Turkey Creek NC TMDL Decision Document

TMDL: Total Maximum Daily Load (TMDL) for Fecal Coliform Bacteria in Turkey Creek in the White Oak River Basin (HUC 03030001040005) ATTAINS TMDL ID: NC_TMDL_TurkeyCreek_Shellfish LOCATION: Onslow County, North Carolina STATUS: Final
IMPAIRMENT/POLLUTANT: Two segments (see next page) of Turkey Creek are not meeting water quality criteria for pathogens and not supporting the designated uses of shellfish harvesting. A TMDL was submitted by the North Carolina Department of Environmental Quality (NCDEQ) that provides fecal coliform loads as a surrogate to address the pathogen impairment.
BACKGROUND: The NCDEQ submitted the final Total Maximum Daily Loads, Fecal Coliform, Turkey Creek, North Carolina (the “TMDL,” “Submission,” or “Report”) by electronic mail requesting review and approval to the EPA Region 4 dated October 4, 2022. The NCDEQ provided a preliminary draft Report to the EPA staff on August 12, 2022, and the TMDL document was placed on public notice
on September 2, 2022. The EPA reviewed these drafts of the TMDL and provided comments on August 16, 2022, which were addressed in the final Report. The submission included:
 Submittal electronic mail notification
 Report: Total Maximum Daily Load (TMDL) for Fecal Coliform Bacteria in Turkey Creek in the White Oak River Basin (HUC 03030001040005)
 Report Appendices, including: o North Carolina Department of Marine Fisheries Monitoring Data Summary o Turkey Creek Steady-State Tidal Prism Model Inputs and Parameters o NCDMF Mapping of Potential Pollution Sources in B-9 Growing Area
o Public Notice Announcement This document explains how the Submission meets the statutory and regulatory requirements of TMDLs in accordance with section 303(d) of the Clean Water Act and the EPA’s implementing regulations in 40 CFR Part 130. EPA Region 4 REVIEWER: Marion Hopkins, North Carolina Assessment, Listing and TMDL Coordinator, [e-mail].
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Waters Addressed in this TMDL Approval Action:

Waterbody ID Waterbody Classification* Acres Impaired
NC18-87-1a Turkey Creek - From source to 0.25 miles inland of Intracoastal Waterway (ICWW) to ICWW SA; ORW 79.5 acres
NC18-87-1b Turkey Creek - From 0.25 miles inland of ICWW to ICWW SA; ORW 59.6 acres
* SA: suitable for commercial shellfishing and all other tidal saltwater use ORW: Outstanding Resource Waters supplemental classification
Location of Waters Addressed in this TMDL Approval Action:
Figure 1.1 from the Report – Turkey Creek Shellfish Growing Area (B-9) Classifications

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This document contains the EPA's review of the above-referenced TMDL. This TMDL review document includes TMDL review guidelines that summarize currently effective statutory and regulatory requirements relating to TMDLs. These TMDL review guidelines are not themselves regulations. Any differences between these guidelines and the EPA's TMDL regulations should be resolved in favor of the regulations themselves. The italicized sections of this document describe the EPA's statutory and regulatory requirements for approvable TMDLs. The sections in regular type reflect the EPA's analysis of the state/tribe’s compliance with these requirements. Section 303(d) of the Clean Water Act (CWA) and the EPA’s implementing regulations at 40 CFR Part 130 set out the statutory and regulatory requirements for approvable TMDLs. The following information is generally necessary for the EPA to determine if a submitted TMDL fulfills the legal requirements for approval under section 303(d) and the EPA regulations and should be included in the submittal package. Use of the verb “must” below denotes information that is required to be submitted because it relates to elements of the TMDL required by the CWA and by regulation. 1. Description of Waterbody, Pollutant of Concern and Pollutant Sources The TMDL analytical document must identify the waterbody as it appears on the state/tribe’s 303(d) list, including the
pollutant of concern. The TMDL submittal must include a description of the point and nonpoint sources of the pollutant of concern, including the magnitude and location of the sources. Where it is possible to separate natural background from
nonpoint sources, a description of the natural background must be provided, including the magnitude and location of the source(s). Such information is necessary for the EPA’s review of the load and wasteload allocations, which is required by
regulation. The TMDL submittal should also contain a description of any important assumptions made in developing the TMDL, such as: (1) the assumed distribution of land use in the watershed; (2) population characteristics, wildlife resources,
and other relevant information affecting the characterization of the pollutant of concern and its allocation to sources; (3) present and future growth trends, if taken into consideration in preparing the TMDL; and, (4) explanation and analytical
basis for expressing the TMDL through surrogate measures, if applicable. Surrogate measures are parameters such as percent fines and turbidity for sediment impairments, or chlorophyll a, and phosphorus loadings for excess algae. Two segments of Turkey Creek (HUC 03030001040005), classified as shellfish harvesting waters, are impaired because of elevated fecal coliform bacteria levels. The waters, located near North Topsail Beach,
North Carolina, are within shellfish area B-9 as defined by the North Carolina Division of Marine Fisheries (NCDMF). Most of the shellfish growing area is designated by the NCDMF as Conditionally Approved -
Closed. According to the NCDMF website,1 “Conditionally Approved areas can be open to harvest under
certain conditions, such as dry weather when stormwater runoff is not having an impact on surrounding water quality.” These restricted shellfish harvesting areas are identified as areas that do not meet their
designated uses due to elevated fecal coliform levels.
There are three fecal coliform monitoring stations sampled by the NCDMF within Turkey Creek in periodic Sanitary Surveys. The Report includes a map identifying the impaired segments and the monitoring stations. (Figure 1.1; see above). A data summary can be found in Appendix A of the Report.
In their most recent Sanitary Survey, the NCDMF documented various types of nonpoint sources of
fecal coliform in watersheds that contribute to the restricted shellfish harvesting areas. The Survey suggested that runoff from impervious surfaces, subdivisions, and other cleared land is the primary contributor. To a lesser extent, wildlife, grazing animals, and agricultural runoff may also contribute to fecal coliform impairments.

1 https://deq.nc.gov/about/divisions/marine-fisheries/shellfish-sanitation-and-recreational-water-quality/shellfish-growing-areas#classifications
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There are no operating wastewater treatment plants in the Turkey Creek Watershed. The NC Department of Transportation (NCDOT) has several roads in the project area and has a statewide Phase I NPDES stormwater permit (NCS000250). Land cover distribution and land cover statistics are shown in Figure 1.2 and Table 1.2 of the Report. Around thirty percent of the watershed is forested, twenty percent is
agricultural land and 5 percent is developed land. Assessment: The EPA concludes that North Carolina has adequately identified the impaired waterbodies, the pollutant of concern, and the magnitude and location of the pollutant sources. 2. Description of the Applicable Water Quality Standards and Numeric Water Quality Target
The TMDL submittal must include a description of the applicable state/tribe water quality standard, including the designated use(s) of the waterbody, the applicable numeric or narrative water quality criterion, and the statewide antidegradation
policy. Such information is necessary for the EPA’s review of the load and wasteload allocations, which is required by regulation. A numeric water quality target for the TMDL (a quantitative value used to measure whether or not the applicable
water quality standard is attained) must be identified. If the TMDL is based on a target other than a numeric water quality criterion, then a numeric expression, usually site specific, must be developed from a narrative criterion and a description of
the process used to derive the target must be included in the submittal. The target for the TMDL is derived from the State saltwater criteria for the shellfish harvesting designated use as well as the similar State standards for Approved Shellfish Growing Areas. The North Carolina water quality standard, at 15A NCAC 02B.0221 (Tidal Salt-Water Quality Standards for Class SA Waters) for shellfish harvesting use is as follows (note that MF is an abbreviation for the membrane
filter procedure for bacteriological analysis and ml is an abbreviation for milliliters):

Organisms of coliform group: fecal coliform group not to exceed a median MF 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.

Approval of shellfish growing areas is governed by 15A NCAC 18A .0431 (Standards for an Approved Shellfish Growing Area) and the National Shellfish Sanitation Program (NSSP) guidance: 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”
According to the NSSP Guide for the control of Molluscan Shellfish (2017 revision; website:
https://www.fda.gov/media/117080/download), “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.”
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In short, the TMDL objective is to meet North Carolina water quality fecal coliform standards as well as the NSSP standard for the approved classification of growing areas. Both standards have the same numeric targets, but the NSSP standard requires a minimum of 30 samples.
Assessment: The EPA concludes that North Carolina has properly addressed its water quality standards when setting a numeric water quality target. 3. Loading Capacity - Linking Water Quality and Pollutant Sources
As described in the EPA guidance, a TMDL identifies the loading capacity of a waterbody for a particular pollutant. The EPA regulations define loading capacity as the greatest amount of loading that a water can receive without violating water quality standards (40 CFR section 130.2(f)). The loadings are required to be expressed as either mass-per-time, toxicity, or other appropriate measure (40 CFR section 130.2(i)). The TMDL submittal must identify the waterbody’s loading capacity for the applicable pollutant and describe the rationale for the method used to establish the cause-and-effect relationship
between the numeric target and the identified pollutant sources. In most instances, this method will be a water quality model. Supporting documentation for the TMDL analysis must also be contained in the submittal, including the basis for assumptions, strengths and weaknesses in the analytical process, results from water quality modeling, etc. Such information is necessary for the EPA’s review of the load and wasteload allocations, which is required by regulation. In many circumstances, a critical condition must be described and related to physical conditions in the waterbody as part of
the analysis of loading capacity (40 CFR section 130.7(c)(1)). The critical condition can be thought of as the “worst case” scenario of environmental conditions in the waterbody in which the loading expressed in the TMDL for the pollutant of
concern will continue to meet water quality standards. Critical conditions are the combination of environmental factors (e.g., flow, temperature, etc.) that results in attaining and maintaining the water quality criterion and has an acceptably low frequency of occurrence. Critical conditions are important because they describe the factors that combine to cause a violation of water quality standards and will help in identifying the actions that may have to be undertaken to meet water quality standards. Section 3.2 and Appendix B of the Submission describe the State’s method for determining the loading capacity. The loading capacity (i.e., “TMDL”) for each segment is expressed as percent load reduction based on the applicable water quality criteria value. TMDL values are shown on page iv and in Table 3.7
of the Report, presented here:

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As described in Section 3.2 of the Submission, the TMDLs were calculated using the steady-state tidal prism model, which incorporates the influences of tidally induced transport, freshwater input, and removal of fecal coliform via decay. Results of the model show required reductions in loading are higher for the second part of the standard (not more than 10 percent of the samples shall exceed 43/100 ml).
Use of the higher load reductions is appropriate and allows for both parts of the standard to be met.
Assessment: The EPA concludes that the loading capacity, having been calculated using the EPA-reviewed water quality models and using observed concentration data and water quality targets consistent with numeric water quality criteria, has been appropriately set at a level necessary to attain
and maintain the applicable water quality standard. The TMDL is based on a reasonable approach for
establishing the relationship between pollutant loading and water quality. 4. Load Allocation (LA)
The EPA regulations require that a TMDL include LAs, which identify the portion of the loading capacity allocated to
existing and future nonpoint sources and to natural background (40 CFR section 130.2(g)). Load allocations may range from reasonably accurate estimates to gross allotments (40 CFR section 130.2(g)). Where it is possible to separate natural
background from nonpoint sources, load allocations should be described separately for background and for nonpoint sources.
If the TMDL concludes that there are no nonpoint sources and/or natural background, or the TMDL recommends a zero load
allocation, the LA must be expressed as zero. If the TMDL recommends a zero LA after considering all pollutant sources, there must be a discussion of the reasoning behind this decision, since a zero LA implies an allocation only to point sources
will result in attainment of the applicable water quality standard, and all nonpoint and background sources will be removed.
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All fecal coliform loadings from nonpoint sources such as agriculture land and forestlands are reported as
LAs. The LA allocations were estimated by subtracting the Margin of Safety and Wasteload allocations from the total loading capacity. Assessment: The EPA concludes that the LAs provided in the Report are reasonable and will result in
attainment of the water quality standards.
5. Wasteload Allocation (WLA) The EPA regulations require that a TMDL include WLAs, which identify the portion of the loading capacity allocated to existing and future point sources (40 CFR section 130.2(h)). If no point sources are present or if the TMDL recommends a zero WLA for point sources, the WLA must be expressed as zero. If the TMDL recommends a zero WLA after considering all pollutant sources, there must be a discussion of the reasoning behind this decision, since a zero WLA implies an allocation only to nonpoint sources and background will result in attainment of the applicable water quality standard, and all point
sources will be removed. In preparing the wasteload allocations, it is not necessary that each individual point source be assigned a portion of the allocation of pollutant loading capacity. When the source is a minor discharger of the pollutant of concern or if the source is contained within an aggregated general permit, an aggregated WLA can be assigned to the group of facilities. However, it is necessary to allocate the loading capacity among individual point sources as necessary to meet the water quality standard. The TMDL submittal should also discuss whether a point source is given a less stringent wasteload allocation based on an
assumption that nonpoint source load reductions will occur. In such cases, the state/tribe will need to demonstrate reasonable assurance that the nonpoint source reductions will occur within a reasonable time. There are no operating wastewater treatment plants in the Turkey Creek Watershed, however, the NCDOT has some roads in the project area and has a statewide Phase I NPDES stormwater permit
(NCS000250). To calculate the WLA for this source, 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 U.S. highways, North Carolina highway roads, and State route roads within the watershed. The NCDOT ROW is 1.3 percent
of the total watershed area. The resulting WLA for NCDOT is shown on pages iv and in Table 3.5 of the
Report, presented here:

Assessment: The EPA concludes that the WLAs provided in the Report are reasonable and will result in the attainment of water quality standards. This is because the TMDL accounts for the NCDOT point
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source discharging to impaired segments in the watershed and the WLA requires that fecal coliform loads comply with water quality criteria (TMDL targets).
6. Margin of Safety (MOS) The statute and regulations require that a TMDL include a margin of safety to account for any lack of knowledge concerning the relationship between load and wasteload allocations and water quality [CWA section 303(d)(1)(C), 40 CFR section 130.7(c)(1)]. The EPA 1991 guidance explains that the MOS may be implicit, i.e., incorporated into the TMDL through conservative assumptions in the analysis, or explicit, i.e., expressed in the TMDL as loadings set aside for the MOS. If the MOS is implicit, the conservative assumptions in the analysis that account for the MOS must be described. If the MOS is explicit, the loading set aside for the MOS must be identified. An explicit margin of safety was used, based on ten percent of the fecal coliform water quality standard
(see Section 3.3.1 of the Report), which is considered appropriate to address uncertainty in the TMDL. This explicit margin of safety reserves 10 percent of the allowable pollutant load to address uncertainties in the calculation of the necessary load reduction to achieve water quality standards. The State’s assessment methodology allows for a 10 percent exceedance before a waterbody is considered impaired.
Pathogen excursions occurring above the 90th percentile are considered extreme and short duration
events which cannot be adequately controlled by best management practices (BMPs). Assessment: The EPA concludes that the TMDL incorporates an adequate margin of safety.
7. Seasonal Variation

The statute and regulations require that a TMDL be established with consideration of seasonal variations. The method chosen for including seasonal variations in the TMDL must be described [CWA section 303(d)(1)(C), 40 CFR section 130.7(c)(1)].
Seasonality was addressed in the Report by assessing and modeling water quality in the impaired
waterbodies based on the data collected throughout the year, across many years. The period of record for monitoring for each segment contains a range of hydrologic conditions that include both low and high streamflow. 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. Seasonality is discussed further in Section
3.3.4 of the Report.
Assessment: The EPA concludes that the TMDL allocations ensure protection of water quality standards throughout all seasons.
8. Monitoring Plan to Track TMDL Effectiveness
The EPA's 1991 document, Guidance for Water Quality-Based Decisions: The TMDL Process (EPA 440/4-91-001), recommends a monitoring plan to track the effectiveness of a TMDL, particularly when a TMDL involves both point and
nonpoint sources, and the WLA is based on an assumption that nonpoint source load reductions will occur. Such a TMDL should provide assurances that nonpoint source controls will achieve expected load reductions, and such a TMDL should
include a monitoring plan that describes the additional data to be collected to determine if the load reductions provided for in the TMDL are occurring and leading to attainment of water quality standards.
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The NCDMF will continue to monitor water quality in Turkey Creek using the systematic random sampling strategy as outlined in the NSSP’s Model Ordinance and guidance document. This data will be used to evaluate progress towards the goal of reaching water quality standards. The next NCDMF Sanitary Survey for the B-9 shellfish growing area will help further identify sources of bacteria and
drainage pathways and provide a mechanism to evaluate progress in attaining TMDL targets. Assessment: Although not a required element of the EPA’s TMDL approval process, the affected waters are part of a routine monitoring plan that evaluates the progress toward attainment of water quality standards. The EPA is taking no action on the monitoring plan. 9. Implementation Plans On August 8, 1997, Bob Perciasepe (the EPA Assistant Administrator for the Office of Water) issued a memorandum, “New Policies for Establishing and Implementing Total Maximum Daily Loads (TMDLs),” that directs regions to work in partnership with states/tribes to achieve nonpoint source load allocations established for 303(d)-listed waters impaired solely or primarily by nonpoint sources. To this end, the memorandum asks that regions assist states/tribes in developing implementation plans that include reasonable assurances that the nonpoint source load allocations established in TMDLs for waters impaired solely or primarily by nonpoint sources will in fact be achieved. The memorandum also includes a discussion of renewed focus on the public participation process and recognition of other relevant watershed management processes used in the TMDL process. Although implementation plans are not approved by the EPA, they help establish the
basis for the EPA’s approval of TMDLs.

The NCDMF comprehensive Sanitary Surveys include evaluations of properties in the area to determine potential sources of pollution. Based on information provided in the most recent Survey, implementation measures should include continued maintenance and repair of septic systems, stormwater controls, pet waste management, and proper manure application to crops. Local stakeholder groups, governments,
and agencies are encouraged to develop detailed implementation plans and use 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 Clean Water Act Section 319 and 205j funds. Individual landowners may apply for the Community Conservation Assistance Program and Agriculture Cost Share Program to improve the condition of their property.

Assessment: Although not a required element of the TMDL approval, North Carolina discussed how information derived from the TMDL analysis process can be used to support implementation of the TMDLs. The EPA is taking no action on the implementation portion of the Submission.
10. Reasonable Assurances

The EPA guidance calls for reasonable assurances when TMDLs are developed for waters impaired by both point and nonpoint sources. In a water impaired by both point and nonpoint sources, where a point source is given a less stringent wasteload allocation based on an assumption that nonpoint source load reductions will occur, reasonable assurance that the nonpoint source reductions will happen must be explained in order for the TMDL to be approvable. This information is
necessary for the EPA to determine that the load and wasteload allocations will achieve water quality standards.
In a waterbody impaired solely by nonpoint sources, reasonable assurances that load reductions will be achieved are not required in order for a TMDL to be approvable. However, for such nonpoint source-only waters, states/tribes are strongly encouraged to provide reasonable assurances regarding achievement of load allocations in the implementation plans described in section 9, above. As described in the August 8, 1997 Perciasepe memorandum, such reasonable assurances
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should be included in state/tribe’s implementation plans and “may be non-regulatory, regulatory, or incentive-based, consistent with applicable laws and programs.” Existing and future point sources are required to comply with their NPDES permits, which must include the requirements and assumptions of the TMDL. The NCDEQ has no direct regulatory authority over most nonpoint source discharges. Therefore, voluntary incentive-based mechanisms will be used to
implement management measures to ensure that reductions in nonpoint source pollutant loadings can be achieved for the targeted impaired waters. Cooperation and active participation by the general-public and various industry, business and environmental groups is critical to successful implementation of TMDLs. There are links to a number of
publications and information resources on the EPA's Nonpoint Source Pollution web page (http://www.epa.gov/polluted-runoff-nonpoint-source-pollution) relating to the implementation and evaluation of nonpoint source pollution control measures. The State recognizes that local citizen-led and implemented management measures have the potential to provide the most efficient and comprehensive avenue for reduction of loading rates from nonpoint sources.
Assessment: The EPA considered the reasonable assurances contained in the Report. The point source is required to comply with their NPDES permit, which must include the requirements and assumptions of the TMDL. The point source must meet the criteria at the point of discharge in order to meet the
regulatory definition of “not causing or contributing to a water quality violation.” Reductions for nonpoint sources are expected to occur as a result of the incentive and voluntary programs already in place. 11. Public Participation

The EPA policy is that there must be full and meaningful public participation in the TMDL development process. Each state/tribe must, therefore, provide for public participation consistent with its own continuing planning process and public participation requirements (40 CFR section 130.7(c)(1)(ii)). In guidance, the EPA has explained that final TMDLs submitted to the EPA for review and approval must describe the state/tribe’s public participation process, including a summary of significant comments and the state/tribe’s responses to those comments. When the EPA establishes a TMDL, the EPA regulations require the EPA to publish a notice seeking public comment (40 CFR section 130.7(d)(2)). Inadequate public participation could be a basis for disapproving a TMDL; however, where the EPA determines that a state/tribe has not provided adequate public participation, the EPA may defer its approval action until adequate public participation has been provided for, either by the state/tribe or by the EPA. The Report was made available to the public for review and comment from September 2, 2022, to October 3, 2022. The NCDEQ provided the opportunity for public involvement via several avenues: notice of the proposed TMDL was posted on the NCDEQ website; a notice of the availability was sent
to interested persons or groups who have requested this type of information; and the NCDEQ corresponded with the NCDOT, the affected NDPES permittee located in the impaired watershed. No public comments were received. Assessment: The EPA concludes that the State involved the public during the development of the
TMDL and provided adequate opportunities for the public to comment on the Report.
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12. Submittal Letter A submittal letter should be included with the TMDL analytical document, and should specify whether the TMDL is being submitted for a technical review or is a final submittal. Each final TMDL submitted to the EPA must be accompanied by a submittal letter that explicitly states that the submittal is a final TMDL submitted under section 303(d) of the Clean Water Act for the EPA review and approval. This clearly establishes the state/tribe’s intent to submit, and the EPA’s duty to review, the TMDL under the statute. The submittal letter, whether for technical review or final submittal, should contain such information as the name and location of the waterbody and the pollutant(s) of concern. Assessment: An electronic mail message dated October 4, 2022 was submitted by Pam Behm, Branch
Chief of the Modeling and Assessment Branch, Planning Section, Division of Water Resources, NCDEQ. The message included the appropriate information and the final submission. 13. Conclusion
After a full and complete review, the EPA finds that the Total Maximum Daily Load (TMDL) for Fecal
Coliform Bacteria in Turkey Creek in the White Oak River Basin (HUC 03030001040005) report satisfies all of the elements of approvable TMDLs. This APPROVAL is for 2 TMDLs, addressing 2 waterbodies for use impairments due to fecal coliform.