Water Quality Standards for Contact Recreation, Bacteria TMDLs, and MS4 Permits

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11th Annual EPA Region 6MS4 Operators’ ConferenceHouston, TX

Water Quality Standardsfor Contact Recreation,Bacteria TMDLs, and MS4 Permits

11th Annual EPA Region 6MS4 Operators’ ConferenceHouston, TX

Water Quality Standardsfor Contact Recreation,Bacteria TMDLs, and MS4 Permits

Presented byMICHAEL F. BLOOM, P.E., CFMSenior Associate

TOPICSTOPICS

• Technical basis for freshwater criterion

• Research for new standard

• Current Region 6 standards

• Region 6 contact recreation impairments

• Recent bacteria TMDLs

• Implications for MS4 permits







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LAKE ERIE, ERIEPENNSYLVANIA


KEYSTONE LAKEOKLAHOMA


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STUDY CONDITIONSSTUDY CONDITIONS

BEACH

LAKEWWTP

RAW RESULTS

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ILLNESS RATES VS. E. COLI DENSITIES

R2 = 0.80

EPA CRITERIA

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CONCERNSCONCERNS

• Actual level of exposure was not evaluated;

• Actual pathogenic organisms not measured;

• Only two of nine trials showed statistical differences between swimmers and non-swimmers;

• The correlation between swimmer and non-swimmer illness rates was 0.67;

Haas, C., et. al. 2006. Expert Review Report Regarding United States Environmental Protection Agency’s Water Quality

Criteria for Bacteria – 1986: Application to Secondary Contact Recreation. (Report No. 2006-38) Metropolitan Water Reclamation District of Greater Chicago, Chicago, IL., July.

CONCERNSCONCERNS

• Only “highly credible” GI symptoms were “counted”in the regression;

• The hypothesis that indicator densities are correlated with pathogen densities has not been tested; and,

• Application of the criterion to bodies of water other than lakes with nearby municipal wastewater discharges is questionable.

Haas, C., et. al. 2006. Expert Review Report Regarding United States Environmental Protection Agency’s Water Quality Criteria for Bacteria – 1986: Application to Secondary Contact Recreation. (Report No. 2006-38) Metropolitan Water Reclamation District of Greater Chicago, Chicago, IL., July.

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APPLIED CONDITIONSAPPLIED CONDITIONS

STUDY CONDITIONSSTUDY CONDITIONS

BEACH

LAKEWWTP

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OKLAHOMA STANDARDSOKLAHOMA STANDARDS

SOURCE: http://www.owrb.ok.gov/util/rules/pdf_rul/Chap45.pdf

OKLAHOMA STANDARDS (Continued)OKLAHOMA STANDARDS (Continued)

SOURCE: http://www.owrb.ok.gov/util/rules/pdf_rul/Chap45.pdf

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TEXAS STANDARDSTEXAS STANDARDS

SOURCE: http://info.sos.state.tx.us/pls/pub/readtac$ext.ViewTAC?tac_view=4&ti=30&pt=1&ch=307&rl=Y

(A) Freshwater

(i) Contact recreation. The geometric mean of E. coli should not exceed 126 per 100 ml. In addition,

single samples of E. coli should not exceed 394 per 100 ml. Contact recreation applies to all bodies of

freshwater except where specifically designated otherwise in §307.10 of this title.

(ii) Noncontact recreation. The geometric mean of E. coli should not exceed 605 per 100 ml.

(B) Saltwater.

(i) Contact recreation. The geometric mean of Enterococci should not exceed 35 per 100 ml. In

addition, single samples of Enterococci should not exceed 89 per 100 ml. Contact recreation applies to all

bodies of saltwater, except where specifically designated otherwise in §307.10 of this title.

(ii) Noncontact recreation. The geometric mean of Enterococci should not exceed 168 per 100 ml.

(C) Fecal coliform bacteria. Fecal coliform bacteria can be used as an alternative instream indicator of

recreational suitability until sufficient data are available for E coli or Enterococci. For segments designated as

oyster waters in §307.10 of this title, fecal coliform can continue to be used as an indicator of recreational

suitability because fecal coliform is used as the indicator for suitability of oyster water use as described in

paragraph (3)(B) of this subsection. Fecal coliform can also continue to be used as a surrogate indicator in

effluent limits for wastewater discharges. Fecal coliform criteria are the same for both freshwater and

saltwater, as follows.

(i) Contact recreation. The geometric mean of fecal coliform should not exceed 200 per 100 ml. In

addition, single samples of fecal coliform should not exceed 400 per 100 ml.

(ii) Noncontact recreation. Fecal coliform shall not exceed 2,000 per 100 ml as a geometric mean. In

addition, single samples of fecal coliform should not exceed 4,000 per 100 ml.

NEW MEXICO STANDARDSNEW MEXICO STANDARDS

SOURCE: http://www.nmcpr.state.nm.us/nmac/parts/title20/20.006.0004.pdf

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ARKANSAS STANDARDSARKANSAS STANDARDS

SOURCE: http://www.adeq.state.ar.us/regs/files/reg02_final_071125.pdf



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LOUISIANA STANDARDSLOUISIANA STANDARDS

SOURCE: http://deq.louisiana.gov/portal/Portals/0/planning/regs/title33/33v09.pdf

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LOUISIANA STANDARDSLOUISIANA STANDARDS

SOURCE: http://deq.louisiana.gov/portal/Portals/0/planning/regs/title33/33v09.pdf

IMPAIRMENTS NATIONALLYIMPAIRMENTS NATIONALLY

• Total number of causes of impairment reported nationally is 70,000

• Pathogens reported as the cause of impairment 10,000 times

• Pathogens are the number one impairment cause nationally

• More pathogen TMDL’s have been adopted than any other pollutant

SOURCE: Section 305(b) report available on EPA website. Seehttp://iaspub.epa.gov/waters10/attains_nation_cy.control?p_report_type=T

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SOURCE: Section 305(b) report available on EPA website. Seehttp://iaspub.epa.gov/waters10/attains_nation_cy.control?p_report_type=T

EPA Region 6 StatisticsEPA Region 6 Statistics

665

70

479

106

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LA

NANA131191Total No. of Adopted TMDLs

NANA45160Adopted TMDLs for Bacteria*

NANA8821,640Total No. of Impairments

NANA437549Total No. of Pathogens Impairments

NANA11Rank of Pathogens Among Impairments

ARNMTXOK

*Includes E. Coli, Fecal Coliform, and Enterococcus bacteria.

SUMMARY OF BACTERIA LEVELS OBSERVED IN REPRESENTATIVE MONITORING CONDUCTED BY

MEDIUM AND LARGE MS4 OPERATORS

SOURCE: Pitt, R. 2007. Website: http://unix.eng.ua.edu/~rpitt/Research/ms4/mainms4.shtml

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BUFFALO & WHITEOAK BAYOUS (HOUSTON, TX)BUFFALO & WHITEOAK BAYOUS (HOUSTON, TX)


SOURCE: http://www.tceq.state.tx.us/assets/public/implementation/water/tmdl/22buffalobayou/22-bbbwbtmdl_adopted.pdf

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BLEST means “BACTERIA LOAD ESTIMATION SPREADSHEET TOOL”



BLEST means “BACTERIA LOAD ESTIMATION SPREADSHEET TOOL”

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“JTF” MS4 Permit Impacts“JTF” MS4 Permit Impacts

• Prior to TMDL adoption

• Prior to Implementation Plan adoption

• Develop and implement Interim Bacteria Reduction Plan

– Identify and remove impediments to Green Infrastructure

– Revise post-construction BMP manuals

– Develop measurable goals

– Assess potential bacteria sources

– Develop interim controls for bacteria sources

SOURCE: Hosch, C., 2008. Conditional No Objection to Draft Permit… TXS001201. Letter to Chris Linendoll, Section Manager, Wastewater Permitting Section, TCEQ from Claudia Hosch, US EPA. October 3.

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JustificationJustification

Proceeding with interim bacteria reduction activities in

the permit at this time, in advance of bacteria TMDLs,

supports the statutory and regulatory requirements

for MS4 permits to reduce the discharge of pollutants

to the maximum extent practical; effectively prohibit

the discharge of non-storm water into the MS4; ensure

discharges do not cause or contribute to violations of

water quality standards; and contribute to necessary

pollutant reductions identified by the TMDLs as they

are completed.


Other ThoughtsOther Thoughts


• General Permits will be impacted also

– Construction General

– Small MS4 General Permits

• Wastewater permits have been impacted

– Monitoring

– Effluent limits

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TOPICSTOPICS













FOR ADDITIONAL INFORMATIONFOR ADDITIONAL INFORMATION

Michael F. Bloom, P.E., CFMSenior AssociatePBS&J1250 Wood Branch Park Drive, Suite 300Houston, TX [email protected]

Water Quality Standards for Contact Recreation, Bacteria TMDLs, and MS4 Permits

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