Final Report and Recommendations from the Water Quality Task Force
The TallulahRiver Watershed Council
3/31/2011
Table of Contents
Introduction 2
Key Constituents in Watershed Quality Issues 3
Threats to Water Quality 3
Sources of Threats to Water Quality 4
Oversight Roles of Key Constituents 5
Water Quality Task Force Activities 6
Discussions with Georgia Power Company 6
Discussions with the DNR Fisheries Operation 8
Discussions with Georgia EPD 9
Discussions with the LakeBurton Club10
Discussions with an Expert in Water Quality Issues11
Foaming within the Watershed12
Implications of the Nutter Report13
Conclusions14
Recommendations15
Testing15
Practices17
Final Comments18
Exhibit A19
Addendum20
Meeting with GPC20
Meeting with LBC22
Recommendations left Unaddressed 22
Update to the Nutter report24
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Final Report and Recommendations
The Water Quality Task Force of
The TallulahRiver Watershed Council
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The Tallulah River Watershed Council (TRWC) was formed in 2006 under a slightly different name by resolution of the Lake Burton Civic Association. The purpose of the TRWC was and remains to identify, understand and address potential threats to the watershed from a variety of sources that have emerged or might continue to emerge, such as diminution of water quality, interbasin water transfers, unregulated or irresponsible development, etc.
The Water Quality Task Force (WQTF) was formed and began operations in the spring of 2008. As the TRWC evolved into several distinct task forces, with clearly defined areas of focus, the WQTF understood its mission to be to develop answers and/or recommendations regarding the following questions:
What is the current level of water quality in the various segments of the Tallulah River (TR) watershed?
How has water quality deviated in recent years from earlier standards?
What have been the primary contributors to any changes in water quality?
Who are the key constituents in observing, monitoring and addressing past and future changes in the watershed’s water quality?
Based on the discoveries from the preceding studies, are changes to how key constituents observe and monitor water quality issues warranted?
What roles should the key constituents play going forward to ensure diligent oversight of water quality issues and activation of remediation efforts when emerging threats to water quality are identified?
The WQTF was formed at a time when concerns about water quality in the TR watershed had begun to deepen. A Georgia Department of Transportation project to widen Highway 76 resulted in significant sedimentation wash into LakeBurton. Allegations of faulty management of stormwater runoff, questionable treatment of wastewater plant effluent and washing of chemicals used in the maintenance of the golf course were levied against the proprietors of the Waterfall development, and a lawsuit was filed. Anecdotes of sedimentation build-up in parts of LakeSeed were passed around. Concerned citizens began taking and sharing pictures of stormwater runoff to document purportedly heavy sedimentation and surfactant flows. And a nonscientific survey of residents of LakeBurton revealed overall perceptions of diminished water quality (the survey focused entirely on opinions and contained no data regarding water
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quality). Accordingly, the WQTF began its operations at a time when interest in the status of water quality in the TR watershed was very high.
The remainder of this report provides background information and describes the study methodology of the WQTF, its findings and recommendations.
KEY CONSTITUENTS IN WATERSHED QUALITY ISSUES
There are many levels of people/organizations which have fingerprints on water quality issues in the TR watershed. Among those with more than occasional presence in the watershed, there are two key categories: those with permanent involvement, and those with episodic involvement.
People/organizations with permanent involvement include:
Georgia Power Company (GPC)
Local community/civic associations
TallulahRiver Watershed Council (TRWC)
Shoreline property owners throughout the watershed
Residential developments (e.g., Lake Burton Club)
Commercial developments (e.g., LaPrade’s and Anchorage Marinas)
Rabun County Road Department
Rabun CountyMarshal
GeorgiaDepartment of Natural Resources (DNR)
Georgia Environmental Protection Department (EPD, division of DNR)
U. S. Forest Service
U. S. Federal Energy Regulatory Commission (FERC)
Industry (should it emerge, little current presence)
Organizations with episodic involvement include:
Developers of single family residences
Developers of watershed residential communities (e.g., Heaven’s Landing)
GeorgiaDepartment of Transportation
THREATS TO WATER QUALITY
While threats to water quality in the watershed may come from many sources, they may be categorized in three distinct groups: biological, chemical and sedimentary. For example, biological threats would include fecal coliform stemming from human or animal waste, or algae blooms from whatever source. Chemical threats would include such contaminants as synthetic fertilizers, herbicides and pesticides. Sediment threats come from wash of soil into the watershed from a variety of sources such as boat wake reverberation on untended shorelines, road scraping on unpaved roads lying above the shoreline, improperly maintained silt fences on homesite construction projects, etc.
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SOURCES OF THREATS TO WATER QUALITY
There are numerous sources of practices that can negatively affect the quality of water in the TR watershed. Fortunately, there is very limited industrial activity present within the watershed boundaries (pollutants from industrial spills and waste have degraded water quality in many lakes, rivers and watersheds throughout the country). However, there are still a number of activities which can and do negatively impact water quality. Following is an illustrative (but not comprehensive) list of such activities. Inclusion of an item does not mean it has happened; it may only refer to the possibility of the threat emerging.
From homeowners:
Landscaping tended with harmful fertilizers, pesticides, herbicides and fungicides without proper buffering barriers between the shoreline and the landscaping.
Constructed rock walls without rip rap to dampen boat wake.
Improperly constructed or unrepaired septic drainage areas.
Unguarded practices such as blowing leaves into the lake, spraying sealant on shoreline decks and walkways, spillage from putting gasoline into boats in homesite slips, etc.
Homes with untended shorelines, subject to erosion from boat wake, etc.
From agricultural operations and wildlife:
Spreading harmful fertilizers, pesticides, herbicides and fungicides on crop lands adjacent to shorelines.
Livestock waste, as well as waste from wildlife, principally geese.
From commercial/residential developments:
Failure to protect against siltation wash during construction.
Improper waste water treatment facilities and maintenance.
Landscaping issues as described in the homeowners’ section.
Improper golf course maintenance practices.
Spreading of improperly-handled waste water treatment effluent on lands adjacent to shorelines.
Dumping of residues from construction into watershed run-off zones (paint, washing of concrete trucks, etc.).
From governmental road and highway departments:
Periodic scraping of unpaved county roads (with subsequent wash).
Highway construction/rerouting.
Spraying rights-of-way with herbicides, etc.
From “reservoir aging”:
Sediment build-up from human activity and normal wash in untended areas.
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With sediment build-up comes warming of surface water due to shallower pools and shifting of aquatic life (fewer predators, more bottom-feeding species).
There may well be many other sources of threats to water quality in the watershed, but the foregoing list comprises those which are or might be most common.
Within the past decade, there have been a few notable allegations of major transgressions negatively affecting water quality in the watershed. The two most publicized activities relate to the rerouting of Highway 76 on the northeast boundaries of LakeBurton, and operations of the (former) Waterfall residential and golf course development, also in LakeBurton. Both alleged transgressions were subjected to either legal or governmental remediation (still unresolved regarding the Waterfall lawsuit).
The WQTF has not attempted to evaluate the merits of any of the foregoing remediations. It has not evaluated culpability of any party regarding degradation of water quality. Its sole mission has been to evaluate the current status of water quality without assessing responsibility to any entity for contributing to such status.
OVERSIGHT ROLES OF KEY CONSTITUENTS
The most influential constituent with respect to oversight of water quality within the watershed is Georgia Power Company. GPC owns the majority of shoreline properties in the lakes of the TR watershed. Its licensing agreement with FERC does not require that it monitor the water quality within the watershed. However, GPC has established a voluntary program and routinely tests water quality throughout the watershed (as it does in all reservoirs dedicated to power generation by GPC). Any time GPC discovers worrisome results from its testing, it alerts the appropriate local, state or federal authorities which have proper authority to take whatever action is deemed necessary.
FERC’s involvement is indirect. FERC does not have direct responsibility for monitoring or addressing water quality issues, nor does it require licensees to monitor water quality. It cannot issue a license for a hydroelectric project unless the state certifying agency has either issued a water quality certification for the project, or has waived certification by failing to act on a request for certification. FERC’s license contains requirements related to flows, drawdowns and walleye spawning habitat. FERC’s license does not contain requirements related to wastewater disposal or biological sampling.
Georgia DNR has two levels of involvement in water quality issues: through its EPD division (discussed separately), and through its Wildlife Resources Division, which oversees many operations, including the fish hatcheries located throughout the state, including one on Lake Burton. The LakeBurton fish hatchery periodically conducts fish
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health testing, an important procedure which analyzes levels of contaminants absorbed or ingested by fish in the reservoir.
The Watershed Protection Branch of the Georgia EPD, according to its website, “manages water resources in Georgia through permits to local governments and industry to discharge treated wastewater and to local governments, industry, farmers and subdivisions for surface water and groundwater withdrawals. The Branch ensures that Georgia's public water systems are operating properly to supply safe drinking water to citizens, works to control nonpoint sources of pollution, including erosion and sedimentation, and manages storm water discharges. This Branch also conducts water
quality monitoring and modeling of Georgia's waterways.” EPD monitors about 20% of Georgia’s waterways, with higher priority placed on waterways with adjacent industrial plants and activities.
The various civic and community associations (e.g., Lake Rabun Association, Seed Lake Association, Lake Burton Civic Association), at their discretion, can have multiple contributory roles regarding protection and enhancement of water quality issues in the TR watershed. These associations are sources of communication vehicles to members which can provide useful information leading to responsible citizenship practices affecting water quality, and are key sources for funding necessary activities supporting water quality that are not performed by other entities, for manpower related to projects needed to address water quality issues, and for guidance regarding the setting of priorities for what is most important to watershed residents.
Finally, the TRWC is, to borrow the analogy coined by former baseball player Reggie Jackson, the “straw that stirs the drink” leading to focus on and action regarding water quality and related lifestyle issues in the TR watershed.
Its Watershed Master Plan task force is drafting a long-range plan designed to guide orderly growth and progress throughout the watershed;
Its Water Management task force is currently focused on the threat of an interbasin water transfer out of the TR watershed to the Chattahoochee basin;
Its Government and Industry Affairs task force coordinates issues of importance to the TRWC with federal, state and local governmental authorities;
Its Communications task force develops and coordinates messages needed for delivery to key constituents with local civic and community associations; and
Its Water Quality task force undertakes the role defined on the first page of this report, basically, to determine what needs to be done to protect water quality and to determine and to attempt to negotiate who is best positioned to perform key tasks.
WATER QUALITY TASK FORCE ACTIVITIES
Discussions with Georgia Power Company. The WQTF met with representatives of GPC to learn how it tests water quality in the watershed. GPC testing is done in many
locations in Lakes Burton, Seed, Rabun, TallulahFalls and Yonah. Surface-to-bottom
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profile testing is done at multiple sites in each body of water (e.g., 10 locations throughout LakeBurton) at least 3 times per year*. These locations represent influent water quality from the major tributaries that impact water quality in the reservoirs.
GPC collects surface samples for chemical analyses at several sites on Burton to further understand the dynamics occurring within the reservoir over time. These surface samples are analyzed for a range of chemicals that influence the ecology of the system. All of these data are included in the documents provided to FERC at the time of hydro relicensing, and shared with GA-EPD or others as requested. Maintaining data over long periods adds insight to the dynamics of this reservoir as it matures.
Analyses may be performed for a numbers of analytes, including:
-Temperature- Dissolved oxygen
-Alkalinity- Ammonia
-Calcium- Chlorophyll-a
-Fecal coliform*- Hardness
-Magnesium- Nitrate
-Nitrite- TSI chlorophyll-a
-TSI total phosphorus- Total phosphorus
-Secchi depth- Turbidity
-Specific conductance- TSI Secchi
-pH
*Testing for fecal coliform is done weekly from Memorial Day until
Labor Day
Data are presented in the form of annual minimum, maximum, mean and standard deviation concentrations.
Exhibit A is attached to this report. The graph presented on Exhibit A shows yearly mean water quality data for the TR watershed from 1995 through the most current data for 2010. The graph shows no identifiable trends over the years in the annual means for all categories of analytes, except for fecal coliform, which as noted, is subject to weekly testing. When fecal coliform concentration at a site exceeds an established threshold, the site is closed and daily sampling is conducted until the concentration drops below the threshold.
Two comments are appropriate regarding the exiting testing regimen. First, while current testing does include tests for nitrates, nitrites and phosphorus, which are often included in fertilizers, modern fertilizers have many components that are not included in the testing regimen. Nor does the testing include specific testing for components of herbicides, pesticides or fungicides.
Second, turbidity is included in the ongoing testing regimen, but turbidity is at best a transitory measure of the impact of sedimentation. There is no known current
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measurement of levels of the lake floor or ongoing changes thereto. For example,
elevations were recorded at various points throughout the watershed before the river was dammed and the lakes were created, but there is no known current measurement of what the elevation of the floor may be at those same locations. To the extent that large quantities of sediment flow into the watershed, from whatever sources, the health of the watershed will continue to be impaired. As water depth decreases while sediment builds, water temperature rises, fish habitats are compromised (spawning grounds are diminished) and the entire character of the lake will continue to change over time.
Finally, publishing annual means of analytes is helpful, but the WQTF maintains that publishing seasonal data would further illuminate water quality status. For example, to the extent that run-off of lawn/golf course treatments is an item of concern, reporting annual means of measured contaminants would not reveal the extent of the possible problem, as the inactivity in the winter and resulting absence of contaminants would mask the higher concentrations when treatments are actively applied in the summer.
Discussions with the DNR Fisheries operation. On separate occasions, the WQTF met and discussed with the Senior Fisheries Biologist at the Department of Natural Resource’s fish hatcheries operation on LakeBurton the testing done by that operation. Briefly, “fish health testing” is periodically conducted by DNR on various species of fish resident in the watershed. Each test is performed on a single species, and involves capturing a number of the species selected for the test, and samples are produced and sent to a laboratory for analysis regarding what the fish has absorbed or ingested.
Predator fish are selected for testing as one species ingesting others broadens the overall picture of what is in the water throughout the watershed. Selection of species is further differentiated by “top feeders” and “bottom feeders” to broaden the diversity of sampling, although most species selected travel broadly in their habitats, so each test is thought to reveal conditions throughout such habitat (e.g., throughout Lake Burton, not just where the fish sample was collected).
The recent history of testing, and the results of the testing, are summarized below.
DateSpecies TestedResults
11/00Spotted BassLow level mercury concentration,
advisory to limit consumption of
large fish to one meal/week (no
restriction re fish < 16”)
11/00Channel CatfishNo contamination
2/01Largemouth BassLow level mercury concentration,
advisory to limit consumption of
large fish to one meal/week (no
restriction re fish < 16”)
11/04Brown TroutNo contamination
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11/06*Walleye PikeLow level mercury concentration,
advisory to limit consumption of
large fish to one meal/week (no