HomeMy WebLinkAboutQueens Creek TMDL_APPROVEDTotal Maximum Daily Loads for Fecal Coliform
for Queens Creek, North Carolina
[Waterbody IDs: 19-41-16-1; 19-41-16-5; 19-41-16-3; 19-41-16-4a; 19-41-16-4b; 19-41-16-2;
19-41-16a; 19-41-16b1; 19-41-16b2; 19-41-16c; 19-41-16d]
Final Report
August 2011
Prepared by:
NC Department of Environment and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
White Oak River Basin
Queens Creek Fecal Coliform TMDL
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Table of Contents
List of Abbreviations .............................................................................................................. ii
SUMMARY SHEET ................................................................................................................. iii
1 INTRODUCTION .............................................................................................................. 1
1.1 TMDL Components ......................................................................................................... 2
1.2 Documentation of Impairment ....................................................................................... 4
1.3 Watershed Description ................................................................................................... 5
1.4 Water Quality Characterization ...................................................................................... 8
2 SOURCE ASSESSMENT .................................................................................................. 10
2.1 Nonpoint Source Assessment ....................................................................................... 10
2.2 Point Source Assessment .............................................................................................. 11
3 TOTAL MAXIMUM DAILY LOADS AND LOAD ALLOCATION ............................................. 12
3.1 TMDL Objective ............................................................................................................. 12
3.2 Modeling ....................................................................................................................... 12
3.2.1 Approach ................................................................................................................... 12
3.2.2 Existing Load Calculation .......................................................................................... 13
3.2.3 TMDL Calculation ...................................................................................................... 15
3.3 TMDL Allocation ............................................................................................................ 16
3.3.1 Margin of Safety (MOS) ............................................................................................ 17
3.3.2 Waste Load Allocation (WLA) ................................................................................... 17
3.3.3 Load Allocation (LA) .................................................................................................. 18
3.3.4 Critical Condition and Seasonal Variation ................................................................ 19
3.3.5 TMDL Summary ......................................................................................................... 20
4 TMDL IMPLEMENTATION PLAN .................................................................................... 22
5 PUBLIC PARTICIPATION ................................................................................................ 22
6 FURTHER INFORMATION .............................................................................................. 22
7 REFERENCES ................................................................................................................. 23
Appendix A: NCDEH Monitoring Data Summary .................................................................. 25
Appendix B: NCDEH Mapping of Potential Pollution Sources in D-2 Growing Area ............... 32
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Appendix C: Public Announcement ..................................................................................... 33
Appendix D: Public Comments Responsiveness Summary ................................................... 34
List of Abbreviations
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SUMMARY
Total Maximum Daily Load (TMDL)
1. 303(d) Listed Waterbody Information
State: North Carolina
County: Onslow
Major River Basin: White Oak River Basin
Watershed: USGS HUC 03020106020060
Impaired Waterbody (2010 303(d) List):
Waterbody Name – [AU] Description Water Quality
Classification Acres
Bell Swamp - [19-41-16-1] From source to Queen Creek SA;HQW 1
Dicks Creek - [19-41-16-5] From source to Queen Creek SA;HQW 22.8
Halls Creek - [19-41-16-3] From source to Queen Creek SA;HQW 26.9
Parrot Swamp - [19-41-16-4a] From source to DEH closure line. SA;HQW 65.3
Parrot Swamp - [19-41-16-4b] From DEH closure line to Queen Creek SA;HQW 46.3
Pasture Branch - [19-41-16-2] From source to Queen Creek SA;HQW 1
Queen Creek - [19-41-16a] DEH closed area from source to DEH
Conditionally Approved closed line at
Queens Creek Road Bridge.
SA;HQW 283.7
Queen Creek - [19-41-16b1] From DEH Conditionally Approved
closed line at Queens Creek Road
Bridge to DEH Conditionally Approved
Open line at northeast mouth of
Parrot Swamp.
SA;HQW 150.8
Queen Creek - [19-41-16b2] From DEH Conditionally Approved
closed line at Queens Creek Road
Bridge to DEH Conditionally Approved
Open line at northeast mouth of
Parrot Swamp.
SA;HQW 11.6
Queen Creek - [19-41-16c] From DEH Conditionally Approved
Open line at northeast mouth of
Parrot Swamp to Intracoastal
Waterway.
SA;HQW 283.8
Queen Creek - [19-41-16d] DEH closed area at mouth of Dicks
Creek
SA;HQW 3
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Constituent(s) of Concern: Fecal Coliform Bacteria
Designated Uses: Shellfish harvesting, biological integrity, propagation of aquatic life, and
recreation.
Applicable Tidal Salt Water Quality Standards for Class SA Waters:
“Organisms of coliform group: fecal coliform group not to exceed a median MF count of
14/100 ml and not more than 10 percent of the samples shall exceed an MF count of 43/100
ml in those areas most probably exposed to fecal contamination during the most unfavorable
hydrographic and pollution conditions.”
For the approval of shellfish growing areas “the median fecal coliform Most Probable Number
(MPN) or the geometric mean MPN of water shall not exceed 14 per 100 milliliters, and not
more than 10 percent of the samples shall exceed a fecal coliform MPN of 43 per 100
milliliters (per five tube decimal dilution) in those portions of areas most probably exposed to
fecal contamination during most unfavorable hydrographic conditions” (15A NCAC 18A .0431
Standards for an Approved Shellfish Growing Area). In addition, “a minimum of the 30 most
recent randomly collected samples from each sample station shall be used to calculate the
median or geometric mean and 90th percentile to determine compliance with this standard”
(NSSP, 2007).
2. TMDL Development
Development Tools (Analysis/Modeling): Spreadsheet-based steady-state tidal prism model
Critical Condition: The 90th percentile concentration is the concentration exceeded only 10%
of the time. Since the data used for model simulation spans 5 years, the critical condition is
implicitly included in the value of the 90th percentile of model results.
Seasonal Variation: Given the long-term flow and water quality data record used to estimate
the fecal coliform load, the seasonal variability is implicitly included in the analysis.
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3. TMDL Allocation Summary
Fecal Coliform Load (MPN/day)
Waterbody AUs Existing
Load1 WLA2 LA MOS TMDL %
Reduction
Lower Queens 19-41-16c;
19-41-16d
Less than
TMDL 1.16E+10 1.68E+12 1.88E+11 1.88E+12 0%
Middle Queens 19-41-16b1;
19-41-16b2
Less than
TMDL 5.17E+09 3.57E+11 4.02E+10 4.02E+11 0%
Upper Queens,
Pasture Branch,
Bells Swamp
19-41-16a;
19-41-16-2;
19-41-16-1
8.61E+11 7.72E+09 2.81E+11 3.21E+10 3.21E+11 63%
Dicks Creek 19-41-16-5 Less than
TMDL 1.12E+09 3.39E+10 3.89E+09 3.89E+10 0%
Parrot Swamp 19-41-16-4a;
19-41-16-4b 1.07E+11 2.14E+09 8.33E+10 9.49E+09 9.49E+10 11%
Halls Creek 19-41-16-3 2.58E+11 7.23E+08 3.03E+10 3.45E+09 3.45E+10 87%
1. For Lower Queens, Middle Queens, and Dicks Creek, the calculated existing loads are less than the TMDL,
and hence no reduction is needed from those subwatersheds.
2. WLA applies solely to NCDOT.
4. Public Notice Date: June 27, 2011
5. Submittal Date: August 1, 2011
6. Establishment Date: August 18, 2011
7. EPA Lead on TMDL (EPA or blank):
8. Endangered Species (yes or blank):
9. MS4s Contributions to Impairment (Yes or Blank):
10. TMDL Considers Point Source, Nonpoint Source, or both: Both
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1 INTRODUCTION
Section 303(d) of the federal Clean Water Act (CWA) and the U.S. Environmental
Protection Agency’s (EPA) implementing regulations direct each State to develop a Total
Maximum Daily Load (TMDL) for each impaired water quality limited segment on the
Section 303(d) list, taking into account seasonal variations and a protective margin of
safety (MOS) to account for uncertainty. A TMDL reflects the total pollutant loading
that a waterbody can receive and still meet water quality standards.
TMDLs are established to achieve and maintain water quality standards. A water quality
standard is the combination of a designated use for a particular body of water and the
water quality criteria designed to protect that use. Designated uses include activities
such as swimming, drinking water supply, and shellfish propagation and harvest. Water
quality criteria consist of narrative statements and numeric values designed to protect
the designated uses. Criteria may differ among waters with different designated uses.
The Queens Creek watershed is located in the White Oak River Basin (NC Subbasin 03-
05-01 – HUC 03020106020060) along the North Carolina coast in Onslow County. The
river is located within the shellfish area designated D-2 by the North Carolina Division of
Environmental Health (NCDEH). Most of the shellfish growing area is conditionally open
or closed, or prohibited (Figure 1.1).
When shellfish harvesting is the designated use, the primary parameter of concern is
fecal coliform bacteria (FC). Fecal coliform bacteria are found in the intestinal tract of
humans and other warm-blooded animals. Few fecal coliform bacteria are pathogenic;
however, the presence of elevated levels of fecal coliform in shellfish waters indicates
recent sources of pollution. Some common waterborne diseases associated with the
consumption of raw clams and oysters harvested from polluted water include viral and
bacterial gastroenteritis and hepatitis A. Fecal coliform in surface waters may come
from point sources (e.g., NPDES stormwater conveyances) and nonpoint sources.
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Figure 1.1 – Queens Creek Shellfish Growing Area (D-2) Classifications
1.1 TMDL Components
The 303(d) process requires that a TMDL be developed for each of the waters appearing
in Category 5 of a state’s Integrated Report. The objective of a TMDL is to estimate
allowable pollutant loads and allocate to known sources so that actions may be taken to
restore the water to its intended uses (USEPA, 1991). This TMDL is the total amount of
a pollutant that can be assimilated by the receiving water while still achieving North
Carolina’s water quality criteria for shellfish waters. Currently, TMDLs are expressed as
a “mass per unit time, toxicity, or other appropriate measure” (40 CFR 130.2(i)). It is
also important to note that the TMDLs presented herein are not literal daily limits.
These loads are based on an averaging period that is defined by the water quality
criteria.
Generally, the primary components of a TMDL, as identified by EPA (1991, 2000) and the
Federal Advisory Committee (USEPA, 1998) are as follows:
Target Identification or selection of pollutant(s) and end-point(s) for consideration. The
pollutant and end-point are generally associated with measurable water quality related
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characteristics that indicate compliance with water quality standards. North Carolina
indicates known pollutants on the 303(d) list.
Source Assessment. All sources that contribute to the impairment should be identified
and loads quantified, where sufficient data exist.
Reduction Target. Estimation or level of pollutant reduction needed to achieve water
quality goal. The level of pollution should be characterized for the waterbody,
highlighting how current conditions deviate from the target end-point. Generally, this
component is identified through water quality modeling.
Allocation of Pollutant Loads. Allocating pollutant control responsibility to the sources
of impairment. The wasteload allocation portion of the TMDL accounts for the loads
associated with existing and future point sources. Similarly, the load allocation portion
of the TMDL accounts for the loads associated with existing and future non-point
sources, stormwater, and natural background.
Margin of Safety. The margin of safety addresses uncertainties associated with
pollutant loads, modeling techniques, and data collection. Per EPA (USEPA, 2000), the
margin of safety may be expressed explicitly as unallocated assimilative capacity or
implicitly due to conservative assumptions.
Seasonal Variation. The TMDL should consider seasonal variation in the pollutant loads
and end-point. Variability can arise due to stream flows, temperatures, and exceptional
events (e.g., droughts, hurricanes).
Critical Conditions. Critical conditions indicate the combination of environmental factors
that result in just meeting the water quality criterion and have an acceptably low
frequency of occurrence.
Section 303(d) of the CWA requires EPA to review all TMDLs for approval or disapproval.
Once EPA approves a TMDL, then the waterbody may be moved to Category 4a of the
Integrated Report. Waterbodies remain in Category 4a until compliance with water
quality standards is achieved. Where conditions are not appropriate for the
development of a TMDL, management strategies may still result in the restoration of
water quality.
TMDL is comprised of the sum of individual wasteload allocations (WLAs) for point
sources, load allocations (LAs) for nonpoint sources, and natural background levels. The
TMDL must include a margin of safety (MOS), either implicitly or explicitly, that accounts
for the uncertainty in the relationship between pollutant loads and the quality of the
receiving waterbody, and in the scientific and technical understanding of water quality
in natural systems.
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1.2 Documentation of Impairment
The North Carolina Division of Water Quality (NCDWQ) Surface Water and Wetlands
classification for these impaired waters is Class SA, HQW Waters – Shellfish Harvesting
Waters (15A NCAC 02B.0221 Tidal Salt Water Quality Standards for Class SA Waters).
Class SA waters are waterbodies suitable for commercial shellfishing and all other tidal
saltwater use (NCAD, 2003).
Eleven segments, or assessment units (AUs), of Queens Creek and its tributaries have
been included in Category 5 of the 2010 North Carolina Integrated Report, as shown
below in Table 1.1.
Table 1.1 – Queens Creek Impaired Assessment Units
–
Bell Swamp - [19-41-16-1] From source to Queen Creek SA;HQW 1
Dicks Creek - [19-41-16-5] From source to Queen Creek SA;HQW 22.8
Halls Creek - [19-41-16-3] From source to Queen Creek SA;HQW 26.9
Parrot Swamp - [19-41-16-4a] From source to DEH closure line. SA;HQW 65.3
Parrot Swamp - [19-41-16-4b] From DEH closure line to Queen Creek SA;HQW 46.3
Pasture Branch - [19-41-16-2] From source to Queen Creek SA;HQW 1
Queen Creek - [19-41-16a] DEH closed area from source to DEH
Conditionally Approved closed line at
Queens Creek Road Bridge.
SA;HQW 283.7
Queen Creek - [19-41-16b1] From DEH Conditionally Approved
closed line at Queens Creek Road
Bridge to DEH Conditionally Approved
Open line at northeast mouth of
Parrot Swamp.
SA;HQW 150.8
Queen Creek - [19-41-16b2] From DEH Conditionally Approved
closed line at Queens Creek Road
Bridge to DEH Conditionally Approved
Open line at northeast mouth of
Parrot Swamp.
SA;HQW 11.6
Queen Creek - [19-41-16c] From DEH Conditionally Approved
Open line at northeast mouth of
Parrot Swamp to Intracoastal
Waterway.
SA;HQW 283.8
Queen Creek - [19-41-16d] DEH closed area at mouth of Dicks
Creek
SA;HQW 3
These restricted shellfish harvesting areas are identified as areas that do not meet their
designated uses. Waters within this classification, according to 15A NCAC 02B.0221
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(Tidal Salt Water Quality Standards for Class SA Waters), must meet the following water
quality standard in order to meet their designated use:
Organisms of coliform group: fecal coliform group not to exceed a median
MF count of 14/100 ml and not more than 10 percent of the samples shall
exceed an MF count of 43/100 ml in those areas most probably exposed
to fecal contamination during the most unfavorable hydrographic and
pollution conditions.
In addition, for approval of shellfish growing areas “the median fecal coliform Most
Probable Number (MPN) or the geometric mean MPN of water shall not exceed 14 per
100 milliliters, and not more than 10 percent of the samples shall exceed a fecal
coliform MPN of 43 per 100 milliliters (per five tube decimal dilution) in those portions
of areas most probably exposed to fecal contamination during most unfavorable
hydrographic conditions” (15A NCAC 18A .0431 Standards for an Approved Shellfish
Growing Area).
For this report, the monitoring data averaging period was based on monitoring
procedures for classifying SA water, i.e. fecal coliform concentration cannot exceed a
median of an MPN of 14 per 100 ml and the 90th percentile of an MPN of 43 per 100 ml.
The averaging period for the monitoring data required at least 30 samples per station
within the most recent five-year period, September 2005 – August 2010. A detailed
analysis of the data used can be found in Appendix A.
1.3 Watershed Description
Queens Creek and its tributaries fall within the NCDEH D-2 Growing Area in Onslow
County. The Queens Creek watershed was delineated using EPA BASINS
(http://water.epa.gov/scitech/datait/models/basins/). The resulting watershed outline
is provided below in Figure 1.2. The watershed covers about 36 square miles. The
towns of Swansboro and Hubert are within the watershed. Oyster and clam production
are good throughout the area, however most of the shellfish beds areas are prohibited,
or conditionally closed or open, due to high fecal coliform levels.
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Figure 1.2 – Queens Creek Watershed Delineation
The dominant tide in this region is the lunar semi-diurnal (M2) tide with a mean tidal
range of 3.11 ft based on the NOAA station at Beaufort, NC (NOAA, 2010).
The 2006 National Land Cover Database (NLCD) was used to obtain land cover
characteristics of the watershed (http://www.mrlc.gov/nlcd2006_downloads.php).
Land cover distribution is shown in Figure 1.3 and land cover acreages are provided in
Table 1.2. The dominant land covers in this watershed are forest (26%), crops and
pasture lands (18%), wetlands (17%), shrub/scrub areas (14%), and developed lands
(14%).
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Figure 1.3 – 2006 NLCD Land Cover of the Queens Creek Watershed
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Table 1.2 – 2006 Land Cover Distribution of the Queens Creek Watershed
Cultivated Crop 4,109.9 17.7%
Pasture/Hay 62.5 0.3%
Deciduous Forest 4.6 0.0%
Evergreen Forest 5,566.2 24.0%
Mixed Forest 643.2 2.8%
Developed High Intensity 14.1 0.1%
Developed Low Intensity 1,412.1 6.1%
Developed Medium Intensity 108.5 0.5%
Developed Open Space 1,607.7 6.9%
Grassland Herbaceous 1,584.5 6.8%
Shrub/Scrub 3,175.7 13.7%
Emergent Herbaceous Wetlands 636.7 2.7%
Woody Wetlands 3,225.1 13.9%
Barren Land 63.7 0.3%
Open Water 1,025.9 4.4%
Total Area 23,240.2 100.0%
1.4 Water Quality Characterization
The Shellfish Sanitation and Recreational Water Quality Section of the NCDEH is
responsible for classifying shellfish harvesting waters to ensure oysters and clams are
safe for human consumption. NCDEH adheres to the requirements of the National
Shellfish Sanitation Program (NSSP), with oversight by the U.S. Food and Drug
Administration. NCDEH conducts shoreline surveys and collects routine bacteria water
quality samples in the shellfish-growing areas of North Carolina. The data are used to
determine if the water quality criteria are being met. If the water quality criteria are
exceeded, the shellfish areas are closed to harvest, at least temporarily, and
consequently the designated use is not being achieved.
NCDEH has monitored shellfish growing regions throughout North Carolina for the past
several decades. Queens Creek is sampled using the systematic random sampling
strategy as outlined in the National Shellfish Sanitation Program’s Model Ordinance and
guidance document. In addition to the routine random monitoring of the areas,
conditional area samples are collected after rainfall events for some stations.
There are 27 fecal coliform monitoring stations sampled by the NCDEH in the D-2
Growing Area, as shown in Figure 1.4. Of these, 16 are within the Queens Creek
watershed. Most of the data available were collected through the random monitoring
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strategy, although four stations (7, 9, 11, and 16) are sampled under the conditional
monitoring strategy which is targeted towards measuring fecal coliform concentrations
after rainfall events, typically in conditionally-approved open growing areas. NCDEH
data from September 2005-August 2010 are summarized in Appendix A for those
stations within the Queens Creek watershed. The 2010 NCDEH Sanitary Survey Report
notes four stations did not meet standards for growing area criteria (NCDEH, 2010). The
report also notes that there was widespread improvement in bacteriological water
quality within the D-2 area since the previous Sanitary Survey Report in 2006.
Figure 1.4 – NCDEH Fecal Coliform Monitoring Stations
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2 SOURCE ASSESSMENT
2.1 Nonpoint Source Assessment
Non-point sources are diffuse sources that typically cannot be identified as entering a
water body at a single location. Nonpoint source loading typically occurs during rain
events when surface runoff transports water carrying fecal coliform over the land
surface and discharges it into the stream network. The transport of fecal coliform from
the land to the restricted shellfish harvesting area is dictated by the hydrology, soil type,
land use, and topography of the watershed.
There are many types of nonpoint sources in watersheds that contribute to the
restricted shellfish harvesting areas. The most recent NCDEH Shoreline Survey (NCDEH,
2010) documented and mapped potential sources of fecal coliform in Queens Creek.
The resulting map is provided in Appendix B. The survey found that stormwater
draining into Queens Creek and its tributaries is of particular concern due to the steep
grades along the shoreline throughout the area. Runoff is conveyed rapidly via ditches,
pipes, and lawns into shellfishing waters. With the increasing development in the
region, the majority of the stormwater reaching Queens Creek originates in residential
neighborhoods and roadways. Growth in the area continues to proceed at a high rate.
Overall, 56 subdivisions were noted in the D-2 growing area during the shoreline survey.
Ten of these subdivisions are new, and several of the pre-existing subdivisions surveyed
are now at or near capacity. Over 700 new homes have been constructed within the
various subdivisions of the D-2 watershed since the last survey was conducted in 2006.
Wildlife in the watershed are considered to make up background concentrations of fecal
coliform. There are various forested areas and agricultural fields scattered throughout
the watershed, so wildlife is prevalent throughout the majority of this region. Large
populations of deer, foxes, raccoons, and other small mammals are found in the area, as
well as waterfowl and other birds. Waste from these animals can be transported
through stormwater ditches into shellfishing waters, and have some impact on the
growing area during rainfall events.
Grazing animals contribute fecal coliform through either direct access to streams or
runoff from deposition or manure spreading. According to the shoreline survey, there
are several small horse farms within the D-2 watershed. There are also four cattle farms
and two residences where a small number of chickens are kept penned. It is not likely
that any of these farms has a significant impact on water quality within the area, as
most are located well away from the water, and those that are not contain only a few
animals within large pastures (NCDEH, 2010). Land cover data for the watershed
indicates that pasture/hay land area (grazing land) represents less than 1 percent of the
watershed.
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Agricultural fields of soybeans, corn, tobacco, and winter wheat, as well as a few large
forested areas are also likely to contribute contaminants to the creeks and waterways
following rain events.
Nonpoint source contributions to the bacterial levels from human activities generally
arise from malfunctioning or improperly-sited septic systems and their associated drain
fields, or illicit connections of sanitary sewage to the stormwater conveyance system.
The majority of onsite systems in the growing area were visited and inspected during
the shoreline survey (NCDEH, 2010) and most were found to be functioning properly.
Several issues were located, however, and were reported to the Onslow County Health
Department for corrective action.
2.2 Point Source Assessment
All wastewater discharges to surface water in the State of North Carolina must receive a
permit to control water pollution. The CWA initiated strict control of wastewater
discharges with responsibility of enforcement given to the Environmental Protection
Agency (EPA). The EPA then created the National Pollutant Discharge Elimination
System (NPDES) to track and control point sources of pollution. The primary method of
control is by issuing permits to discharge with limitations on wastewater flow and
constituents. The EPA delegated permitting authority to the State of North Carolina in
1975.
While there are two operating wastewater treatment plants within the D-2 growing
area, neither contains an outfall that discharges to waters in the Queens Creek
watershed. Therefore, neither plant is considered to be contributing to the fecal
coliform impairment. The first plant is the Kingsbridge Package Wastewater Treatment
Plant and serves the Kingsbridge II subdivision. This plant does not have an outfall.
After treatment and chlorine disinfection, effluent is pumped into one of two low-
pressure pipe nitrification fields. The daily flow of the plant averages only 3,000 gallons
per day, even though the plant is permitted for up to 48,000 gallons per day. The
second plant is the Webb Creek WWTP (NC0062642), which discharges outside the
Queens Creek watershed into Wallace Creek.
The NC Department of Transportation (NCDOT) has a number of roads in the project
area, including Highway 24, and has a statewide Phase I NPDES stormwater permit
(NCS000250). Stormwater has previously been considered to be a nonpoint source;
however, NPDES-permitted sources are to be included in the wasteload allocation (WLA)
per EPA guidance (USEPA, 2002).
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3 TOTAL MAXIMUM DAILY LOADS AND LOAD ALLOCATION
3.1 TMDL Objective
The TMDL objective is to meet North Carolina water quality fecal coliform standards of a
median MF count of 14 per 100 ml and not more than 10 percent of the samples shall
exceed an MF count of 43 per 100 ml. In addition, the National Shellfish Sanitation
Program (NSSP) standard for the approved classification of growing areas requires that
fecal coliform concentrations not exceed a median or geometric mean of a MPN of 14
per 100 ml and the 90th percentile of a MPN of 43 per 100 ml, with a minimum of the 30
most recent samples used to calculate compliance.
Both standards have the same numeric targets but the NSSP standard uses a minimum
30- sample averaging period. Data collected from September 2005 through August
2010 were used for the purpose of this TMDL.
3.2 Modeling
3.2.1 Approach
Bay and coastal waters such as Queens Creek and its tributaries are subject to the action
of the tides. The ebb and flood of the tide serves to move water between locations
exchanging and mixing with other water. The tide and amount of freshwater discharge
into the embayment are the dominant influences on the transport of fecal coliform.
Therefore, the TMDL was calculated using the spreadsheet-based steady-state tidal
prism model. This modeling approach has been used in approved TMDLs in several
other states (VADEQ, 2005; MDE, 2004).
The steady-state tidal prism model is spreadsheet-based and incorporates the
influences of tidally induced transport, freshwater input, and removal of fecal coliform
via decay. Depending on the geometry of the embayment, the model may have
multiple segments. The model assumes that the embayment is well mixed within a
single segment, and freshwater input, tidal range, and the first-order decay of fecal
coliform are all constant. A brief description of the model is presented below.
The steady-state tidal prism model calculates fecal coliform load using equation 3.1:
L = [C(Qb + kV) – Q0C0] x Cf (3.1)
where:
L = fecal coliform load (counts per day)
C = mean fecal coliform concentration (MPN /100ml) of the segment
k = the fecal coliform removal/decay rate (per day)
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C0 = the fecal coliform concentration (MPN/100ml) entering the segment on the
flood tide
Q0 = the quantity of water that enters the segment on the flood tide that did not
flow out of the segment on the previous ebb tide (m3 per tidal cycle)
Qb = the quantity of mixed water that leaves the segment on the ebb tide that did
not enter the segment on the previous flood tide (m3 per tidal cycle)
V = the mean volume of the segment (m3)
Cf = the unit conversion factor
The fecal coliform decay rate, k, was set at 0.36 per day, which is considered a
conservative estimate. The value of the decay rate varies from between 0.3 and 3.0 in
salt water (Thomann and Mueller, 1987). Qb and Q0 are estimated based on the steady
state condition as follows:
Qb = Q0 + Qf
Q0 = βQT
where:
Qf = mean freshwater input during one tidal cycle
β = exchange ratio
QT = the quantity of water that enters the segment on the flood tide
QT is calculated based on the tidal range. The mean tidal range is assumed to be 3.11 ft,
as monitored at a nearby NOAA station at Beaufort, NC. The dominant tide in this
region is the lunar semi-diurnal (M2) tide with a tidal period of 12.42 hours. Therefore,
the M2 tide is used as the representative tidal cycle. In general, the exchange ratio
varies from 0.3 to 0.7, based on the previous model tests in coastal embayments (Kuo et
al., 1998; Shen et al., 2002). A mean value of 0.5 was used for the exchange ratio.
The stream flow (Qf) used to represent the fresh water inflow was based on a ratio of
the drainage area of the Queens Creek watershed as compared to the drainage area and
the stream flows measured by the U.S. Geological Survey at the New River gaging
station (USGS 02093000) near Gum Branch, NC. The selection of the gaging station for
use in the model is determined by its similarity in watershed characteristics to Queens
Creek watershed and the proximity of the station to the TMDL study area.
3.2.2 Existing Load Calculation
Model segmentation is provided below in Figure 3.1. Existing median and 90th
percentile concentrations are required for each segment as model inputs. These were
calculated by combining monitoring data from all monitoring stations within each
segment and calculating the overall median and the 90th percentile fecal coliform
Queens Creek Fecal Coliform TMDL
________________________________________________________________________
14
concentrations. Table 3.1 provides the monitoring stations used in each model segment
and the overall median and 90th percentile concentrations.
NCDEH conditional monitoring data were not used to calculate existing concentrations.
Conditional monitoring only takes place in a few stations in the conditionally-approved
open growing area in lower Queens Creek (segment m1) after rainfall events to see if
waters can be reopened to shellfishing. These concentrations tend to be inconsistently
higher compared to stations where conditional monitoring data were not collected (as
shown in Appendix A, Table A.1). Therefore, to avoid creating bias in the model,
conditional data were not used to calculate existing loads.
Figure 3.1 – Model Segmentation
Queens Creek Fecal Coliform TMDL
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15
Table 3.1 – Monitoring stations associated with each model segment
Model
Segment # Waterbodies AU#
NCDEH
Monitoring
Station(s)
Median FC
(MPN/100 ml)
90th Percentile
FC
(MPN/100ml)
m0 Ocean Boundary 18, 31, 24 4.0 11.0
m1 Lower Queens 19-41-16c;
19-41-16d 7, 9, 9A, 11, 16 7.3 30.0
m2 Middle Queens 19-41-16b1;
19-41-16b2 2, 5, 13, 35, 36 7.8 45.0
m3
Upper Queens,
Pasture Branch,
Bells Swamp
19-41-16a;
19-41-16-2;
19-41-16-1
2 13.5 75.0
b1 Dicks Creek 19-41-16-5 30 7.8 26.0
b2 Parrot Swamp 19-41-16-4a;
19-41-16-4b 11A 11.0 38.0
b3 Halls Creek 19-41-16-3 3 49.0 168.0
The concentrations listed in Table 3.1 were then used in Equation 3.1 to calculate the
existing fecal coliform loads associated with both the median and the 90th percentile
concentrations. Table 3.2 presents the estimated existing loads for each segment.
3.2.3 TMDL Calculation
The TMDL was calculated by using Equation 3.1 and the North Carolina water quality
fecal coliform standards of a median of 14 counts per 100 ml and a 90th percentile of 43
counts per 100 ml. Table 3.2 presents the estimated TMDL for each segment.
The percent load reduction needed to meet the fecal coliform standard was estimated
using equation 3.2:
Reduction = (Existing Load – TMDL)/Existing Load (3.2)
Queens Creek Fecal Coliform TMDL
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16
Table 3.2 – Load reduction requirements under variations of standard criteria
Standard
Category
Segment
# AU# Standard
(MPN/100ml)
Existing Load
(MPN/day)
TMDL
(MPN/day)
Percent
Reduction
Required
Median
m1 19-41-16c;
19-41-16d 14 Less than
TMDL 5.98E+11 0%
m2 19-41-16b1;
19-41-16b2 14 Less than
TMDL 1.31E+11 0%
m3 19-41-16a;
19-41-16-2;
19-41-16-1
14 1.58E+11 1.05E+11 34%
b1 19-41-16-5 14 Less than
TMDL 1.27E+10 0%
b2 19-41-16-4a;
19-41-16-4b 14 3.48E+10 3.09E+10 11%
b3 19-41-16-3 14 8.05E+10 1.12E+10 86%
90th
Percentile
m1 19-41-16c;
19-41-16d 43 Less than
TMDL 1.88E+12 0%
m2 19-41-16b1;
19-41-16b2 43 Less than
TMDL 4.02E+11 0%
m3 19-41-16a;
19-41-16-2;
19-41-16-1
43 8.61E+11 3.21E+11 63%
b1 19-41-16-5 43 Less than
TMDL 3.89E+10 0%
b2 19-41-16-4a;
19-41-16-4b 43 1.07E+11 9.49E+10 11%
b3 19-41-16-3 43 2.58E+11 3.45E+10 87%
For segments m1, m2, and b1, the calculated existing loads are less than the TMDL, and
hence no reduction in loading from these watersheds is needed. The FC water quality
standard will be met in these segments once TMDLs are implemented and loading is
reduced from the watersheds of the other segments.
Required reductions in loading are higher for the 90th percentile model results
(highlighted in orange in Table 3.2) and allow for both standards to be met. Therefore,
the TMDLs were calculated using the 90th percentile criterion.
3.3 TMDL Allocation
Total Maximum Daily Load (TMDL) can be defined as the total amount of pollutant that
can be assimilated by the receiving water body while achieving water quality standards.
A TMDL can be expressed as the sum of all point source allocations (WLAs), nonpoint
source allocations (LAs), and an appropriate margin of safety (MOS), which takes into
account any uncertainty concerning the relationship between effluent limitations and
water quality. This definition can be expressed by equation 3.3.
Queens Creek Fecal Coliform TMDL
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17
MOSLAsWLAsTMDL (3.3)
The goal of the TMDL is to estimate allowable pollutant loads and to allocate those
loads in order to implement control measures and to achieve water quality standards.
The Code of Federal Regulations (40 CFR § 130.2 (1)) states that TMDLs can be
expressed in terms of mass per time, toxicity, or other appropriate measures. The
systematic procedures adopted to estimate TMDL allocations are described below.
3.3.1 Margin of Safety (MOS)
A Margin of Safety (MOS) is required as part of a TMDL in recognition of many
uncertainties in the understanding and simulation of water quality in natural systems.
For example, knowledge is incomplete regarding the exact nature and magnitude of
pollutant loads from various sources and the specific impacts of those pollutants on the
chemical and biological quality of complex, natural water bodies. The MOS is intended
to account for such uncertainties in a manner that is conservative from the standpoint
of environmental protection.
As a conservative estimate in the TMDL calculation, an explicit MOS of 10% is included.
The explicit MOS was achieved by multiplying the TMDL by 10%. These loads are shown
in Table 3.3.
Table 3.3 – Margin of Safety Allocation
–
90th
Percentile
m1 1.88E+12 1.88E+11 1.69E+12
m2 4.02E+11 4.02E+10 3.62E+11
m3 3.21E+11 3.21E+10 2.89E+11
b1 3.89E+10 3.89E+09 3.50E+10
b2 9.49E+10 9.49E+09 8.54E+10
b3 3.45E+10 3.45E+09 3.10E+10
3.3.2 Waste Load Allocation (WLA)
As described in Section 2.2, NCDOT is the only NPDES-permitted discharge in the
watershed included in the WLA as a contributing source. Data is not available to
calculate the existing load for the NCDOT.
Queens Creek Fecal Coliform TMDL
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18
The WLA for NCDOT land was isolated from other sources by multiplying the total load
and the ratio of NCDOT road right of way (ROW) area to total subwatershed area. The
NCDOT ROW area was calculated by multiplying the road length and width of US
highways, NC roads, and state route roads within the watershed. The NCDOT ROW is
2.6% of the total watershed area, as shown below in Table 3.4. The resulting WLA for
NCDOT is provided below in Table 3.5.
NCDOT should continue to implement measures required by the permit, including illicit
discharge detection and elimination, post-construction controls, management of
hydraulic encroachments, sediment and erosion control, BMP retrofits, stormwater
pollution prevention for industrial facilities, research, and education programs.
Table 3.4 - Queens Creek Watershed NCDOT Contributing Area by Subwatershed
m1 652.7 4.5 0.7%
m2 252.2 3.6 1.4%
m3 17,080.8 456.3 2.7%
b1 579.4 18.6 3.2%
b2 2137.8 53.5 2.5%
b3 1366.0 31.8 2.3%
Total 22,068.9 568.3 2.6%
Table 3.5 – NPDES Wasteload Allocations
NCDOT
m1 N/A 1.16E+10
m2 N/A 5.17E+09
m3 N/A 7.72E+09
b1 N/A 1.12E+09
b2 N/A 2.14E+09
b3 N/A 7.23E+08
3.3.3 Load Allocation (LA)
All fecal coliform loadings from nonpoint sources such as non-MS4 urban land,
agriculture land, and forestlands are reported as LAs. The LA allocations were estimated
by subtracting the MOS and WLA allocations from the TMDL. The estimated allocations
of fecal coliform loading for nonpoint sources are presented in Table 3.6.
Queens Creek Fecal Coliform TMDL
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19
Table 3.6 – Nonpoint Source Allocation
m1 1.68E+12
m2 3.57E+11
m3 2.81E+11
b1 3.39E+10
b2 8.33E+10
b3 3.03E+10
3.3.4 Critical Condition and Seasonal Variation
The EPA Code of Federal Regulations (40 CFR 130.7 (c) (1)) requires TMDLs to take into
account critical conditions for stream flow, loading, and water quality parameters. The
intent of this requirement is to ensure that the water quality of the waterbody is
protected during times when it is most vulnerable. The critical condition accounts for
the hydrologic variation in the watershed over many sampling years whereas the critical
period is the condition under which a waterbody is the most likely to violate the water
quality standard(s).
The 90th percentile concentration is the concentration exceeded only 10% of the time.
Since the data used for model simulation spans 5 years, the critical condition is implicitly
included in the value of the 90th percentile of model results. Given the length of the
monitoring record and the standard’s recognition of unusual and infrequent events, the
90th percentile is used instead of the absolute maximum.
The EPA also requires that these TMDL studies take into account seasonal variations.
The consideration of critical condition and seasonal variation is to account for the
hydrologic and source variations. Seasonal variations involve changes in surface runoff,
stream flow, and water quality as a result of hydrologic and climatologic patterns. For
the Queens Creek TMDL study, variations due to changes in the hydrologic cycle as well
as temporal variability in fecal coliform sources are accounted for by the use of the long-
term data record to estimate the current load.
The seasonal fecal coliform distribution for the stations in Segment m1 of Queens Creek
is presented in Figure 3.2 and includes both the random and conditional monitoring
data. The seasonal distributions of fecal coliform concentrations for the other segments
are presented in Appendix A. The results show that high fecal coliform levels occur
throughout the year in the estuary. The largest standard deviation corresponds to the
highest concentration for each station. These high concentrations result in a high 90th
percentile concentration. Given the long-term flow and water quality data record used
to estimate the fecal coliform load, the seasonal variability is implicitly included in the
analysis.
Queens Creek Fecal Coliform TMDL
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20
Figure 3.2 - Seasonal distribution of fecal coliform concentrations (random and conditional
monitoring data combined) in Segment m1 (log scale)
3.3.5 TMDL Summary
A summary of the TMDL is provided below in Table 3.7. Reductions in fecal coliform
loading are required for Upper Queens Creek (including Pasture Branch and Bells
Swamp), Parrot Swamp, and Halls Creek. Reductions in loading from these watersheds
allow for standards to be met throughout Queens Creek.
The largest percent reduction is needed from the Halls Creek area. Land cover in this
subwatershed is primarily mixed between developed land (28%), shrub/scrub (20%),
forest (19%), and cropland (14%). The potential sources map produced by NCDEH
(Appendix B) shows a concentrated amount of stormwater outfalls in this watershed.
Queens Creek Fecal Coliform TMDL
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21
Table 3.7 – Estimated TMDL and Load Allocation for Fecal Coliform for Queens Creek
Fecal Coliform Load (MPN/day)
Waterbodies AUs Existing
Load1 WLA LA MOS TMDL %
Reduction
Lower Queens 19-41-16c;
19-41-16d
Less than
TMDL 1.16E+10 1.68E+12 1.88E+11 1.88E+12 0%
Middle Queens 19-41-16b1;
19-41-16b2
Less than
TMDL 5.17E+09 3.57E+11 4.02E+10 4.02E+11 0%
Upper Queens,
Pasture Branch,
Bells Swamp
19-41-16a;
19-41-16-2;
19-41-16-1
8.61E+11 7.72E+09 2.81E+11 3.21E+10 3.21E+11 63%
Dicks Creek 19-41-16-5 Less than
TMDL 1.12E+09 3.39E+10 3.89E+09 3.89E+10 0%
Parrot Swamp 19-41-16-4a;
19-41-16-4b 1.07E+11 2.14E+09 8.33E+10 9.49E+09 9.49E+10 11%
Halls Creek 19-41-16-3 2.58E+11 7.23E+08 3.03E+10 3.45E+09 3.45E+10 87%
1. For Lower Queens, Middle Queens, and Dicks Creek, the calculated existing loads are less than the
TMDL, and hence no reduction is needed from those subwatersheds.
Queens Creek Fecal Coliform TMDL
________________________________________________________________________
22
4 TMDL IMPLEMENTATION PLAN
An implementation plan is not included in this TMDL. Local stakeholder groups,
governments, and agencies are encouraged to develop an implementation plan and
utilize funding sources for water quality improvement projects targeted at BMP
construction and public outreach. Some potential funding sources include the North
Carolina Clean Water Management Trust Fund, and Section 319 and 205j funds.
Individual land owners may apply for the Community Conservation Assistance Program
and Agriculture Cost Share Program to improve the condition of their property. The
next NCDEH Sanitary Survey for the D-2 shellfish growing area will help further identify
current sources of bacteria and drainage pathways that allow bacteria to enter Queens
Creek and its tributaries.
NCDEH will continue to monitor water quality in Queens Creek using the systematic
random sampling strategy as outlined in the National Shellfish Sanitation Program’s
Model Ordinance and guidance document. This data will be used to evaluate progress
towards the goal of reaching water quality standards.
5 PUBLIC PARTICIPATION
A draft of the TMDL was publicly noticed through various means. NCDWQ electronically
distributed the draft TMDL and public comment information to known interested
parties. The announcement is provided in Appendix C. The TMDL was also available
from the NCDWQ’s website at http://portal.ncdenr.org/web/wq/ps/mtu/tmdl/tmdls
during the comment period. The public comment period lasted from June 27 – July 27,
2011. NCDWQ received two comments from NCDOT. A summary of their comments
and NCDWQ’s response is provided in Appendix D.
6 FURTHER INFORMATION
Further information concerning North Carolina’s TMDL program can be found on the
Internet at the Division of Water Quality website:
http://portal.ncdenr.org/web/wq/ps/mtu
Technical questions regarding this TMDL should be directed to the following members
of the NCDWQ Modeling/TMDL Unit:
Pam Behm
e-mail: pamela.behm@ncdenr.gov
Kathy Stecker
e-mail: kathy.stecker@ncdenr.gov
Queens Creek Fecal Coliform TMDL
________________________________________________________________________
23
7 REFERENCES
Kuo, A., Butt, A., Kim, S. and J. Ling. 1998. Application of a tidal prism water quality
model to Virginia Small Coastal Basins. SRAMSOE No. 348.
MDE. 2004. Total Maximum Daily Loads of Fecal Coliform for Restricted Shellfish
Harvesting Areas in the Potomac River Lower Tidal Basin in St. Mary's County, Maryland.
NCAD. 2003. NC Administration Code.
NCDEH. 2010. Report of Sanitary Survey, Area D-2, Queens Creek Area, June 2005
through May 2010. NC Division of Environmental Health Shellfish Sanitation and
Recreational Water Quality.
NOAA. 2010. Tides Online. National Oceanic and Atmospheric Administration/National
Ocean Service. Website: http://co-ops.nos.noaa.gov/
NSSP. 2007. National Shellfish Sanitation Program Guide for the control of Molluscan
Shellfish 2007, Section IV, Chapter II (Bacteriological Standards). US Food and Drug
Administration, 2007. Website: http://www.fda.gov/Food/FoodSafety/Product-
SpecificInformation/Seafood/FederalStatePrograms/NationalShellfishSanitationProgram
/UCM053698
Shen, J., H. Wang, and M. Sisson. 2002. Application of an Integrated Watershed and
Tidal prism Model to the Poquoson Coastal Embayment (submitted to Department of
Environmental Quality, Commonwealth of Virginia). Virginia Institute of Marine Science
Special Report 380, Gloucester Point, VA.
Thomann, R. V. and J. Mueller. 1987. Principles of surface water quality modeling and
control. Harper Collins Publishers.
USEPA. 1991. Guidance for Water Quality-Based Decisions: The TMDL Process.
Assessment and Watershed Protection Division, Washington, DC.
USEPA. 1998. Draft Final TMDL Federal Advisory Committee Report. U.S.
Environmental Protection Agency, Federal Advisory Committee (FACA). Draft final
TMDL Federal Advisory Committee Report. 4/28/98.
USEPA. 2000. Revisions to the Water Quality Planning and Management Regulation
and Revisions to the National Pollutant Discharge Elimination System Program in
Support of Revisions to the Water Quality Planning and management Regulation; Final
Rule. Fed. Reg. 65:43586-43670 (July 13, 2000).
Queens Creek Fecal Coliform TMDL
________________________________________________________________________
24
USEPA. 2002. Wayland, Robert, H. and James A. Hanlon. "Establishing Total Maximum
Daily Load (TMDL) Wasteload Allocations (WLAs) for Storm Water Sources and NPDES
Permit Requirements Based on Those WLAs". Memo to Water Division Directors
Regions 1-10. United States Environmental Protection Agency, Washington, D.C. 22
November 2002.
VADEQ. 2005. Total Maximum Daily Load Report for Shellfish Areas Listed Due to
Bacterial Contamination.
Queens Creek Fecal Coliform TMDL
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25
Appendix A: NCDEH Monitoring Data Summary
Table A.1 – Queens Creek NCDEH Monitoring Data Summary, September 2005 - August 2010
2 30 Random 13.5 13.7 75
3 30 Random 49 37.6 168
5 30 Random 7.8 10.3 48
7 30 Random 5.8 7.6 43
115 Conditional 23 25.4 168
9A 30 Random 10.1 8.9 35
9 30 Random 4.5 5.9 22
120 Conditional 23 22.0 157
11A 30 Random 11 8.9 38
11 30 Random 6.8 7.4 34
110 Conditional 23 22.8 133
13 30 Random 7.8 7.7 28
16 30 Random 6.2 5.2 18
118 Conditional 22 18.4 105
18 30 Random 3 3.9 12
24 29 Random 2 3.9 14
30 30 Random 7.8 7.3 26
31 30 Random 4.25 3.5 8
35 30 Random 7.8 9.5 62
36 30 Random 6.8 6.1 25
Queens Creek Fecal Coliform TMDL
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26
Figure A.1 – NCDEH Monitoring Stations
Queens Creek Fecal Coliform TMDL
________________________________________________________________________
27
Figure A.2 - Seasonal distribution of fecal coliform concentrations in Segment m0 (log scale)
Figure A.3 - Seasonal distribution of RANDOM monitoring fecal coliform concentrations in
Segment m1 (log scale)
Queens Creek Fecal Coliform TMDL
________________________________________________________________________
28
Figure A.4 - Seasonal distribution of CONDITIONAL monitoring fecal coliform concentrations in
Segment m1 (log scale)
Figure A.5 - Seasonal distribution of fecal coliform concentrations (random and conditional
monitoring data combined) in Segment m1 (log scale)
Queens Creek Fecal Coliform TMDL
________________________________________________________________________
29
Figure A.6 - Seasonal distribution of fecal coliform concentrations in Segment m2 (log scale)
Figure A.7 - Seasonal distribution of fecal coliform concentrations in Segment m3 (log scale)
Queens Creek Fecal Coliform TMDL
________________________________________________________________________
30
Figure A.8- Seasonal distribution of fecal coliform concentrations in Segment b1 (log scale)
Figure A.9- Seasonal distribution of fecal coliform concentrations in Segment b2 (log scale)
Queens Creek Fecal Coliform TMDL
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31
Figure A.10- Seasonal distribution of fecal coliform concentrations in Segment b3 (log scale)
Queens Creek Fecal Coliform TMDL
________________________________________________________________________
32
Appendix B: NCDEH Mapping of Potential Pollution Sources in D-2 Growing Area
Figure B.1 - NCDEH Mapping of Potential Pollution Sources in D-2 Growing Area (NCDEH, 2010)
Queens Creek Fecal Coliform TMDL
________________________________________________________________________
33
Appendix C: Public Announcement
-----Original Message-----
From: wrri-news-owner@lists.ncsu.edu [mailto:wrri-news-owner@lists.ncsu.edu]
Sent: Tuesday, June 28, 2011 4:21 AM
To: wrri-news@lists.ncsu.edu
Subject: [wrri-news] Digest (1 messages)
The WRRI Daily Digest
Volume 1 : Issue 778 : "mime" Format
June 27, 2011
North Carolina Department of Environment and Natural Resources, Division of Water Quality
Now Available for Public Comment
DRAFT Total Maximum Daily Load for Fecal Coliform for Queens Creek, White Oak River Basin, North
Carolina
This draft TMDL report was prepared as a requirement of the Federal Water Pollution Control Act,
Section 303(d). Interested parties are invited to comment on the draft TMDL report by July 27, 2011.
Comments concerning the report should be directed to Pam Behm at pamela.behm@ncdenr.gov or
write to:
Pam Behm
NC Division of Water Quality
Planning Section
1617 Mail Service Center
Raleigh, NC 27699
The draft TMDL can be downloaded from the following link:
http://portal.ncdenr.org/web/wq/ps/mtu/tmdl/tmdls#QueensCreek
***************************************************************
Pam Behm
NC DWQ Modeling and TMDL Unit
1617 Mail Service Center
Raleigh, NC 27699
Email: pamela.behm@ncdenr.gov
Phone: 919-807-6419
Fax: 919-807-6497
E-mail correspondence to and from this address may be subject to the North Carolina Public Records
Law and may be disclosed to third parties.
Queens Creek Fecal Coliform TMDL
________________________________________________________________________
34
Appendix D: Public Comments Responsiveness Summary
The public comment period lasted from June 27 – July 27, 2011. Two comments were received
from NCDOT. A summary of their comments and NCDWQ’s response is provided below.
Comment 1
NCDOT commented that there is insufficient information on model inputs and outputs provided
in the report. For example, existing fecal coliform loads to seven of the assessment units, as
well as existing loads from NCDOT, are omitted from the report.
Response: The model used for this study is a spreadsheet-based, simplified, steady-state tidal
prism model. As described in Section 3.2.1., existing loadings (as the model output) are
calculated based on the median and the 90th percentile of the observed data from each segment
(the values used are listed in Table 3.1 and these are model inputs). Similarly, the TMDL
loadings were calculated based on the median and 90th percentile standard (14 and 43
MPN/100ml, respectively). Model parameters such as exchange ratio and mean tidal range are
described and the values used are given in section 3.2.1. The value used for the fecal coliform
decay rate has been added to section 3.2.1.
The model is structured in such a way that multiple assessment units can be included in a single
segment as shown in Table 3.1. Therefore, the load calculated for the segment applies to all the
assessment units in the same segment. Table 3.2 is revised to show the assessment units
included in each model segment. Existing loadings are not included in the report for those
model segments and associated assessment units where the calculated existing load was less
than the calculated TMDL load and therefore received a 0% required reduction. Five of the
eleven assessment units received a 0% required reduction. In addition, as explained in section
3.3.2, data is not available to calculate the existing load specifically for the NCDOT.
Comment 2
NCDOT requested clarification on the averaging period used as the basis for NCDOT’s WLA and
the time period used for compliance evaluation.
Response: The averaging period used to develop the NCDOT’s WLA was September 2005
through August 2010. NCDEH will continue to monitor Queens Creek and its tributaries using
the systematic random sampling strategy as outlined in the National Shellfish Sanitation
Program’s Model Ordinance and guidance document. This data will be used to assess overall
progress towards meeting TMDL goals and determine if the water quality criteria are being met.
Section 4 was modified to clarify compliance evaluation.