appendix a ssurgo soils - illinois.govosco silt loam, 5 to 10 percent slopes, eroded 667.65 0.3636...

Appendix ASSURGO Soils

SSURGO Soils Appendix A Lake Springfield and Sugar Creek

Watershed

Description Acres Percent

Alvin fine sandy loam, 10 to 18 percent slopes, eroded 26.34 0.0143

Assumption silt loam, 10 to 15 percent slopes, eroded 8.17 0.0044


Assumption silt loam, 2 to 5 percent slopes 150.14 0.0818



Buckhart silt loam, 0 to 2 percent slopes 1584.89 0.8631

Buckhart silt loam, 2 to 5 percent slopes 2919.71 1.5900

Camden silt loam, 0 to 2 percent slopes 7.23 0.0039

Camden silt loam, 2 to 5 percent slopes 30.53 0.0166

Camden silt loam, 5 to 10 percent slopes, eroded 11.09 0.0060

Clarksdale silt loam, 0 to 2 percent slopes 1159.82 0.6316

Clarksdale silt loam, 2 to 5 percent slopes 4.95 0.0027

Clarksdale silt loam, terrace, 0 to 2 percent slopes 4.04 0.0022

Cowden silt loam, 0 to 2 percent slopes 1299.10 0.7075

Denny silt loam 17.40 0.0095

Denny silt loam, 0 to 2 percent slopes 485.07 0.2642

Drury silt loam, 2 to 5 percent slopes, rarely flooded 184.87 0.1007

Dumps, mine 182.06 0.0991

Edinburg silty clay loam, 0 to 2 percent slopes 553.59 0.3015

Elburn silt loam, 0 to 2 percent slopes 6.85 0.0037

Elco silt loam, 10 to 18 percent slopes 1291.32 0.7032

Elco silt loam, 10 to 18 percent slopes, eroded 2686.83 1.4632

Elco silt loam, 5 to 10 percent slopes, eroded 367.67 0.2002

Elco silty clay loam, 10 to 18 percent slopes, severely eroded 1206.11 0.6568

Elkhart silt loam, 5 to 10 percent slopes, eroded 161.87 0.0882

Fayette silt loam, 10 to 18 percent slopes, eroded 69.67 0.0379

Fayette silt loam, 5 to 10 percent slopes, eroded 2923.10 1.5919

Fayette silty clay loam, 10 to 18 percent slopes, severely eroded 8.12 0.0044

Harrison silt loam, 2 to 5 percent slopes 51.26 0.0279

Harrison silt loam, 5 to 10 percent slopes, eroded 3835.02 2.0885

Hartsburg silty clay loam 910.51 0.4958

Hartsburg silty clay loam, 0 to 2 percent slopes 4806.44 2.6175

Hickory clay loam, 10 to 18 percent slopes, severely eroded 95.72 0.0521

Hickory loam, 10 to 18 percent slopes, eroded 287.56 0.1566

Hickory silt loam, 10 to 18 percent slopes 251.12 0.1368

Hickory silt loam, 18 to 35 percent slopes 758.62 0.4131

Huntsville silt loam, 0 to 2 percent slopes, frequently flooded 17.61 0.0096

Ipava silt loam, 0 to 2 percent slopes 65834.49 35.8525

Ipava silt loam, 2 to 5 percent slopes 316.88 0.1726

Keller silt loam, 2 to 5 percent slopes 32.23 0.0175

Kendall silt loam, 0 to 2 percent slopes, rarely flooded 162.23 0.0884

Keomah silt loam, 0 to 2 percent slopes 2618.66 1.4261

Landfills 49.61 0.0270

Lawson silt loam 15.47 0.0084

Lawson silt loam, 0 to 2 percent slopes, frequently flooded 2559.12 1.3937

SSURGO Soils Appendix A Lake Springfield and Sugar Creek

Watershed

Description Acres Percent

Marseilles silt loam, 35 to 60 percent slopes 121.86 0.0664

Navlys silt loam, 10 to 18 percent slopes, eroded 14.85 0.0081

Navlys silt loam, 5 to 10 percent slopes, eroded 169.58 0.0924

Navlys silty clay loam, 10 to 18 percent slopes, severely eroded 9.34 0.0051

Orthents, silty, rolling 37.70 0.0205

Osco silt loam, 2 to 5 percent slopes 15188.19 8.2713

Osco silt loam, 5 to 10 percent slopes, eroded 667.65 0.3636

Plano silt loam, 2 to 5 percent slopes 14.56 0.0079

Proctor silt loam, 0 to 2 percent slopes, rarely flooded 296.74 0.1616

Radford silt loam, 0 to 2 percent slopes, frequently flooded 1629.18 0.8872

Rozetta silt loam, 2 to 5 percent slopes 7125.47 3.8804

Sable silty clay loam 3269.27 1.7804

Sable silty clay loam, 0 to 2 percent slopes 10750.66 5.8547

Sawmill silty clay loam, 0 to 2 percent slopes, frequently flooded 2835.69 1.5443

Shiloh silty clay loam, 0 to 2 percent slopes 145.12 0.0790

Spaulding silty clay loam, 0 to 2 percent slopes 155.12 0.0845

Tama silt loam, 2 to 5 percent slopes 763.91 0.4160

Tama silt loam, 5 to 10 percent slopes, eroded 149.47 0.0814

Tice silty clay loam, 0 to 2 percent slopes, frequently flooded 859.56 0.4681

Urban land 536.00 0.2919

Vesser silt loam, 0 to 2 percent slopes, occasionally flooded 32.95 0.0179

Virden silty clay loam 1011.16 0.5507

Virden silty clay loam, 0 to 2 percent slopes 27787.86 15.1329

Water 4551.09 2.4785

Worthen silt loam, 0 to 2 percent slopes, rarely flooded 93.85 0.0511

Zook silty clay loam, 0 to 2 percent slopes, frequently flooded 35.94 0.0196

Grand Total 183625.93 100.0000

Appendix B

Historical Water Quality Data

Historical Water Quality Data Appendix B Lake Springfield and Sugar Creek

Watershed

Segment Station Date Time Parameter Type Result Units Depth

Sugar Creek 5576190 1980-03-31 17:00 Boron 30 µg/L




Sugar Creek 5576250 1980-01-17 10:00 Boron Total Recoverable 650 µg/L

Sugar Creek 5576250 1980-02-07 10:00 Boron Total 550 µg/L




Sugar Creek 5576250 1980-05-20 11:00 Boron Dissolved 980 µg/L

























































Watershed




































































Watershed



























Sugar Creek 5576250 1988-11-03 12:00 Boron total digestion 5560 µg/L

Sugar Creek 5576250 1988-11-03 12:00 Boron total digestion 5540 µg/L

Sugar Creek 5576250 1988-12-01 12:00 Boron wet sieved (native water) 1940 µg/L







































Watershed




































































Watershed

































Sugar Creek EOA 01 1999-01-27 7:45 BORON,Dissolved ug/l 250

Sugar Creek EOA 01 1999-01-27 7:45 BORON,Total ug/l 260


































Watershed




































Sugar Creek EOA-01 2003-01-30 0:00 Boron Dissolved 9900 ug/l

Sugar Creek EOA-01 2003-01-30 0:00 Boron Total 9800 ug/l

Sugar Creek EOA-01 2003-01-30 10:30 Boron,Total,ug/l 9800 ug/l

Sugar Creek EOA-01 2003-01-30 10:30 Boron,Dissolved,ug/l 9900 ug/l












Sugar Creek EOA-01 2003-05-22 10:15 Boron,Total,ug/l 1200 mg/l

















Watershed


Sugar Creek EOA-01 2003-11-06 9:30 Boron,Dissolved,ug/l 8600




Sugar Creek EOA-01 2003-12-11 10:00 Boron,Total,ug/l 920
























Sugar Creek EOA-01 2004-08-31 10:00 Boron,Dissolved,ug/l 13000 mg/l















Sugar Creek EOA-01 2005-02-09 9:45 Boron,Dissolved,ug/l 310 umho/cm




Sugar Creek EOA-01 2005-03-17 12:00 Boron,Total,ug/l 450 umho/cm



















Watershed
















Sugar Creek EOA-01 2005-12-28 10:15 Boron,Total,ug/l 10000























Sugar Creek EOA-01 2008-07-25 10:30 Boron Dissolved 1970 ug/l 1 ft

Sugar Creek EOA-01 2008-07-25 10:30 Boron Total 1990 ug/l 1 ft



Sugar Creek EOA-04 2003-06-04 0:00 Phosphorus Dissolved 0.24 mg/l

Sugar Creek EOA-04 2003-06-04 0:00 Phosphorus Total 0.33 mg/l





Sugar Creek EOA-04 2008-05-20 13:45 Phosphorus as P Dissolved 0.092 mg/l

Sugar Creek EOA-04 2008-05-20 13:45 Phosphorus as P Total 0.132 mg/l

Sugar Creek EOA-04 2008-08-25 8:15 Phosphorus as P Dissolved 0.596 mg/l 1 ft

Sugar Creek EOA-04 2008-08-25 8:15 Phosphorus as P Total 0.656 mg/l 1 ft

Sugar Creek EOA-04 2008-10-16 9:00 Phosphorus as P Dissolved 0.563 mg/l 1 ft

Sugar Creek EOA-04 2008-10-16 9:00 Phosphorus as P Total 0.423 mg/l 1 ft

Springfield Lake REF-1 2000-05-24 Phosphorus Total 0.196 mg/l 1 ft






Springfield Lake REF-1 2001-05-01 Phosphorus Total 0.149 mg/L 1 ft

Springfield Lake REF-1 2001-06-07 0:00 Phosphate-phosphorus as P Total 0.206 mg/l 1 ft

Springfield Lake REF-1 2001-06-07 12:05 Phosphorus as P Total 0.206 mg/l 1 ft





Watershed



Springfield Lake REF-1 2001-09-12 13:20 Phosphorus as P Total 0.546 mg/l












Springfield Lake REF-1 2002-06-03 0:00 Phosphate-phosphorus as P Total 0.281 mg/l






Springfield Lake REF-1 2002-06-06 Phosphorus Total 0.260




Springfield Lake REF-1 2002-07-01 0:00 Phosphate-phosphorus as P Total 1090 mg/kg 18 ft





Springfield Lake REF-1 2002-07-01 10:35 Phosphorus as P Total 1090 mg/kg 10 ft





















Springfield Lake REF-1 2003-05-13 Phosphorus Total KK 21 ft












Springfield Lake REF-1 2003-06-11 Phosphorus Total .229Q 19 ft





Watershed




































































Watershed


Springfield Lake REF-1 2003-10-22 Phosphorus Total 0.250 21 ft






































Springfield Lake REF-1 2005-07-21 8:15 Phosphorus as P 1104 mg/kg 17 ft

Springfield Lake REF-1 2005-08-26 0:00 Phosphate-phosphorus as P Total 733 ug/l 17 ft






Springfield Lake REF-1 2005-08-26 08:30 Phosphorus as P Total 939 ug/l 17 ft












Springfield Lake REF-1 2009-05-28 Phosphorus as P 0.088 mg/l 19 ft









Watershed



Springfield Lake REF-1 2011-07-06 Phosphorus as P 0.228 mg/l











































Springfield Lake REF-3 2002-07-01 0:00 Phosphate-phosphorus as P Total 810 mg/kg 1 ft







Springfield Lake REF-3 2003-05-13 Phosphorus Total KK


Springfield Lake REF-3 2003-06-11 Phosphorus Total .182Q





Springfield Lake REF-3 2005-07-21 10:13 Phosphorus as P 623 mg/kg 1 ft








Watershed







Springfield Lake REF-1 2002-04-09 0:00 Phosphate-phosphorus as P Dissolved 0.013 mg/l 1 ft



















































Springfield Lake REF-1 2004-05-26 13:30 Phosphorus as P Dissolved 0.144 mg/l










Watershed












Springfield Lake REF-1 2004-10-29 9:20 Phosphorus as P Dissolved 0.108 mg/l 1 ft








Springfield Lake REF-1 2005-04-13 11:00 Phosphorus as P Dissolved mg/l 1 ft








Springfield Lake REF-1 2005-08-26 0:00 Phosphate-phosphorus as P Dissolved 629 ug/l 10 ft








































Watershed























Springfield Lake REF-1 2005-08-26 08:30 Phosphorus as P Dissolved 736 ug/l 19 ft













































Watershed






Springfield Lake REF-1 2000-04-28 Solids, Total Suspended (TSS) 18.2 mg/l













Springfield Lake REF-1 2000-09-26 Solids, Total Suspended (TSS) 12 mg/l






Springfield Lake REF-1 2001-06-07 0:00 Solids, Total Suspended (TSS) Non-filterable 18 mg/l 1 ft











































Watershed
































































Springfield Lake REF-1 2004-07-07 9:45 Solids, Total Suspended (TSS) Total 4 mg/l




Watershed









Springfield Lake REF-1 2005-04-13 10:30 Solids, Total Suspended (TSS) Dissolved 16 mg/l 1 ft

















Springfield Lake REF-1 2005-08-26 0:00 Solids, Total Suspended (TSS) 4.5 mg/l 10 ft

Springfield Lake REF-1 2005-08-26 0:00 Solids, Total Suspended (TSS) 6 mg/l 19 ft









































Watershed










Springfield Lake REF-1 2009-05-28 Solids, Total Suspended (TSS) 10.5 mg/l 1 ft






Springfield Lake REF-1 2009-07-23 Solids, Total Suspended (TSS) 9 mg/l 1 ft




















































Watershed




































































Watershed




































Springfield Lake REF-3 2004-08-10 14:05 Solids, Total Suspended (TSS) 34 mg/l



Springfield Lake REF-3 2004-09-16 13:55 Solids, Total Suspended (TSS) 29 mg/l





























Watershed




































































Watershed























































Springfield Lake REF-1 2000-05-24 Chlorophyll a (Corrected) 30.7 µg/L





Springfield Lake REF-1 2000-10-24 Chlorophyll a (Corrected) 93 µg/L

Springfield Lake REF-1 2001-05-01 0:00 Chlorophyll a 151 ug/l 4 ft



Springfield Lake REF-1 2001-06-07 0:00 Chlorophyll a 30.8 ug/l 3 ft




Watershed












Springfield Lake REF-1 2002-05-09 0:00 Chlorophyll a 45 ug/l 2.7 ft

Springfield Lake REF-1 2002-05-09 0:00 Chlorophyll a 35.6 ug/l 2.7 ft

Springfield Lake REF-1 2002-05-09 Chlorophyll a (corrected) 35.60









































Springfield Lake REF-1 2004-05-11 0:00 Chlorophyll a, corrected for pheophytin Total 35.8 ug/l 5 ft



Springfield Lake REF-1 2005-04-13 10:30 Chlorophyll a, corrected for pheophytin Total 43 ug/l 3 ft






Springfield Lake REF-1 2009-05-28 Chlorophyll a, corrected for pheophytin 86.1 ug/l 4 ft




Watershed










Springfield Lake REF-1 2011-05-03 Chlorophyll a (corrected) 50.10 µg/L

Springfield Lake REF-1 2011-06-09 Chlorophyll a, corrected for pheophytin 66 ug/l 5 ft








Springfield Lake REF-1 2001-05-01 15:00 Chlorophyll a, corrected for pheophytin 151 ug/l 4 ft

Springfield Lake REF-1 2001-06-07 12:05 Chlorophyll a, corrected for pheophytin 27.2 ug/l 3 ft




Springfield Lake REF-1 2002-05-09 13:45 Chlorophyll a, corrected for pheophytin 35.6 ug/l 2.7 ft












































Watershed




































































Watershed






























Springfield Lake REF-3 2002-07-09 10:30 Chlorophyll a, corrected for pheophytin 106 ug/l 3.7 ft













Springfield Lake REF-1 2002-04-09 0:00 Depth, bottom 20 ft 1 ft







Springfield Lake REF-1 2003-07-23 0:00 Depth, bottom 23.5 ft 9 ft




Springfield Lake REF-1 2004-10-29 9:20 Depth, bottom Dissolved 24 ft 1 ft








Springfield Lake REF-1 2005-08-26 8:30 Depth, bottom Total 21 ft 10 ft

Springfield Lake REF-1 2005-10-07 8:30 Depth, bottom Total 20 ft 10 ft





Watershed






Springfield Lake REF-1 2003-07-23 11:30 Depth, bottom 23.5 ft 21 ft


























Springfield Lake REF-1 2000-05-10 Dissolved Oxygen 8.3 mg/L 0



















Springfield Lake REF-1 2000-05-24 Dissolved Oxygen 7 mg/L 11

















Watershed




































































Watershed


















Springfield Lake REF-1 2001-04-04 Dissolved Oxygen 13.9 0

Springfield Lake REF-1 2001-04-04 Dissolved Oxygen 13 1

















































Watershed




































































Watershed































Springfield Lake REF-1 2012-10-24 Dissolved Oxygen 7.48 0.05





































Watershed




































































Watershed






































Springfield Lake REF-2 2012-10-24 Dissolved Oxygen 8 7.1






























Watershed




































































Watershed

















Springfield Lake REF-2 5/22/201 Dissolved Oxygen 8.4 0



















































Watershed




































































Watershed



























Springfield Lake REF-5 2007-06-11 Dissolved Oxygen 5.5









































Watershed




































































Watershed


















Springfield Lake REF-1 2000-05-10 Temperature 24 Deg C 0

Springfield Lake REF-1 2000-05-10 Temperature 23.5 Deg C 5

















































Watershed






















































Springfield Lake REF-1 2001-04-04 Temperature 13.7 0














Watershed










Springfield Lake REF-1 2001-05-24 Temperature 22 3


























































Watershed




































































Watershed


Springfield Lake REF-1 2012-10-24 Temperature 18.58 0.05


































































Watershed




























































Springfield Lake REF-1 2013-10-28 Temperature 14 9.34








Watershed




































































Watershed













































Springfield Lake REF-2 5/22/201 Temperature 23.25 0























Watershed



































































Appendix CBATHTUB Model Files

Appendix ELRS Calculations

D

LRS Calculations Appendix D Springfield Lake and Sugar Creek Watershed

Table 8-8 LRS Summary for TSS in Lake Springfield (REF).

Location

Target Concentration

(mg/L)

Existing Concentration1

(mg/L)

Average Overland and

Tributary Flow (cfs)

Target Loading Capacity (lbs/day)

Actual Load1

(lbs/day)

Percent Reduction

Needed (%)

REF-1 19 19.3 7.6 779 789 1.3%

REF-2 19 26.5 7.1 726 1,011 28.2%

REF-3 19 41.2 3.5 363 786 53.8%

REF-5 19 53.4 120.4 12,336 34,670 64.4%

REF-6 19 47.8 74.9 7,672 19,298 60.2%

Lake Total 19 41.0 213.6 21,876 47,206 53.7% 1 Existing Concentration was calculated using the 90th percentile of observed TSS concentrations in a given location (EPA 2007)

Maximum Load reduction is 81.4% for REF-3, overall 40.6% reduction targeted.

Avg Flow (cfs)

LRS Target (mg/L) L/CF sec/day mg/lb


Lake Total 213.6 19 28.3 86,400 453,592 21,876

Table 8-8 LRS Summary for TSS in Lake Springfield (REF).

Location Target Concentration (mg/L) Existing Concentration1 (mg/L) Percent Reduction Needed (%)

REF-1 19 19.3 1.3%

REF-2 19 26.5 28.2%

REF-3 19 41.2 53.8%

REF-5 19 53.4 64.4%

REF-6 19 47.8 60.2%

Lake Total 19 41.0 53.7% 1 Existing Concentration was calculated using the 90th percentile of observed TSS concentrations in a given location (EPA 2007)

Location Acres Percent Flow

LRS Target (mg/L) L/CF sec/day mg/lb


REF-1 6,091 3.6% 7.6 19 28.3 86,400 453,592 779

REF-2 5,680 3.3% 7.1 19 28.3 86,400 453,592 726

REF-3 2,839 1.7% 3.5 19 28.3 86,400 453,592 363

REF-5 96,498 56.4% 120.4 19 28.3 86,400 453,592 12,336

REF-6 60,016 35.1% 74.9 19 28.3 86,400 453,592 7,672

Lake Total 171,123 100% 213.6 19 28.3 86,400 453,592 21,876

Appendix E Responsiveness Summary

Responsiveness Summary

Lake Springfield and Sugar Creek Watershed Total Maximum Daily Load

This responsiveness summary responds to substantive questions and comments received during the first public comment period from March 27, 2014 through April 28, 2014 postmarked, including those from the second public meeting from March 27, 2017 through April 8, 2017 post marked, is discussed below.

What is a TMDL?

A Total Maximum Daily Load (TMDL) is the sum of the allowable amount of a pollutant that a water body can receive from all contributing sources and still meet water quality standards or designated uses. The Lake Springfield and Sugar Creek TMDL Watershed report contains a plan detailing the actions necessary to reduce pollutant loads to the impaired water bodies and ensure compliance with applicable water quality standards. The Illinois EPA implements the TMDL program in accordance with Section 303(d) of the federal Clean Water Act and regulations there under.

Background

The Lake Springfield and Sugar Creek TMDL Watershed is located in Central Illinois in Sangamon, Morgan, and Macoupin Counties. There are three waterbody segments and one lake that have TMDL/LRS allocations developed. The Clean Water Act and USEPA regulations require that states develop TMDLs for waters on the Section 303(d) List. Illinois EPA is currently developing TMDLs for pollutants that have numeric water quality standards and for waterbody segments that do not have water quality standards and at this time Illinois EPA has developed a load reduction strategy. The lake is impaired mainly due to elevated levels of phosphorus and total suspended solids and a TMDL has been developed for total phosphorus. The streams are impaired due to total phosphorus, total suspended solids, sedimentation and siltation.

Public Meetings

The first public meeting was held at Lincoln Land Community College (Trutter Center), 5250 Shepherd Road, Springfield, Illinois on March 27, 2014 at 3:00pm. All comments from the first public meeting have been incorporated into the final draft report. An additional public meeting was held at Lake Springfield Beach House, 240 Long Bay Drive, Springfield, Illinois, on March 7, 2017. There were approximately 40 attendees at the second public meeting and the meeting record remained open until midnight, April 8, 2017. The Illinois EPA provided public notice for all meetings. This notice gave the date, time, location, and purpose of the meeting. The notice also provided references to obtain additional information about this specific site, the TMDL Program and other related issues. The draft TMDL Report was available for review at the Village of Chatham Public Library, the Village of Auburn Public Library, and City Water Light & Power (CWLP) – Property Management Center (200 East Lake Shore Drive) during business hours, and also on the Agency’s web page at http://www.epa.state.il.us/water/tmdl. The public review comments and the responses are presented below:

Responsiveness Summary Appendix E Lake Springfield and Sugar Creek Watershed


Questions & Comments

1. Loading from septic systems are not quantified; please revise report to include a realisticestimate of the loading from the estimated 1500 systems in the watershed.

Response

Based on information from Springfield CWLP a total of 431 septic systems exist near the margins of Lake Springfield (CWLP) as discussed in Section 5.4.3 of the draft final TMDL report -Typical TP loads for residential septic systems are cited in the literature as approximately 1-2.7 g/person/year (USEPA 2002). This equates to an estimated 3.8-10.3 lbs/day (Median of 7.0 lbs/day) of total phosphorus entering the Lake from septic systems, which is implicitly included in the LA. Additional text has been added in Section 7.2.1 to clarify potential septic loads.

No verified data is available regarding the estimated number of septic systems throughout the watershed (1500 - source unverified), however, the geographic range of influence for TP loads from septic systems is typically considered quite small with TP loads not extending more than a few hundred feet from the source (USEPA 2002). Often only failing systems are included as sources of TP, but little data exist on failing systems within proximity of the lake. Estimates included in the TMDL study is based on all the septic systems reported to be in relative proximity to the lake.

2. Since a septic tank is an end-of-pipe pollution control device for distributing the effluent,please explain why the State of Illinois does not require NPDES permits. Why doesn’tIEPA require all systems around the lake perimeter (especially the open systems) todischarge into the SMSD system?

Response

The Illinois Department of Public Health administers the septic system permitting process that serves individual home/business, and the discharge from such facilities are covered under the Septic System General Permit administered by USEPA.

The Sangamon County Water Reclamation District (SCWRD) and the Springfield CWLP have ongoing programs in-place to eliminate septic systems around Lake Springfield. Each entity provides a maximum of $5,000 towards the installation of a private septic tank effluent pump (STEP) system to pump sanitary sewage from septic systems serving individual homes and businesses to SCWRD collection system in proximity to Lake Springfield. As of April 2014, there are 27 individual private septic tank effluent pumps that have been installed or permitted for installation under this program.

3. Revise Tables showing costs of proposed BMP’s to show both initial costs and annualmaintenance costs.

allison.ristau

Inserted Text


Response

Maintenance costs are highly variable based on selected BMP and specific application. Maintenance is discussed in the implementation plan where applicable. The Tables in Section 9 of the report show cost/payment schedule per EQIP or other program guidelines. Additional cost clarification has been added to Section 9.12

4. Proposed monitoring appears to fall far short of what is needed to support the adaptivemanagement strategy that is proposed. Provide evidence in final draft that the proposedmonitoring plan will provide sufficient data on system response, to inform successivemanagement actions.

Response

As watershed based plans are developed, monitoring becomes an integral part of the project. The watershed workgroup in consultation with IEPA will determine further monitoring needs to gather information before and after implementation plans to support and make decisions for adaptive management strategies.

5. 8.3.1.4 CWLP has told regulators in 401/404 permit applications and EIS documents thatwater will be transferred from Hunter Lake to Lake Springfield when water levels droponly 1 foot or less below full pool. Explain what impacts such pumping scenarios wouldhave on the narrative and results of this TMDL document.

Response

The estimate for the volume of water transferred from a proposed Hunter Lake to Lake Springfield was provided by the Springfield CWLP and is included in the load capacity analysis. The proposed lake is expected to meet 0.05 mg/L TP WQS for lakes which was used to model the TP load. The impact of the one-foot or less below full pool transfer is inherent to the volume estimates provided. Any additional possible impact of this pumping on the Lake Springfield modeling inputs are not expected to be significant on the temporal scale of the model output.

6. 8.3.1.5 Why are phosphorus discharges from POTWs not monitored. Why doesn’t IEPArequire it?

Response

Illinois EPA continues to include TP monitoring requirements for major facilities (1.0 MGD and above) and for facilities that discharge to phosphorus impaired waterbody segments upon renewal of the NPDES permit. Currently the Agency doesn’t require minor facilities not discharging to a TP impaired waterbody to monitor. However, the Agency does encourage such monitoring for future data needs and will require monitoring for the facilities covered in the TMDL during the next NPDES permit renewal.


7. 8.3.2.3 Please provide scientific basis for 19 mg/l target.

Response

As part of the TMDL development process the Agency started to include Load Reduction Strategy (LRS) in TMDL watershed projects since 2012 for those pollutants that currently do not have numeric water quality standards. Developing an LRS involves determining the loading capacity and load reduction necessary that is needed for the water body to meet “Full Use Support” for its designated uses. The load capacity is not divided into WLA, LA, or MOS, these are represented by one number as a target concentration for load reduction within each unique watershed. The LRS for this watershed is only for two parameters (Total Phosphorus and Total Suspended Solids); all other parameters such as Sedimentation/Siltation and Turbidity will be addressed separately. The Load Reduction Strategy provides guidance (with no regulatory requirements) for voluntary nonpoint source reduction efforts by implementing agricultural and urban stormwater best management practices (BMPs). The Load Reduction Strategy target of 19 mg/L was derived from stream segments that fully supported their designated uses (data 1999 through 2013). This includes data from the Illinois EPA’s Surface Water Section’s ambient monitoring, intensive basin surveys, and special studies. The pollutants (or parameters) for which data were compiled are Total Phosphorus (TP), and Total Suspended Solids (TSS). Mathematical operations were kept to a minimum in-order to establish targets which are as accurate and relevant as possible to help stakeholders with target endpoints when developing watershed plans and BMPs in the watershed. This data underwent a quality control check and carefully discriminated against any data that did not pass all the rigorous quality assurance checks. Only the data that passed all checks was used to calculate the targets in this strategy.

8. 8.3.5 Please provide evidence supporting the assertion “…likely result in elimination ofexcess algae growth in the lake”, and the baseline from which excess would be measured.

Response

Text has been added to clarify Section 8.3.5.

9. Section 9.5. Explain more clearly how phosphorus loads from internal cycling can bereduced to the required extent.

Response

Text has been added to clarify Section 9.6.2.

10. Section 9.6.1 In the final version, include commitment to require P monitoring from allpoint sources, or explain why such a commitment is not being made.


Response

Please refer to response #6 above.

Text has been added to clarify Section 9.6.1. to strengthen the recommendation, that requirements for NPDES permits must be addressed by the Agency’s DWPC/Permit Section upon NPDES Permit renewal.

11. Section 9.9. The actions taken during the last few decades have utterly failed tosignificantly improve water quality. Citing such actions fails to provide reasonableassurance of future compliance. In the final draft, please provide information on actualcommitments that extend into the future (e.g. expiration dates for each of the grants,subsidies, and CREP and other contracts that were cited). Quantify the extent to whichpast trends would need to be scaled up in-order to reach target reductions.

Response

Text has been added in Section 9.9. – directing the reader to Lake Springfield Watershed Management Plan for more details.

12. Section 9.9. Simply citing activities conducted in the past proves nothing. To lendcredibility to the estimated costs of future actions, the costs of all past actions cited shouldalso be provided.

Response

Documenting past activities and success stories helps watershed workgroups to take adaptive management approach for future projects. Text has been added in Section 9.9. - directing the reader to Lake Springfield Watershed Management Plan for more details.

13. Section. 9.9 This entire section implies that the cost of compliance should fall primarily onthe taxpayers, not on the lake owner. In the final draft please clarify that State of Illinoishas the power to enact legislation to control agricultural runoff, but has failed to do so.Also, clarify that the lake owner has the power to increase water rates to dredge the lakeand to operate a maintenance program that removes sediment that enters the lake.

Response

Text has been added regarding CWLPs funding potential as lake owners to Section 9.11.

14. Section 9.13.3. Does the City intend to make an actual commitment to meeting the 10 and25 year milestones?


Response

The forthcoming Lake Springfield Watershed Management Plan will provide detail on projects and parties involved and will demonstrates the local commitment for addressing water quality issues in the watershed.

15. We understand that the WLA of 0.31 lbs/day of TP assigned to the village of Chatham willbe mandated, enforced as a special condition in the village’s MS4 permit, and not avoluntary target or goal as with the majority of the watershed being agricultural andtherefore exempt from this requirement.

Response

That is correct. The MS4 WLA will be referenced in the Special Condition language and therefore will be the permit limit.

16. Section 5.1.1.2 – Total phosphorus in Sugar Creek there is no numeric water qualitystandard (WQS) for TP for streams in Illinois. IEPA set a target of 0.739 mg/L for the LakeSpringfield watershed because the WQS for reservoirs is 0.05 mg/L. How can a mandatedTP concentration be imposed on Chatham when there is no rule promulgated by the IllinoisPollution Control Board regulating TP in streams?

Response

The WLA for TP applied to the MS4 permit for the Village of Chatham is a result of the MS4 system discharging to Lake Springfield and/or its tributaries and is intended to address the in-lake numeric WQS of 0.05 mg/L for TP and not the LRS target value for TP in streams.

17. We disagree with the conclusion that there were no data gaps in the Stage 1 report.

Response

The TMDL consultant who has significant experience in developing USEPA approved TMDLs has evaluated all relevant information for the TMDL study and concluded that sufficient data was available to run the models.

18. It is not evident in the report that testing was performed immediately upstream ordownstream of the village corporate limits to properly assess a WLA for TP specific to thewatershed within the village.

Response

Testing or sampling was not performed at locations upstream or downstream of the municipal boundary. As discussed in the report, allocations for MS4 permits were calculated as a proportion of the contributing watershed included within the municipal boundary.


19. Considering the burdensome implications of imposing the 0.31 lbs/day TP WLA onChatham, we believe a more detailed study should be performed that includes TP datacollection within the Chatham portion of the Lake Springfield watershed to better calibratethe BATHTUB model.

Response

Such a study would lend confidence to the BATHTUB calibration; however, the collection of sufficient data would require a significant effort with involving sampling under a variety of flow conditions at various times of year. A study of this nature is beyond the current scope of this TMDL project, but may be beneficial as a precursor to any changes to the Village of Chatham’s MS4 General Permit monitoring program.

20. We object to the TMDL calculations that provide a reserve capacity for an additional 5.8lbs/day coming into Lake Springfield from the proposed Hunter Lake. Any additionalphosphorus loading to the lake would be an aggravation of pollution already in the lakeand is not allowed under the Clean Water Act which forbids issuance of NPDES permitsthat fail to ensure compliance with water quality standards. Illinois EPA v. Illinois Pollution

Control Board, 386 Ill. App. 3d 375 (2008), Ala. Dept. of Env. Mgmt. v. Ala. Rivers

Alliance, Inc., 14 So. 3d 853, 864, 866–68 (Ala. Civ. App. 2007)Proposing a source of new phosphorus pollution to the lake makes no sense when the draftTMDL states both an 86% decrease in internal phosphorus loading in the lake and a 96%reduction in external phosphorus loading are needed if the phosphorus water qualitystandard is to be met.

Response

USEPA directs IEPA to include Reserve Capacity in load capacity analysis where potential new sources are known, in-order to account for future potential contributions from point sources (new and expanded plants). The proposed Hunter Lake diversion project does not meet the traditional definition of a wastewater treatment plant improvement requiring an NPDES Permit, although the load would be considered a new source of phosphorus. The draft report is taking a conservative approach for including the TP load for future actions that may or may not happen. The TMDL report acknowledges this, and based on discussion with USEPA “reopener language” is included in the report. If the diversion project proceeds the TMDL may be reopened to recalculate the load capacity analysis should the load contribution from the project is higher than the original estimated load (please refer to Section 8.3.1.4 – Reserve Capacity).

21. We also do understand why the proposed TMDL calls for no reductions in phosphorusloading from wastewater treatment facilities contributory to the lake. This makes no sensewhen the aim of the TMDL is to also reduce aquatic algae in the lake. As Table 8-2identifies, loading from wastewater treatment facilities is likely to be a high source ofphosphorus under low flow conditions. It is summer low flow months when algal growthis likely to be highest. Relying solely on phosphorus reductions from non-point sources islikely to be of little help in reducing summer algae blooms. Reductions in phosphorus from


wastewater treatment facilities will be needed. The final TMDL should take this seasonal factor into account in considering the necessary load reductions.

Failure to require reductions from wastewater treatment facilities clearly renders the TMDL incapable of providing reasonable and is an improper wasteload allocation. 40 CFR §§130.2 (i), 130.7. Am. Farm Bureau Fed'n v. United States EPA, 792 F.3d 281 (3d Cir. 2015)

Response

In-order to estimate total phosphorus loading for each POTW, the average total phosphorus concentration from all wastewater treatment plants (WWTP) was calculated for all available effluent data in the watershed. Based on a review of effluent data from similar WWTPs in the region, the estimated effluent concentration of 2.425 mg/L input into the model for each WWTP is within a reasonable range of expected phosphorus concentrations from small treatment plants particularly lagoon systems. During the next cycle of NPDES Permit renewal, the Agency will require NPDES Permittees to monitor for total phosphorus. If the wastewater treatment plants are not able to meet the concentration and the WLA, Permittees will be required to install additional treatment or modify their existing treatment process.

22. We disagree with the approach the Agency has taken to set a target phosphorus level forSugar Creek. As we understand from the discussion on this topic at the March 7, 2017public meeting, the Agency developed the number of 0.739 mg/L phosphorus by takingthe average of the levels of phosphorus from unimpaired streams nearby. This approachis problematic for a number of reasons. First if any measurements were taken in nearbystreams after a storm event, the values you included in your calculations likely containresults with atypically high phosphorus levels. The median value would be a much betternumber to use. The value the Agency obtained is much higher than either the median(0.200 mg/L phosphorus) or average (0.379 mg/L phosphorus) level of phosphorus thatthe Illinois EPA calculated for all streams in Illinois. See Table 3-1 in IEPA/BOW/99-020report Baseline Loading of Nitrogen, Phosphorus, and Sediments from Illinois Watersheds

(Find at www.epa.state.il.us/water/water-quality/baseline-load-report-final-1999.pdf )Further, it is doubtful that adequate monitoring would confirm that these nearby watersare actually unimpaired.

In addition, the number is significantly higher than water quality standards for phosphorus in streams that have been adopted by other states in the Midwest. Wisconsin has adopted standards of 0.075 mg/L phosphorus for streams and 0.1 mg/L phosphorus for rivers. (See http://docs.legis.wisconsin.gov/code/admin code/nr/100/102/) Minnesota has adopted a phosphorus standard of 0.15 mg/l for streams in the southern region of the state. (See https://www.revisor.mn.gov/rules/?id=7050.0222).


Response

Please refer to response No.7, as the methodology used in selecting the target number is similar. Illinois does not have water quality criteria for nutrients at the present time, and the proposed LRS target numbers are only recommended to be used as targets for voluntary planning and implementation activities until such time nutrient water quality criteria become available. The Illinois Nutrient Loss Reduction Strategy – Science Advisory Board is working on developing nutrient criteria (report expected early 2018).

23. We understand that the Sangamon Soil & Water Conservation District (SWCD) is workingwith Northwater Consulting under a 319 grant to determine the most strategic placeswithin the Lake Springfield watershed to install best management practices to reducephosphorus and total suspended solids runoff. We applaud the work of the SangamonSWCD and its partners in the Lake Springfield Watershed Project in developing the Lake.Lake Springfield Watershed Management Plan. However, it is the Agency’s responsibilityto make sure that the proposed TMDL meets the reasonable assurance requirement.

As described below, the TMDL must include a demonstration that the load allocations in the TMDL will be implemented:

Reasonable assurance. Reasonable assurance means that you demonstrate that each wasteload allocation and load allocation in a TMDL will be implemented. For point sources regulated under section 402 of the Clean Water Act you must demonstrate reasonable assurance by procedures that ensure that enforceable National Pollutant Discharge Elimination System (NPDES) permits (including coverage to individual sources under a general NPDES permit) will be issued expeditiously to implement applicable wasteload allocations for point sources. For nonpoint sources, you must demonstrate reasonable assurance by specific procedures and mechanisms that ensure load allocations for nonpoint sources will be implemented for that waterbody. Specific procedures and mechanisms for nonpoint sources must apply to the pollutant for which the TMDL is being established, must be implemented expeditiously and must be supported by adequate funding. Examples of specific procedures and mechanisms which may provide reasonable assurance for nonpoint sources include State, Territorial, and authorized Tribal regulations, local ordinances, performance bonds, contracts, cost-share agreements, memorandums of understanding, site-specific or watershed-specific voluntary actions, and compliance audits of best management practices. (See https://www3.epa.gov/region6/water/npdes/tmdl/definitions.htm) Section 9 provides a good history of management efforts undertaken in the watershed and lists of many practices that could be undertaken to reduce pollution, but fails to include the procedures and mechanisms described above that are needed to provide reasonable assurance that the TMDL will be implemented. The Agency should work with the members of the Lake Springfield group to develop the required assurances before the TMDL is finalized.


Response

We agree, USEPA requires reasonable assurance that TMDLs will be achieved and WQS will be met. Reasonable assurance that the WLAs will be implemented is provided by regulatory actions. Per 40 CFR 122.44(d) (1) (vii) (B), NPDES permit effluent limits must be consistent with assumptions and requirements of all WLAs in an approved TMDL. IEPA implements its Municipal Separate Storm Sewer (MS4) and NPDES permit programs and is responsible for making the effluent limits consistent with the WLAs in the TMDL. Effluent from wastewater treatment plants and in-stream monitoring (as required by NPDES Permit) is reported to IEPA and should provide reasonable assurance that WQS will be met.

In addition, the Sangamon County Water Reclamation District is expanding its Sugar Creek Water Reclamation Plant that discharges to Sugar Creek downstream of Lake Springfield, to include Biological Nutrient Removal Treatment Process and upon completion of the expansion the plant will be discharging less phosphorus than the current level being discharged to the receiving stream.

As to compliance with the load allocation, this is a voluntary program, and the Agency is confident in the successful completion and future implementation of Lake Springfield Watershed Management Plan to provide Reasonable Assurance that the Load Allocation will be achieved. The past success of the watershed group supports this approach, and the Agency is encouraging stakeholders to take advantage of Section 319 cost-share funding program and other available resources to implement best management practices (BMPs) identified in the Implementation Plan.

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