Statewide Mercury Total Maximum Daily Load (TMDL)
The U.S. Environmental Protection Agency approved Minnesota's Statewide Mercury Total Maximum Daily Load study in March 2007. Since then, the MPCA has worked with stakeholders representing a broad range of interests to identify strategies and timelines that would be included in an implementation plan. The stakeholders' recommendations, completed in June 2008, are contained in the Strategy Framework for Implementing Minnesota's Statewide Mercury TMDL.
The impaired waters TMDL process consists of data collection and assessment, listing those waters not meeting water quality standards, developing a pollution reduction plan, implementing the plan, and then evaluating the implementation by collecting more data.
Mercury impairments make up two-thirds of the 2004 list of impaired waters for Minnesota. The mercury impairments on the list are mainly for fish tissue concentration exceedences, but also include water column mercury concentration exceedences.
Minnesota’s Mercury Impaired Waters (in red)

The Statewide Mercury TMDL
There is a strong connection between the Minnesota Department of Health Fish Consumption Advisory (FCA) and MPCA’s impairment determination. When the FCA limitation is more restrictive than one meal per week, the water body is impaired.
There are strong regional differences between northeastern (NE) Minnesota, dominated by forests and wetlands, and the rest of the state, with the NE having significantly higher mercury concentrations in fish.
Atmospheric deposition of mercury is uniform across the state and supplies more than 99.5% of the mercury getting into fish. Agency research has demonstrated that 70% of current mercury deposition in Minnesota comes from anthropogenic [people] sources and 30% from natural sources, such as volcanoes. There are no known natural sources in the state that emit mercury directly to the atmosphere.
There is a slight general downward trend in fish tissue mercury concentrations, but lakes still remain impaired. About 90% of the mercury deposition in the state originates from outside the state, so the first cut allocation is a 90% federal share and a 10% state share; the federal government will be responsible for meeting its reduction goal, developing schedules and meeting reasonable assurance requirements of the Clean Water Act (CWA).
The long-term goal of the mercury TMDL is for the fish to meet water quality standards; the approach for Minnesota’s share is mass reductions from state mercury sources. This mercury TMDL establishes that there needs to be a 93% reduction in state emissions from 1990 for the state to meet its share. Water point sources will be required to stay below 1 percent of the total load to the state and all but the smallest dischargers will be required to develop mercury minimization plans. Air sources of mercury will have a 93% emission reduction goal from 1990 levels. Air sources will be divided into three sectors: products, energy, and mining.
EPA Approval
- EPA Revision Approval 9/28/2010
Final Appendix A (wq-iw4-01m)
Final EPA approval letter (wq-iw4-01g)
EPA Approval Letter, April 3, 2008 [2 pages]
EPA TMDL Decision Document [8 pages]
Table 1: Revised Appendix A of the approved Mercury TMDL [21 pages]
Table 2: New Mercury Impairments included in Appendix A [2 pages]
Table 3: Lakes and river reaches removed from the 2006 TMDL List [2 pages]
Table 4: Changes in assessment unit ID #s [2 pages]
Table 5: Corrections to Region locations [1 page]
Table 6: Revised Appendix B of the approved Mercury TMDL [29 pages]
Table 7: Change in NPDES Permit number from the original Appendix B [1 page]
Attachment 1: The original EPA approval letter for the MPCA Statewide Mercury TMDL, March 27, 2007 [38 pages]
Work Products
Final Minnesota Mercury TMDL Approved by the EPA on March 27, 2007 (file size = 2.2 MB) (wq-iw4-01b)
Appendices (wq-iw4-01h)
Sources of Mercury Pollution and the Methylmercury Contamination of Fish in Minnesota (p-p2s4-06)
Response to Comments
Issue by Person Matrix (wq-iw4-01j)
Issue Response Table of Contents (wq-iw4-01j-toc)
Cover Letter and Response to Comments wq-iw4-01k)- Impaired Waters covered and not covered by the Hg TMDL
Links
Contact Information
Howard D. Markus, Ph.D., P.E.
Mercury TMDL Coordinator
Minnesota Pollution Control Agency
520 Lafayette Road N.
St. Paul, MN 5515-4194
651-757-2551; 800-657-3864
howard.markus@state.mn.us
