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North Canadian RiverOklahoma River

Shell Creek

Draft TMDLs For Bacteria

22ndnd PUBLIC MEETING PUBLIC MEETINGSeptember 12, 2006September 12, 2006

AGENDAAGENDA

• Welcome / Introductions

• Recap Current Studies

• Revisions in Version 2

• Issues Raised To Date

• NPS Watershed Plans (OCC)

• Questions

• Comments

Review Current Studies

North Canadian River: Canton Dam to Yukon, including Shell Creek

Prepared by Parsons

And DEQ

North Canadian River & Oklahoma River: Yukon to Dale

Prepared by ACOG

Presented by Paul Yue

NC02

NC05

NC03

NC04

NC08

NC06

NC07

NC01

Shell Crk

Yukon

Lake Overholser

HW 81

Del City Midwest City

Dale

Upstream of OKC discharge

XXX Rd

Monitoring Data

• If more than 10% of data above the standards Problem

• North Canadian River (NC01)FC – 33% exceed

E-Coli – 13% exceedEnterococci – 94% exceed

North Canadian River: Canton Dam to Yukon, including Shell Creek

Prepared by Parsons and DEQ

North Canadian River

• Enterococci - 89% Reduction

Shell Creek

• Fecal Coliform - 92% Reduction

REDUCTION RATES (Parsons Report)

Streams Fecal Coliform

E Coli Enterococci

N Canadian River

68% 48% 89%

Shell Creek 92% 62% 90%

North Canadian River & Oklahoma River: Yukon to Dale

Prepared by ACOG

North Canadian River (ACOG)

EL RENO STATION ENTEROCOCCIREDUCTION GOAL: 95.6%

REDUCTION RATES (ACOG Report)

Sites Fecal Coliform

E. Coli Enterococci

NC01 92.4% None 95.6%

NC02 53.1% None 95.9%

NC03 70.7% None 81.0%

NC04 94.0% 63.0% 99.3%

NC05 98.2% 63.8% 99.7%

NC06 None None 87.7%

NC07 None None 4.9%

NC08 18.3% None 83.2%

Proposed RevisionsIn Version 2

Demonstrate progress toward meeting the reduction goals

Demonstrate progress toward attainment of water quality standards

What Is Necessary To Comply With The TMDL ?

Clarifications added

“Permitted MS4 stormwater discharges are considered point sources. Since these sources are associated with wet weather events, they are assigned the same pathogen reduction goals as the nonpoint source load allocations. These reduction goals apply only to the pathogen contribution from within the MS4. Permitted stormwater dischargers are not expected orrequired to produce the entire pathogen loading reduction specified in this TMDL. ”

Do Stormwater Dischargers Have To Produce The Entire Reduction Required

By The TMDL ?

“The suitability of the current criteria for pathogens and the beneficial uses of the receiving stream should be reviewed.”

Are Current Water Quality Standards Appropriate ?

3 Approaches To WQS Revisions

• Remove The Use Requires a Use Attainability Analysis Existing Uses Cannot Be Removed

Are Current Water Quality Standards Appropriate ?

3 Approaches To WQS Revisions

• Modify Application Of The Criteria Exemption For High Flows Allowance For “Natural” Conditions Establish A Subcategory Of The Use Special Provision For Urban Areas

Are Current Water Quality Standards Appropriate ?

3 Approaches To WQS Revisions

• Revise The Numeric Criteria Remove Indicator(s) Change The Numeric Values Risk-Based Approaches

Are Current Water Quality Standards Appropriate ?

“Unless or until the water quality standards are revised and approved by EPA, Federal rules require that this TMDL must be based on attainment of the current standards. If revisions to the pathogen standards are approved in the future, the reductions specified in this TMDL will be re-evaluated.”

Are Current Water Quality Standards Appropriate ?

Appendix FStormwater Permit Provisions

• Yukon

• Mustang

• Bethany

• Warr Acres

• Moore

• Del City

• Midwest City

• Oklahoma City

• Spencer

• Nicoma Park

• Choctaw

• ODOT

• OTA

• Tinker AFB

Appendix FStormwater Permit Provisions

OKR04 Requirements

• Ensure that discharges that would cause or contribute to any water quality standards exceedance will not occur

• Discharge of a pollutant into any water for which a Total Maximum Daily Load (TMDL) for that pollutant has been either established or approved by the DEQ or EPA is prohibited, unless your discharge is consistent with that TMDL

Appendix FStormwater Permit Provisions

1. Develop A Bacteria Reduction Plan

2. Develop Or Participate In A Bacteria Monitoring Program

3. Annual Reporting

“Compliance with the following provisions will constitute compliance with the requirements of this TMDL”.

Appendix FStormwater Permit Provisions

1. Develop A Bacteria Reduction Plan

• Consider ordinances or other regulatory mechanisms• Evaluate the existing SWMP• Educational programs• Implement BMPs• Modifications to the dry weather field screening and illicit discharge detection and elimination program• Periodic evaluation of effectiveness• Ensure progress toward attainment of water quality standards.

• Implementation schedule (2 years)

Appendix FStormwater Permit Provisions

2. Develop Or Participate In A Bacteria Monitoring Program

• Establish the effectiveness of the selected BMPs• Demonstrate progress toward the reduction goals• TMDL monitoring schedule or commitment to participate in regional program (18 months)• Implemented within 2 years

Appendix FStormwater Permit Provisions

3. Annual Reporting

• Include a TMDL implementation report in the annual report.• Status and actions taken to implement the TMDL

Appendix FCAFO Permit Provisions

• These NPDES permits are issued by EPA

• CAFO permits in the watershed and their management plans must be reviewed

• Further actions necessary to reduce bacteria loads and achieve progress toward meeting the reduction goals must be implemented

• Forward to EPA for follow up

Issues Raised To Date

Monitoring Data

Average Fecal Coliform Conc

0500

1000150020002500300035004000

Fec

al C

olif

orm

(/1

00 m

l)

Monitoring Data

Average E Coli Conc

0100200300400500600700800

E C

oli

(/10

0 m

l)

Monitoring Data

Average Enterococci Conc.

02000400060008000

100001200014000

En

tero

cocc

i (/1

00 m

l)

Applicability Of TheLoad Duration Curve Model

• Load Duration Curve (LDC) Method is approved by EPA

• LDC – a proven method for TMDL development

Applicability Of TheLoad Duration Curve Model

• LDC – used by many states (AR, LA, TX, KS, MO, CA, OH, TN, NC, ND, WI, VA, OR, NJ, IN, …)

• And EPA

Geometric Meanvs

Maximum ValuesFecal Coliform

Impaired = Violate EITHER TestNot Impaired = Pass BOTH Tests

E. Coli. And EnterococciImpaired = Violate BOTH TestsNot Impaired = Pass EITHER Test

For Impairment determination, use 2-year geometric meanNot 30-day geometric mean (OAC 785:46-15)

Bacterial Source Tracking (BST)

• BST is considered by the experts to still have great uncertainty.

• “In all, fewer than 30%percent of challenge isolates were classified to the correct source-animal species by any method” – USGS Report http://wv.usgs.gov/press.html

BST Examples

• Turkey Creek Watershed, OK (2003) by USGS (43% isolates unidentified)

• Four Mile Run – Northern Virginia (49% isolates unidentified)

North Canadian River (ACOG)

EL RENO STATION ENTEROCOCCIREDUCTION GOAL: 95.6%

REDUCTION RATES ** (ACOG Report)

Sites Fecal Coliform

E. Coli Enterococci

NC01 88.8 % 31.0 % 98.5 %

NC02 95.5 % 44.0 % 98.4 %

NC03 95.1 % 96.8 % 98.7 %

NC04 79.0 % None 98.7 %

NC05 92.8 % None 99.1 %

NC06 82.0 % None 98.8 %

NC07 88.4 % None 99.9 %

NC08 67.5 % None 86.5 %** Re-calculated reduction rates

REDUCTION RATES (ACOG Report)

Sites Fecal Coliform

E. Coli Enterococci

NC01 92.4% None 95.6%

NC02 53.1% None 95.9%

NC03 70.7% None 81.0%

NC04 94.0% 63.0% 99.3%

NC05 98.2% 63.8% 99.7%

NC06 None None 87.7%

NC07 None None 4.9%

NC08 18.3% None 83.2%

Nonpoint SourcesWhat Programs Are Available?

What Are The Plans ForThe North Canadian River?

Greg KloxinOklahoma Conservation Commission

What Happens Next ?

• Comments Accepted Through October 12• Comment Responsiveness Summary• Final Draft Submitted For EPA Approval• Incorporate In Water Quality Management Plan

How To Provide Comments Oral Comments Accepted This Evening

By Mail:Dr. Karen MilesWater Quality DivisionOklahoma Department of Environmental QualityP.O. Box 1677Oklahoma City, OK 73101-1677

By Email:Karen.Miles@deq.state.ok.us

Comments Must Be Received By

October 12 !

QUESTIONS

COMMENTS

Thank You

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