Charleston Waterkeeper, the College of Charleston’s Masters of Environmental Studies Program, Mount Pleasant Waterworks, and the Town of Mount Pleasant have teamed up to investigate fecal contamination in Upper Inlet Creek.  Upper Inlet Creek is a tidal creek located between Sullivan’s Island and Mount Pleasant above the Atlantic Intracoastal Waterway.  The area is an important habitat for a variety of estuarine life and harbors many commercial and recreational shellfish beds.

DHEC’s water quality data indicate high levels of the fecal indicator bacteria fecal coliform bacteria are present in Upper Inlet Creek.  Accordingly, the creek is listed on South Carolina’s 303(d) list of impaired waterways.  DHEC is scheduled to develop and implement a total maximum daily load, or TMDL for short, for fecal coliform by 2016.  A TMDL is simply a plan to restore the water quality of Upper Inlet Creek.

Meanwhile, DHEC is working to transition fecal indicator bacteria from fecal coliform to Enterococcus.  Enterococcus is considered a better fecal indicator bacteria for marine waters because it survives better than fecal coliform. To help inform this transition, the Upper Inlet Creek Project will quantify bacterial water quality in the creek using both fecal coliform and Enterococcus.

Identifying sources of fecal contamination is often difficult.  Sources include stormwater, human inputs, and wildlife.  To help narrow down the long list of potential sources, the Upper Inlet Creek Project will employ an optical brightener analysis.  Optical brighteners are a component in most laundry detergents and can help differentiate between human and animal sources of fecal contamination.  Both the bacteriological and optical brightener analyses are being conducted at the water quality lab at Mount Pleasant Waterworks.

Our first sampling run took place in early March, aboard the Charleston Waterkeeper’s boat the Lady C.  We’ll sample once per month for an entire year in order to produce a comprehensive dataset.  We hope the data set will be used to make future water quality management decisions regarding Upper Inlet Creek and to ensure the health and quality of Charleston’s waterways.

A big thanks to Jill for posting this overview of the Upper Inlet Creek Project. Charleston Waterkeeper is proud to work with the College of Charleston’s Masters of Environmental Studies Program, Mount Pleasant Waterworks, and the Town of Mount Pleasant on this project.  Stay tuned to Charleston Waterkeeper’s  Twitter (using the hashtag #UIS) and Facebook accounts for updates and progress!

Help protect your right to clean water by supporting this important project and others like it. Become one of the 400.

A Quick History Lesson

In the 1990s scientists discovered the Charleston Harbor estuary frequently experienced low levels of dissolved oxygen (DO). The low DO levels meant that much of the estuary failed to meet state water quality standards for dissolved oxygen. Low levels of DO threatened the health of fish and other aquatic species. Research revealed the problem was due to both natural conditions and point source discharges from NPDES permit holders.

This triggered DHEC’s obligation under the Clean Water Act to develop a DO total maximum daily load, or TMDL for short. A TMDL is a plan to cap the total discharge of dissolved oxygen demanding pollutants to help the estuary meet its water quality standard for DO. The cap is then divided among all sources of oxygen demanding pollutants.

To set the cap, DHEC and scientists attempted to develop a computer model that incorporated the Ashley, Cooper, and Wando Rivers and the Charleston Harbor. However, the computers available at the time were not powerful enough to run the model. DHEC ultimately developed two TMDLs, one for the Ashley River and another for the Cooper and Wando Rivers and the Charleston Harbor.

Another Acronym Gets Involved

The TMDLs required NPDES permit holders to achieve a 60% reduction in discharges of oxygen demanding pollutants. DHEC and permit holders agreed to implement the reductions in two phases. The first phase was implemented in most permits by 2003 (a few permit holders challenged implementation in court). Shortly afterward, the Cooper River Water Users Association, a coalition of NPDES permit holders working through the Berkeley, Charleston, Dorchester Council of Governments (BCDCOG), offered to fund development of a “3D” model that would incorporate the Ashley, Cooper, and Wando Rivers and the Charleston Harbor.

DHEC agreed to work with the BCDCOG and the Cooper River Water Users Association on development of a 3D water quality model to inform implementation of the second phase of reductions. Two environmental engineering firms, Tetra Tech and Jordan, Jones, and Goulding, completed the 3D model and delivered it to DHEC in 2008. Afterwards, DHEC began development of a revised TMDL, combining and updating the Ashley River TMDL and the Cooper and Wando Rivers and Charleston Harbor TMDL.

In October 2012, DHEC issued public notice of its revision and published a draft of the revised TMDL for public comment. Charleston Waterkeeper requested an extension of the 30 day comment period and filed a Freedom of Information Act request in order to review the documentation contained in DHEC’s files regarding development of the revised TMDL.

After reviewing the draft revised TMDL, 3D modeling report, and DHEC’s TMDL file we developed several concerns regarding the provisions for public participation and how the TMDL accounted for stormwater inputs. We submitted our comments to DHEC in late December 2012. The South Carolina Department of Natural Resources and the EPA also submitted comments.

TMDLs are Complicated

This lengthy narrative highlights the simple fact that TMDL development is difficult. Unfortunately, this also presents a significant barrier to public participation. For instance, the TMDL document itself is forty-three pages long. DHEC’s TMDL file contains thousands of pages of technical reports, scientific studies, correspondence, and notes. The 3D modeling report requires an environmental engineering background and experience with water quality modeling to fully understand.

That’s why the work of groups like Charleston Waterkeeper is so important. Our work lowers the barrier to public participation. We were able to use the power of the law to review DHEC’s files, extend the public comment period, and devote resources to reviewing the TMDL and its supporting materials to ensure the public’s right to clean water is adequately protected. Without this work the public would lack a voice in the TMDL process.

DHEC takes public comments seriously and considers and responds to each comment. In response to our comments DHEC added language to the TMDL clarifying how stormwater inputs were accounted for in the TMDL. DHEC also added an explicit statement outlining how public notice and comment are handled when the revised TMDL is implemented and reallocated in the future. Charleston Waterkeeper is proud to play a role in development of the revised TMDL. We believe our water quality is best protected when DHEC, permit holders, and the public are actively engaged in the TMDL process.

Visit oysterpoint.org for more information and to register a team for the relay race.

On this election day, we can’t help but reflect on our rights as citizens. One of the most fundamental freedoms we hold dear at Charleston Waterkeeper is our right to clean water.

For the past few weeks, as part of GIVE 444, we’ve featured photos urging the protection of our right to blankable water (i.e. swimmable, playable, fly fishable, etc.).

Today, we’re featuring our first GIVE 444 ambassador: Rhett L. Boyd, Jr., founder of Rogue Wave Surf Shop. We asked Rhett what clean water means to him, and here’s his story…

Clean water is pure joy. I love to drink it, swim in it, and surf it. Many of my favorite memories are of crisp fall morning surf sessions. I’ve built my life and business around the tides, swell patterns, and waves our local beach communities offer. The life that I know and love is based around clean water. It’s important to protect our waterways to provide the same enjoyment for future generations. My son rode his first wave with me this summer, and I want to make sure that he is able to enjoy the ocean, creeks, and rivers to the fullest. We are blessed and must take responsibility for caring for our local environment and the gift of clean water.

Join us and Rhett to help “Protect your right to surfable water.” Become one of the 400 donors by donating $40 today to Charleston Waterkeeper at GIVE444.org.

First up: lets look at how the Clean Water Act protects and improves the quality of our local waterways. The Clean Water Act is revolutionary because it devised a two part system to attack water pollution.  The first part deals with pollution at the source where it is created and discharged. [Stay tuned for more on this]  The second part deals with the in-stream water quality of local waterways and is the subject of this post.

Water Quality Standards

The Ashley/Cooper River Basin a/k/a the Charleston Harbor Watershed

Water quality standards are the foundation for protection of in-stream water quality.  In South Carolina, DHEC is responsible for developing and maintaining our water quality standards.  Simply put, water quality standards are goals for the in-stream water quality of a waterway.  They have three parts: (1) a designated use, (2) water quality criteria, and (3) antidegradation rules.

A “designated use” is an officially recognized human or ecological use for a particular waterway.  For example, DHEC classifies recreation as a designated use of Shem Creek.  Other designated uses include protection and propagation of fish and shellfish, public water supply, and agricultural and industrial uses.  A single section of a waterway may have more than one designated use, and different sections may have different uses.  Every waterway must have at least one designated use.

All designated uses must be protected.  DHEC accomplishes this by defining the “water quality criteria,” or the level of water quality, necessary to protect each designated use.  Water quality criteria are set using data and scientific judgment about the impact of water pollution on each designated use.  They can be numeric limits on the amount of a pollutant or a narrative description of the desired water quality.

Existing water quality must be maintained.  The primary tools for maintaining water quality are “antidegradation rules.” These rules are designed to minimize the impact of new or expanding sources of pollution on in-stream water quality.  Properly developed and implemented antidegradation rules can protect existing water quality from deterioration.

Impaired Waterways

Water quality standards are essential for protecting our right to clean water.  But merely setting goals for water quality is not enough.  That’s why the Clean Water Act requires each state to develop a list of waterways that do not meet water quality standards.

This list, known as the 303(d) list, requires states to review existing water quality data and determine which waterways do not support their designated uses.  These waterways are known as “impaired waterways.”  Each state develops a 303(d) list every 2 years.  In South Carolina, DHEC develops our 303(d) list.  According to the last 303(d) list, approximately 41% of waterways statewide are listed as impaired.

The most recent data available for our area indicates there are 102 impaired waterways in the Ashley/Cooper River Basin.  That means the quality of the water in 102 of our local waterways makes them unfit for their designated use. The impacted uses in our area are highlighted in the pie chart below.

These 4 designated uses are impacted by a number of different “impairments” or pollutants.  The high levels (or low levels in the case of dissolved oxygen) of these pollutants make waterways unfit for their designated uses. A single waterway can have more than one impairment impacting more than one designated use.  The impairments for our area are reflected in the bar graph below.
More than half of the impaired waterways in our area are impaired for fecal coliform. Fecal coliform is an “indicator bacteria” which points to the possible presence of fecal pollution.  Fecal pollution is exactly what it sounds like and comes from many different sources.  It impacts recreational and shellfishing uses of our waterways.  Fortunately, DHEC regularly monitors local shellfish beds for potential contamination and warns the pubic and shellfish harvesters.

Twenty-one percent of the impaired waterways are impaired for low dissolved oxygen. Dissolved oxygen is simply oxygen dissolved in water.  Just as we need air to breath, fish and other aquatic life need dissolved oxygen for respiration.  A wide variety of pollutants lower dissolved oxygen levels when they are discharged to our waterways.

Ten percent of the impaired waterways are impaired for high levels of mercury. One source of mercury is coal burning power plants.  As coal is burned mercury is released to the air.  When it rains, mercury returns to the ground with rainfall where it enters our waterways and contaminates fish and other aquatic life.  Mercury is highly toxic and DHEC warns about eating several species of fish caught in our local waterways that are contaminated with mercury.

Explore the impaired waterways in your area using this map:

View Ashley/Cooper River Basin Impaired Waterways in a larger map

Total Maximum Daily Load (TMDL)

After determining which waterways do not meet their water quality standards, the next step is to develop a plan for fixing the cause of the impairment.
A “Total Maximum Daily Load,” or TMDL for short, is a two part plan to improve the quality of an impaired waterway. The first part is a cap on the maximum amount of a pollutant a waterway can receive and still meet its water quality standards.  The second part is a plan that describes how each source of a pollutant must be reduced.  After an impaired waterway is identified, DHEC is responsible for developing TMDLs.

In our watershed several waterways have TMDLs in place for fecal coliform or low levels of dissolved oxygen.  These are highlighted in the interactive map below.

View Ashley/ Cooper River Basin TMDLs in a larger map

TMDLs can be and have been successful in helping some of our impaired local waterways meet their water quality standards.  Unfortunately, TMDL development is slow and DHECs resources for developing and implementing TMDL have dwindled.

Wrapping It All Up

The Clean Water Act uses a three part approach to protect the quality of our waterways: goals, evaluation, and intervention (water quality standards, 303(d) list, TMDLs).  Underlying this framework is the notion that local water users have the best knowledge of their local waterways and therefore the highest interest in protecting them.  That’s why the Clean Water Act provides for public participation at every stage, from establishing and updating water quality standards to TMDL development.  Charleston Waterkeeper uses these tools to identify water pollution hotspots and advocate for our right to swimmable, drinkable, fishable water.  You can participate by supporting this work with a $40 donation.  Join us.  Become one of the 400.  GIVE 444.

Fly Fishing in the Ashley/Cooper River Basin

Last week, we celebrated the passing of a piece of legislation that served as a transformative turning point in our nation’s history. October 18, 2012 marked the 40th anniversary of the Clean Water Act, an important reminder of how far we’ve come in protecting Charleston’s waterways, but also of how far we have to go.

To celebrate, we launched the GIVE 444 campaign. The campaign was kicked off with an editorial in the Post & Courier about the role of the Clean Water Act in improving Charleston’s own waterways [paper version below]. Next, we launched the actual campaign by sending out this eblast to our faithful supporters (if you’re not on our email list, be sure to sign up here).

In essence, the campaign serves to celebrate not only the 40th anniversary of the Clean Water Act, but also Charleston Waterkeeper’s own 4th anniversary (on September 16th). We’ve grown from a mere idea into a tangible reality, and it has only been possible because of the overwhelming support we’ve received from all of you. Thank you!

The GIVE 444 campaign has three goals: CELEBRATE, EDUCATE, and PARTICIPATE.

On the celebration end, we will be featuring a variety of activities that tie us to the water here in the Charleston area. From surfing to fishing, we’ll be posting photo PSAs with a simple call to action, “Protect your right to ___able water.” If you’d like to see a specific activity (e.g. “Protect your right to oyster roastable water.”), let us know, and we’ll try to feature it (also, if you have a great hi-res photo of you or a friend enjoying a water-based activity in Charleston, send it our way; we’ll see what we can do to include it in the campaign). We’ll be posting these PSAs throughout our social media platforms, so be sure to friend us on Facebook or follow us on Twitter to get the latest.

Next, the campaign will strive to educate. Over the next few weeks, we will be publishing reports and information that shed light on the current quality of Charleston’s waterways while also noting the issues that may be threatening our right to clean water–from point-source pollution to waters impaired with fecal pollution. As a data-driven organization, we rely on empirical information to identify and address water pollution issues throughout the Charleston Harbor watershed. After all, it is not possible to measure progress if we first don’t establish a baseline.

Stay tuned as our first piece will be going live later this afternoon.

Finally, as part of GIVE 444, we want the public to participate. We want you to play a role in the process of protecting Charleston’s right to clean water. Over the past year, we have built and operationalized our primary programs: our water quality monitoring program, our permit watchdog program, and our patrol program (which also serves to support the first two initiatives). We have created these programs as a way to get closer to our fundamental goal: protecting and improving Charleston’s waterways. Throughout the next four weeks, we will be asking YOU to participate in this goal by donating $40 (in honor of the Clean Water Act’s 40th anniversary). Your donation will help fund our integral programs. To donate, visit GIVE444.org.

Our goal is to encourage 400 donors to donate $40 throughout the next four weeks. Join us. Become one of the 400.

Tony Bartelme’s article in today’s Post and Courier titled “Big permit backlog at DHEC raises questions” highlights the existence of zombie permits and a deficiency in the National Pollutant Discharge Elimination System (NPDES) here in South Carolina.

NPDES was created by the Clean Water Act in 1972 to restrict and eventually eliminate the discharge of pollutants into our waterways.  Under NPDES it’s illegal to release pollutants into the water, unless it’s authorized by a permit from DHEC. These permits are known as “NPDES permits.”  They contain limits on the types and amounts of pollutants a permit holder can discharge to our waterways.  And they are the primary tool DHEC uses to protect our right to clean water.

According to the article, statewide, more than 500 permit holders discharge pollutants under an expired permit.  Statewide the most out-of-date permit expired on April 30, 1994.  That’s over 18 years ago!

Our data indicate expired permits are an issue locally as well.  In the Ashley/Cooper River Basin about 36 permit holders discharge pollutants under an expired permit. The most out-of-date permit expired on July 31, 2000.  Over 12 years ago!  The most up-to-date permit became effective about 1 year ago on September 1, 2011.  It expires August 31, 2016.

Zombie Permits

Unfortunately NPDES allows this back log to happen.  That’s because, even though a permit expires after 5 years, a permit holder is permitted to continue discharging pollutants, so long as it applies for a new permit before the expiration date. During the limbo period after the permit expiration date, but before a new permit is issued, a discharger must continue to comply with the limits outlined in the expired permit.  These are known as “zombie permits.”

The 5 year renewal cycle is a very important feature of NPDES.  It allows   DHEC the opportunity to review a permit holder’s treatment performance, permit compliance, and water quality data before reissuing a permit.  In many cases that means better limits and controls on the pollutants a permit holder is allowed to discharge. It also allows the public and groups like Charleston Waterkeeper to weigh in on what limits should be included in a reissued permit.

Long story short, the public ends up with the short end of the stick.  Zombie permits chill the public’s right to be involved in the renewal process. And our waterways don’t get the full protection they deserve from up-to-date treatment technology and permit limits.

It’s disappointing that DHEC hasn’t taken advantage of the opportunity to fully protect our waterways. To be sure, the renewal process is often complicated and difficult.  Public comments can be lengthly and difficult to resolve.  Permit holders often employ environmental engineers, lawyers, and trade groups to advocate for favorable permits.  But, all this doesn’t excuse DHEC of its obligation to timely review, update, and reissue NPDES permits that protect our right to clean water.

Tackling the Problem

We commend DHEC and its Director Catherine Templeton for tackling the back log of expired NPDES permits.  But we urge caution.  Permits should not be reissued just to be released from limbo. DHEC should be provided with the staff and resources required to counterbalance pressure from permit holders.  Permits should only be reissued after thorough review by DHEC, input from the permit holder, and a full and fair opportunity for public participation.

At Charleston Waterkeeper we’ll continue working to establish a baseline of our permit holder’s treatment performance. We’ll also be active as permits in our watershed come up for renewal.  As a member of the public you can urge your local legislators to ensure that DHEC has the resources and support required to tackle this job.

NPDES has fallen short of eliminating all pollutant discharges to our waterways nationwide.  But it can work better for us here locally.  We’re working to ensure it does.

Projects like this take a lot of time, money, and resources.  A pilot study helps us determine how to use those things most efficiently.  We also designed our pilot study to test our logistics, equipment, sample collection methods, and analysis protocols.  This process will help ensure the quality and reliability of the data we produce.

Our pilot study has three types of monitoring stations: water, land, and tidal creek.  Water stations are on the water in highly used areas accessible only by boat.  Land stations are also on the water, but at popular recreation areas accessible by land.  Tidal creek stations are generally located at the mouth, middle, and headwaters of a tidal creek.  Over the next several weeks, we’ll be rotating through each group of monitoring stations on a weekly basis.

Yesterday morning we sampled our water stations.  The day began early at the Charleston Waterkeeper office where we prepared our sample collection equipment, field notebooks, and chain-of-custody documentation. Our team of field investigators met at the City Marina a short while later.  After quickly preparing the Lady C we hit the water.  We pulled the first sample in the Ashley River near Charleston Community Sailing’s practice site at 9:12 A.M.  A few hours later, we collected the last sample near the northern tip of Morris Island, a popular gathering spot on summer weekends.

Afterwards we motored back to the City Marina and transferred the sample cooler to the lab.  At the lab we processed the samples, prepared them for analysis, and left them to incubate for 24 hours.  We’ll share the preliminary data with you here and on Facebook and Twitter so you can follow our progress.

A pilot study like this is also an important first step in the development of a quality assurance project plan, or QAPP for short.  A QAPP is a document that outlines the data collection, storage, and analysis methods a water quality monitoring project will employ.   A QAPP also provides the quality control protocols required to produce credible data capable of informing you where our local waterways meet standards for safe swimming.

Our pilot study will occur over the next several weeks (keep an eye out for us on the water!).  After the pilot study is complete, we’ll be working to develop our QAPP.  Once that’s done we can start regularly monitoring bacteria levels in our local waterways.  Our goal is to start regular sampling Wednesday May 1, 2013.  Twenty-four hours later we’ll be able to notify you where our tidal creeks and rivers meet standards for safe swimming.  That way you can make an informed decision about where you use our local waterways.

Rome wasn’t built in a day, and neither was our Water Quality Monitoring Program.  Good things like this take time, hard work, and support.  A big thank you to all those who’ve helped make this program a reality!

Summer 2008, Hudson River, NY

Cyrus Buffum takes a water sample off the R. Ian Fletcher--Hudson Riverkeeper's patrol boat--during a visit to the Hudson River Valley. Three months before establishing Charleston Waterkeeper, Buffum visited Riverkeeper to learn from the success of the very first Waterkeeper organization.

Summer 2012, Charleston Harbor, SC

Cheryl Carmack, Charleston Waterkeeper's water quality intern, pulls a water quality sample from the Lady C--Charleston Waterkeeper's patrol boat--as part of the organization's water quality monitoring program.

Infiltration is groundwater that enters the sanitary sewer system through cracks or leaks in sewer pipes or manhole covers.  Inflow, on the other hand, is stormwater that enters sanitary sewers via an illicit connection like a roof drain or down spout.  Either way, as today’s Post and Courier article “Tidal Water Bacteria Levels Monitored After Two Sewage Spills” makes clear, it’s a serious issue for sanitary sewer systems and our right to clean water.

Inflow and infiltration are one cause of sanitary sewer overflows. Other causes include blockages, power outages, and sewer line breaks.  Since we started tracking these events in December 2011 there’s been 23 of them. The smallest are a few hundred gallons while the largest was around 500,000 gallons.  There were three overflows this past Tuesday.

Preventing sanitary sewer overflows is a tough job. The average sanitary sewer system in our area has several hundred miles of gravity sewers, force main, and service laterals, hundreds of pump stations, and a sewage treatment plant or two.  All that infrastructure and equipment has to operate flawlessly 24/7, rain, shine, occasional snow, or hurricane.  Prevention requires nearly constant inspection, maintenance, and upgrades.  And, of course, lots of money.

The next time pay your bill to Charleston Water System, Mount Pleasant Waterworks, or  the North Charleston Sewer District, remember you’re helping prevent sanitary sewer overflows.  You can also encourage your sanitary sewer system provider to invest more resources in inflow and infiltration prevention.  If you see an overflow immediately report it to you sanitary sewer service provider.  Clean water is priceless, but it costs money.  And it’s worth paying for.