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Pathogen and Turbidity TMDLs and OKR04

Pathogen and Turbidity TMDLs and OKR04. Richard Smith, INCOG Oklahoma MS4 Conference Oklahoma City Zoo Education Center November 7-8, 2012. 303(d) List and TMDL Basics. 303(d) WQ studies : formal, lengthy, mostly OWRB & OCC, Part 136 and USAP procedures.

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Pathogen and Turbidity TMDLs and OKR04

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  1. Pathogen and Turbidity TMDLs and OKR04 Richard Smith, INCOG Oklahoma MS4 Conference Oklahoma City Zoo Education Center November 7-8, 2012

  2. 303(d) List and TMDL Basics • 303(d) WQ studies: formal, lengthy, mostly OWRB & OCC, Part 136 and USAP procedures. • TMDL(Total Maximum Daily Load) is usual outcome. • Stormwater permitteesmust address 303(d) and TMDLs in their SWMPs. • 2010 303(d) list– is latest EPA approved. • Fecal coliform– no longer in WQS = no more FC TMDLs. • Models: Load Duration Curve mostly, some QUAL models. • BMPs & Monitoring– preferred by ODEQ over numeric limits.

  3. National 303(d) Statistics Top 15 Causes of 303(d) Impairment Nationally = Top 5 in Oklahoma Created from data on EPA website: http://iaspub.epa.gov/waters10/attains_nation_cy.control?p_report_type=T

  4. TMDLs & WLA_MS4 Calculations TMDL = Σ WLA + Σ LA + MOS + WLA_MS4 Amount of Pollution A Waterbody Can Receive Without Violating Water Quality Standards Point Sources = Wasteload Allocations “LA” Nonpoint Sources & Natural Background = Load Allocations “WLA” Photos by Richard Smith, INCOG

  5. What is a Wasteload Allocation ? • Sets NPDES / OPDES permit limits. • For Municipal WWTP discharges (WLA): • Flow (MGD) • BOD & Ammonia • Bacteria • Toxics (metals, ammonia) • Both concentrations (as mg/L) and mass (as lbs/day). • Seasonal limits (summer, spring, winter). • For Stormwater discharges (WLA_MS4): • TMDL may or may not have numeric mass limits. • TMDL report specifies compliance strategy = BMPs and monitoring. • WLA_MS4 is either aggregate or individual.

  6. Latest TMDL Efforts in Oklahoma • Managed by ODEQ, with contracts to Parsons Engineering. Some done by ODEQ, a few by INCOG and ACOG. • Bacteria (many hundreds) began ~2005, continue through 2015. Mostly Parsons. LDC Method. Total MS4_WLA. • Turbidity (hundreds) began 2009, continue through 2015. Mostly Parsons. LDC Method. No MS4_WLA. • Metals and Dissolved Solids – just starting new TMDLs. • No methods yet for pesticides or other parameters. • DO-based TMDLs only when 303(d), all others are WLA. • No TMDL Implementation Plans. Few Watershed Base Plans.

  7. Complex TMDL Implementation • Non-Permitted Sources: • Agriculture no enforcement, voluntary only; 319(h) programs. • Rural Landsno enforcement, voluntary only; 319(h) programs. • Non-permitted MS4sno enforcement, no requirements. • Permitted Sources: • WWTPs must disinfect effluents + added treatment. • MS4s (Phase 1 & 2)must implement BMPs and monitor. • CAFOs develop a “water quality-based reduction plan” if needed and comply with the ELG and EPA’s NPDES permit for CAFOs.

  8. Typical Urban Bacteria Sources Controllable Partly Controllable Uncontrollable Regrowth

  9. EPA’s Bacteria Study 2007-2012 • Correlation between human illness and exposuresto: • WWTP (treated) effluent discharges. • Untreated (raw) sewage in water. • Animal feces in water. • Improving laboratory test methods. • Selection of better parametersfor use as WQS. • More accurate numerical criteria. • Differences in susceptibility between children & adults. • Sampling / preservationmethods. • Surrogate parameters(e.g., pharmaceuticals). • Bacteria Source Tracking& other differentiating tests.

  10. “Pathogens” vs. Indicator Organisms • 303(d) testing is for “indicator organisms”. • Indicators are in fecesof all warm-blooded mammals. • No direct 303(d) testing for pathogenic strains. • Presence of “indicators” = potential for pathogens. • Pathogens can be bacteria, viruses, protozoans, etc. • Positive indicator tests: • May not be from human sources. • May have no pathogens present.

  11. Difficulties Controlling Bacteria • Most urban bacteria studies show animals as the primary sources: • Pets (dogs and cats) • Wildlife (small birds and critters) • Migratory, non-migratory large birds (geese, ducks) • Livestock in urban areas • Most WWTP discharges are disinfected or soon will be. • Human sewage (bypasses). • Regrowth in stream beds and MS4 pipes.

  12. How Stormwater Fits Into a TMDL Urban runoff is “nonpoint”. EPA put stormwater into its NPDES point source permit program. This turned “nonpoint” into “point source” for enforcement. TMDLs therefore treat stormwater permittees as “point sources” = WLA_MS4 Photo by INCOG

  13. Effectiveness Monitoring EPA is considering requiring sampling for several purposes: Demonstrate BMP effectiveness. “Outcome-Based” = monitoring Compliance with TMDL implementation plans. Demonstrate attainment of WQS. Document overall program effectiveness. “Output-Based” Image by Richard Smith, INCOG

  14. How OKR04 Addresses 303(d) PART II.B CONTENTS OF THE NOTICE OF INTENT 2. Information on the Municipal Separate Storm Sewer System The name of the major receiving water(s) and an indication of whether any of your receiving waters are on the latest CWA §303(d) list of impaired waters. If you have discharges to 303(d) waters, a certification that your Storm Water Management Program complies with the requirements of PART III. A. Part III.A COMPLIANCE WITH WATER QUALITY STANDARDS Operators seeking coverage under this permit shall not be causing or have the reasonable potential to cause or contribute to a violation of a water quality standard. If you have discharges to receiving waters included on the latest CWA § 303(d) list of impaired waters, you must document in your SWMP how you will comply with this requirement.

  15. How OKR04 Addresses 303(d) PART VIII.B REQUIREMENTS FOR SMALL MS4s THAT ELECT TO ADOPT THE OPTIONAL PERMIT REQUIREMENTS FOR MUNICIPAL CONSTRUCTION ACTIVITIES [7th MCM] 8. Storm Water Pollution Prevention Plans b. If your construction site discharges into a receiving water which has been listed on the Clean Water Act 303(d) list of impaired waters, and your discharges contain the pollutant(s) for which the water body is impaired, you must document in your SWP3 how the BMPs and other controls selected for your site will control the discharge of the pollutant(s) of concern.

  16. TMDL Requirements in OKR04 PART I.C LIMITATIONS ON COVERAGE 6. Discharges not consistent with a Total Maximum Daily Load (TMDL) 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, unlessyour discharge is consistent with that TMDL. You must incorporate into your SWMPany conditions necessary to ensure discharges are consistent with the assumptions and requirements of any such TMDL. This eligibility condition applies at the time you submit a Notice of Intent for coverage.

  17. TMDL Requirements in OKR04 PART III.B ESTABLISHED TOTAL MAXIMUM DAILY LOAD ALLOCATIONS 1. If a TMDL is established…, your discharges must meet the requirements of the TMDL and/or its associated implementation plan within any timeframes established in the TMDL. Monitoring and reporting of the discharges may also be required as appropriate to ensure compliance with the TMDL. 2. …you must incorporate any limitations, conditions, and requirements applicable to your discharges into your SWMP to ensure that the waste load allocation, load allocation and/or the TMDL’s associated implementation plan will be met within any timeframes established in the TMDL. Monitoring and reporting of the discharges may also be required as appropriate to ensure compliance with the TMDL.

  18. TMDL Report’s Appendix F for MS4s “Compliance with the following provisions will constitute compliance with the requirements of this TMDL”. 1. Bacteria Reduction Plan (submit plan within 12 months of notification). 2. Bacteria Monitoring Program (submit monitoring schedule or regional commitment within 18 months and fully implement within 3 years of notification). 3. TMDL Implementation Report (submit annually with Phase II Annual Report). ODEQ has not yet sent out any TMDL Notifications to start the “Appendix F clock” ticking.

  19. What’s Driving the New EPA ? • Historically: • 1990 & 1999 – Phase I & II regulations. • EPA guidance, memorandums, etc. • General Permits for each State. • Now: • Construction ELG’s = rulemaking. • Lawsuits= court mandates. • Continued urban pollution & 303(d)problems. • Fear of more TMDL lawsuits. • New types of TMDLsthat address urban NPS. • National Research Council’s stinging report. • Political climatein Washington.

  20. EPA 2002 Memorandum From EPA Memorandum, November 22, 2002, “Establishing Total Maximum Daily Load (TMDL) Wasteload Allocations (WLAs) for Storm Water Sources and NPDES Permit Requirements Based on Those WLAs” “EPA expects that most [water quality-based effluent limits] … will be in the form of BMPs, and that numeric limits will be used only in rare instances.” “EPA’s policy recognizes that …storm water discharges are … not easily characterized, only in rare cases will it be feasible or appropriate to establish numeric limits for municipal and small construction storm water discharges.”

  21. EPA 2010 Memorandum • “Since 2002, States and EPA have obtained considerable experience in developing TMDLs and WLAs…. The technical capacity to monitorstormwater and its impacts …has increased.” • Where discharges have the reasonable potential to cause water quality problems, permits should contain numeric effluent limitations. • Measurable Goals should be enforceable provisions. • PAs should consider BMP numeric benchmarks and monitoringfor estimating BMP effectiveness. The 2010 EPA Memorandum was pulled for further consideration due to nationwide concerns.

  22. Impervious Cover & Runoff Quality Graph by Richard Smith, INCOG

  23. Examples of Current Standards for New Development Volume Retention Data from 2010 EPA PowerPoint

  24. Multi-Pollutant TMDLs & One Target New EPA strategy: Reducing flow reduces all pollutant loads. • Reduce flow by: • Removing impervious cover, • Disconnecting impervious cover, • Increase use of porous surfaces, • Attenuate impervious cover using flow-based LID. • TMDL goal: Avoids individual pollutant TMDL goals. • Already being donein several EPA Regions.

  25. Are there any Questions ? Photo by Richard Smith, INCOG

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