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HomeMy WebLinkAboutTMDLTCEQ Draft for Public Comment April 2 012 Implementation Plan for Three Total Maximum Daily Loads for Indicator Bacteria in the Carters Creek Watershed Segments 1209C, 1209D, 1209L Assessment Units 1209C_o1, 1209D_o1, 12091_01 Water Quality Planning Division, Office of Water TEXAS COMMISSION ON ENVIRONMENTAL QUALITY Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Distributed by the Total Maximum Daily Load Team Texas Commission on Environmental Quality MC-203 P.O. Box 13087 Austin, Texas 78711-3087 E-mail: tmdl@tceq.texas.gov TMDL implementation plans are also available on the TCEQ website at: <www.tceq.texas.gov/implementation/water /tmdl/ > The preparation of this report was financed in part through grants from the U.S. Environmental Protection Agency. This plan is based in part on technical reports prepared for the TCEQ by the Texas Insti- tute for Applied Environmental Research (TIAER), and in large part on the recommendations of the four stakeholder work groups organized by the Texas Water Resources Institute (TWRI). Agencies engaged in the development of this document include: Brazos County Health Department USDA Natural Resources Conservation Service, Brazos County Field Office Brazos County Road and Bridge Department Brazos County Soil and Water Conservation District #450 Brazos River Authority City of Bryan City of College Station Texas A&M University Texas AgriLife Extension Service Texas AgriLife Research Texas Department of Transportation, Bryan District Texas Parks and Wildlife Department In compliance with the Americans with Disabilities Act, this document may be requested in alternate formats by contacting the TCEQ at 512/239-0028, Fax 239-4488, or 1-800-REIAY-TX (TDD), or by writing P.O. Box 13087, Austin, TX 78711-3087. Texas Commission on Environmental Quality For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Contents Executive Summary ................................................................................................................................ 1 Management Measures .................................................................................................................... 3 Control Actions ................................................................................................................................. 3 Introduction ........................................................................................................................................... 3 Watershed Overview .............................................................................................................................. 5 SummaryofTMDLs .............................................................................................................................. 6 Pollutant Sources and Loads ........................................................................................................... 7 Waste Load Allocation (WLA) ......................................................................................................... 8 Wastewater Treatment Facilities ............................................................................................... 8 Regulated Stormwater ................................................................................................................ 9 Load Allocation (LA) ...................................................................................................................... 10 Allowance for Future Growth (FG) ................................................................................................ 11 Total Maximum Daily Load (TMDL) ............................................................................................. 12 Implementation Strategy ..................................................................................................................... 12 Adaptive Implementation ............................................................................................................... 13 Activities and Milestones ................................................................................................................ 13 Management Measures and Control Actions ...................................................................................... 13 Management Measures ................................................................................................................... 13 Control Actions ............................................................................................................................... 14 Management Measure 1.0 .............................................................................................................. 14 Responsible Parties and Funding ............................................................................................ 16 Measurable Milestones .............................................................................................................. 17 Management Measure 2 .0 ............................................................................................................. 20 Responsible Parties and Funding ............................................................................................ 20 Measurable Milestones .............................................................................................................. 21 Management Measure 3.0 ............................................................................................................. 25 Responsible Parties and Funding ............................................................................................ 26 Measurable Milestones ............................................................................................................. 27 Management Measure 4.0 ............................................................................................................. 30 Responsible Parties and Funding ............................................................................................ 30 Measurable Milestones .............................................................................................................. 31 Management Measure 5.0 ............................................................................................................. 33 Responsible Parties ................................................................................................................... 38 Measurable Milestones ............................................................................................................. 40 Management Measure 6.o ............................................................................................................. 44 Responsible Parties ................................................................................................................... 45 Measurable Milestones ............................................................................................................. 46 Control Action 1.0 ........................................................................................................................... 49 Responsible Parties ................................................................................................................... 50 Measurable Milestones .............................................................................................................. 51 Control Action 2 .0 .......................................................................................................................... 54 Responsible Parties ................................................................................................................... 55 Measurable Milestones ............................................................................................................. 55 Sustainability ....................................................................................................................................... 57 Water Quality Indicators ..................................................................................................................... 57 Implementation Milestones ................................................................................................................ 58 Communication Strategy ..................................................................................................................... 58 Texas Commission on Environmental Quality iii For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed References ............................................................................................................................................ 60 Appendix A. I-Plan Matrix ................................................................................................................. 63 Appendix B. Load Reduction Estimates ............................................................................................ 75 Figures Figure 1. Figure 2. Tables Table 1. Table 2. Table 3. Table 4. Table 5. Table 6. Table 7. Table 8. Table 9. Table 10. Tablen. Table 12. Table 13. TableA-1. TableA-2. TableA-3 TableA-4 TableA-5 TableA-6. Table A-7. TableA-8. Table B-i. Carters Creek Project Segments .................................................................................... 2 Carters Creek Watershed ............................................................................................... 5 Summary of routine monitoring E. coli data, August 1997 -December 2010 ........... 7 Waste Load Allocations for TPDES Regulated Facilities ............................................. 9 TMDL Allocation Summary for Impaired Creeks Ooads in billion MPN/day) ......... 12 Summary of Management Measure 1: Watershed Monitoring and Assessment ..... 19 Summary of Management Measure 2: Possible Tax Valuation Modification .......... 23 Summary of Management Measure 3: OSSF Education, Inspection, Operation, Maintenance, and Tracking ......................................................................................... 28 Summary of Management Measure 4: SSO Initiative ............................................... 32 Summary of Management Measure 5: Voluntary Agricultural BMPs ...................... 42 Summary of Management Measure 6: Development and Redevelopment Mitigation .......................................................................................... 47 MS4 Phase II SWMPs Partially within the Carters Creek Watershed ...................... 49 Summary Control Action 1: Individual MS4 Phase II SWMPs ................................. 52 Permitted WWTFs in the Carters Creek Watershed .................................................. 54 Summary of Control Action 2: Continued Monitoring WWTF Effluent E. coli Levels according to Individual Permit Requirements .................................... 56 Watershed Monitoring and Assessment - Implementation Schedule and Tasks ......................................................................... 64 Tax Valuation Amendments -Implementation Schedule and Tasks ...................... 66 OSSF Education, Inspection, Operation, Maintenance and Tracking - Implementation Schedule and Tasks ......................................................................... 68 SSO Initiative Implementation -Implementation Schedule and Tasks ................. 70 Voluntary Agricultural BMPs -Implementation Schedule and Tasks ..................... 71 Development/Redevelopment Water Quality Mitigation - Implementation Schedule and Tasks ......................................................................... 73 Individual MS4 Phase II SWMPs -Implementation Schedule and Tasks .............. 74 Continue Monitoring WWTF Effluent E.coli Levels according to Individual Permit Requirements -Implementation Schedule and Tasks ............... 74 Livestock BMP Fecal Coliform Removal Efficiencies ................................................ 80 Texas Commission on Environmental Quality iv For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed List of Acronyms AU BC BCAD BCHD BMP BRA COB cocs CRP DMR E.coli EQIP E&O FG FOTG GIS I-Plan LA LIP LDC MCM MGD MOS MPN MS4 NPS NRCS OSSF QAPP sso SWCD SWMP SWQMIS TexasA&M TIAER TMDL TPDES TPWD TS SW CB TWRI TxDOT USEPA WLA WQMP WWTF Animal Unit Brazos County Brazos County Appraisal District Brazos County Health Department Best Management Practice Brazos River Authority City of Bryan City of College Station Clean Rivers Program Discharge Monitoring Report Escherichia coli Environmental Quality Incentives Program Education and Outreach Allowance for Future Growth Field Office Technical Guide Geographic Information System TMDL Implementation Plan Load Allocation Landowner Incentive Program Load Duration Curve Minimum Control Measure Million Gallons per Day Margin of Safety Most Probable Number Municipal Separate Storm Sewer System Nonpoint Source Pollution USDA Natural Resource Conservation Service On-site Sewage Facility (aerobic and conventional) Quality Assurance Project Plan Sanitary Sewer Overflow Soil and Water Conservation District Stormwater Management Program Surface Water Quality Monitoring Information System Texas A&M University at College Station Texas Institute for Applied Environmental Research Total Maximum Daily Load Texas Pollutant Discharge Elimination System Texas Parks and Wildlife Department Texas State Soil and Water Conservation Board Texas Water Resources Institute Texas Department of Transportation U.S. Environmental Protection Agency Waste Load Allocation Water Quality Management Plan Wastewater Treatment Facility Texas Commission on Environmental Quality v For Public Comment, April 2012 ----~ _. ---------·~ ..: Implementation Plan for Three TMDLs for Indicator Bacteria in the Carters Creek Watershed Executive Summary The Texas Commission on Environmental Quality is considering Three Total Maximum Daily Loads (TMDLs) for Indicator Bacteria in the Carters Creek Watershed (Segments 1209C, 1209D, and 1209L) for public comment and simul- taneously considering this associated Implementation Plan for public comment. This implementation plan, or I-Plan: • describes the steps that watershed stakeholders and the TCEQ will take to- ward achieving the pollutant reductions identified in the TMDL report • outlines the schedule for implementation activities. The ultimate goal of this I-Plan is to restore the contact recreation uses in Seg- ments 1209C, 1209D, and 1209L of the Carters Creek watershed (Figure 1) by reducing bacteria concentrations to levels established in the TMDL. The TMDL identified regulated and unregulated sources of Escherichia coli (E. coli) in the watershed that could contribute to water quality impairment. Regu- lated sources identified include permitted dischargers, such as industrial discharges, municipal separate storm sewer systems (MS4s), and wastewater treatment facilities (WWTFs). Sanitary sewer overflows, dry weather discharges, and illicit discharges are a subset of these regulated sources. Unregulated sources that could contribute to the E.coli load in the Carters Creek watershed include domestic animals (e.g., cattle, dogs, and horses), neglected and failing on-site sewage facilities (OSSFs), and wildlife and other unmanaged ani- mals (e.g., deer, feral hogs, grackles). This I-Plan includes six management measures and two control actions that will be used to reduce the level of bacteria in the Carters Creek watershed. Implemen- tation of these management measures will largely be dependent upon the availability of funding. Progress will be reviewed under the TCEQ's adaptive management process. Texas Commission on Environmental Quality For Public Comment, April 2012 l r.~ ~-ii =· TCEQ Figure 1. 2 Carters Creek Project Segments 4 Miles Legend --Impaired Segments --streams ~Lakes --Major Roads ~Cities This map was developed by the TMDL Program of the TCEQ. No claims are made to the accuracy or completeness of the data or to its suitabil~y for a particular use. For more information concerning this map contact the TMDL Team at 512-239-6457. Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Management Measures I. Coordinate and expand existing water quality monitoring in the watershed and conduct a watershed bacteria source survey. 2. Determine feasibility of modifying tax valuation requirements for agricultural lands and quantify expected water quality impacts of modifications and impacts of transition- ing from agriculture to wildlife valuations. 3. Work to improve OSSF identification, inspection, pre-installation planning, education, operation, maintenance and tracking to ensure proper system functioning. 4. Implement sanitary sewer overflow (SSO) initiatives as appropriate across the water- shed. 5. Implement voluntary Best Management Practice (BMPs) on agricultural or undevel- oped properties. 6. Co ntinue existing efforts and work to establish new mechanisms that encourage and promote fature development and redevelopment that will mitigate adverse water quality impacts in the watershed. Control Actions I. Implement entity-specific MS4 Phase II Stormwater Management Programs (SWMPs) throughout the watershed. 2. Monitor WWTF ejjluent E. coli concentrations according to individual permit require- ments. This I-Plan identifies the responsible parties, technical and financial needs, monitoring and outreach efforts, and a schedule of activities for each of the man- agement measures and the two control actions. It describes the process that the TCEQ and stakeholders will use to assess progress and adjust the plan periodical- ly. The TCEQ will report results and evaluations from implementation tracking to stakeholders as needed. Introduction To keep Texas' commitment to restore and maintain water quality in impaired rivers, lakes, and bays, the TCEQ works with stakeholders to develop an I-Plan for each adopted TMDL. A TMDL is a technical analysis that: • Determines the amount of a particular pollutant that a water body can receive and still meet applicable water quality standards, and • Sets limits on categories of sources that will result in achieving standards. This I-Plan is designed to guide activities that will achieve the water quality goals for the Carters Creek watershed as defined in the TMDL. It is a flexible tool that governmental and nongovernmental organizations involved in implementation use to guide their activities to reduce bacteria loads. The participating partners Texas Commission on Environmental Quality 3 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed may accomplish the activities described in this I-Plan through rule, order, guid- ance, or other appropriate formal or informal action. This I-Plan contains the following components: 1) A description of control actions and management measures1 that will be im- plemented to achieve the water quality target. 2) A schedule for implementing activities (Appendix A). 3) The legal authority under which the participating agencies may require im- plementation of the control actions. 4) A follow-up tracking and monitoring plan to determine the effectiveness of the control actions and management measures undertaken. 5) Identifi cation of measurable outcomes and other considerations the TCEQ and stakeholders will use to determine whether the I-Plan has been properly executed, water quality standards are being achieved, or the plan needs to be modified. 6) Identifi cation of the communication strategies the TCEQ will use to dissemi- nate information to stakeholders. 7) A review strategy that stakeholders will use to periodically review and revise the plan to ensure there is continued progress in improving water quality. This I-Plan also includes causes and sources of the bacterial impairment, man- agement measure descriptions, estimated potential load reductions, technical and financial assistance needed, educational components for each measure, schedule of implementation, measurable milestones, indicators to measure pro- gress, monitoring components, and responsible entities. Consequently, projects developed to implement unregulated (non point) source elements of this plan that meet the grant program conditions may be eligible for funding under the EPA's Section 319(h) grant program. 1 Control actions refer to regulated sources reduction strategies, generally TPDES permits. Man- agement measures refer to strategies for reducing unregulated pollutants, generally through voluntary best management practices (BMPs). Texas Commission on Environmental Quality 4 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Watershed Overview The Carters Creek watershed (highlighted areas in Figure 2) lies within the Nava- sota River watershed. Located within the Brazos River Basin, the Navasota River watershed is the second largest basin by area in Texas (Brazos River Authority, 2007), with a drainage area of approximately 2 ,235 square miles. The Navasota River flows 125 miles south to its confluence with the Brazos River (Brazos River Authority, 2007). Carters Creek, historically an intermittent stream, is now perennial due to wastewater inflows. It originates in central Brazos County and flows 17 miles be- fore joining the Navasota River. Burton Creek is a tributary of Carters Creek, which is also a perennial stream in its lower reaches due to wastewater inflows. Country Club Branch is a tributary of Burton Creek with intermittent flow. The drainage area of the Carters Creek watershed is about 58 square miles. Portions of the growing cities of Bryan and College Station, defined in the 2000 U.S. Cen- sus as urbanized areas, lie within the Carters Creek watershed . legend + Permitted Di$Gharge Facility t TCEQ Stauon --Impaired Stream -TrJbu~rles 6 Country Club Lake Watershed (Supporting) Fin Feather Lake Watershed (Supporting) t3' Country Ch.1b Braoch Watershed (lmpalr11d) D Burton Creek Watol'llhod (Impaired) [5 Carters Creek Watersh&d (Impaired) Figure 2. Carters Creek Watershed . 6 N o 0.6 1 2 Miles I I I I I t i I I Illustrates water quality monitoring stations, permitted dischargers, and subwatershed areas. Texas Commission on Environmental Quality 5 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed The western portion of the watershed is dominated by developed urban area; the eastern portion is predominantly rural. The Burton Creek and Country Club Branch subwatersheds are dominated by urban landscape, with residential and commercial/ industrial land uses combining to cover almost 100 percent of the area. Exceptional growth is being seen throughout the watershed and its sur- rounding areas. As a result, the rural areas of the watershed are slowly transitioning to residential and commercial uses. The cities of Bryan and College Station are rapidly growing urban areas. Their combined estimated population of 133,600 in 2000 has grown to 170,058 in 2010. Based on population data from the 2000 census, the population of the en- tire Carters Creek watershed was estimated at 91,211, of which 23,006 were estimated to be in the Burton Creek watershed (US Census Bureau, 2009). These population estimates were obtained by multiplying the tract-level census data by the proportion of each census tract within each watershed. This estimation pro- cedure assumes that the population is uniformly distributed within the area of each census tract. Summary of TMDLs This section summarizes the information developed for Three Total Maximum Daily Loads for Indicator Bacteria in the Carters Creek Watershed. Additional background information including the problem definition, endpoint identifica- tion, source analysis, linkages between sources and receiving waters and pollutant load allocations can be found in the draft TMDLs for the Carters Creek watershed. Unless otherwise noted, all information contained in this section was derived from the Technical Support Document for Bacteria TMDLs, Carters Creek Watershed (Segments 1209D, 1209L & 1209C) (Millican, 2011). Carters Creek (1209C) was first listed as impaired for elevated bacteria levels in the 1999 Clean Water Act Section 303(d) List and Schedule for Development of Total Maximum Daily Loads (TCEQ, 1999). Country Club Branch (1209D) and Burton Creek (1209L) were first listed as impaired in the 2006 Texas Water Quality Inventory and 303(d) List (TCEQ, 2006). Segments 1209C, 1209D, and 1209L are listed due to impairment of their prima- ry contact recreation uses, which is caused by elevated levels of indicator bacteria. The standards for water quality are defined in the Texas Surface Water Quality Standards (TCEQ, 2010b). E. coli are the preferred indicator bacteria for assessing the recreational use in freshwater, and were used for analysis to support TMDL development for the Carters Creek watershed. The criteria for assessing attainment of the primary contact recreation use are expressed as the number (or "counts") of E.coli bacte- Texas Commission on Environmental Quality 6 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed ria, given as the most probable number (MPN). For the E. coli indicator, if the minimum sample requirement is met, the primary contact recreation use is not supported when: • the geometric mean of all E. coli samples exceeds 126 MPN per 100 mL; • and/or individual samples exceed 399 MPN per 100 mL more than 25 percent of the time. Table 1 provides a summary of the water quality data from January 2001 to De- cember 2010 and illustrates the current water quality at the monitoring station and stream segment levels. Data collected from each site were well above the bac- teria criteria, indicating that the contact recreation uses of the creeks are not supported. Table 1. Summary of routine monitoring E.coli data, August 1997-December 2010 (Data source: TCEQ SWQMIS) Range of Measured Station Segment E.coli Geometric Geometric No. Concentrations Mean Mean Segment Station Location Samples (MPN/100 ml) (MPN/100 ml) (MPN/100 ml) 12090 11795 Duncan Street 13 2 ->2,500 583 583 1209L 11783 State Hwy 6 30 12 ->24,000 517 517 1209C 11784 State Hwy 30 34 4 ->24,000 643 705 11785 Bird Pond Road 44 4 ->24,000 757 Pollutant Sources and Loads Sampling for the Carters Creek TMDL consisted solely of routine, quarterly wa- ter-quality monitoring conducted between September 2001 and October 2007 by the Brazos River Authority (BRA) through the TCEQ's Clean Rivers Program. The geometric mean concentration of E. coli exceeded the criterion of 126 MPN/10omL at all sites under all flow conditions. No additional monitoring was conducted as a part of the TMDL development process. The TMDL analysis identified potential bacteria sources that could elevate bacte- ria levels in the Carters Creek watershed. Unregulated sources identified in the TMDLs include malfunctioning OSSFs, agriculture practices, development, and waste from pets, wildlife, and unmanaged animals. Regulated dischargers in the Carters Creek watershed include WWTFs, industrial facilities, and regulated stormwater discharges. Texas Commission on Environmental Quality 7 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Load duration curves (LDCs) were used to analyze sources and determine load reductions for the TMDLs. LDCs define the relationship between flow (volume per time) and loadings (mass bacteria per time). The procedures for developing LDCs are explained more fully in the TMDL report. The TMDL allocations are based on the high flow conditions (flows above the 9oth percentile). A TMDL estimates the maximum amount of a pollutant that the stream can re- ceive in a single day without exceeding water quality standards. It also establishes maximum pollutant contribution levels from source categories that will result in achieving water quality standards. The pollutant load allocations were calculated using the following equation: TMDL = }.:WLA + }.:LA+ }.:FG +MOS Where: WLA = waste load allocation, the amount of pollutant allowed from per- mitted dischargers LA = load allocation, the amount of pollutant allowed from unregulated sources FG = future growth associated with regulated facilities MOS= margin of safety of 5% Updates to TMDLs are made through the TCEQ's Water Quality Management Plan (WQMP), which provides long-range planning and technical data for man- agement activities, as required under the Texas Water Code and the federal Clean Water Act. Waste Load Allocation (WLA) The WLA is the waste load allocation for regulated source contributions in the watershed including WWTFs (WLAwwTF) and regulated stormwater (WLAsw). Wastewater Treatment Facil ities WWTFs regulated under the Texas Pollution Discharge Elimination System (TPDES) are allocated a daily waste load (WLAwwrF), calculated as their full per- mitted discharge flow rate multiplied by the instream geometric criterion after reductions for the margin of safety (MOS) (Table 2). This is expressed in the fol- lowing equation: WLAwwrF =criterion* flow (MGD) *conversion factor * (1 -FMos) Texas Commission on Environmental Quality 8 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Where: Criterion= 126 MPN/100 mL Flow (MGD) =full permitted flow Conversion factor= 3.7854E+o7100 mL / MGD FMos = fraction ofloading assigned to MOS (5% or 0.05) Table 2. Waste Load Allocations for TPDES Regulated Facilities Final E.coli Permitted WLAWWTF * TPDES Out-NP DES Flow (Billion Segment Number fall Number Pe rmittee/Facility Name (MGD) MPN/day) 1209L_o1 WQ0010426 001 TX0022616 City of Bryan / 8.o 36.25 -001 Burton Creek WWfF Total 8.o 36.25 1209C_o1 WQ0010024 001 TX0047163 City of College Station / 9.5 43.05 -006 Carter Creek WWfF 1209C_o1 WQ000400 001 TX0002747 TexasA&M University/ 0.93 4.214 2-000 Central Utility 1209C_o1 WQ0012296 001 TX0085456 R&B Mobile Home Park LLC 0.013 0.0589 -001 / Glen Oaks MHP WWfF 1209C_o1 WQ0013153 001 TX0098663 City of College Station / 0.0085 0.03851 -001 Carter Lake WWfF Total 10.4515 47.36 *Load includes a reduction for MOS of 5% Regulated Stormwater Stormwater discharges from MS4, industrial, and construction areas are consid- ered regulated point sources. Therefore, the WLA calculations must also include an allocation for regulated stormwater discharges (WLAsw). A simplified ap- proach for estimating the WLA for these areas was used in the development of these TMDLs due to the limited amount of data available, the complexities asso- ciated with simulating rainfall runoff, and the variability of stormwater loading. Further detail on how the WLAsw was calculated can be found in the Technical Support Document for Bacteria TMDLs, Carters Creek Watershed (Segments 1209D, 1209L & 1209C). The calculation used to calculate allowable loads from regulated stormwater is expressed by the following equation: :LWLAsw = (TMDL -:LWLAwwrF -LA -:LFG -MOS) * FDAswP Texas Commission on Environmental Quality 9 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Where: L:WLAsw = sum of all permitted stormwater loads TMDL =total maximum allowable load L:WLAwwrF = sum of all WWTF loads LA= tributary load allocations entering the segment L:FG = sum of future growth loads from regulated facilities MOS = margin of safety load FDAsWP = fractional proportion of drainage area under jurisdiction of stormwater permits Load Allocation (LA) The load allocation is the sum of loads from unregulated sources. The load allocation is the sum of the tributary bacteria load (LATL) entering the segment and all remaining loads in the segment from unregulated sources (LAsEG): LA = LAsEG + LAn Where: LA= allowable load from unregulated sources (predominately nonpoint sources) LAsEG = allowable loads from unregulated sources within the segment L:LAn = tributary load allocations entering the segment The LAn is calculated as: LAn = Qn-ib * Criterion Where: Criterion= 126 MPN/100 mL Qn-ib = median value of the very high flow regime at Station 11783 on Bur- ton Creek, which represents the tributary inlet to an impaired segment The unregulated loading within the segment (LAsEG) is calculated as: LAsEG = TMDL -L:WLAwwrF -L:WLAsw -LAn -L:FG -MOS Texas Commission on Environmental Quality 10 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Where: LAsEG = allowable load from unregulated sources within the segment TMDL =total maximum allowable load LWLAWWTF = sum of all WWTF loads LWLAsw = sum of all permitted stormwater loads LATL = tributary load allocations entering the segment LFG = sum of future growth loads from regulated facilities MOS = margin of safety load Allowance for Future Growth (FG) The future growth component of the TMDL equation addresses the requirement of TMDLs to account for future loadings that may occur because of population growth, changes in community infrastructure, and development. The assimilative capacity of streams increases as the amount of flow increases. Increases in flow allow for additional indicator bacteria loads if the concentrations are at or below the contact recreation standard. Currently four municipal WWTFs that service the Bryan/College Station area dis- charge into Burton Creek and Carters Creek. To account for the probability that new flows from WWTF discharges may occur in both assessment units, a provi- sion for future growth was included in the TMDL calculations. The provision is based on an estimate of the population increase for the cities of College Station and Bryan from year 2010 estimates to year 2030 projections obtained from the Texas Water Development Board (TWDB, 2006). Assuming an even distribution of estimated and projected populations the percent increase calculated was di- rectly applied to current discharge amounts for each WWTF. The discharge from the Texas A&M Central Utility plant was not included in the future growth esti- mate since population growth should not directly affect future discharges from this facility. Thus, the future growth (FG) term is calculated as follows: FG =criterion * (%Pop3o * L DMR) *conversion factor * (1 -FMos) Where: Criterion= 126 MPN/100 mL Texas Commission on Environmental Quality 11 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed %Pop3o = estimated percent increase in population between 2010 and 2030 2: DMR =sum of average discharges (MGD) of the WWTFs in the assess- ment unit as reported in the discharge monitoring reports (DMRs) for January 2008 -May 2009 (or most recently available data on January 4, 2010) Conversion factor = 3. 7854 x 107 100 mL / million gallons FMos =fraction ofloading assigned to MOS (5% or 0.05) Total Maximum Daily Load (TMDL) The TMDL was based on the median flow in the 0-10 percentile range (very high flow regime) for flow exceedance from the LDC developed for the most- downstream station within each assessment unit. Allocations are based on the current geometric mean criterion for E.coli in freshwater of 126 counts/100 mL for each component of the TMDL. The TMDL equation can be expanded to show the components of WLA and LA: TMDL = I:WLAwwrF + I:WLAsw + LAsEG + LATL + I:AFG +MOS Table 3. TMDL Allocation Summary for Impaired Creeks (loads in billion MPN/day) Seg-Future ment Stream Name TMDL MOS WLAWVfTF WLAsw LAsEG LArL Growth 1209D Country Club Branch 14.38 0.2746 0 5.217 0 8.890 0 1209L Burton Creek 199.9 8-428 36.25 116.7 1.409 31.31 5.785 1209C Carters Creek 814.6 30.74 47.36 269.8 259.2 199.9 7.625 Implementation Strategy This plan documents six management measures and two control actions to re- duce bacteria loads. Management measures are voluntary activities, such as working to identify OSSFs in the watershed. Control actions are regulatory activi- ties, such as implementing the TCEQ MS4 Phase II Stormwater Management Programs (SWMPs). Management measures were selected based on feasibility, costs, support, and timing. Implementation activities can be implemented in phases based on the needs of the stakeholders, availability of funding, and the progress made in improving water quality. Texas Commission on Environmental Quality 12 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Adaptive Implementation All I-Plans are implemented using an adaptive management approach in which measures are periodically assessed for efficiency and effectiveness. This adaptive management approach is one of the most important elements of the I-Plan. The iterative process of evaluation and adjustment ensures continuing progress to- ward achieving water quality goals, and expresses stakeholder commitment to the process. At annual meetings, the stakeholders will periodically assess progress using the schedule of implementation, interim measurable milestones, water quality data, and the communication plan included in this document. If periodic assessments find that insufficient progress has been made or that implementation activities have improved water quality, the implementation strategy will be adjusted. Activities and Milestones To facilitate the development of the Carters Creek watershed TMDL I-Plan, two general stakeholder meetings were held in April and August of 2010. From these meetings, a Coordination Committee was formed. This Committee consists of critical watershed stakeholders and is considered the local decision making body for the development of the I-Plan. The Coordination Committee felt it pertinent to form work groups to determine appropriate management and control measures as appropriate for each work group's respective area of interest. The work groups formed are: Natural Resources, Planning and Development, Storm- water and Transportation, and Wastewater. Collectively, the Coordination Committee and the work groups have held about 20 meetings to date in the de- velopment of this I-Plan. Each work group developed detailed, consensus-based action plans that consid- ered bacteria loading sources in the watershed. The management measures contained in this I-Plan are the combined products of the four work groups. Indi- vidual work group reports can be found on the Carters Creek website at: <http://cartersandburton.tamu.edu/ >. Management Measures and Control Actions The Carters Creek watershed I-Plan includes six stakeholder-developed man- agement measures and two control actions. Management Measures I. Coordinate and expand existing water quality monitoring in the watershed and conduct a watershed bacteria source survey. Texas Commission on Environmental Quality 13 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed 2. Determine feasibility of modifying tax valuation requirements for agricultural lands and quantify expected water quality impacts of modifications and impacts of transition- ing from agriculture to wildlife valuations. 3. Work to improve OSSF identification, inspection, pre-installation planning, education, operation, maintenance and tracking to ensure proper systemfanctioning. 4. Implement SSO initiatives as appropriate across the watershed 5. Implement voluntary BMPs on agricultural or undeveloped properties. 6. Continue existing efforts and work to establish new mechanisms that encourage and promote future development and redevelopment that will mitigate adverse water quality impacts in the watershed. Control Actions 1. Implement entity-specific MS4 Phase II SWMPs throughout the watershed. 2. Monitor WWTF effluent E. coli concentrations according to permit requirements. Management Measure 1.0 Coordinate and expand existing water quality monitoring in the watershed and conduct watershed bacteria source survey. The purpose of this management measure is to develop a more refined under- standing of the spatial and temporal dynamics of E. coli loading in the Carters Creek watershed. The water quality impairments in Carters and Burton Creeks are based on quarterly data collected at 4 sampling locations (TCEQ Stations 11783, 11784, 11785, 11795) (Millican, 2011). To accurately identify and address the sources of water quality impairments in the Carters Creek watershed, an in- tensified monitoring campaign is needed. With the exception of station 11795, monitoring has been reduced to station 11785 on Carters Creek since 2007. Monitoring at station 11795 resumed in 2011 and will continue through 2012 on a quarterly basis. The two large WWTFs do monitor and self-report their effluent for E. coli; however, this data is not used for water body assessment. This effort will begin with coordinating the monitoring that already exists in the watershed. Brazos River Authority (BRA), City of Bryan (COB), and City of Col- lege Station (COCS) personnel will develop a sampling schedule and communication structure to coordinate with each other about needed changes to the sampling schedule. This coordination will ensure that instream water quality monitoring and WWTF self-reported data are collected on the same dates at ap- proximately the same time. This approach will ensure a level of consistency in the data that will make them comparable. Expanding the monitoring in the watershed is a primary goal of all four work groups. Quarterly monitoring collected at one site is not sufficient to accurately Texas Commission on Environmental Quality 14 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed determine the quality of a water body, nor is it sufficient to aid watershed manag- ers in identifying and addressing instream water quality. The data used in the development of the TMDL indicated that elevated E. coli levels exist under all flow conditions at each of the four monitored sites, which does not help to identi- fy critical areas of need in the watershed. An expanded monitoring network that collects data at strategic locations on a refined time scale will aid entities involved in the management of their watershed in identifying where problem areas for E. coli loading may be and when they are most problematic. Monitoring is needed in the watershed to accomplish two primary goals: 1) better define where problem loading areas are in the watershed 2) monitor long-term trends in water quality following BMP implementation Further evaluation of potential sources of pollution in the watershed is also need- ed. Piecemeal information exists across the watershed regarding potential sources of pollution in the watershed. A physical survey of the stream network in the watershed will be conducted and paired with a GIS source survey to further understand potential sources of E. coli loading in the watershed. To partially fulfill these needs, TWRI has worked with local watershed stakehold- ers to facilitate development of a proposal that defines desired water quality monitoring goals, objectives, tasks, and expected outcomes of a special monitor- ing and source assessment project. Funding for this project has been approved by the TCEQ's Nonpoint Source Program 319(h) Grant to implement this measure. In this proposal, monitoring is planned to occur at 16 locations. Six of these sites will be monitored every other week for two years to provide additional data for the TCEQ's SWQMIS database for use in future water body assessments and es- tablishing a baseline water quality prior to BMP implementation. The other 10 sites will be monitored monthly to provide supplemental data collected by volun- teer monitors organized through the Texas Stream Team that will illustrate spatial variations in water quality, thus helping to illustrate where E. coli loading is most problematic in the watershed. Two of the monitoring sites within these groups overlap with each other to illus- trate the quality /usefulness of volunteer data collected. Two stations will also be equipped with automated stormwater sampling equipment to illustrate hydrolog- ical variations on instream water quality and better illustrate when elevated E. coli loadings occur in relation to rain events. Data produced through this project will provide needed water quality data to wa- tershed stakeholders thus aiding them in better managing their local water resources and in illustrating future improvements in water quality. The proposal Texas Commission on Environmental Quality 15 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed also includes a watershed source survey that will further understanding of E.coli pollutant loading impacting the stream network in the watershed by conducting physical observations along the length of the creek and its tributaries. A comprehensive watershed GIS survey will also be conducted to provide a better understanding of pollutant sources in the watershed. Specific details of the moni- toring will be available in the project's work plan and quality assurance project plan (QAPP). 1WRI will manage the project and coordinate its execution, ensuring that water quality data are collected as defined in the project work plan and QAPP. Data will be reported to the TCEQ for inclusion in their surface water quality monitoring information system (SWQMIS) for use in future water body assessments. 1WRI will facilitate necessary reporting and accounting functions as well. Additional monitoring needs identified in the future will be conducted contingent upon the receipt of funding specifically for additional water quality monitoring. Responsible Parties and Funding Each entity listed below will only be responsible for expenses associated with its own monitoring efforts. • BRA -Clean Rivers Program • COB • cocs • Texas AgriLife Research • TCEQ -CWA §319(h) Nonpoint Source Grant Program funding • TCEQ -Regional Office • TCEQ -Clean Rivers Program • 1WRI • Watershed volunteers BRA will continue Clean Rivers Program (CRP) monitoring in the watershed and will coordinate efforts with other monitoring entities in the watershed. COB will coordinate monitoring of its WWTFs with other monitoring in the wa- tershed. Support of monitoring efforts will also be provided. COCS will coordinate monitoring of its WWTFs with other monitoring in the wa- tershed. Support of monitoring efforts will also be provided. Texas AgriLife Research will provide data collection and analysis support as needed for special water quality monitoring projects in the watershed. Texas Commission on Environmental Quality 16 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed A proposal for grant funding to conduct an enhanced spatial and temporal moni- toring project was submitted by TWRI to the TCEQ during the FY 2012 319 (h) Grant request for grant applications and was approved. TCEQ -Regional Office will continue to support monitoring efforts in the water- shed through their involvement in coordinated monitoring efforts. TCEQ -Clean Rivers Program will continue to support monitoring in the Carters Creek watershed through BRA. TWRI will assist in coordinating monitoring efforts in the watershed, will assist watershed stakeholders in the development of the monitoring proposal, and will manage the project and ensure that it is completed as described. Watershed volunteers will be organized when funds have been secured to conduct supplemental monitoring in the watershed. This monitoring will provide addi- tional insight into the extent and potential sources of the water quality impairment and will aid in targeting future BMP implementation. Measurable Milestones The measureable milestones are as follows. Year 1: • TWRI will facilitate the establishment of appropriate contracts between the TCEQ and entities receiving funding to conduct watershed monitoring. • TWRI will organize monitoring efforts and develop the project QAPP. • The TCEQ and BRA continue CRP monitoring efforts in the watershed. Year 2: • Monitoring and assessment will begin and continue throughout the year. • The TCEQ and BRA continue CRP monitoring efforts in the watershed. Year 3: • Monitoring will continue through the year and conclude. • Data assessment will commence • Areas of the watershed will be identified where future implementation efforts will be targeted. • Reporting will begin. • The TCEQ and BRA continue CRP monitoring efforts in the watershed. Texas Commission on Environmental Quality 17 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed • Reporting requirements will be met. • Reports will be submitted to local stakeholders and TCEQ for review that il- lustrate the current state of water quality in the Carters Creek watershed and establish a good baseline of data for assessing BMP effectiveness. • The TCEQ and BRA continue CRP monitoring efforts in the watershed. Year 5: • Upon completion of monitoring and assessment, responsible parties as ap- propriate will use monitoring and source assessment results to collectively plan targeted BMP implementation. • The TCEQ and BRA continue CRP monitoring efforts in the watershed. Texas Commission on Environmental Quality 18 For Public Comment, April 2012 Table 4. Summary of Management Measure 1: Watershed Monitoring and Assessment Causes and Sources: General nonpoint and point sources Key Element (1), Management Measure: Coordinate and expand existing water quality monitoring in the watershed (3) (6) (2) Technical and (4) (5) Interim, Potential Load Financial Assistance Education Schedule of Measurable Reduction Needed Component Implementation Milestones Monitoring will Technical: Make presentations on Year1: -Funding secured. aid in setting a for development and preliminary data and -Establish contracts, -Contracts estab- baseline for management of the findings. Provide wa-procure supplies, lished. quantifying grant to conduct ex-ter quality data to BRA develop QAPP, and -QAPP developed. future load re-panded watershed for inclusion in the initiate monitoring. -Monitoring initiat- ductions from monitoring. basin highlights re--Continue CRP. ed. BMPs. port. Technical: Prepare final report Year 2: -Continued monitor- to complete monitor-detailing project find--Continue water ing as scheduled. ing outlined in ings and highlighting quality monitoring -Completion of proposed special pro-recommendations for and water body re-watershed recon- ject. Texas A&M targeting future BMP connaissance naissance survey. students will provide implementation. surveys. this assistance. -Continue CRP. Financial: Train volunteers to Year3: -Completion of mon- to support expanded enhance volunteer -Complete monitor-itoring. monitoring, assess-monitoring in the wa-ing, data -Completion of ment, and analysis of tershed. assessments, and data assessment. watershed E. coli dis-report develop--Reports developed. tribution, sources, and ment. -Data submitted to concentration. -Deliver information TCEQ for future on findings to water body assess- stakeholders. ment. -Continue CRP. Financial: Develop informational Year4&5: Determinations made Non-federal matching news releases high--Complete reporting on BMP implementa- funds will be obtained lighting local water requirements and tion. in forms such as per-quality. use findings to di- sonnel and volunteer rect future BMP time. implementation. -Continue CRP. (7) (8) (9) Indicators of Monitoring Responsible Progress Component Entity Data collected N/A -TCEQ NPS Pro- as planned, gram: Funding. and submitted -TWRI: project to TCEQ. management, re- porting, data collection. -Texas AgriLife Research: data analysis and collec- tion. -BRA/TCEQ RO & CRP: continue exist- ing CRP monitoring. -Cities of Bryan and College Sta- tion: data collection, analysis. -All: plan targeted BMP implementa- tion. Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Management Measure 2.0 Determine feasibility of modifying tax valuation requirements for agricultural lands and quantify expected water quality impacts of modifications and im- pacts of transitioning from agriculture to wildlife valuations. The purpose of this management measure is to determine if there are any water quality benefits to be gained through the modification of current agricultural use valuation requirements imposed by the local tax assessor's office. For smaller properties, overgrazing by livestock may be a function of animal numbers being housed on a property to maintain county requirements for tax valuation purposes instead of more appropriate BMPs. To determine if water quality improvements might be achieved, discussions will be initiated with the Brazos County Appraisal District (BCAD) office to evaluate the requirements of a property receiving an agricultural use valuation. U.S. De- partment of Agriculture-Natural Resources Conservation Service (NRCS) and Texas AgriLife Extension Service personnel will compare currently used require- ments of BCAD to applicable NRCS recommendations for selected conditions within Brazos County and will make suggestions to the BCAD for modifying tax requirements as appropriate. Additionally, using mailings from the BCAD as a vehicle to get educational materials to selected landowners will be explored. Wildlife use valuation is another option that can be used by landowners who do not wish to engage in agricultural practices yet still maintain their tax valuation levels on par with agricultural levels. More information on this management op- tion can be found on the Texas Parks and Wildlife Department (TPWD) website at: <www.tpwd.state.tx.us/landwater/land/private/agricultural_land/>. The po- tential differences in E. coli loading for a conversion from agricultural to wildlife tax valuation are not well known, but changes in sources and quantities of bacte- ria loading may occur. A research project was recommended as a feasible mechanism for determining what the associated costs and water quality impacts may be from a conversion from agriculture valuation to wildlife valuation. Funding will be sought to sup- port a graduate student in conducting a research project to assess these impacts. Responsible Parties and Funding Each entity listed below will only be responsible for undertaking efforts to identi- fy areas where improvements can be made. Graduate student support is the only additional funding needed to complete this management measure. Texas Commission on Environmental Quality 20 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed • BCAD • Brazos County Soil and Water Conservation District (SWCD) #450 • NRCS -Brazos County Field Office • Texas AgriLife Extension Service • Texas A&M -Agricultural Economics Department • TWRI BCAD will be asked to participate in discussions on making improvements to the requirements for agricultural land valuations for taxing purposes. Brazos County SWCD #450 will participate in discussions with the BCAD to im- prove agricultural land-valuation tax requirements such that water quality improvement can be realized. Brazos County NRCS will participate in discussions on making improvements to requirements for agricultural land valuations for taxing purposes with the BCAD and will provide technical basis for these discussions. NRCS will work with BCAD to develop an improved set of requirements if improvements are deemed feasible. Texas AgriLife Extension Service will participate in discussions to make im- provements to the requirements for agricultural land valuations for taxing purposes. Texas AgriLife Extension Service will also provide educational materi- als as appropriate and funding allows for mailings and other educational opportunities. The Department of Agricultural Economics at Texas A&M and others as appro- priate will work to secure funding to conduct a research project that quantifies changes in landowner behavior when land is transitioned from agricultural uses to wildlife uses. Behavioral impacts of agricultural tax valuation requirements could also be evaluated. TWRI will assist in efforts to secure funding for Texas A&M -Agricultural Eco- nomics Department to conduct their assessment. Measurable Milestones The measureable milestones are as follows. Year 1: • Completed discussions by NRCS, SWCD, and the Texas AgriLife Extension Service with the BCAD to evaluate agriculture valuation requirements for are- as where modifications can be made to improve water quality. • If feasible, work will begin to modify requirements for agricultural tax valua- tions. Texas Commission on Environmental Quality 21 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed • Discussions completed with Appraisal District on the ability to send educa- tional materials to landowners receiving agricultural and wildlife valuations along with annual tax statements from the Appraisal District. • Begin seeking funding to assess water quality impacts resulting from a shift from agricultural land uses to wildlife land uses. Year 2: • Contingent upon receipt of funding, work will begin on assessing potential water quality changes because of shifting properties from agricultural tax val- uations to wildlife tax valuations. • Based upon outcomes of discussions with BCAD, continue work to modify re- quirements for agricultural tax valuations. • Begin sending educational materials to landowners with agricultural or wild- life tax valuations through the BCAD. Year 3: • Contingent upon previous years' activities, continue effort to quantify water quality impacts from transitioning land uses from agricultural to wildlife. • If allowable, continue disseminating educational material to landowners through BCAD mailings. Year4: • Complete efforts to quantify water quality impacts from transitioning land us- es from agricultural to wildlife if funding secured. • Results of work presented to watershed stakeholders and the TCEQ as well as published for widespread use. • If allowable, continue disseminating educational material to landowners through BCAD mailings. Year 5: • If allowable, continue disseminating educational material to landowners through BCAD mailings. Texas Commission on Environmental Quality 22 For Public Comment, April 2012 Table 5. Summary of Management Measure 2: Possible Tax Valuation Modification Causes and Sources: Livestock and wildlife nonpoint sources Key Element (1 ), Management Measure: Determine the water quality impacts of (1) modifications to tax valuation requirements for agricultural lands and (2) of transitioning from agriculture to wildlife valuations (3) (6) (2) Technical and (4) (5) Interim, (7) Potential Load Financial Assis-Education Schedule of Measurable Indicators of Reduction tance Needed Component Implementation Milestones Progress Cannot be Technical: Discussions will in-Year1: -Funding source -Feasible tax quantified until Support ofNRCS, elude educating the -Discuss tax modifi-identified/ secured. requirement levels of change SWCD, and Texas Tax Assessor's office cations and use of -Tax requirement modifications are determined. AgriLife Extension as necessary on the Appraisal District discussions com-identified. Service personnel for need for tax re-mailing for educa-plete. -Funding discussions on tax quirement tional material -Educational materi-secured. requirement modifi-modifications. dissemination. al dissemination cations. -Seek funds for land discussed. use change assess- ment. Financial: Selected, existing Year2: -Complete tax re-Number of No financial support educational materi--Continue to discuss quirement educational is needed to discuss als will be used in tax modifications. modifications if fea-materials dis- tax modifications. mailings if allowed. -Disseminate educa-sible. seminated. Should educational tional materials. -Disseminate educa- material dissemina--If funded, initiate tional materials. tion be allowed, land use change as--If funded, land use existing funds will be sessment. change assessment used to the extent initiated. possible. Technical: Project reports will Year3: -Continued dissemi-Land use change A student trained in illustrate water -Continue dissemi-nation of assessment final- water resource eco-quality impacts be-nation of educational materi-ized. nomics to carry out cause ofland use educational materi-als. the agricultural to transition. als. -Continuation of wildlife use assess--If funded, continue land use change as- ment. land use change as-sessment. sessment. (8) (9) Monitoring Responsible Component Entity Documentation -NRCS: tech- of progress nical indicators assistance. achieved. -AgriLife Ex- tension: technical as- sistance. Monitoring SWCD: support designed to need for tax re- establish base-quirement line and modifications. identify prob- !em areas. TexasA&MAg Economics: land use change assessment if funded. Table 5, continued Possible Tax Valuation Modification (3) (6) (2) Technical and (4) (5) Interim, (7) (8) (9) Potential Load Financial Assis-Education Schedule of Measurable Indicators of Monitoring Responsible Reduction tance Needed Component Implementation Milestones Progress Component Entity Financial: Publications will be Year4: -Continued dissemi-TWRI: help seek For the student to developed for wide -Continue dissemi-nation of funding for land conduct assessment; dissemination of nating educational educational materi-use change as- roughly estimated at project findings. materials. als. sessment. $2,500/month for -If funded, complete -Completed land use time and supplies for land use change change assessment 2 years. assessment and dis-and dissemination tribute results. of results. Year 5: -Continued dissemi- -Complete tax re-nation of quirement educational materi- modifications if fea -als. sible. -Continue dissemi- nation of educational materi- als. Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Management Measure 3.0 Work to improve OSSF identification, inspection, pre-installation planning, ed- ucation, operation, maintenance and tracking to ensure proper system functioning. The purpose of this management measure is to improve the identification, in- spection, pre-installation planning, education, operation, maintenance, and tracking of all OSSFs in the watershed to minimize the potential negative water quality impacts from malfunctioning systems. Identifying all OSSFs in the Carters Creek watershed is the first step in this pro- cess. Tracking OSSF locations, age, and type is a current practice employed in Brazos County; however, systems installed prior to 1978 were not well document- ed or not documented at all. Systems of this age or older have an increased likelihood of failure and as such identifying the location of these systems will aid in reducing potential E. coli loading to the Carters Creek watershed. The initial step in this process will be to collect geographic information system (GIS) infor- mation on known OSSFs in the watershed as well as the known sewerage system extent. From there, dwellings and other facilities not served by known systems will be identified. AB OSSFs are identified, they will be tracked using GIS to doc- ument pertinent information related to the installation, operation, maintenance, and performance history of the system. Inspecting all septic systems in the watershed is also a goal of this management measure. Aerobic OSSFs installed in the county are currently required by county ordinance to be inspected triennially by a licensed service provider to ensure that systems are properly operating and that adequate maintenance is being per- formed. No such inspection requirement exists for conventional OSSFs. A new or amended ordinance will be required to enact this requirement. Knowledge and understanding of operation and maintenance requirements for OSSFs (aerobic and conventional) is viewed as being generally deficient through- out the watershed and is especially deficient for new homeowners who purchase a home with a previously existing OSSF. Improved mechanisms are needed and will be explored to provide education and outreach (E&O) materials to home- owners on the proper operation and maintenance of an OSSF and its importance in preserving local environmental quality. Pre-installation planning for new OSSF construction will also be evaluated. Cur- rent OSSF sizing and spray field sizing is based purely on the number of rooms in a house and/or its total square footage. These sizing requirements will be evalu- ated to determine if a better metric is available to more appropriately size OSSFs. Texas Commission on Environmental Quality 25 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed To aid in accomplishing some of these goals, 'IWRI worked with watershed stakeholders to develop and submit a project proposal that, if funded, will identi- fy potential OSSFs in the watershed and assign a potential pollution contribution risk to each system using a GIS methodology. The proposed work will also pro- vide needed OSSF education and outreach to local watershed stakeholders. Spe- cific details of the GIS identification and prioritization methodology will be available in the project's work plan and quality assurance project plan (QAPP) assuming there is sufficient funding. Funding has been sought from the TCEQ's Nonpoint Source Program through the annual 319(h) Grant funding program to implement this measure. Responsible Parties and Funding Each entity listed below will only be responsible for undertaking efforts to identi- fy areas where improvements can be made. No expense of resources is currently associated with activities described in this management measure. • Brazos County GIS Coordinator • Brazos County Health Department • COB • cocs • Texas AgriLife Extension Service • 1WRI Brazos County Health Department (BCHD) personnel will be responsible for the bulk of the activities associated with this management measure. They have the authority and jurisdiction over OSSFs in the county and as such will be responsi- ble for deciding upon changes to these authorities and implementing them. COB and COCS will assist in efforts to identify all OSSFs in the watershed by providing GIS support through providing information about locations of known OSSF and wastewater conveyance systems within each city. The Texas AgriLife Extension Service will assist as needed in the development and delivery of E&O materials to OSSF owners in the watershed. 'IWRI will provide needed technical assistance to administer project funding if received; will develop and employ the GIS identification and ranking methodolo- gy and will coordinate OSSF E&O programming with Texas AgriLife Extension Service. Texas Commission on Environmental Quality 26 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Measurable Milestones The measureable milestones are as follows. Year 1: • BCHD will continue to ensure that required OSSF inspections are completed, and will develop a mechanism to verify that OSSF inspections occur as docu- mented. • BCHD and others as appropriate will evaluate ways in which E&O material delivery to homeowners with OSSFs can be improved, and will develop a strategy for implementing the approach. • COB and COCS will transfer GIS information as needed to BCHD for use in OSSF identification efforts. • OSSF identification and documentation will begin as funding and personnel time exists. Year 2: • BCHD will continue to identify OSSFs in the watershed as funding and per- sonnel time exists. • BCHD will evaluate changes to new OSSF sizing requirements and make a recommendation on modifications to the existing requirements. • BCHD and others, as appropriate, will deliver E&O materials to OSSF system owners. • Contingent upon support oflocal government leaders, BCHD will work to amend county ordinances to establish inspection requirements on all OSSFs. Years 3 and beyond: • BCHD will complete OSSF identification in the watershed and will continually add new OSSF data to a GIS of watershed OSSFs. • Following amendment of OSSF inspection ordinance, BCHD will begin im- plementing new inspection policy. • BCHD and others, as appropriate, will deliver E&O materials to OSSF system owners. Texas Commission on Environmental Quality 27 For Public Comment, April 2012 Table 6. Summary of Management Measure 3: OSSF Education, Inspection, Operation, Maintenance, and Tracking Causes and Sources: Nonpoint sources from OSSFs Key Element (1), Management Measure: Work to improve OSSF identification, inspection, pre-installation planning, education, operation, maintenance, and tracking to ensure proper system functioning (2) (3) (6) (7) Potential Technical and (4) (5) Interim, Indicators to (8) Load Financial Assis-Education Schedule of Measurable Measure Monitoring Reduction tance Needed Component Implementation Milestones Progress Component 2.67Xl010 Technical: BCHD and others as Year 1: -GIS layers coor--GIS completed. -Documen-cfu/day BCHD will provide appropriate will eval--Begin identifying dinated with -All OSSFs identi-tation of needed technical as-uate E&O OSSFs in watershed. BCHD, cities of fied. progress Estimated sistance for most mechanisms for de--Coordinate GIS in-Bryan and College indicators using an items. Texas AgriLife livering information formation. Station. achieved. equation Extension Service can to OSSF owners. -E&O delivery from EPA's provide educational -Evaluate E&O deliv-mechanisms iden- 2001Proto-assistance as needed. ery mechanisms. tified and put into coif or Cities of Bryan & Col--Ensure OSSF inspec-use. Developing lege Station provide tions occur as -OSSF inspections Pathogen GIS support. required. continue as re- 1MDLs. quired. Appendix B Financial: BCHD and others will Year2: -OSSFs in water--All OSSFs in--BRA'sCRP provides Financial assistance distribute materials -Continue OSSF iden-shed identified. spected. monitoring additional is being sought to to OSSF owners. tification. - Ordinance -E&O items deliv-@TCEQ calculation provide additional -Evaluate changes to amendment re-ered. station information. man power to identify OSSF sizing. quiring inspection 11785. and prioritize poten--Deliver E&O materi-of all OSSFs. tial OSSFs in the als. -OSSF sizing re- watershed and pro--Amend ordinances quirements vide needed E&O. as support oflocal evaluated and government leaders amended. exists. (9) Responsible Entity -BCHD: tech- nical assistance, lead entity on all items. -Texas AgriLife Ex- tension: technical assis- tance for E&O. -1WRI: assistance in develop- ing/ administeri ng proposal, conducting GIS based OSSF as- sessment. Table 6, continued OSSF Education, Inspection, Operation, Maintenance, and Training (2) (3) (6) (7) Potential Technical and (4) (5) Interim, Indicators to (8) (9) Load Financial Assis-Education Schedule of Measurable Measure Mon itoring Responsible Reduction tance Needed Component Implementation Milestones Progress Component Entity Potential AB OSSFs are identi-Year 3 and beyond: -Ordinance -Monitoring -COB&COCS: Financial: fied, E&O materials -Continue and com-amendments designed to technical assis- Funding support to will be delivered. plete OSSF complete. establish tance and GIS correct identified identification. baseline support as OSSF malfunctions -Continually add new and identify needed; cities may be needed and OSSF info to water-problem provide info to will be determined shed GIS. areas. the county. after systems are -Following ordina nce identified and in-amendment, begin spected. implementing in- spection policy. -Continue delivery of E&O materials as needed. Workshops will be -BC GIS Coor- planned and provided dinator: to OSSF owners, in-update and spectors, service maintain GIS providers and others layer of OSSFs (if needed). county-wide. Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Management Measure 4.0 Implement sanitary sewer overflow (SSO) initiatives as appropriate across the watershed. The purpose of this management measure is to continue the implementation of the SSO initiatives in the watershed, thus minimizing the impacts of raw sewage being spilled in the watershed due to failures in the wastewater delivery system. COB currently has a SSO initiative in place; COCS is in the process of establishing their SSO initiative that is similar in nature to the COB's. These initiatives include a host of activities that each city will carry out in efforts to reduce the number of SSOs that occur within their respective service areas, including portions of the Carters Creek watershed. Within the SSO initiatives, the cities will conduct rou- tine sewer pipe inspections, using inflow and infiltration studies to prioritize needed system repairs and/or replacements; additionally, manholes will undergo visual inspections to prioritize needed repairs. Tracking SSOs using GIS and doc- umenting the source of the SSO will also serve to prioritize future repairs. Repairs and replacements are tracked annually. Implementing the SSO initiative complements the implementation of the COB and COCS Phase II MS4 permits. Identification of illicit discharges to the MS4 system overlaps with identifying SSOs in some cases, and as a result, can lead to better identification and quantification of these events. Responsible Parties and Funding Entities listed below will only be responsible for undertaking efforts within its specific jurisdiction. Expenses associated with this management measure are built into annual operating budgets, and may vary annually. Amounts of work ac- complished each year are dependent upon annual approved budgets. • COB • cocs COB will be responsible for continuing implementation of its SSO initiative and seeking funding to be allocated to accomplish needed objectives. COCS will be responsible for establishing its SSO initiative, establishing funding for this initiative, and implementing the outlined objectives. Texas Commission on Environmental Quality 30 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Measurable Milestones The measureable milestones are as follows. Year 1: • COB will continue to implement the components of its SSO initiative and track SSO events, repairs, and replacements. • COCS will work to establish its SSO initiative and begin to implement it once funded. Year 2 and beyond: • COB and COCS will continue to implement their SSO initiatives and track SSO events, repairs, and replacements. Texas Commission on Environmental Quality 31 For Public Comment, April 2012 Table 7. Summary of Management Measure 4: SSO Initiative Causes and Sources: Point and nonpoint sources from SSOs Key Element (1 ), Management Measure: Implement sanitary sewer overflow (SSO) initiatives as appropriate across the watershed. (2) (3) (6) (7) Potential Technical and (4) (5) Interim, Indicators to Load Financial Assis-Education Schedule of Measurable Measure Reduction tance Needed Component Implementation Milestones Progress 1.72x1010 Technical: Bryan and College Year1: -GIS layers -SSO initiatives cfu/day The cities of Bryan Station disseminate -COB continues imple-illustrating funded. and College Station E&O materials to menting SSO initiative SSO events, -SSO initiative Estimated retain needed tech-sewerage customers as planned. repairs, and objectives met. using an equa-nical capabilities on to aid in reducing -COCS establish SSO replacements tion from staff to accomplish SSOs (Fats, Oils, & initiative and begin im-made. EPA's 2001 the goals of their SSO Grease education for plementation. Protocol for initiatives. example). -Track SSO events, re- Developing pairs, and replacements Pathogen annually in GIS. -Conduct E&O to mini-TMDLs. mize future SSOs. Financial: Participating in E&O Year 2 and beyond: -Number of - # offeet of pipe Financial support is events such as the -COB and COCS contin-E&O dissemi-replace annual- Appendix B currently set aside for local Earth Day cele-ue implementing SSO nations/ ly. provides these efforts through bration, and other initiative as planned. views/ events. - # of SSO events additional annually approved media is an avenue of -Track SSO events, re-declining. calculation budgets by each re-dissemination. pairs, and replacements information. spective city. annually in GIS. -Conduct E&O to mini- mize future SSOs. Financial: Websites, brochures, Should the need for PSAs, water plan capital improvement tours. projects arise, addi- tional financial resources may be needed and will be sought as needed. (8) (9) Monitoring Responsible Component Entity Documentation COB: of progress in di-implement and ca tors achieved. fund its SSO initiative. BRA'sCRP COCS: monitoring @ establish, im- TCEQ station plement, and 11785. fund its SSO initiative. Monitoring designed to establish base- line and identify problem areas. Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Management Measure 5.0 Voluntary BMP implementation on agricultural or undeveloped properties. The purpose of this management measure is to mitigate potential E. coli loadings derived from agricultural lands by targeting education and outreach to watershed landowners that illustrate water quality benefits of appropriately planned BMP implementation on areas within priority areas of the watershed. These efforts will further show landowners how water quality improvements can be achieved while still meeting their individual land management goals. Despite the rapid expansion of the urbanized areas in and around Bryan and Col- lege Station, agricultural uses still make up a sizable portion of the land use in the eastern portion of the Carters Creek watershed. According to the BCAD, 9,775 acres of the watershed are classified as agricultural lands for taxing purposes. This accounts for approximately 27 percent of the total watershed area Properly planned implementation of BMPs in targeted areas of a watershed has proven to have positive impacts on water quality while simultaneously improving animal health/performance and profit margins for livestock producers (Redmon et al., 2011), and can be effective in the Carters Creek watershed as well. Through the development of water quality management plans (WQMPs), site-specific plans are developed and approved by SWCDs to meet landowner goals while im- proving water quality management. Rather than take a blanket approach to implementing BMPs on all agriculturally designated lands in the watershed, a targeted approach is recommended as a way to identify those areas that have the highest likelihood for contributing fecal ma- terial to the creek. A ranking system will be developed and based largely on the following criteria, in decreasing order of significance: • Proximity to the main channel of Carters Creek • Proximity to 3rd order streams or higher • Active use of the property • Grazed -top priority • Un-grazed -not a priority • Pasture type • Managed pasture -top priority • Unimproved pasture/ rangeland -low priority • Size of the property • > 50 acres -top priority • < 50 and > 25 acres -second priority • < 25 acres -lowest priority Texas Commission on Environmental Quality 33 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed • Likelihood of near future development This ranking system will not be used to designate where actual BMP implementa- tion will occur. Instead, this ranking system will simply prioritize what properties will likely yield the best possibilities for improving water quality as a result of BMP implementation. Using property rankings, education and outreach will be targeted to landowners such that they are informed of the water quality benefits that can be realized through the proper environmental stewardship, management planning, and implementation of BMPs focused on improving water quality while simultaneously meeting landowner usage goals. Natural resource management professionals will apply this ranking system, and will use their best professional judgments in final prioritization. Implementation will take place on a solely vol- untary basis. It should be noted that land development pressure will likely limit the adoption of BMP implementation in some areas of the watershed. Some properties on the fringe of existing developed areas that are currently used for livestock grazing are actively being marketed for development and an ensuing use change. Bacteria contributions from wildlife sources can also be mitigated through im- plementing appropriate BMPs and/or habitat management practices that can promote the use of areas away from the riparian corridor by wildlife species pre- sent in the watershed. Technical assistance can be provided to landowners by Texas Parks and Wildlife Department (TPWD) such that individual landowner management goals are met while simultaneously improving wildlife habi- tat/ availability and promoting natural resource conservation. Feral hogs have also been identified as contributors to the bacteria load in the watershed. Feral hogs are an invasive species that is known to inhabit white- tailed deer range and habitats (Taylor, 1991). Specific watershed population esti- mates are not available but can be extrapolated to range from approximately 237 up to 509 animals based on published density estimates presented in Mellish et al. (2011) and Wagner & Moench (2009) respectively. Given the low number of hogs and the urbanizing nature of this watershed, education and outreach is seen as the most appropriate mechanism for managing feral hog populations and bac- teria contributions to the watershed. Texas State Soil and Water Conservation Board The Texas State Soil and Water Conservation Board (TSSWCB) is the lead agency in Texas responsible for planning, implementing, and managing programs and practices for preventing and abating agricultural and silvicultural (forestry- related) nonpoint source pollution (Texas Agriculture Code Section 2oi.026). In accordance with this responsibility, the TSSWCB administers a certified WQMP Program that provides, through local SWCDs, for the development, implementa- Texas Commission on Environmental Quality 34 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed tion, and monitoring of individual WQMPs for agricultural and silvicultural lands. Each WQMP is developed, maintained, and implemented under rules and criteria adopted by the TSSWCB. A WQMP achieves a level of pollution preven- tion or abatement consistent with the state's water quality standards. A WQMP is a site-specific plan designed to assist landowners in managing non- point source pollution from agricultural and silvicultural activities. WQMPs are traditional conservation plans based on the criteria outlined in the NRCS Field Office Technical Guide (FOTG). The FOTG is the best available technology and is tailored to meet local needs. A WQMP includes appropriate land treatment prac- tices, production practices, management measures, technologies, or combinations thereof. WQMPs are developed in cooperation with the landowner with assistance from the NRCS and approved by the local SWCD and are certified by the TSSWCB. This approach to preventing and abating nonpoint source pollu- tion uses a voluntary approach while affording the landowner a mechanism for compliance with the state's water quality standards. The TSSWCB regularly performs status reviews on WQMPs to ensure that the producer is implementing the measures prescribed in the WQMP. The TSSWCB administers technical and cost-share assistance programs to assist producers in implementing their WQMPs. The TSSWCB uses both state general revenue and federal grants to fund the WQMP Program. Several essential practices from the NRCS FOTG included in a WQMP are of spe- cific applicability to the bacteria reduction goals of this TMDL and I-Plan. A grazing management system is a vital component of a WQMP for livestock opera- tions. Grazing management examines the intensity, frequency, duration and season of grazing to promote ecologically and economically stable relationships between livestock and forage species. The distribution of grazing animals is managed to maintain adequate and desired vegetative cover, including on sensitive areas like riparian corridors. Livestock distribution is managed through cross-fencing, al- ternate water sources, supplemental feed placement, and shade or cover manipulation. The expected forage quality, quantity, and species are analyzed to plan for an appropriate forage-animal balance. Grazing management systems plan for potential contingencies such as severe drought, wildfires, or flooding in order to protect the resource, protect grazing animals, and reduce economic risk. The TSSWCB, in collaboration with NRCS and the Brazos County SWCD #450, will continue to provide technical assistance to landowners in developing and im- plementing WQMPs. The TSSWCB will develop WQMPs on 100% of the livestock operations in the Carters Creek watershed who request planning assistance Texas Commission on Environmental Quality 35 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed through the SWCD. The TSSWCB will annually perform status reviews on at least 50% of all WQMPs in the Carters Creek watershed. Since the beginning of the TSSWCB WQMP Program in 1995, financial incentive funds (state general revenue) have been allocated to SWCDs in priority areas across the state and obligated by the SWCDs to individual producers. A lesser amount of funding is reserved by the TSSWCB for individual producers and SWCDs not in priority areas. Neither the Brazos County SWCD #450 nor Carters Creek is in a priority area. Livestock producers in the Carters Creek watershed seeking financial assistance from the TSSWCB to implement specific BMPs pre- scribed in a WQMP may request funding through the statewide, non-priority area allocation. U.S. Department of Agriculture Natural Resources Conservation Service The NRCS is a federal agency that works hand-in-hand with Texans to improve and protect their soil, water, and other natural resources. For decades, private landowners have voluntarily worked with NRCS specialists to prevent erosion, improve water quality, and promote sustainable agriculture. The NRCS provides conservation planning and technical assistance to landown- ers, groups, and units of government to develop and implement conservation plans that protect, conserve, and enhance their natural resources. When provid- ing assistance, NRCS focuses on the sound use and management of soil, water, air, plant, and animal resources. NRCS helps customers manage their resources in a way that prevents resource degradation, ensures sustainability, allows for productivity, and respects the customers' needs. Conservation planning can make improvements to livestock operations, crop production, soil quality, water quali- ty, pastureland, forestland, and wildlife habitats. The NRCS also integrates ecological and economic considerations in order to address private and public concerns. The NRCS administers numerous Farm Bill Programs authorized by the U.S. Congress that provide financial assistance for many conservation activities: • Conservation Innovation Grants (CIG) • Conservation Stewardship Program (CSP) • Environmental Quality Incentives Program (EQIP) • Agricultural Water Enhancement Program (AWEP) • Farm and Ranch Lands Protection Program (FRPP) • Grassland Reserve Program (GRP) • Wetlands Reserve Program (WRP) • Wildlife Habitat Incentives Program (WHIP) Texas Commission on Environmental Quality 36 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed • Conservation Reserve Program (CRP) administered by USDA Farm Service Agency EQIP and other programs were reauthorized in the federal Food, Conservation, and Energy Act of 2008 (Farm Bill) to provide a voluntary conservation program for farmers and ranchers that promotes agricultural production and environmen- tal quality as compatible national goals. People who are engaged in livestock or agricultural production on eligible land may participate in EQIP. EQIP offers fi- nancial and technical assistance to eligible participants for installation or implementation of structural and management practices on eligible agricultural land. EQIP also provides financial assistance to implement conservation practices. EQIP activities are carried out according to a plan of operations developed in conjunction with the producer that identifies the appropriate conservation prac- tice(s) to address resource concerns. All practices are subject to NRCS technical standards described in the FOTG and adapted for local conditions. Local SWCDs approve these plans. Local Work Groups provide recommendations to USDA-NRCS on allocating EQIP county base funds and on resource concerns for other USDA Farm Bill pro- grams. Carters Creek watershed stakeholders are encouraged to participate in the Local Work Group in order to promote the goals of this I-Plan Management Measure as compatible with the resource concerns and conservation priorities for EQIP. Soil and Water Conservation Districts An SWCD, like a county or school district, is a subdivision of state government. SWCDs are administered by a board of five directors who are elected by their fel- low landowners. There are 216 individual SWCDs organized in Texas. Through decades old agreements, SWCDs offer agricultural landowners and operators technical assistance through a partnership with the NRCS and the TSSWCB. It is through this conservation partnership that local SWCDs are able to furnish tech- nical assistance to farmers and ranchers in the preparation of a complete soil and water conservation plan to meet each land unit's specific capabilities, and needs. The Carters Creek watershed is wholly within the Brazos County SWCD #450. Texas Parks and Wildlife Private Lands Services TPWD Private Lands Services is a program to provide practical information for private landowners on ways to manage wildlife resources consistent with other land use goals, to ensure plant and animal diversity, to provide aesthetic and economic benefits, and to conserve soil, water, and related natural resources. To participate, landowners may request assistance by contacting the TPWD district Texas Commission on Environmental Quality 37 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed serving their county <www.tpwd.state.tx.us/landwater/land/technical_ guidance/biologists/>. TPWD cost share programs available to private landowners in the Carters Creek watershed include the Landowner Incentive Program (LIP) and the Pastures for Upland Birds program. Each assists landowners to manage their properties in a way that benefits wildlife while supporting landowner goals. To learn more about TPWD's programs or request assistances from a TPWD biologist, visit the web- site: <www.tpwd.state.tx.us/landwater/land/private/lip/>, which explains the types of projects funded by LIP. Once the property's potential has been deter- mined, a biologist will provide recommendations and, if requested, help the landowner develop a written wildlife management plan. The local Brazos County wildlife biologist can be reached at 979-845-5798. Texas AgriLife Extension Service AgriLife Extension, an agency of The Texas A&M University System, serves Tex- ans through community-based education and outreach. With the mission of improving the lives of people, businesses, and communities across Texas and be- yond through high-quality, relevant education, AgriLife Extension custom- designs and delivers its programs in focused areas of the state. These programs are based on local needs and supported by sound science. Extension education encompasses areas of agriculture and natural resources, community economic development, family and consumer sciences, and youth development programs such as 4-H (Texas AgriLife Extension Service, 2011). Using TSSWCB CWA §319(h) nonpoint source grant funding, Texas AgriLife Ex- tension Service and the Texas Water Resources Institute are developing a suite of curricula under the Lone Star Healthy Streams program. These will focus on providing needed information to producers on methods to improve the manage- ment of grazing cattle, horses, and feral hogs such that bacterial loading from these sources can be effectively reduced. Once developed, these educational pro- grams will be delivered statewide and will promote the adoption of BMPs, as well as participation in federal and state cost-share programs. Responsible Parties Entities listed below will only be responsible for providing technical assistance and aiding landowners in identifying available financial assistance. • Governmental Agencies • Brazos County SWCD #450 • TPWD • TSSWCB • USDANRCS Texas Commission on Environmental Quality 38 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed • Local Landowners • Texas AgriLife Extension Service Governmental agencies will work with landowners to voluntarily implement BMPs on their properties to mitigate potential impacts from livestock and wild- life. In doing this, agencies will first make pointed efforts to notify producers of program availability and respective financial assistance available through these programs. Technical assistance will be provided at the request of local landown- ers through identified programs based on individual landowner management goals. When available, financial assistance opportunities will be promoted to lo- cal landowners and assistance will be provided to landowners aiding them in applying for available funds. The TSSWCB and NRCS will continue to provide appropriate levels of financial assistance to agricultural producers that will facilitate the implementation of BMPs and WQMPs in the Carters Creek watershed, as described in this manage- ment measure. As was previously discussed, the land use dynamics are rapidly changing in the Carters Creek watershed shifting from an agricultural landscape to urban development. As such, the TSSWCB expects the demand for financial assistance to implement WQMPs to be very low and, therefore does not antici- pate establishing a priority area for Carters Creek. The TSSWCB expects that existing levels of financial assistance funding reserved for statewide, non-priority area use will be sufficient, depending on continued appropriations from the Texas Legislature, to satisfy demand and need for finan- cial assistance in Carters Creek. NRCS expects that existing levels of financial assistance available through multiple Farm Bill programs will be sufficient, de- pending on continued appropriations from the U.S. Congress, to satisfy demand and need in Carters Creek. Local landowners will be responsible for volunteering to receive technical assis- tance to improve management on their properties. In doing so, landowners must agree to and fulfill the terms and conditions of an individual program. The TSSWCB and AgriLife Extension anticipate receiving grant funding to deliver the Lone Star Healthy Streams curricula (grazing cattle, horses, feral hogs) to landowners statewide, including program delivery targeted to Carters Creek. Texas Commission on Environmental Quality 39 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Measurable Milestones The measureable milestones are as follows. Year 1: • Natural resource managers will develop a property prioritization system to identify properties where voluntary BMP implementation will likely have the greatest affect on mitigating water quality. • Contact information for each identified property will be compiled. • The need for watershed-specific education will be evaluated and a listing of E&O needs will be developed. Year 2: • Appropriate natural resource managers will make contact with individual landowners of priority 1 properties via existing direct mailings notifying them of technical and financial assistance program availability and explaining the significance of their participation. • Agencies, as appropriate, will begin working directly with private landowners at their request to develop property-specific management plans and begin im- plementing designated BMPs. • E&O delivered as needed. Year 3: • Appropriate natural resource managers will make contact with individual landowners of second priority properties via direct mailings notifying them of technical and financial assistance program availability and explaining the sig- nificance of their participation. • Agencies, as appropriate, will continue working directly with private land- owners at their request to develop property-specific management plans and begin implementing designated BMPs. • E&O delivered as needed. Year4: • Appropriate natural resource managers will make contact with individual landowners of third priority properties via direct mailings notifying them of technical and financial assistance program availability and explaining the sig- nificance of their participation. • Agencies, as appropriate, will continue working directly with private land- owners at their request to develop property-specific management plans and begin implementing designated BMPs. • E&O delivered as needed. Texas Commission on Environmental Quality 40 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Year 5: • Appropriate natural resource managers will make contact with individual landowners of priority properties not already participating in technical or fi- nancial assistance programs via direct mailings notifying them of their availability and explaining the significance of their participation. • Agencies, as appropriate, will continue working directly with private land- owners at their request to develop property-specific management plans and begin implementing designated BMPs. • E&O delivered as needed. Texas Commission on Environmental Quality 41 For Public Comment, April 2012 Table 8. Summary of Management Measure 5: Voluntary Agricultural BMPs Causes and Sources: Nonpoint sources from agricultural and wildlife land uses Key Element (1 ), Management Measure: Voluntary BMP implementation on private properties (3) (2) Technical and (4) (5) Potential Load Re-Financial Assis-Education Schedule of duction tance Needed Component Implementation Specific Technical: Existing E&O ef-Year 1: reduction not de-Agency support will forts will be -Property prioritiza- fined. provide needed tech-continued includ-tion developed and Load reduction equa-nical assistance as ing direct mailing, completed. tion developed based requested by local newsletters, news--Contact information on site-specific see-landowners and de-paper articles, and compiled. narios and BMP pendent upon their event participa--E&O needs assessed. implementation. management goals. tion. Equation derived Financial: Need assessed for Year2: using modified equa-Financial support for watershed-specific -Contact made with tion from EPA's 2001 technical assistance E&O; recommen-priority 1 landown- Protocolfor Develop-is currently available dations made ers. ing Pathogen through a variety of accordingly. -Begin working with TMDLs. programs and is landowners asap- available through a propriate. competitive process. -Deliver E&O asap- propriate. Appendix B provides Financial: In/near watershed Year3: additional calculation Special project fund-programming de--Contact made with information. ing is currently livered (e.g., Lone priority 2 landown- available for the de-Star Healthy ers. livery of some E&O Streams). -Continue working activities in/near the with landowners as watershed. appropriate. -Deliver E&O asap- propriate. (6) Interim, (7) (8) (9) Measurable Mile-Indicators of Monitoring Responsible stones Progress Component Entity -Development of -# of acres under Tracking of Agencies priority ranking management properties (TPWD, system. plans. under TSSWCB, -Identification of -# and type of management NRCS, Brazos priority land-BMPs docu-plans. Co.SWCD owners. mented. #450) provide -Compilation of technical & fi- landowner con-nancial tact info. assistance as available. -Documentation - # oflivestock/ Tracking# Private Land- of landowner wildlife impact-and types owners contacts. ed byBMPs. ofBMPs volunteer to -Documentation implemented. participate in of landowner programs. participation. -E&O needs as-Monitoring Texas AgriLife sessed and designed to Research de- prioritized. establish livers E&O as -E&O delivery baseline and needed. documented. identify prob- !em areas. Table 8, continued Voluntary Agricultural BMPs (3) (2) Technical and Potential Load Re-Financial Assis- duction tance Needed Financial: The watershed does not lie within any current special prior- ity areas for funding consideration; this may reduce the like- lihood of securing program funds. (4) Education Component Informational websites publi- cized, publications highlighted, work- shops delivered. (6) (5) Interim, (7) (8) (9) Schedule of Measurable Mile-Indicators of Mon itoring Res ponsible Implementation stones Progress Component Entity Year 4 and beyond: BRA's CRP -Contact made with monitoring priority 3 landown-@TCEQ sta- ers. tion 11785. -Continue working with landowners as appropriate. -Deliver E&O asap- propriate. Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Management Measure 6.0 Continue existing efforts and work to establish new mechanisms that encourage and promote future development and redevelopment that will mitigate adverse water quality impacts in the watershed. The purpose of this management measure is to continue existing efforts and work toward establishing new mechanisms that will be used to encourage and promote future development and redevelopment such that negative impacts on water quality are minimized. Development and redevelopment occur in the watershed on a continual basis with the bulk of new development occurring near the riparian areas along Carters Creek and redevelopment occurring in the older urban areas. While change is in- evitable, taking appropriate actions before and during the planning phase of a development project can lessen the impacts of these changes and is the goal of this management measure. Implementing and promoting mechanisms such as existing ordinance amendments, new ordinance development, establishing recognition programs for exceptional work in environmental stewardship, and continuing to protect riparian areas (existing green spaces near creeks) from fu- ture development will all work toward minimizing adverse water quality. Development is a critical driver of local economies. Regardless of this situation, existing ordinances regulating development will be evaluated for areas where im- provements can be made to mitigate adverse water quality impacts. New ordinances or other mechanisms may also be considered for use in enhancing wa- ter quality control requirements. These could include increasing or adding requirements for stream buffers, water quality and erosion control measures, wastewater line locations, wetland mitigation, and others. An informed and involved community also plays a role in achieving long-term improvements in water quality. Building upon existing efforts in the watershed to involve and inform citizens of local water quality issues as well as raise their awareness of how their actions impact the watershed will aid in getting this mes- sage across. Local stream clean-ups present an excellent opportunity for giving people a first-hand look at local water bodies and present an opportunity for de- livery of E&O content and materials. Developing an "Environmental Stewardship Awards" program is another way to inform the public of good practices and re- ward those businesses who implement these practices. Educating local public officials is also a high priority E&O activity. Educational needs will be prioritized and workshops/meetings will be targeted to educate lo- cal public officials and elected leaders about general water quality issues such as watershed functions; the local bacteria impairment; the importance and benefits Texas Commission on Environmental Quality 44 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed of riparian restoration; watershed protection; various control measures; and the implications of poor water quality. In support of implementing the Carters Creek TMDL, a Texas Watershed Steward workshop was held March 2011 in College Station. Sponsored by the TSSWCB, Texas AgriLife Extension Service, TWRI, the City of College Station, and other partners, this workshop discussed what it is to be a watershed steward, sources of water pollution, managing urban and rural lands using BMPs, and how to get in- volved in protecting and enhancing their community water resources. There were nearly 40 participants including concerned citizens, landowners, local business- es, and professionals in a variety of fields. The Texas Watershed Steward Program was developed by AgriLife Extension through CWA 319(h) nonpoint source grants from the TSSWCB. More information about the Texas Watershed Steward Program is available at <http://tws.tamu.edu>. Responsible Parties Entities listed below will be responsible for providing technical assistance and working to evaluate needs for establishing mechanisms that will be used to en- courage and promote future development and redevelopment that reduces adverse water quality impacts. • Brazos County • COB • cocs Developing new or amending existing ordinances depends largely on public per- ception. Without public or political support, it is unlikely that new or amended ordinances will pass. As a result, changes to ordinances or development of new ordinances will be timed accordingly. Brazos County will be responsible for implementing ordinances that are applica- ble to unincorporated areas of the county, and will participate in determining the feasibility of a local environmental awards program, and educational needs. Brazos County will also participate in programming for expanding local knowledge on water quality issues. COB will be responsible for planning future development in the COB and amend- ing or developing ordinances to direct future development or re-development. COB will also participate in determining the feasibility of a local environmental awards program, determining educational needs, and developing or delivering E&O activities as needed with other participating entities. COCS will be responsible for planning future development in the COCS, amend- ing or developing ordinances to direct future development or redevelopment, will Texas Commission on Environmental Quality 45 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed participate in determining the feasibility of a local environmental awards pro- gram, educational needs and will participate in, develop or deliver E&O activities as needed with other participating entities. COCS will also continue its 'Green- ways' program to protect critical riparian areas from future development pending funding and land availability. Measurable Milestones The measureable milestones are as follows. Year 1: • Assess the feasibility of and make a determination regarding the establish- ment of a local awards program that recognizes the activities of developers and other businesses that excel in environmental stewardship and protecting or improving local water quality. • As needed in support of entity-specific MS4 Phase II SWMPs, respective enti- ties will work to amend or develop ordinances to better protect instream water quality. • Continue existing efforts to protect riparian areas as funds and support oflo- cal government leaders allow. • Determine educational needs, establish plan for their delivery, and deliver events according to plan. • Conduct local involvement efforts such as stream cleanups as needed. Year 2 and b eyond: • If deemed feasible, establish local environmental awards program. • Respective entities will work to amend or develop ordinances to better protect instream water quality in support of entity specific MS4 Phase II SWMPs. • Continuation of existing efforts to protect riparian areas will occur as funds and support oflocal government leaders allow. • Continued implementation of educational events as planned. Texas Commission on Environmental Quality 46 For Public Comment, April 2012 Table 9. Summary of Management Measure 6: Development and Redevelopment Mitigation Causes and Sources: Nonpoint sources from developmenUredevelopment related land use changes Key Element (1 ), Management Measure: Continue existing, and work to establish, mechanisms that encourage and promote future development and redevelopment that will mitigate adverse water quality impacts in the watershed (3) (6) (2) Technical and Fi-(4) (5) Interim, (7) (8) (9) Potential Load nancial Assistance Education Schedule of lmple-Measurable Indicators of Monitoring Responsible Reduction Needed Component mentation Milestones Progress Component Entity Specific load Technical: Host workshops Year 1: -Awards # of acres under GIS tracking Brazos County reduction not Entity personnel as needed to -Complete evaluation program riparian protec-riparian pro--Ordinances in unincor- defined will supply needed educate elected of awards program evaluation tion. tection areas, po rated areas of the Impacts from technical support and local officials feasibility and make complete. e.g., conser-county. ordinance modifi-for evaluating on general water a determination. -Documented vation -Participating in assess- cation/develop-award program, quality topics. -Begin to amend ex-#of amended easements, ment oflocal awards ment cannot be amending/ <level-isting or develop or new ordi-green ways, program. quantified until oping new new ordinances in nances parks. -Planning/ delivery/ par- the action is com-ordinances, and support of entity developed in ticipation in E&O plete. pursuing additional specific SWMPs. support of activities. riparian area pro--Continue riparian SWMPs. tection. area protection as funding allows. A hypothetical Financial: Conduct commu-Year 2 and beyond: Documented # Maintenance or BRA'sCRP COB load reduction Assistance will be nity involvement -Iffeasible, establish of acres of land improvement monitoring -Ordinances in the city's equation was needed for the pro-activities and local environmental in riparian areas seen in E. coli @TCEQ jurisdiction. developed for curement of incorporate E&O awards program. protected as concentrations station -Participating in assess- riparian area riparian areas in the as appropriate -Continue as needed funding allows. in selected 11785. ment of local awards protection and near future as the (stream cleans, to amend existing or stream reaches. program. illustrates paten-current economy etc.). draft new ordinances -Planning/ delivery/ par- tial reductions per has resulted in in support of entity ticipation in E&O acre ofland pro-much reduced aper-specific SWMPs. activities. tected based on ating budgets. -Continue riparian -GIS tracking of entity local conditions. area protection as specific items. funding allows. Table 9, continued Development and Redevelopment Mitigation (3) (6) (2) Technical and Fi-(4) (5) Interim, (7) (8) (9) Potential Load nancial Assistance Education Schedule of Im pie-Measurable Indicators of Monitoring Responsible Reduction Needed Component mentation Milestones Progress Component Entity Equation derived Financial: Coordinate staff -E&O delivery Monitoring co cs using modified Assistance may be education efforts documented. designed to -Ordinances in the city's equation from needed to operate between entities establish jurisdiction. EPA's 2001 an awards program to maximize water quality -Participating in assess- Protocol for and will likely weigh educational baseline and ment of local awards Developing Path-heavily on the deci-opportunities for identify program, planning/ de- ogen 1MDLs. sion to implement local staff mem-problem are-livery/ participation in such a program. be rs. as of bacteria E&O activities. Appendix B pro-contribution. -Continuing Greenways vides additional program as funding and calculation infor-local/ political support mation. allows. -GIS tracking of entity specific items. Informational websites publi- cized, publications high- lighted, workshops deliv- ered. Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Control Action 1.0 Implement entity-specific MS4 Phase II SWMPs throughout the watershed. Through this control action, responsible entities will continue to implement ac- tions outlined in their entity specific MS4 Phase II SWMPs. The development and implementation of MS4 permits in Brazos County is a recent occurrence as illus- trated in Table 10. Table 10. MS4 Phase II SWMPs Partially within the Carters Creek Watershed Permit Permit Entity Name Number Effective Date Brazos County MS4 TXR040172 May 1, 2009 City of Bryan MS4 TXR040336 June 23, 2009 City of College Station MS4 TXR040008 December 1, 2010 Texas A&M University MS4 TXR040237 March 12, 2009 Texas Department of Transportation Bryan District MS4 TXR040181 May 1, 2009 Each of the entities listed above is responsible for the items included in their spe- cific permits only. Annual reports are submitted to the TCEQ and document implementation progress and compliance with permit requirements. The TCEQ is responsible for enforcing permit compliance. Because these MS4 permits are relatively new, some BMPs within designated Minimum Control Measures (MCMs) defined in individual MS4 permits have yet to be implemented. Further, quantifiable instream water quality impacts have yet to be realized from the BMPs that have been implemented and are likely masked by other watershed influences. Improvements in current water quality levels are expected from BMPs that are awaiting implementation. General MCMs included in these SWMPs are public education, public participation and involvement, illic- it discharge detection and elimination, construction site runoff control, stormwater management in new construction and redevelopment, and pollution prevention and good housekeeping. Adaptive management is a critical part of the SWMP process and will be critical to the long-term success of protecting and restoring water quality in the Carters Creek watershed. Each of the listed MS4 Phase II SWMPs is a five-year permit that will be revised and reapproved in cooperation with each entity and the TCEQ. This will allow each SWMP to be tailored to maximize mitigation of stormwater based on lessons learned in the previous five-year period. Texas Commission on Environmental Quality 49 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed In an effort to coordinate and support the implementation of MS4 MCMs, the en- tities listed have formed a group named Brazos Clean Water. This group meets roughly quarterly to plan and coordinate E&O efforts delivered throughout the county and watershed. Responsible Parties Entities listed below will be responsible for implementing only items set forth in their own MS4 Phase II SWMPs. Coordination and collaboration between entities in the application of these SWMPs is encouraged; however, despite collaboration, each entity remains solely responsible for implementing its own SWMP. • Brazos County • COB • cocs • Texas A&M University • Texas Department of Transportation (TxDOT) Bryan District • TCEQ Brazos County will be responsible for implementing its currently active MS4 Phase II SWMP, completing annual reporting requirements, working with the TCEQ to revise and renew its permit, and collaborating with other MS4 entities as needed. The County will continue participation in Brazos Clean Water. The COB will be responsible for implementing its currently active MS4 Phase II SWMP, completing annual reporting requirements, working with the TCEQ to revise and renew its permit, and collaborating with other MS4 entities as needed. The COB will continue participation in Brazos Clean Water. The COCS will be responsible for implementing its currently active MS4 Phase II SWMP, completing annual reporting requirements, working with the TCEQ to revise and renew its permit, and collaborating with other MS4 entities as needed. The COCS will continue participation in Brazos Clean Water. Texas A&M University will be responsible for implementing its currently active MS4 Phase II SWMP, completing annual reporting requirements, working with the TCEQ to revise and renew its permit, and collaborating with other MS4 enti- ties as needed. Texas A&M will continue participation in Brazos Clean Water. The TxDOT Bryan District will be responsible for implementing its currently ac- tive MS4 Phase II SWMP, completing annual reporting requirements, working with the TCEQ to revise and renew its permit, and collaborating with other MS4 entities as needed. TxDOT Bryan District will continue participation in Brazos Clean Water. Texas Commission on Environmental Quality 50 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed The TCEQ is responsible for MS4 permit compliance and enforcement. Measurable Milestones The measureable milestones are as follows. All Years: Measureable milestones for MS4s are entity-specific, and are reported individual- ly to the TCEQ in each MS4 entity's annual report. Texas Commission on Environmental Quality 51 For Public Comment, April 2012 Table11. Summary Control Action 1: Individual MS4 Phase II SWMPs Causes and Sources: Nonpoint sources from stormwater Key Element (1 ), Control Action: Implement entity-specific MS4 Phase II SWMPs throughout the watershed (3) (6) (2) Technical and (4) (5) Interim, (7) Potential Load Financial Assis-Education Schedule of Measurable Indicators of Reduction tance Needed Component Implementation Milestones Progress Specific load Technical: Continue coordination Year 1: Annual reports Permit compli- reduction not Each individual of E&O delivery -Continue compiled and ance by all MS4 defined MS4 entity will through Brazos Clean participation in submitted to entities. supply needed Water. the Brazos Clean TCEQ. Impacts from technical support Water and im- individual for implementing its plement MCMs SWMPsare respective SWMPs. and BMPs ac- different and cording to difficult to individual MS4 quantify. Phase II SWMPs. Financial: Utility bill inserts, fly-# ofBMPs im-Maintenance or Each individual ers, brochures, plemented by improvement MS4 entity will websites, PSAs, display each MS4 enti-seen in E. coli supply or identify booths at local events tyand concentrations needed financial Public presentations as documented in in selected support for imple-described in individual annual reports. stream reaches. menting their MS4 permits (topics respective SWMPs. may include proper pet waste management, appropriate lawn care practices, impacts of stormwater, rainwater harvesting, and others). E&O delivery documented in annual reports. (8) (9) Monitoring Responsible Component Entity BRA'sCRP Brazos County monitoring @ -Implementing its SWMP. TCEQ station -Completing annual 11785. SWMP report. -Revising and keeping its MS4 permit current. -Coordinating with other MS4 entities. Monitoring COB designed to -Implementing its SWMP. establish base--Completing annual line and SWMP report. identify prob--Revising and keeping its lem areas. MS4 permit current. -Coordinating with other MS4 entities. co cs -Implementing its SWMP. -Completing annual SWMP report. -Revising and keeping its MS4 permit current. -Coordinating with other MS4 entities. Table 11, continued Individual MS4 Phase II SWMPs (3) (6) (2) Technical and (4) (5) Interim, (7) (8) (9) Potential Load Financial Assis-Education Schedule of Measurable Indicators of Monitoring Responsible Reduction tance Needed Component Implementation Milestones Progress Component Entity TexasA&M -Implementing its SWMP. -Completing annual SWMP report. -Revising and keeping its MS4 permit current. -Coordinating with other MS4 entities. TxDOT Bryan District -Implementing its SWMP. -Completing annual SWMP report. -Revising and keeping its MS4 permit current. -Coordinating with other MS4 entities. TCEQ -Ensuring permit compli- ance & enforcement. Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Control Action 2.0 Continue monitoring WWTF effluent E. coli levels according to individual per- mit requirements. In November 2009, the TCEQ commissioners approved Rule Project No. 2009- 005-309-PR. This rule requires the addition of bacteria limits for either E.coli in fresh water discharges or Enterococci in saltwater discharges to all TPDES do- mestic permits during their next permit amendment or revision. This rule is defined in Title 30 Administrative Code Chapter 309 and the frequency of testing required is defined in Chapter 319. Through this control action, responsible enti- ties will continue to monitor E. coli concentrations in WWTF effluent as required by individual WWTF permits and any subsequent permit amendments or revi- sions. Currently, five permitted WWTFs exist in the Carters Creek watershed and two of those are required to monitor E. coli levels in their effluent. The other three will be required to monitor for E. coli upon renewal of (or amendment to) their permits. Section 303(d)(1)(C) of the Clean Water Act requires that an MOS be included in all TMDLs. Applying this in the Carters Creek watershed will result in 5 percent reductions in allowable E.coli discharge limits as described in individual TPDES permits. The allowable daily average for E. coli will be reduced from 126 cfu/10omL down to 120 cfu/10omL. Changes will occur following the approval of the TMDL and during the next amendment or revision to an individual permit. Table 12. Permitted WWTFs in the Carters Creek Watershed Permit Effective Entity Name Permit Number E. coli Monitoring Date Burton Creek WWfF WQ0010426 I TX0022616 Yes 7/17/2009 Carters Creek WWfF WQ0010024 I TX0047163 Yes 7/29/2009 Carter Lake WWfF WQ0013153 I TX0098663 No 12/22/2009 Glen Oaks WWfF WQ0012296 I TX0085456 No 9/11/2009 Texas A&M Central Utility WQ0004002 I TX0002747 No 6/30/2009 Each of the entities listed above is responsible for adhering to the requirements of their specific permits only. The terms and conditions in each individual permit are agreed upon by both the TCEQ and the permittee. Each permit specifically outlines the effluent constituents that require monitoring as well as the monitor- ing and reporting frequency to which the permittee must adhere. The TCEQ Texas Commission on Environmental Quality 54 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed reviews and documents compliance with individual permits. WWfF permits are issued on every five years and must be renewed by the permittee. Responsible Parties Entities listed below will be responsible for complying with the specific require- ments listed within their individual permits. • COB • cocs • Glen Oaks WWfF Owner/Operator • TexasA&M • TCEQ COB will be responsible for operating the Burton Creek WWfF in accordance with permit requirements. COCS will be responsible for operating the Carters Creek and Carter Lake WWfFs in accordance with permit requirements. The owner and operator of the Glen Oaks WWfF will be responsible for operat- ing the Glen Oaks WWfF in accordance with permit requirements. Texas A&M will be responsible for operating the Texas A&M Central Utility in ac- cordance with permit requirements. The TCEQ is responsible for permit compliance and enforcement. Measurable Milestones The measureable milestones are as follows. All Years: Owners and operators of each permitted discharger will operate their own per- mitted systems in accordance and in compliance with their individual permits. Texas Commission on Environmental Quality 55 For Public Comment, April 2012 Table 13. Summary of Control Action 2: Continued Monitoring WWTF Effluent E. coli Levels according to Individual Permit Requirements Causes and Sources: WWTF effluent Key Element (1), Control Action: Continue monitoring WWTF effluent E.coli levels according to individual permit requirements (3) (6) (2) Technical and (4) (5) Interim, (7) (8) (9) Potential Load Financial Assistance Education Schedule of Measurable Indicators of Monitoring Responsible Reduction Needed Component Implementation Milestones Progress Component Entity No immediate Technical: wwrF tours are pro-All years: E. coli concen-Permitted -BRA'sCRP COB responsible for operat- load reduction Each entity has tech-vided upon request to Each entity will: trations in discharges monitoring @ ing Burton Creek WWfF. expected. If nical assistance the general public and -Operate their effluent re-operated ac-TCEQ station recurring prob-required or will ac-highlight the overall permitted dis-ported as cording to 11785. !ems identified, quire technical operation and mainte-charges in required permits. load reduction assistance as needed. nance, functioning and accordance with through dis- maybe real-impacts of the systems; their individual charge ized. presentations are also permits. monitoring made to groups (school -Report E. coli report. classes, career fairs, levels in effluent etc.) explaining opera-as required by tions and environ-permit. mental implications of proper WWfF opera- tion. Financial: Monitoring COCS responsible for oper- Each entity currently designed to ating Carters Creek and has needed financial establish base-Carter Lake WWfFs. resources. If addition-line and al financial resources identify prob- are needed, they will lem areas. be acquired. Owner/operator of Glen Oaks WWfF operates WWfF. Texas A&M responsible for operating the Texas A&M Central Utility. TCEQ responsible for per- mit compliance and enforcement. Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Sustain ab i I ity The TCEQ and stakeholders in TMDL implementation projects periodically as- sess the results of the planned activities and other sources of information to evaluate the efficiency of the I-Plan. Stakeholders evaluate several factors, such as the pace of implementation, the effectiveness of BMPs, load reductions, and progress toward meeting water quality standards. The TCEQ will document the results of these evaluations and the rationale for maintaining or revising ele- ments of the I-Plan, and will present them as summarized in the following section. The TCEQ and stakeholders will track progress using both implementation mile- stones and water quality indicators. These terms are defined as: • Water Quality Indicator -A measure of water quality conditions for com- parison to pre-existing conditions, constituent loadings, and water quality standards. • Implementation Milestones -A measure of administrative actions under- taken to effect an improvement in water quality. Water Quality Indicators Water quality monitoring staff of the BRA will monitor the status of water quality during implementation and additional funding will be sought to conduct supple- mental monitoring in the watershed at currently undefined locations. The following summary describes routine water-quality monitoring activities in the Carters Creek watershed. The BRA monitors in Carters Creek. The TCEQ is con- ducting a short-term monitoring project in County Club Branch. Monitoring is no longer conducted in Burton Creek due to resource constraints. The purpose of this monitoring is to collect E.coli data to determine water quality standards at- tainment in the Carters Creek watershed. Carters Creek (1209C): Site 11785, Carters Creek at Bird Pond Road, is locat- ed in the downstream portion of the watershed and is east of the COCS. This site is monitored quarterly by BRA and is both a current and historic water quality site with E. coli data dating back to 2001. Site 11784, Carters Creek at Highway 30, is located at the approximate mid-point of Carters Creek, downstream of the COB and mostly upstream of the COCS. This historic site is no longer monitored. BRA collected quarterly E. coli data at this site from 2001 to 2007. Country Club Branch (1209D): Site 11795, Country Club Branch at Duncan St., is located between Fin Feather Lake and Country Club Lake within the Bur- Texas Commission on Environmental Quality 57 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed ton Creek subwatershed. This site is currently being monitored quarterly under a special study by the TCEQ Region 10 Office. Historic E. coli data exists back to 1997; however, only 12 data points exist between 1997 and 2010. Monitoring is scheduled to end at this site in August 2012. Burton Creek (120 9L): Station 11783, Burton Creek Downstream ofWWTF, is located just upstream of the Highway 6 crossing and immediately upstream of Burton Creek's confluence with Carters Creek. This is a historic data site and E. coli data were collected at this site by BRA from 2001 to 2007. This site is no longer monitored. Implementation Milestones Implementation tracking provides information that can be used to determine if progress is being made toward meeting goals of the TMDL. Tracking also allows stakeholders to evaluate actions taken, identify those actions which may not be working, and make any changes that may be necessary to get the plan back on target. Schedules of implementation activities and milestones for this I-Plan are included in Appendix A. Communication Strategy Communication is necessary to ensure stakeholders understand the I-Plan and its progress in restoring water quality conditions. The TCEQ will disseminate the in- formation derived from tracking I-Plan activities to all interested parties, organizations, and individuals. The TCEQ will report results and evaluations from implementation tracking to stakeholders as needed. The TMDL Program will summarize all actions taken to address the impairment and will report trends observed in the water quality data collected to track the progress of implementation as needed. Responsible parties are committed to providing appropriate information to the TCEQ to update these progress assessments and communicating information at annual meetings. In accordance with the Clean Water Act §319, the state must annually report to USEPA on success in achieving the goals and objectives of the Texas Nonpoint Source Management Program, including progress in implementing the NPS por- tion of TMDLs. The TCEQ and TSSWCB jointly publish Managing Nonpoint Source Water Pollution in Texas: Annual Report, which highlights the state's ef- forts during each fiscal year to collect data, assess water quality, implement projects that reduce or prevent NPS pollution, and educate and involve the public to improve the quality of water resources. Information derived from tracking and review activities of the Carters Creek Surface Water Quality and Pollution Source Assessment will be reported in each annual report. Previously published Texas Commission on Environmental Quality 58 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed annual reports are available at <www.tceq.texas.gov/waterquality/nonpoint- source/mgmt-plan/annual-reports.html>. The TCEQ will participate in annual meetings for up to the next five years to sup- port stakeholders in evaluating their progress. Stakeholders will continue to take part in annual meetings over the five-year period to evaluate implementation ef- forts. At the completion of the scheduled I-Plan activities, stakeholders will assemble and evaluate the actions, overall impacts, and results of their imple- mentation efforts. Texas Commission on Environmental Quality 59 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed References American Veterinary Medical Association U.S. Pet Ownership Calculator. (2007). <www.avma.org/reference/mar ketstats/ ownership.asp>. Brenner, F.J., J.J. Mondok, R.J. McDonald, Jr. (1996). "Watershed Restoration through Changing Agricultural Practices." Proceedings of the A WRA Annual Symposium Watershed Restoration Management: Physical, Chemical and Biological Consid- erations. American Water Resources Association, Herndon, VA. TPS-96-1, pp. 397- 404. Byers, H.L., Cabrera, M.L., Matthews, M.K., Franklin, D.H., Andrae, J.G., Radcliffe, D.E., McCann, M.A., Kuykendall, H.A., Hoveland, C.S., Calvert II, V.H. (2005). Phos- phorus, Sediment, and Escherichia coli Loads in Unfenced Streams of the Georgia Piedmont, USA. Journal of Environmental Quality. 34. 2293-2300. Canter, L.W. and R.C. Knox (1985). 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A Long-term, Watershed-Scale, Evaluation of the Impacts of Animal Waste BMPs on Indicator Bacteria Concentrations. Journal of the American Water Resources As- sociation. 38. 15. Texas Commission on Environmental Quality 60 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Karthikeyan, R. (2011). Personal Communication on "Fate and Transport of Bacteria in Rural Texas Streams." TSSWCB Project 07-06. Lewis, D.J., Atwill, E. R., Lennox, M.S., Pereira, M.D.G., Miller, W.A., Conrad, P.A., Tate, K. W. (2010). Management of Microbial Contamination in Storm Runoff from California Coastal Dairy Pastures. Journal of Environmental Quality. 39. 1782- 1789. Line, D. E. (2002). Changes in Land Use/Management and Water Quality in the Long Creek Watershed. Journal of the American Society of Agronomy. 38. 1691-1701. Line, D. E. (2003). Changes in a Stream's Physical and Biological Conditions Following Livestock Exclusion. 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Wastewater Engineering, Treatment, Disposal, Reuse. 3rd. Ed. New York: McGraw-Hill Co. Millican, J., Hauck, L.M .. (2011). Technical Support Document for Bacteria TMDLs, Carters Creek Watershed (Segments 1209D, 1209L & 1209C)), ed. T. S. U. Texas Institute for Applied Environmental Research. Stephenville, Texas. Larsen, R.E., Miner, J.R., Buckhouse, J.C., Moore, J.A. (1994). Water-Quality Benefits of Having Cattle Manure Deposited Away from Streams. Bioresource Technology. 48. 113-118. Redmon, L., Wagner, K,. Peterson, J . 2011. Lone Star Healthy Streams: Beef Cattle Manual. Texas AgriLife Extension. B-6245. Roodsari, R.M., Shelton, D.R., Shirmohammadi, A., Pachepsky, Y .A., Sadeghi, AM., Starr, J.L. (2005). Fecal Coliform Transport as Affected by Surface Condition. American Society of Agricultural Engineers. 48. 7. Sheffield, R.E., Mostaghimi, S., Vaughan, D. H., Collins Jr., E.R., Allen, V.G. (1997). Off- Stream Water Sources for Grazing Cattle as a Stream Bank Stabilization and Water Quality BMP. Transactions of the ASAE. 40. 595-604. Stuntebeck, T.D., Bannerman, R.T. (1998). Effectiveness of Barnyard Best Management Practices in Wisconsin. USGS Fact Sheet. FS-051-98. Texas Commission on Environmental Quality 61 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Sullivan, T.J., Moore, J.A., Thomas, D.R., Mallery, E., Snyder, K.U., Wustenberg, M., Wustenberg, J., Mackey, S.D., Moore, D.L. (2007). Efficacy of Vegetated Buffers in Preventing Transport of Fecal Coliform Bacteria from Pasturelands. Environmen- tal Management. 40. 958-965. Tate, K. W., Pereira, M.D.G., Atwill, E. R. (2004). Efficacy of Vegetated Buffer Strips for Retaining Cryptosporidium parvum. Journal of Environmental Quality. 33. 2243- 2251. Tate, K. W., Atwill, E. R., Bartolome, J.W., Nader, G. (2006). Significant Escherichia coli Attenuation by Vegetative Buffers on Annual Grasslands. Journal of Environmen- tal Quality. 35. 795-805. Taylor, R. 1991. The Feral Hog in Texas. TPWD Report available online: <www.tpwd.state.tx.us/publications/pwdpubs/media/pwd_bk_W7000_0195.pdf> TCEQ (2008). 2008 Texas Water Quality Inventory and 303(d) List. <www.tceq.texas.gov/waterquality /assessment/ o8twqi/twqio8.html >. TCEQ (2010). 2010 Guidance for Assessing and Reporting Surface Water Quality in Texas. <www.tceq.texas.gov/assets/public/compliance/monops/water/ 10twqi/2010_guidance.pdf>. TCEQ (2011). Implementation Plan for One Total Maximum Daily Load for Bacteria in Gilleland Creek. < www.tceq.texas.gov/ assets/public/implementation/water/ tmdl/ 69gilleland/ 69-gillelandiplan. pdf>. Texas AgriLife Extension Service. 2011. Texas AgriLife Extension Service website. <http://agrilifeextension.tamu.edu/> TWDB (2006). Population Projections Data. <www.twdb.state.tx.us/wrpi/data/proj/ popproj.htm>. Accessed January 14, 2010. USEPA (2001). Protocol for Developing Pathogen TMDLs. <www.epa.gov/owow/tmdl/ pathogen_all. pdf>. USEPA (2010). Implementing Agricultural Best Management Practices Improves Water Quality. Nonpoint Source Program Success Story. Wagner, K., and Moench, E. 2009. Education Program for Improved Water Quality in Capano Bay: Task Two Report. TWRI TR-347. Wagner, K. 2011. Evaluation of Methods to Assess and Reduce Bacterial Contamination of Surface Water from Grazing Lands. Ph.D. Dissertation. Texas A&M University, College Station, TX. Young, R.A., Huntrods, T., Anderson, W. (1980). Effectiveness of Vegetated Buffer Strips in Controlling Pollution from Feedlot Runoff. Journal of Environmental Quality. 9. 483-487. Texas Commission on Environmental Quality 62 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Appendix A. I-Plan Matrix Texas Commission on Environmental Quality 63 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Table A-1. Watershed Monitoring and Assessment -Implementation Schedule and Tasks Plan Responsible Year Parties Implementation Measure Implementation Milestones 1 TWRl, AgriLife Re-Develop watershed monitoring and -Proposal developed. search, Brazos County, reconnaissance proposal. -Proposal submitted to prospec- COB, COCS, Texas A&M tive funding agency. TxDOT TWRl Organize and implement volunteer -Volunteers organized. water quality monitoring effort de--Volunteers trained. pendent upon receipt of grant - -volunteer monitoring initiated. funding. TWRl Maintain Carters Creek Water -Website updated as needed. Quality website. TWRl, subcontractors as When funded, organize and estab--Project funded. appropriate lish contracts for watershed -Contracts established. monitoring, initiate watershed -Project initiated. monitoring and reconnaissance project. TWRl, AgriLife Re-Develop project QAPP. -QAPP developed. search, COB, COCS, -QAPP approved. TexasA&M 2 TWRl, subcontractors as Continue watershed monitoring -Project reporting completed as appropriate and reconnaissance project. planned. -Watershed reconnaissance com- pleted. -Water quality monitoring un- derway. Volunteers Continue volunteer water quality -Water quality data collected and monitoring. submitted. TWRl, subcontractors as Conduct public meetings to de-- # of meetings held. appropriate scribe monitoring efforts and how - # of invited presentations given. the data will be used. -#of people in attendance at meetings. TWRl Maintain Carters Creek Water -Website updated as needed. Quality website. TWRl, AgriLife Re-Revise project QAPP. -QAPP revised. search -QAPP revision approved. 3 TWRl, subcontractors as Depending on project start time, -Project completed/nearing com- appropriate either conclude or near completion pletion. of watershed monitoring and re--Project reporting completed as connaissance project. planned. -Water quality monitoring results summarized and reported. -Water quality data submitted to TCEQ for SWQMIS inclusion. Texas Commission on Environmental Quality 64 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Table A-1 , continued Monitoring and Assessment Schedule Plan Responsible Year Parties Implementation Measure Implementation Milestones TWRI, subcontractors as Present project findings to water-- # of public meetings conducted. appropriate shed stakeholders. - # of participants in public meet- ings. TWRI Maintain Carters Creek Water -Website updated as needed. Quality website. 4 TWRI, subcontractors as If needed, conclude watershed -Project completed/nearing com- appropriate monitoring and reconnaissance pletion. project. -Project reporting completed as planned. -Water quality monitoring results summarized and reported. -Water quality data submitted to TCEQ for SWQMIS inclusion. TWRI Maintain Carters Creek Water -Website updated as needed. Quality website. TWRI, subcontractors as Present project findings to water-- # of public meetings conducted. appropriate shed stakeholders. -#of participants in public meet- in gs. 5 Brazos County, COB, Upon completion of water quality -Targeted BMP implementation COCS, Texas A&M, monitoring and reconnaissance plan based on watershed moni- TxDOT project, use data in directing future toring project findings. BMP implementation. TWRI Maintain Carters Creek Water -Website updated as needed. Quality website. Texas Commission on Environmental Quality 65 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Table A-2. Tax Valuation Amendments -Implementation Schedule and Tasks Plan Responsible Year Parties Implementation Measure Implementation Milestones 1 Brazos County Hold discussions with Brazos County -Discussions initiated. NRCS, Brazos Appraisal District on modifying re--Outcomes of discussions deter- County SWCD, quirements for Ag tax valuations. mined and next steps identified. AgriLife Extension Brazos County Discuss using Brazos County Ap--Discussions initiated. NRCS, Brazos praisal District mailings as -Outcomes of discussions deter- County SWCD, educational material outlet. mined and next steps identified. AgriLife Extension Brazos County If permissible, provide educational -Documentation of educational NRCS, AgriLife Ex-materials to Brazos County Appraisal materials mailed. tension District for mailing. -# of materials mailed. Texas A&M Ag Eco-Develop proposal and seek funds for -Funding sources identified. nomics & TWRI work to define potential water quality -Funding applications submitted. changes because ofland-use change from Ag to Wildlife uses. 2 Brazos County If amenable, work with Brazos Coun--If amenable, modified require- NRCS, Brazos ty Appraisal District on modifying ments for receiving Ag valuation County SWCD, requirements for Ag tax valuations. for property taxes. AgriLife Extension Brazos County If permissible, provide educational -Documentation of educational NRCS, AgriLife Ex-materials to Brazos County Appraisal materials mailed. tension District for mailing. -# of materials mailed. Texas A&M Ag Eco-When funded, initiate work to define -Assessment initiated. nomics & TWRI potential water quality changes as a result of!and-use change from Ag to Wildlife uses. 3 Brazos County If permissible, continue to provide -Documentation of educational NRCS, Brazos educational materials to Brazos materials mailed. County SWCD, County Appraisal District for mailing. -# of materials mailed. AgriLife Extension Texas A&M Ag Eco-If funded, continue work to define -Develop project reports summa- nomics & TWRI potential water quality changes be-rizing findings. cause of!and-use change from Ag to Wildlife uses. 4 Brazos County If permissible, continue to provide -Documentation of educational NRCS, Brazos educational materials to Brazos materials mailed. County SWCD, County Appraisal District for mailing. -# of materials mailed. AgriLife Extension Texas Commission on Environmental Quality 66 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Table A-2, continued Tax Valuation Amendments Schedule Plan Responsible Year Parties Implementation Measure Implementation Milestones Texas A&M Ag Eco-If funded, complete work to define -Publish reports on project find- no mies & TWRl potential water quality changes be-in gs. cause ofland-use change from Ag to -Disseminate reports to stakehold- Wildlife uses. ers and public. 5 Brazos County If permissible, continue to provide -Documentation of educational NRCS, AgriLife Ex-educational materials to Brazos materials mailed. tension County Appraisal District for mailing. -# of materials mailed. Texas Commission on Environmental Quality 67 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Table A-3 OSSF Education, Inspection, Operation , Maintenance, and Tracking -Implementation Schedule and Tasks Plan Responsible Year Parties Implementation Measure Implementation Milestones 1 BCHD, COB, COCS Begin identifying all OSSFs in water--GIS info coordinated between enti- shed (cities responsible for OSSFs in ties. city only). -Develop approach for identifying undocumented OSSFs. -# of OSSFs identified an added to database. BCHD, AgriLife Evaluate mechanisms for better deliv--Improved E&O mechanisms identi- Extension ering E&O to OSSF owners. tied. BCHD Continue monitoring OSSF inspections -Document inspection follow ups. COB &COCS in as required by county ordinance. -# of inspections finding improperly City bounds operating OSSFs. BCHD, AgriLife Deliver OSSF E&O as needed through - # of E&O materials delivered. Extension identified mechanisms. - # of OSSF owners contacted thru E&O efforts. 2 BCHD, COB, COCS Continue efforts to identify all OSSFs in -GIS info coordinated between enti- watershed (cities responsible for in city ties. OSSFs only). - # of OSSFs identified an added to database. BCHD Evaluate need for modifying OSSF siz--Finding on needed modifications. ing requirements. BCHD If evaluation recommends modifica--Modified ordinances developed and tions, begin process to amend put in place. ordinances to modify sizing require- ments as support oflocal government leaders exists. BCHD Continue monitoring OSSF inspections -Document inspection follow ups. as required by county ordinance. - # of inspections finding improperly operating OSSFs. BCHD, AgriLife Deliver OSSF E&O as needed through -# of E&O materials delivered. Extension identified mechanisms. - # of OSSF owners contacted thru E&O efforts. 3 BCHD Continue efforts to identify all OSSFs in -GIS info coordinated between enti- watershed (cities responsible for in city ties. OSSFs only). - # of OSSFs identified an added to database. BCHD Evaluate need to establish ordinance -Finding on need for new/amended requiring a minimum annual inspec-ordinance. tion of all OSSFs. Texas Commission on Environmental Quality 68 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Table A-3, continued OSSF Education, Inspection, Operation, Maintenance, and Tracking Plan Responsible Year Parties Implementation Measure Implementation Milestones 3 BCHD If evaluation recommends modifica--Modified ordinances developed and cont. tions, begin process to amend put in place. ordinances to modify sizing require- ments as support oflocal government leaders exists. BCHD Continue monitoring OSSF inspections -Document inspection follow ups. as required by county ordinance. - # of inspections finding improperly operating OSSFs. BCHD, AgriLife Deliver OSSF E&O as needed through - # ofE&O materials delivered. Extension identified mechanisms. - # of OSSF owners contacted thru E&O efforts. 4 BCHD Complete efforts to identify all OSSFs -GIS info coordinated between enti- in watershed; add new OSSFs to data-ties. base as constructed. - # of OSSFs identified an added to database. BCHD Following amendment/establishment -E&O delivery of new ordinance and of ordinance requiring inspections on impacts to OSSF owners. all OSSFs, begin notifying all OSSF owners of inspection requirements. BCHD Implement OSSF sizing requirements -OSSF sizing requirements modified following ordinance amendment. in ordinance. BCHD Continue monitoring OSSF inspections -Document inspection follow ups. as required by county ordinance. - # of inspections finding improperly operating OSSFs. BCHD, AgriLife Deliver OSSF E&O as needed through - # of E&O materials delivered. Extension identified mechanisms. - # of OSSF owners contacted th ru E&O efforts. 5 BCHD Add new OSSFs to database as con--GIS info coordinated between enti- structed. ties. - # of OSSFs identified an added to database. BCHD Implement new inspection ordinance -Document inspection follow ups. requiring all OSSFs to be inspected. - # of inspections finding improperly operating OSSFs. BCHD Implement OSSF sizing requirements -OSSF sizing requirements modi- following ordinance amendment. fied in ordinance. BCHD, AgriLife Deliver OSSF E&O as needed through - # of E&O materials delivered. Extension identified mechanisms. - # of OSSF owners contacted thru E&O efforts. Texas Commission on Environmental Quality 69 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Table A-4 SSO Initiative Implementation -Implementation Schedule and Tasks Plan Responsible Year Parties Implementation Measure Implementation Milestones 1 COB Continue implementing SSO initiative -Inflow and infiltration studies com- as planned and funding allows. pleted to target repairs. -# SSO incidents tracked; cause and source identified. -# of repairs documented and tracked. -GIS of SSO initiative actions. co cs Complete development ofSSO initia--SSO initiative developed and com- tive. pleted. COB&COCS Disseminate E&O materials to sewer--#of E&O materials disseminated. age system customers in efforts to - # of customers reached by E&O ma- minimize future SSO events. terial delivery. 2 COB Continue implementing SSO initiative -Inflow and infiltration studies com- as planned and funding allows. pleted to target repairs. - # SSO incidents tracked; cause and source identified. - # of repairs documented and tracked. -GIS ofSSO initiative actions. co cs Begin implementing SSO initiative as -Inflow and infiltration studies com- planned and funding allows. pleted to target repairs. - # SSO incidents tracked; cause and source identified. - # of repairs documented and tracked. -GIS ofSSO initiative actions. COB&COCS -disseminate E&O materials to sewer-- # of E&O materials disseminated. age system customers in efforts to -#of customers reached by E&O ma- minimize future SSO events. terial delivery. 3 and beyond COB&COCS Continue implementing SSO initiative -Inflow and infiltration studies com- as planned and funding allows. pleted to target repairs - # SSO incidents tracked; cause and source identified -# of repairs documented and tracked -GIS of SSO initiative actions COB&COCS Disseminate E&O materials to sewer-- # ofE&O materials disseminated. age system customers in efforts to - # of customers reached by E&O ma- minimize future SSO events. terial delivery. Texas Commission on Environmental Quality 70 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Table A-5 Voluntary Agricultural BMPs -Implementation Schedule and Tasks Plan Responsible Year Parties Implementation Measure Implementation Milestones 1 Brazos County Complete landowner identification of all -Contact information for all NRCS properties actively used in agricultural property owners compiled. use (used to deliver E&O materials by NRCS/SWCD personnel only). Brazos County Develop and apply property prioritization -Developed property ranking ma- NRCS, Brazos matrix to rank properties for voluntary trix. County SWCD, BMP implementation targeting. -Rankings applied to properties in TPWD, TSSWCB watershed. Brazos County E&O needs assessed, recommendations -Determination ofE&O strategy. NRCS, AgriLife made, and begin implementing. -# of E&O materials disseminat- Extension ed. -# oflandowners reached through E&O efforts. 2 Brazos County Make contact with priority 1 landowners -Contacts documented. NRCS informing them about availability volun- tary BMP implementation assistance program and need for participation. Brazos County Begin working with willing landowners to -# oflandowners willing to partic- NRCS, other develop and implement property-specific ipate. agencies asap-plans to improve water quality. - # of plans developed. propriate - # and type of BMPs implement- ed. Brazos County Continue delivering E&O as appropriate. - # ofE&O materials disseminat- NRCS, AgriLife ed. Extension - # ofE& 0 events held. - # oflandowners reached through E&O efforts. 3 Brazos County Make contact with priority 2 landowners -Contacts documented. NRCS informing them about availability of vol- untary BMP implementation assistance program and need for participation. Brazos County Continue working with willing landown--# of landowners willing to partic- NRCS, other ers to develop and implement property-ipate. agencies asap-specific plans to improve water quality. -#of plans developed. propriate -#and type of BMPs implement- ed. Brazos County Continue delivering E&O as appropriate. - # ofE&O materials disseminat- NRCS, AgriLife ed. Extension -# oflandowners reached through E&O efforts. Texas Commission on Environmental Quality 71 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Table A-5, continued Voluntary Agricultural BMPs Plan Responsible Year Parties Implementation Measure 4 Brazos County Make contact with priority 3 lando'A'l1ers NRCS informing them about availability of vol- untary BMP implementation assistance program and need for participation. Brazos County Continue working with willing landown- NRCS , other ers to develop and implement property- agencies asap-specific plans to improve water quality. propriate Brazos County Continue delivering E&O as appropriate. NRCS, AgriLife Extension 5 Brazos County Make second contact with selected land- NRCS owners informing them about availability of voluntary BMP implementation assis- tance program and need for participation. Brazos County Continue working with willing landown- NRCS, other ers to develop and implement property- agencies asap-specific plans to improve water quality. propriate Brazos County Continue delivering E&O as appropriate. NRCS, AgriLife Extension Texas Commission on Environmental Quality 72 Implementation Milestones -Contacts documented. - # oflandowners willing to partic- ipate. -# of plans developed. -#and type of BMPs implement- ed. - # of E&O materials disseminat- ed. -# oflandowners reached through E&O efforts. -Contacts documented. -# oflandowners willing to partic- ipate. - # of plans developed. - # and type of BMPs implement- ed. - # ofE&O materials disseminat- ed. - # oflandowners reached through E&O efforts. For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Table A-6. Development/Redevelopment Water Quality Mitigation -Implementation Schedule and Tasks Plan Responsible Year Parties Implementation Measure Implementation Milestones 1 Brazos County, Evaluate the feasibility of developing -Determination made on feasibility COB, COCS, Texas an awards program to recognize good of awards program. A&M,TxDOT actors in selected sectors (construe- tion, developers, landscapers, etc.). Brazos County, Work to deliver needed education -Documentation of the number and COB, COCS, Texas and outreach programming to local types of education and outreach A&M elected and municipal officials and events held. other decision makers. Brazos County, Explore need to review and amend -Documentation of reviews and/or COB, COCS, Texas existing ordinances in support of en-amendments of existing ordinanc- A&M tity specific SWMPs. es. Brazos County, Amend ordinances or rules as appli--Documentation of ordinance or COB, COCS, Texas cable in support of entity specific rule modifications in support of A&M SWMPs as needed. SWMPs. co cs Continue riparian area protection - # of acres tracked that are consid- through 'Greenways' program as ered or are enrolled in 'Greenways' funds and support oflocal govern-program ment leaders allow; expand -Documentation on riparian area information delivery on riparian area protection protection benefits. Brazos County, Coordinate E&O outreach efforts for -Documentation of coordinated COB, COCS, Texas entity employees, local and elected E&O activities held jointly between A&M,TxDOT officials. entities. 2 and beyond Brazos County, If feasible, establish an awards pro--Documentation of awards given COB, COCS, Texas gram to recognize good actors in annually. A&M,TxDOT selected sectors (construction, <level--Winners publicly announced via opers, landscapers, etc.). available information outlets. Brazos County, Continue as needed to amend ordi--Documentation of ordinance or COB, COCS, Texas nances or rules as applicable in rule modifications in support of A&M support of entity specific SWMPs. SWMPs. co cs Continue riparian area protection -# of acres tracked that are consid- through 'Greenways' program as ered or are enrolled in 'Greenways' funds and support oflocal govern-program. ment leaders allow. Brazos County, Coordinate E&O outreach efforts for -Documentation of coordinated COB, COCS, Texas entity employees, local and elected E&O activities held jointly between A&M,TxDOT officials. entities. Texas Commission on Environmental Quality 73 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Table A-7. Individual MS4 Phase II SWMPs -Implementation Schedule and Tasks Plan Responsible Year Parties Implementation Measure Implementation Milestones All Brazos County, Implement MCMs and BMPs accord--Annual reports to TCEQ docu- COB, COCS, Texas ing to individual entity MS4 Phase II menting progress in implementing A&M,TxDOT SWMPs. MCMs and BMPs. Brazos County, Continue participating in Brazos -Actions of meetings documented COB, COCS, Texas Clean Water to coordinate and plan and brazoscleanwater.org updated. A&M,TxDOT E&O efforts. Brazos County, Delivery of E&O materials to target -Documentation ofE&O efforts. COB, COCS, Texas audiences as needed. -# of E&O materials delivered. A&M,TxDOT -# of people/households reached through E&O efforts. Table A-8. Continue Monitoring WWTF Effluent E.coli Levels according to Individual Permit Requirements -Implementation Schedule and Tasks Plan Responsible Year Parties Implementation Measure Implementation Milestones All COB, COCS, Glen Operate permitted discharges as de--Permit adhered to annually. Oaks WWTF, Texas scribed in each entity specific TPDES A&M permit. COB, COCS, Glen Report E. coli concentrations in dis--E. coli data reported to TCEQ in Oaks WWTF, Texas charge effluent as required by entity Discharge Monitoring Reports. A&M specific TPDES permits. Texas Commission on Environmental Quality 74 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Appendix B. Load Reduction Estimates Texas Commission on Environmental Quality 75 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed Management Measure 3.0 : Load Reduction Estimate OSSF Identification As reported in the Technical Support Document for Bacteria TMDLs, Carters Creek Watershed (Segments 1209D, 1209 L, & 1209C), the Brazos County Health Department indicated that 455 OSSFs are known to exist within the Carters Creek watershed. Of these, 98 percent were thought to be aerobic and are re- quired to be inspected three times annually under a service contract; the other 2 percent (or 9 systems) are conventional OSSFs. Soils in Brazos County are not conducive to conventional OSSFs, and almost all new OSSFs are aerobic systems due to the elevated potential for failure in conventional systems. Using their best professional judgment, the Wastewater Work Group estimated that approximate- ly 50 percent of conventional OSSFs may be failing, or a total of 5 systems. Additionally, it is also assumed that as many as 5 percent of aerobic OSSFs may be experiencing operational problems at any one time and thus could be consid- ered to be malfunctioning. Using the equations presented below, estimated load reductions can be developed for identifying and repairing failing septic systems in the watershed and addressing operational malfunctions of aerobic OSSFs. ConventionalOSSFs 70 gallons fecal coli[ arms person mL 5 failing septic systems * 106 00 * .63 * d * 3785.2 ll 1 mL ay ga on * persons _ 11 cfu 2.52 h h ld -2.10x 10 d ouse o ay In this equation, the inputs are as follows: • 5 OSSFs are considered failing in the watershed (Work Group determination; roughly 50% of current known number of conventional OSSFs in watershed due to soils and conventional OSSF age; further supported by Reed, Stowe and Yanke 2001 findings that soil and system age are major factors in system malfunctions) • 106 ....!:.f.::!:.. =fecal coliform concentration rate in onsite sewage facility effluent lOOmL as reported by Metcalf & Eddy, 1991; Canter & Knox, 1985; Cogger & Carlile, 1984 • .63 = conversion factor to convert between fecal coliform and E. coli derived by dividing the current E. coli standard of 126 cfu/10omL by the previously used fecal coliform standard of 200 cfu/10omL Texas Commission on Environmental Quality 76 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed • 3785.2~ =number of milliliters in a gallon gallon • 70 gallons per person per day is estimated discharge in OSSFs as reported by Horsley & Witten, 1996 • 2.52 persons per household is the US Census Bureau's Brazos County estimate for2009 Assumptions made include: • Identifying these failing septic systems and working with their owners to cor- rect these problems is achievable • Colony Forming Units (CFUs) of E. coli and Most Probably Number (MPN) of E.coli are considered as equals and are used inter-changeably Using these assumptions, an average daily load reduction of 2.10x1011 cf u can be day achieved by repairing these systems. This calculation is easily scalable to account for other failing or malfunctioning OSSFs. Aerobic OSSFs 70 gallons fecal coli/ arms person 22 failing septic systems * 106 100 ml * .63 * day * ml * persons _ 11 cfu 3785.2 ll 2.52 h h ld -9.25x10 d ga on ouse o ay In this equation, the inputs are as follows: • • • • • 22 OSSFs are considered malfunctioning in the watershed (Work Group de- termination; roughly 5% of current known number of aerobic OSSFs in watershed due to improper operation of systems. The county requires three system inspections annually thus minimizing this number.) 106 ....::.f::!._ =fecal coliform concentration rate in onsite sewage facility effluent lOOm L as reported by Metcalf & Eddy, 1991; Canter & Knox, 1985; Cogger & Carlile, 1984 (assumed that effluent from malfunctioning aerobic OSSFs is similar in quality to conventional OSSF effluent .63 = conversion factor to convert between fecal coliform and E. coli derived by dividing the current E. coli standard of 126 cfu/10omL by the previously used fecal coliform standard of 200 cfu/10omL 3 785.2 ~ = number of milliliters in a gallon gallon 70 gallons per person per day is estimated discharge in OSSFs as reported by Horsley & Witten, 1996 Texas Commission on Environmental Quality 77 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed • 2.52 persons per household is the US Census Bureau's Brazos County estimate for2009 Assumptions made include: • Identifying these malfunctioning septic systems and working with their own- ers to correct these problems is achievable • Colony Forming Units (CFUs) of E. coli and Most Probably Number (MPN) of E.coli are considered as equals and are used inter-changeably Using these assumptions, an average daily load reduction of 9.25x1011 cfu can be day achieved by repairing these systems. This calculation is easily scalable to account for other failing or malfunctioning OSSFs. Management Measure 4.0: Load Reduction Estimate 550 Initiative Implementation In the Technical Support Documentfor Bacteria TMDLs, Carters Creek Water- shed (Segments 1209D, 1209L & 1209C), sanitary sewer overflows (SSOs) were identified as one contributor of E. coli into the storm sewer system. Stormwater managers actively identifying these SSOs and subsequently working with wastewater collection system personnel to rectify these problems is one manage- ment measure that will produce a quantifiable E. coli load reduction. Using the SSO information presented in the Technical Support Document for Bacteria TMDLs, Carters Creek Watershed (Segments 1209D, 1209L & 1209C) and pub- lished literature values identified below, the following equation was derived to estimate an estimated load reduction for reducing the average number of SSO events by half. SSOs gallons 107 cfu ml cfu .132 day * 8748 SSO * lOOmL * .63 * 3785.2 gallon = 2.7Sx1012 day In this equation, the inputs are as follows: • .132 ssos = 248 SSOs recorded over a 1,884 day period day • 8748 gallons = 248 SSOs totaling 2,169,622 gallons of sewage sso • 107 -2.:!:_ =fecal coliform concentration rate in raw sewage as reported by lOOmL Metcalf & Eddy, 1991 Texas Commission on Environmental Quality 78 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed • .63 = conversion factor to convert between fecal coliform and E. coli derived by dividing the current E. coli standard of 126 cfu/10omL by the previously used fecal coliform standard of 200 cfu/10omL • 3 785.2 ~ = number of milliliters in a gallon gallon Assumptions made include: • Goal of SSO initiatives are zero SSOs. While SSOs will likely occur as failures cannot be planned, the estimated load reduction is based on zero SSOs occur- rmg. • Colony Forming Units (CFUs) of E. coli and Most Probably Number (MPN) of E. coli are considered as equals and are used inter-changeably Assuming that this level of load reduction can be achieved by reducing the aver- age number of SSO occurrences by half and that the average SSO volume remains about the same, the average daily load in Carters Creek as measured at Station 11785 under very high flow conditions will be reduced from 1.6895 * 1013 MPN to 1.4141*1013 MPN. day day Management Measure 5.0 : Load Reduction Estimate Potential load reductions that could be achieved by implementing practices through the TSSWCB WQMP Program will depend specifically on the particular BMP implemented by each individual landowner and the number of livestock in each landowner's operation. BMPs that have been included in EQIP or WQMP programs, that have been documented to measurably reduce the amount of fecal bacteria loading from cattle, and that can be employed in the Carters Creek wa- tershed include exclusionary fencing, filter strips, prescribed grazing, stream crossings, and alternate or additional watering facilities. Fencing, prescribed grazing, and water development are the three most likely practices to be imple- mented. These BMPs have beeq the subject of various research efforts and estimated bac- teria reduction efficiencies have been established for these practices through these studies. Table B-1 lists the individual practice, the range of bacteria removal efficiency and the midpoint of the efficiency range as described in the literature. While research conducted in these works was not conducted in the Carters Creek watershed, or in Texas in most cases, these studies do illustrate the abilities of these practices to reduce bacteria contributions from livestock. Without water- shed-specific BMP efficiency evaluations, using the midpoint of the effectiveness ranges should be a safe assumption for predicting potential load reductions that Texas Commission on Environmental Quality 79 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed could be realized through voluntary BMP implementation; however, using the lowest effectiveness rate will likely give a more dependable prediction for load reductions. One challenge that will be experienced in the Carters Creek watershed when working with landowners to use these programs will be pressure from land devel- opment. As the population of the Bryan and College Station area continues to grow, increasing demands for currently undeveloped lands in the watershed will persist. Many of the rural areas that are currently used for agricultural purposes on the fringes of the urbanized area are being shopped for development opportu- nities and this trend will likely continue into the future. As a result, landowners who feel that they will sell their property soon may be apprehensive to implement conservation practices through the EQIP or WQMP programs due to require- ments to maintain practices over a designated period. As a result, potential load reductions realized from implementation of this management measure may be minimal. Table B-1. Livestock BMP Fecal Coliform Removal Efficiencies Effectiveness: Effectiveness: Effectiveness: Management Practice Low Rate High Rate Mid-point Fencing to Limit Creek Access 1 30% 94% 62% Filter Strips 2 30% 100% 65% Prescribed Grazing 3 42% 66% 54% Stream Crossing 4 44% 52% 48% Watering Facility 5 51% 94% 72.5% 1 Brenner 1996, Cook 1998, Hagedorn et al. 1999, Line 2002, Line 2003, Lombardo et al. 2000, Meals 2001, Meals 2004 2 Casteel et al. 2005, Cook 1998, Coyne et al. 1995, Fajardo et al. 2001, Goel et al. 2004, Larsen et al. 1994, Lewis et al. 2010, Mankin & Okoren 2003, Roodsari et al. 2005, Stuntebeck & Bannerman 1998, Sullivan 2007, Tate 2006, Young 1980 3 Tate et al. 2004, USEP A 2010 4 Inamdar et al. 2002, Meals 2001 5 Byers et al. 2005, Hagedorn et al. 1999, Sheffield et al. 1997, Wagner 2011 To calculate potential load reductions for each of these five BMPs, a generic equa- tion has been developed based upon the number of animal units, average fecal material production rates of beef cattle, the average E. coli content of beef cattle manure and the selected BMP effectiveness rate as listed above in Table 2. This generic form of equation based on animal units was chosen because an accurate Texas Commission on Environmental Quality 80 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed estimation of BMP implementation cannot be clearly defined. Since BMP imple- mentation is strictly voluntary, no firm number of BMPs that will be installed can be established. The number of cattle or animal units in an operation that volun- tarily implements some of these BMPs can also not be determined prior to the actual implementation. As a result, basing the equation on the number of animal units can serve as a starting point for making estimations of potential load reduc- tions that could be realized by implementing each practice. Potential load Reduction g 37,195-d ay . = #of A Us* AU * 7.97x105 * BMP Ef f ectwness Rate In this equation, inputs are as follows: • AU = animal unit defined as 1,000 pounds of animal weight (i.e. a 1,400lb cow= L4AU) • 37,195 ...!L =the average fecal production rate of beef cattle as reported by day Metcalf & Eddy, 1991 and referenced in Wagner and Moench, 2009. • 7.97x10s =the average E.coli production per gram of beef cattle fecal mat- ter as reported in unpublished data from pastured cattle in the Cedar Creek watershed, Brazos County, Texas (Karthikeyan, 2011). • BMP Effectiveness rate = midpoint of BMP efficiencies as illustrated in Table B-1. Management Measure 6.0: Load Reduction Estimate Riparian Area Protection Using information similar to that used in the Gilleland Creek TMDL I-Plan, the following equation can be used to estimate a projected E. coli load reduction per acre. tons lbs g fecal coli[ orm #of acres * 2--soil savings * 2000-* 453.6-* 1000 cfu ------acre ton lb g of sediment E.coli * .63 " 1 l'f = estimated load reduction 1eca co 1 orm The inputs to this equation are as follows: Texas Commission on Environmental Quality 81 For Public Comment, April 2012 Draft Implementation Plan for Three TMDLs in the Carters Creek Watershed • 2 tons/acre soil savings based on 40% reduction in sediment loss as a result of riparian area protection. • 2,000 lbs/ton is the number of pounds in 1 ton • 453.6 is the number of grams in 1 pound • 1,000 cfu fecal coliform/ gram of sediment • .63 = conversion factor to convert between fecal coliform and E. coli derived by dividing the current E. coli standard of 126 cfu/10omL by the previously used fecal coliform standard of 200 cfu/10omL Assumptions made include: • Colony Forming Units (CFUs) of E. coli and Most Probably Number (MPN) of E.coli are considered as equals and are used inter-changeably • According to NRCS Web Soil Survey, the Sandow Loam dominates the flood plain in the Carters Creek watershed and has an average annual soil loss of s tons/acre; therefore a 40% reduction in sediment loss reduces sediment load- ing to the creeks by 2 tons/ acre • Sediment contains 1,000 cfu of fecal coliform per gram. Number is based on the approximate mid-point of a data set collected in Arkansas (HDR 2003). Using a hypothetical 100 acre area of the watershed as having Riparian Area Pro- tection applied, an estimated E. coli load reduction of 1.14 * 1011 MPN could be day expected. Texas Commission on Environmental Quality 82 For Public Comment, April 2012