originally listed AUID pending collection of dissolved metals data and reassessment of this reach in accordance with IDEM's current methodology 

Table 3-F: Additions to Category 5 based on U.S. EPA comments regarding Indiana's finalized 2010 303(d) list.
BASIN  HYDROLOGIC UNIT CODE  COUNTY  2012 ASSESSMENT UNIT ID  2010 ASSESSMENT UNIT ID*  ASSESSMENT UNIT NAME  CAUSE OF IMPAIRMENT  REASON KEY 
UPPER WABASH  51201060105  WHITLEY  INB0615_T1001  INB0614_T1001  GAFF DITCH  TOTAL LEAD 
LOWER WABASH  51201080409  WARREN  INB0849_01  INB084B_T1046  BIG PINE CREEK  TOTAL LEAD 
LOWER WABASH  51201111506  SULLIVAN  INB11F5_T1002  INB11G7_T1003  KETTLE CREEK  TOTAL MERCURY (FISH TISSUE) 
LOWER WABASH  51201111505  SULLIVAN  INB11F5_T1003  INB11G4_T1003  SULPHUR CREEK  TOTAL ZINC 
LOWER WABASH  51201111505  SULLIVAN  INB11F5_T1003  INB11G4_T1003  SULPHUR CREEK  TOTAL COPPER 
LOWER WABASH  51201111505  SULLIVAN  INB11F5_T1003  INB11G4_T1003  SULPHUR CREEK  TOTAL NICKEL 
LOWER WABASH  51201111505  SULLIVAN  INB11F5_T1005  INB11G4_T1005  SULPHUR CREEK  TOTAL ZINC 
LOWER WABASH  51201111505  SULLIVAN  INB11F5_T1005  INB11G4_T1005  SULPHUR CREEK  TOTAL COPPER 
LOWER WABASH  51201111505  SULLIVAN  INB11F5_T1005  INB11G4_T1005  SULPHUR CREEK  TOTAL NICKEL 
LOWER WABASH  51201111506  SULLIVAN  INB11F6_02  INB11G7_T1003  KETTLE CREEK  TOTAL MERCURY (FISH TISSUE) 
GREAT LAKES  40400010102  LAPORTE  INC0112G_G1092    LAKE MICHIGAN SHORELINE- LAPORTE  TOTAL MERCURY (FISH TISSUE) 
GREAT LAKES  40400010102  LAPORTE  INC0112G_G1092    LAKE MICHIGAN SHORELINE- LAPORTE  PCBS (FISH TISSUE) 
GREAT LAKES  40400010301  PORTER  INC0131_01    SALT CREEK  IMPAIRED BIOTIC COMMUNITIES 
GREAT LAKES  40400010301  PORTER  INC0131_02    SALT CREEK  IMPAIRED BIOTIC COMMUNITIES 
GREAT LAKES  40400010301  PORTER  INC0131_T1001    SALT CREEK - UNNAMED TRIBUTARY  IMPAIRED BIOTIC COMMUNITIES 
GREAT LAKES  40400010301  PORTER  INC0131_T1002    SALT CREEK - UNNAMED TRIBUTARY  IMPAIRED BIOTIC COMMUNITIES 
GREAT LAKES  40400010302  PORTER  INC0132_01    SALT CREEK  IMPAIRED BIOTIC COMMUNITIES 
GREAT LAKES  40400010302  PORTER  INC0132_02    SALT CREEK  IMPAIRED BIOTIC COMMUNITIES 
GREAT LAKES  40400010302  PORTER  INC0132_T1007    BEAUTY CREEK  IMPAIRED BIOTIC COMMUNITIES 
GREAT LAKES  40400010303  PORTER  INC0133_T1031    SALT CREEK  IMPAIRED BIOTIC COMMUNITIES 
GREAT LAKES  40400010403  PORTER  INC0143_T1002    WILLOW CREEK (UPSTREAM OF CHRISMAN DITCH)  DISSOLVED OXYGEN 
GREAT LAKES  4040001020020  LAKE  INC01P1002_T1085    MARQUETTE PARK LAGOONS (WEST)  PCBS (FISH TISSUE) 
GREAT LAKES  4040001020020  LAKE  INC01P1083_T1084    MARQUETTE PARK LAGOONS (EAST)  PCBS (FISH TISSUE) 
GREAT MIAMI  50800030605  FRANKLIN  ING0365_02    WHITEWATER CANAL  PCBS (FISH TISSUE) 
GREAT MIAMI  50800030605  FRANKLIN  ING0365_02    WHITEWATER CANAL  E. COLI 
UPPER ILLINOIS  71200010306  KOSCIUSKO  INK0136_T1001    LAKE ARM  E. COLI 
UPPER ILLINOIS  71200010408  STARKE  INK0148_M1003    KANKAKEE RIVER  PCBS (FISH TISSUE) 
UPPER ILLINOIS  71200010704  STARKE  INK0174_M1004    KANKAKEE RIVER  PCBS (FISH TISSUE) 
UPPER ILLINOIS  71200010705  STARKE  INK0175_M1005    KANKAKEE RIVER - UNNAMED TRIBUTARY  PCBS (FISH TISSUE) 
UPPER ILLINOIS  71200010806  STARKE  INK0186_M1006    KANKAKEE RIVER  PCBS (FISH TISSUE) 
UPPER ILLINOIS  71200020704  BENTON  INK0274_T1001    MINIER LATERAL  E. COLI 
UPPER ILLINOIS  7120003030040  LAKE  INK0334_01    CADY MARSH DITCH  E. COLI 
PATOKA  5120209040070  DUBOIS  INP0947_T1007    PATOKA RIVER  TOTAL LEAD 
WHITE RIVER, EAST FORK  5120208100030  MARTIN  INW08A3_M1058    EAST FORK WHITE RIVER  TOTAL LEAD 
*Provided only for reaches resegmented since the finalized 2010 303(d) list was submitted to U.S. EPA. For all other reaches in the table, the 2010 and 2012 AUIDs are the same.

Attachment 4
Impairments Moved to Category 4A on the Basis of TMDL Completion

Table 4-A: TMDLs completed with U.S. EPA approval received or anticipated prior to IDEM's submission of its finalized 2012 303(d) list.
Key  TMDL Document 
Total Maximum Daily Load for Escherichia coli (E. coli) For the Upper Wildcat Creek Watershed, Howard, Tipton, Grant, and Madison Counties 
Total Maximum Daily Load for Escherichia coli (E. coli) For the Middle Fork Wildcat Creek Watershed, Clinton, Carroll, Tippecanoe, and Howard Counties 
Total Maximum Daily Load for Escherichia coli (E. coli) For the Lower Wildcat Creek Watershed, Carroll, Clinton, Howard, Tippecanoe, and Tipton Counties 
Total Maximum Daily Load for Escherichia coli (E. coli) For the Galena River Watershed, La Porte and St. Joseph Counties 
Total Maximum Daily Load for Escherichia coli (E. coli) in the Highland-Pigeon Creek Watershed and Total Phosphorous for Hurricane Creek, Gibson, Pike, Vanderburgh, Posey, and Warrick Counties 
Total Maximum Daily Load for Escherichia coli (E. coli) in the Cicero Creek Watershed, Hamilton, Tipton, Boone and Clinton Counties 
Total Maximum Daily Load for Escherichia coli (E. coli) in the Upper White River Headwaters Watershed in Randolph, Delaware, and Henry Counties 
Busseron Creek Watershed TMDL Development* 
Pigeon River TMDL * 
*These TMDLs are currently in draft but are expected to be approved prior to Indiana's submission of its finalized 303(d) List of Impaired Waters to U.S. EPA. If any of these TMDLs are not yet approved at this time, their corresponding AU, presently proposed to be placed in Category 4A, will remain in Category 5A.

Table 4-B: Waterbody Impairments Proposed to be Removed from Category 5 to Category 4A of Indiana's Consolidated List for the 2010 cycle based on completion of a TMDL.
BASIN  HYDROLOGIC UNIT CODE  COUNTY  ASSESSMENT UNIT ID  ASSESSMENT UNIT NAME  CAUSE OF IMPAIRMENT  TMDL KEY 
UPPER WABASH  51201070102  TIPTON  INB0712_02  BROAD CREEK  E. COLI 
UPPER WABASH  51201070102  TIPTON  INB0712_T1001  NORTH CREEK  E. COLI 
UPPER WABASH  51201070102  TIPTON  INB0712_T1002  BROAD CREEK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070103  TIPTON  INB0713_01  TURKEY CREEK  E. COLI 
UPPER WABASH  51201070104  GRANT  INB0714_01  WILDCAT CREEK  E. COLI 
UPPER WABASH  51201070105  HOWARD  INB0715_02  GRASSY FORK  E. COLI 
UPPER WABASH  51201070105  GRANT  INB0715_T1002  PRAIRIE RUN  E. COLI 
UPPER WABASH  51201070106  HOWARD  INB0716_04  MUD CREEK  E. COLI 
UPPER WABASH  51201070107  HOWARD  INB0717_01  WILDCAT CREEK  E. COLI 
UPPER WABASH  51201070108  HOWARD  INB0718_01  KOKOMO CREEK  E. COLI 
UPPER WABASH  51201070108  HOWARD  INB0718_02  KOKOMO CREEK  E. COLI 
UPPER WABASH  51201070108  HOWARD  INB0718_T1005  KOKOMO CREEK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070108  HOWARD  INB0718_T1008  MARTIN-YOUNGMAN DITCH  E. COLI 
UPPER WABASH  51201070109  HOWARD  INB0719_01  WILDCAT CREEK  E. COLI 
UPPER WABASH  51201070109  HOWARD  INB0719_T1001  WILDCAT CREEK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070109  HOWARD  INB0719_T1002  WILDCAT CREEK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070109  HOWARD  INB0719_T1003  WILDCAT CREEK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070201  CLINTON  INB0721_01  WILDCAT CREEK, MIDDLE FORK  E. COLI 
UPPER WABASH  51201070201  CLINTON  INB0721_T1012  WILDCAT CREEK, MIDDLE FORK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070201  CLINTON  INB0721_T1013  WHITEMAN DITCH  E. COLI 
UPPER WABASH  51201070202  CARROLL  INB0722_01  WILDCAT CREEK, MIDDLE FORK  E. COLI 
UPPER WABASH  51201070202  CARROLL  INB0722_T1012  WILDCAT CREEK, MIDDLE FORK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070202  CARROLL  INB0722_T1013  MIDDLE FORK BRANCH - SCOFIELD DITCH  E. COLI 
UPPER WABASH  51201070202  CLINTON  INB0722_T1014  ROBINSON BRANCH  E. COLI 
UPPER WABASH  51201070203  CLINTON  INB0723_01  CAMPBELLS RUN  E. COLI 
UPPER WABASH  51201070203  CLINTON  INB0723_02  CAMPBELLS RUN  E. COLI 
UPPER WABASH  51201070203  CLINTON  INB0723_T1012  CRIPE RUN  E. COLI 
UPPER WABASH  51201070204  CLINTON  INB0724_01  WILDCAT CREEK, MIDDLE FORK  E. COLI 
UPPER WABASH  51201070204  CLINTON  INB0724_T1002  WILDCAT CREEK, MIDDLE FORK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070205  CLINTON  INB0725_01  WILDCAT CREEK, MIDDLE FORK  E. COLI 
UPPER WABASH  51201070205  TIPPECANOE  INB0725_02  WILDCAT CREEK, MIDDLE FORK  E. COLI 
UPPER WABASH  51201070205  TIPPECANOE  INB0725_02A  WILDCAT CREEK, MIDDLE FORK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070205  CLINTON  INB0725_T1012  WILDCAT CREEK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070205  CLINTON  INB0725_T1013  DUNK CREEK  E. COLI 
UPPER WABASH  51201070205  CLINTON  INB0725_T1014  HOG RUN  E. COLI 
UPPER WABASH  51201070205  TIPPECANOE  INB0725_T1015  HOFFMAN DITCH  E. COLI 
UPPER WABASH  51201070401  HOWARD  INB0741_03  WILDCAT CREEK, LITTLE, EAST FORK  E. COLI 
UPPER WABASH  51201070401  HOWARD  INB0741_04  WILDCAT CREEK, LITTLE, WEST FORK  E. COLI 
UPPER WABASH  51201070401  TIPTON  INB0741_T1006  KELLY DITCH  E. COLI 
UPPER WABASH  51201070402  HOWARD  INB0742_T1005  REED DITCH  E. COLI 
UPPER WABASH  51201070403  HOWARD  INB0743_04  WILDCAT CREEK  E. COLI 
UPPER WABASH  51201070403  HOWARD  INB0743_T1009  SPRING RUN  E. COLI 
UPPER WABASH  51201070403  HOWARD  INB0743_T1010  HALIHAN DITCH  E. COLI 
UPPER WABASH  51201070404  HOWARD  INB0744_01  HONEY CREEK  E. COLI 
UPPER WABASH  51201070404  HOWARD  INB0744_02  HONEY CREEK, WEST  E. COLI 
UPPER WABASH  51201070404  HOWARD  INB0744_T1002  WALNUT FORK  E. COLI 
UPPER WABASH  51201070405  HOWARD  INB0745_04  WILDCAT CREEK  E. COLI 
UPPER WABASH  51201070405  HOWARD  INB0745_T1009  WILDCAT CREEK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070405  HOWARD  INB0745_T1010  DEARINGER DITCH-KIDDLE DITCH  E. COLI 
UPPER WABASH  51201070405  HOWARD  INB0745_T1011  WILDCAT CREEK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070405  HOWARD  INB0745_T1012  WILDCAT CREEK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070405  HOWARD  INB0745_T1013  WILDCAT CREEK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070405  HOWARD  INB0745_T1014  WILDCAT CREEK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070406  HOWARD  INB0746_03  WILDCAT CREEK  E. COLI 
UPPER WABASH  51201070406  CARROLL  INB0746_03D  WILDCAT CREEK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070406  HOWARD  INB0746_T1005  PETES RUN  E. COLI 
UPPER WABASH  51201070406  HOWARD  INB0746_T1006  WILDCAT CREEK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070406  CARROLL  INB0746_T1007  WILDCAT CREEK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070406  CARROLL  INB0746_T1008  WILDCAT CREEK - UNNAMED TRIBUTARIES (BURLINGTON, IN)  E. COLI 
UPPER WABASH  51201070407  CARROLL  INB0747_01  WILDCAT CREEK  E. COLI 
UPPER WABASH  51201070407  CARROLL  INB0747_T1004  HURRICANE CREEK  E. COLI 
UPPER WABASH  51201070407  CARROLL  INB0747_T1005  WILDCAT CREEK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070408  CARROLL  INB0748_01  WILDCAT CREEK  E. COLI 
UPPER WABASH  51201070408  CARROLL  INB0748_01A  WILDCAT CREEK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070408  CARROLL  INB0748_T1001  WILDCAT CREEK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070408  CARROLL  INB0748_T1002  WILDCAT CREEK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070408  CARROLL  INB0748_T1003  WILDCAT CREEK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070408  CARROLL  INB0748_T1004  WILDCAT CREEK - UNNAMED TRIBUTARY  E. COLI 
UPPER WABASH  51201070409  TIPPECANOE  INB0749_01