2022/23 Bacteria Plan for the Banklick

The BWC is working with the Sanitation District to develop and updated bacteria plan for the Banklick.  This plan will serve as an alternative to the state's required Total Maximum Daily Load (TMDL), which is why we are calling it a "TMDL Alternative Plan". 

This plan:
  • compiles updated bacteria data within the waterways,
  • updates our understanding of potential sources within the watershed,
  • identifies projects that SD1 has/will complete to address overflows from their sewer systems, and
  • will become an supplement/addendum to the BWC's Watershed Plan.
Here's a link to download:
Draft TMDL-Alternative for Bacteria
Appendix A - Implementation Plan

Understanding the TMDL-Alternative

The TMDL-Alternative is a fairly technical document, so here's a few background things to know:
  • Why is it called an "Alternative"? - The Clean Water Act requires states to develop TMDL plans for every waterbody that doesn't meet its water quality standards.  The intent of the TMDL process is to calculate how much pollutant loading a stream can accept before it exceeds water quality standards, then calculate the amount of pollutant reduction that must occur in the watershed from the various sources.  
    This requirement was largely ignored until lawsuits from environmental groups forced states to move forward. 
    In an effort to develop a large number of plans in a short amount of time, TMDLs are being developed with with limited data, simply to 'get the plans done'.   BUT, if an impaired waterbody already has a plan in-place, that plan can serve as a substitute to these generalized-state-developed TMDLs.  By developing our OWN plan, based on the most current local data, our plan will serve as an ALTERNATIVE to the traditional TMDL process that the state uses.  Our local plan is the better option because it uses more robust data sets, incorporates current in-stream data, and gives us ownership of the process. 
  • River Mile Notations - The Banklick is broken down into the following segments 0.0 to 3.5, 3.5 to 8.2, and 8.2 to 19.5.  These numbers are the mile-points along the creek, starting at downstream mouth of the Banklick at 0.0.  The notation for each sampling station includes the Mile Point (MP) along the creek, so you know how far each station is from the mouth of the Banklick (the mainstem is abbreviated BLC).  This also applies to the sub-watersheds of Fowler Creek station (FWC 0.1) and Bullock Pen Creek station (BPC 0.1).
  • Sanitary Sewer System  vs.  Storm Water System  vs.  Combined Sewer System - SD1 operates three different types of "sewers".  There are specific regulatory requirements that relate to each type of system. 
    • Sanitary Sewer System - Our modern type of sewers that convey household sewage to the wastewater treatment plant.  Sanitary Sewer Overflows (SSOs) from this system are illegal and SD1 must eliminate all overflows by 2040.
    • Storm Water System - These convey rainwater ONLY from roadway catch basins and storm water detention basins (at commercial/industrial/neighborhood developments) to local creeks.  EPA regulates these as "Municipal Separate Storm Sewer Systems (MS4)".  SD1 is required to ensure that there are no illicit (illegal) sewage connections or and to minimize other pollutants being carried into the creeks by these stormwater-only pipes. 
    • Combined Sewer Systems - These are legacy sewers from early developments, which collects BOTH household sewage and rainwater runoff from roadways, houses, and other developments.  These older sewers were designed to dump the COMBINED sewage/rain into local creeks.  This approach is no longer used, but a network of these pipes still exist in lower parts of the Banklick Watershed.  These systems have been modified so that they now flow to the wastewater treatment plants during dry weather, but rainwater frequently exceeds the capacity of these pipes, so they overflow during wet weather.  EPA acknowledges that complete elimination of Combined Sewers and their overflows (CSOs) is impractical, so SD1 is required to reduce overflow volume by 85%.
  • Primary Contact Recreation - Bacteria contamination in a creek indicates a potential health hazard for people entering the water.  This means that the water quality in the creek doesn't meet the requirements for "Primary Contact Recreation". Per EPA:  Primary contact recreation standards protect people from illness due to activities involving the potential for ingestion of, or immersion in, water. Primary contact recreation usually includes swimming, water-skiing, skin-diving, surfing, and other activities likely to result in immersion.   In Kentucky, the primary contact recreation season is between May-Oct.

Hope that Helps!  Happy Reading.
Nicole