HomeMy WebLinkAbout030984 RES - 10/18/2016 Resolution by the City Council of the City of Corpus Christi supporting the
Implementation Plan for improved water quality, to reduce bacteria, developed
by the Cole and Ropes Parks' Coordination Committee (CARP) for Cole and
Ropes Park Beaches located in Corpus Christi Bay and the Louisiana Parkway
Watershed (Watershed) in Corpus Christi, Texas.
WHEREAS, the City of Corpus Christi is a coastal city valuing its shoreline for aesthetic,
economic, recreation, and public health reasons; and
WHEREAS, in 2012 the City of Corpus Christi was invited to participate as a stakeholder in
water quality restoration planning for Cole and Ropes Park Beaches: and
WHEREAS, the CARP Coordination Committee, a twelve-member stakeholder committee, was
formed and elected at a public meeting held in 2012, representing thousands of basin
stakeholders, including interests in business, tourism, recreation, environmental resources,
public health and safety, academia, and home ownership, as well as three staff representatives
from the City of Corpus Christi, and was facilitated by the Coastal Bend Bays Foundation and
the Center for Coastal Studies, Texas A&M University— Corpus Christi, on behalf of the Texas
Commission on Environmental Quality(TCEQ); and
WHEREAS, the aforesaid "Watershed" stakeholders and entities represented in the CARP
Coordination Committee,along with the Texas Commission on Environmental Quality(TCEQ),
and the U.S. Environmental Protection Agency (EPA) have worked together to plan and
implement voluntary and mandatory actions appropriate to community needs to improve water
quality through common sense strategies that reflect the natural environment, recreational uses,
and economy or the region; and
WHEREAS, the TCEQ established two separate Total Maximum Daily Loads (TMDL) projects,
for bacteria, otherwise known as pollution budgets, one each, for Cole and Ropes Park; and
WHEREAS, the TMDL is a scientifically determination of how much pollutant the water body
can naturally assimilate each day and remain healthy; and
WHEREAS, the established TMDL projects will require implementation activities that will reduce
existing pollutant loads from point sources and non-point sources that the TCEQ identified
during development of the two TMDLs; and
WHEREAS, the CARP Coordination Committee and Work Group stakeholders spent thousands
of volunteer hours in meetings preparing the Implementation Plan (I-Plan)that will recommend
to TCEQ a variety of activities to remedy the high levels of bacteria in both Cole and Ropes
Park beaches, as identified in the two TMDL projects, and seeks resolutions of support from its
members, which I—Plan is attached as Exhibit A.
L► 3n93 �
INDEXED
NOW, THEREFORE, BE IT HEREBY RESOLVED BY THE CITY OF CORPUS CHRISTI:
Section 1.
That, the City supports the CARP I-Plan and pledges its participation to implement those
activities identified in the I-Plan for which it has responsibility, using those funds that have been
or may be appropriated for them.
Section 2. This Resolution shall take effect and be in full force immediately after its adoption by
the City Council.
ATTEST: THE CITY OF CORPUS CHRISTI
ebecca Huerta Nelda Martinez
City Secretary Mayor
Corpus Christi, Texas
1of nft b e) , 2016
The above resolution was passed by the following vote:
Nelda Martinez ('LL
Rudy Garza
Michael Hunter Ox
Chad Magill 0
Colleen McIntyre 3 i,(
Brian Rosas (j
64
Lucy Rubio
Mark Scott abm "1 .f
Carolyn Vaughn OGC/U
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Approved
Implementation Plan for
Two Total Maximum Daily
Loads for Bacteria at Cole
and Ropes Parks Beaches in
Corpus Christi Bay
Segments 2481CB_o3 and 2481CB_04
Water Quality Planning Division, Office of Water
TEXAS COMMISSION ON ENVIRONMENTAL QUALITY
Draft Implementation Plan for Bacteria at Cole and Ropes Parks Beaches in Corpus Christi Bay
Distributed by the
Total Maximum Daily Load Section
Texas Commission on Environmental Quality
MC-2o3
P.O.Box 13087
Austin,Texas 78711-3087
TMDL Implementation Plans are also available on the TCEQ Web site at:
www.tceq.texas.gov/implementation/water/tmdl/
The preparation of this Implementation Plan was financed in part through grants from
the U.S.Environmental Protection Agency.
And in large part on the recommendations of the
Cole and Ropes Park Coordination Committee Stakeholder Group,
Facilitated by the Center for Coastal Studies at Texas A&M University-Corpus Christi
Agencies that participated in the development of this document include:
Texas Commission on Environmental Quality
This Implementation plan is based in part on reports prepared for the TCEQ by:
• Implementation Plan for Eight Total Maximum Daily Loads for Indicator Bacteria in
Dickinson Bayou and Three Tidal Tributaries
• Implementation Plan for Seventy-Two Total Maximum Daily Loads for Bacteria in the
Houston-Galveston Region
In compliance with the Americans with Disabilities Act,this document
may be requested in alternate formats by contacting the TCEQ at
512/239-0028,Fax 239-4488,or 1-Boo-RELAY-TX(TDD),
Or by writing P.O.Box 13087,Austin,TX 78711-3087
Draft Implementation Plan for Bacteria at Cole and Ropes Parks Beaches in Corpus Christi Ba
Table Contents
Table Contents
List of Figures vi
List of Tables vii
List of Commonly Used Acronyms x
Acknowledgements xii
CARP Members xii
CARP Alternates xii
Past CARP Members xiii
Past CARP Alternates xiii
CARP Support xiii
Past CARP Support xiii
Executive Summary 1
Management Measures(Voluntary Activities) 3
Control Actions(Regulatory Activities) 4
Introduction 5
Watershed Overview 6
Figure 1. Location of Cole and Ropes Parks 7
Figure 2. Cole Park with Louisiana Parkway stormwater outfall and the Oleander Point
location. 8
Figure 3. Ropes Park and the location of the Brawner Parkway stormwater outfall. 9
Texas Beach Watch Program Bacteria Sampling 9
Summary of TMDLs 10
Pollutant Sources and Loads 10
Pollutant Load Allocation 13
Waste Load Allocation (WLA) 13
Load Allocation (LA) 15
Total Maximum Daily Load (TMDL) 15
Implementation Strategy 17
Adaptive Implementation 17
Activities and Milestones 18
Management Measures and Control Actions 19
Management Measures (Voluntary Activities) 19
Control Actions(Regulated Activities) 20
Management Measure 1.0: Education and Outreach 21
Management Measure 1.1: General Awareness 22
Management Measure 1.2: Leave It Better Than You Found It 23
Management Measure 1.3: Pet Waste Disposal 24
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Draft Implementation Plan for Bacteria at Cole and Ropes Parks Beaches in Corpus Christi Ba
Management Measure 1.4: Prevent Intentional Dumping and Disposal 25
Management Measure 1.5: Slow the Flow(Low Impact Development) Initiative 26
Management Measure 2.0: Monitoring 31
Management Measure 2.1: Continue Sampling Enterococcus Levels at Cole and Ropes Parks
31
Management Measure 2.2: Collect Rainfall Data Near Cole and Ropes Parks 33
Management Measure 2.3: Conduct Storm water Outfall Flow Sampling 34
Management Measure 3.0: Research 38
Management Measure 3.1: Evaluate Methods to Remove Bacteria with Green Infrastructure39
Management Measure 3.2: Bacterial Source Tracking 40
Management Measure 3.3: Evaluate the Effectiveness of Public Utilities Programs and
1 Projects in Bacteria Reductions 41
Management Measure 3.4: Promote New Data Analysis Method for Regulatory Justification for
Listing Beaches on the 303(d)List 42
Management Measure 3.5: Identify Water Flow Patterns in Corpus Christi Bay at Cole and
Ropes Parks by the Use of Dye Testing 43
Management Measure 3.6: Change Sampling Date of Current Texas Beach Watch Program to
be More Protective of Public Health 44
Management Measure 4.0: Wastewater Collection Systems 50
Management Measure 4.1: Enhance Existing Fats, Oil& Grease (FOG) Program 50
Management Measure 4.2: Continue the Notification System for Monitoring Sanitary Sewer
Overflows(SSOs) 51
Management Measure 4.3: Expand Collection System Line Cleaning, Inspection, Repair and
Rehabilitation 52
Management Measure 4.4: Implement an Ongoing Inflow and Infiltration Study 53
Management Measure 4.5: Conduct Hydraulic Modeling of Collection System 54
Management Measure 5.0: Stormwater Drainage System 60
Management Measure 5.1: Determine Effectiveness of Storm water Retrofits*to Remove
Bacteria 60
Management Measure 5.2: Continue the Major Outfall Assessment and Repair Program as
Funding Allows 62
Management Measure 5.3: Support and Encourage the Adoption of Stormwater Master Plan
63
Management Measure 6.0: Ordinance and Regulation 66
Management Measure 6.1: Residential Leaking/Broken Private Sewer Laterals Pre-Sale
Inspection/Testing Program 66
Management Measure 6.2: Commercial Cross-Connection Inspection Program 68
Management Measure 6.3: Commercial Leaking/Broken Sewer Laterals Pilot
Inspection/Testing Program 69
Management Measure 6.4: Improved Grease Trap Standards 71
Management Measure 6.5: Strengthen Current Animal Control Ordinances Relating to
Removal and Disposal of Pet Wastes 72
Management Measure 6.6: Implement Measures to Control Feral Cats, Rodents, and
Nuisance Animals 73
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Draft Implementation Plan for Bacteria at Cole and Ropes Parks Beaches in Corpus Christi Bay
Management Measure 6.7: Install Additional Signage 74
Management Measure 6.8: Develop Advisement Protocol to Warn the Public of Periodically
Elevated Bacteria Levels, as Anticipated by Weather Forecasts for Rain, as well as Warnings
During and Immediately After Rainfall 75
Management Measure 6.9: Restrict Access to Bay Waters from City Parks and Other Bayfront
City Properties During Periods of Public Health Risks 76
Management Measure 6.10: Adopt and Enforce Additional Ordinances 78
Management Measure 6.11: Explore Adoption of Additional "Low Impact Development"
Standards in Unified Development Code that will Reduce Volumes of Stormwater Runoff From
Areas of New Development or Significant Redevelopment 80
Control Actions 1.0: Wastewater Collection Systems 89
Control Action 1.1: Continue Existing Fats, Oil& Grease (FOG) Program 89
Control Action 1.2: Continue Monitoring Sanitary Sewer Overflows(SSOs) 90
Control Action 1.3: Continue Collection System Line Cleaning, Inspection, Repair and
Rehabilitation 91
Control Actions 2.0: Stormwater Drainage System 94
Control Action 2.1: Continue Existing Stormwater Programs 94
Control Action 2.2: Continue Drainage System Line Cleaning, Inspection, Repair and
Rehabilitation 95
Control Actions 3.0: Ordinance and Regulation 98
Control Action 3.1: Eliminate Residential Cross-Connections 98
Sustainability 103
Water Quality Indicators 103
Implementation Milestones 104
Communication Strategy 104
References 106
Appendix A. I-Plan Matrix 107
Appendix B. Load Reduction Estimates 117
Appendix C. Formal Support for the I-Plan 122
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Draft Implementation Plan for Bacteria at Cole and Ropes Parks Beaches in Corpus Christi Ba
List of Figures
Figure 1. Location of Cole and Ropes Parks 7
Figure 2. Cole Park with Louisiana Parkway stormwater outfall and the Oleander Point
location. 8
Figure 3. Ropes Park and the location of the Brawner Parkway stormwater outfall. 9
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Draft Implementation Plan for Bacteria at Cole and Ropes Parks Beaches in Corpus Christi Ba
List of Tables
Table 1. Water Quality Inventory Assessment Data 10
Table 2. Percentages of Each AU Designated as an Urbanized Area 14
Table 3. MS4 Permittees in Corpus Christi Bay at Coles and Ropes Park 14
Table 4. TMDL Allocation Summary Corpus Christi Bay at Coles and Ropes Parks (in
Billions MPN/day.) 16
Table 5. MM 1.1. General Awareness. Implementation timeline schedule. 23
Table 6. MM 1.2. Leave It Better Than You Found It. Implementation timeline schedule.
24
Table 7. MM 1.3. Pet Waste Disposal. Implementation timeline schedule. 25
Table 8. MM 1.4. Prevent Intentional Dumping and Disposal. Implementation timeline
schedule 26
Table 9. MM 1.5. Slow the Flow(Low Impact Development) Initiative. Implementation
timeline schedule. 27
Table 10. Summary of Management Measure 1.0: Education and Outreach 28
Table 11. MM 2.1. Continue sampling Enterococcus levels at Cole and Ropes Parks.
Implementation timeline schedule. 32
Table 12. MM 2.2. Collecting Rainfall Data Near Cole and Ropes Parks. Implementation
timeline schedule. 34
Table 13. MM 2.3. Conduct Stormwater Outfall Flow Sampling. Implementation timeline
schedule 35
Table 14. Summary of Management Measure 2.0: Monitoring 36
Table 15. MM 3.1. Evaluate Methods to Remove Bacteria with Green Infrastructure.
Implementation timeline schedule. 40
Table 16. MM 3.2. Bacterial Source Tracking. Implementation timeline schedule 41
Table 17. MM 3.3. Evaluate the effectiveness of Public Utilities programs and projects in
bacteria reductions. Implementation timeline schedule 42
Table 18. MM 3.4. Promote new data analysis method for regulatory justification for
listing beaches on the 303(d) list. Implementation timeline schedule. 43
Table 19. MM 3.5. Identify water flow patterns in Corpus Christi Bay at Cole and Ropes
Parks by the use of dye testing. Implementation timeline schedule. 44
Table 20. MM 3.6. Change sampling date of current TX Beach Watch Program to be
more protective of public health. Implementation timeline schedule. 46
Table 21. Summary of Management Measure Research 47
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Draft Implementation Plan for Bacteria at Cole and Ropes Parks Beaches in Corpus Christi Bay
Table 22. MM 4.1. Enhance existing Fats, Oil & Grease (FOG) program. Implementation
timeline schedule. 51
Table 23. MM 4.2. Continue and Expand the Notification System for Monitoring Sanitary
Sewer Overflows (SSOs). Implementation timeline schedule. 52
Table 24. MM 4.3. Expand Collection System Line Cleaning, Inspection, Repair and
Rehabilitation. Implementation timeline schedule. 53
Table 25. MM 4.4. Implement an Ongoing Inflow and Infiltration Study. Implementation
timeline schedule. 54
Table 26. MM 4.5. Conduct Hydraulic Modeling of Collection System. Implementation
timeline schedule. 55
Table 27. Summary of Management Measure: Wastewater Collection Systems 57
Table 28. MM 5.1. Determine Effectiveness of Stormwater Retrofits to Remove Bacteria.
Implementation timeline schedule. 61
Table 29. MM 5.2. Continue the Major Outfall Assessment and Repair Program as
Funding Allows. Implementation timeline schedule 63
Table 30. MM 5.3. Support and Encourage the Adoption of Stormwater Master Plan.
Implementation timeline schedule. 64
Table 31. Summary of Management Measure: Stormwater Drainage System] 65
Table 32. MM 6.1. Residential Leaking/Broken Private Sewer Laterals Pre-Sale
Inspection/Testing Program. Implementation timeline schedule. 67
Table 33. MM 6.2 Commercial Cross-connection Inspection Program. Implementation
timeline schedule. 69
Table 34. MM 6.3 Commercial Leaking/Broken Sewer Laterals Pilot Inspection/Testing
Program. Implementation timeline schedule. 71
Table 35. MM 6.4 Improved Grease Trap Standards. Implementation timeline schedule.
72
Table 36. MM 6.5. Strengthen Current Animal Control Ordinances Relating to Removal
and Disposal of Pet Wastes. Implementation timeline schedule. 73
Table 37. MM 6.6. Implement Measures to Control Feral Cats, Rodents, and Nuisance
Animals. Implementation timeline schedule. 74
Table 38. MM 6.7. Install Additional Signage. Implementation timeline schedule. 75
Table 39. MM 6.8. Develop Advisement Protocol to Warn the Public of Periodically
Elevated Bacteria Levels, as Anticipated by Weather Forecasts for Rain, as well as
Warnings and Immediately After Rainfall. Implementation timeline schedule 76
Table 40. MM 6.9. Restrict Access to Bay Waters from City Parks and Other Bay Front
City Properties During Periods of Significant Public Health Risks. Implementation
timeline schedule. 78
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Draft Implementation Plan for Bacteria at Cole and Ropes Parks Beaches in Corpus Christi Bay
Table 41. MM 6.10. Adopt and Enforce Additional Ordinances. Implementation timeline
schedule 79
Table 42. MM 6.11. Explore Adoption of Additional "Low Impact Development"
Standards in Unified Development Code that will Reduce Volumes of Stormwater Runoff
From Areas of New Development or Significant Redevelopment. Implementation timeline
schedule 80
Table 44. CA 1.1. Continue existing Fats, Oil & Grease (FOG) program. Implementation
timeline schedule. 90
Table 45. CA 1.2. Continue Monitoring Sanitary Sewer Overflows (SSOs).
Implementation timeline schedule. 91
Table 46. CA 1.3. Continue Collection System Line Cleaning, Inspection, Repair and
Rehabilitation. Implementation timeline schedule. 92
Table 47. Summary of Control Action Wastewater Collection Systems 93
Table 48. CA 2.1. Continue Existing Stormwater Programs. Implementation timeline
schedule 95
Table 49. CA 2.2. Continue Drainage System Line Cleaning, Inspection, Repair and
Rehabilitation. Implementation timeline schedule. 96
Table 50. Summary of Control Action: Stormwater Drainage System] 97
Table 51. CA 3.1. Eliminate Residential Cross-connections. Implementation timeline
schedule 99
Table A-1. CARP Watershed Monitoring and Assessment— Implementation
Schedule and Tasks 108
Table B-1. CARP Watershed Load Reduction Estimates 118
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Draft Implementation Plan for Bacteria at Cole and Ropes Parks Beaches in Corpus Christi Bay
List of Commonly Used Acronyms
A/E Architectural and Engineering
AU Assessment Unit
BEACH Beaches Environmental Assessment,Closure,and Health
BMP Best Management Practice
CA Control Action
CARP Cole and Ropes Parks
CBBEP Coastal Bend Bays&Estuaries Program
CBBF Coastal Bend Bays Foundation
CBCOG Coastal Bend Council of Governments
CCNCPHD Corpus Christi Nueces County Public Health District
CCS Center for Coastal Studies
CCTV Closed Circuit Televising
CFU Colony-forming units
CFS Cubic Feet Per Second
CIP Capital Improvements Program
CITY City of Corpus Christi
CMOM Capacity Assurance,Management,Operation and Maintenance
CMP Coastal Management Program
DNA Deoxyribonucleic Acid
DWL Dry Weather Loading
EC Event Concentration
EMC Event Mean Concentration
EPA Environmental Protection Agency
FG Future Growth
FOG Fats,Oil&Grease
FSE Food Service Establishments
ft. Feet
GIS Geographic Information System
GLO General Land Office
HEM Hexane Extractible Material
I&I Inflow and Infiltration
IA Implementation Activity
I-Plan Implementation Plan
LA Load Allocation
LID Low Impact Development
LDC Load Duration Curve
LF Linear Feet
MM Management Measure
mL Milliliter
MGD Million Gallons Per Day
MOS Margin of Safety
Draft Implementation Plan for Bacteria at Cole and Ropes Parks Beaches in Corpus Christi Bay
MPN Most Probable Number
MS4 Municipal Separate Storm Sewer System
MST Microbial Source Tracking
NELAC National Environmental Laboratory Accreditation Conference
NPDES National Pollutant Discharge Elimination System
NPS Nonpoint Source
NRA Nueces River Authority
PCR Polymerase Chain Reaction
OSSF On-Site Sewage Facility
PSA Public Service Announcements
QAPP Quality Assurance Project Plan
qPCR Quantitative Polymerase Chain Reaction
RDII Rainfall Dependent Inflow/Infiltration
SEA Saltwater Fisheries Enhancement Association
SEP Supplemental Environmental Project
SSMD Single Sample Maximum Density
SSO Sanitary Sewer Overflow
SWMP Stormwater Management Plan
SWQMIS Surface Water Quality Monitoring Information System
TAC Texas Administrative Code
TAMUCC Texas A&M University-Corpus Christi
TBD To Be Determined
TBWP Texas Beach Watch Program
TCEQ Texas Commission on Environmental Quality
TIDRC Texas Illegal Dumping Resource Center
TMDL Total Maximum Daily Load
TPDES Texas Pollutant Discharge Elimination System
TPWD Texas Parks and Wildlife Department
TX Texas
UDC Unified Development Code
USEPA United States Environmental Protection Agency
USFWS United States Fish and Wildlife Service
WLA Waste Load Allocation
WQMP Water Quality Management Plan
WWTF Wastewater Treatment Facility
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Draft Implementation Plan for Bacteria at Cole and Ropes Parks Beaches in Corpus Christi Bay
Acknowledgements
CARP Members
Luz Lumb,Chair, Sally Farris,Co-Chair
Recreation Home Owners
Philippe Tissot, James Klein,
Recreation Environmental
Kori Ellien, Meredith Darden,
City of Corpus Christi Tourism,Convention and Visitors Bureau
Sharon Lewis, Craig Thompson,
City of Corpus Christi Business&Industry
Temple Williamson, Kelly White,
City of Corpus Christi Wastewater Academia
Rosario Martinez Dr.William Burgin,
Environmental,Coastal Bend Bays& Public Health
Estuary Program
CARP Alternates
Adriana Leiva, Florence Tissot,
Recreation Recreation
Leo Trevino, Rae Mooney,
Environmental,Coastal Bend Bays& Environmental,Coastal Bend Bays&
Estuary Program Estuary Program
Gabriel Ramirez, T.J. Carpenter,
City of Corpus Christi Visitors Bureau
Daniel McGinn, Ashleigh Higson,
City of Corpus Christi Tourism,Convention and Visitors Bureau
Jay Reining, Sandra Heatherley,
Environmental Home Owners
Gerald Sansing, Lillian Bass,
Home Owners Academia
Preeti Shrestha, Donna Rosson,
City of Corpus Christi Public Health
Chris Tweedle, Annette Rodriguez,
Academia Public Health
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Draft Implementation Plan for Bacteria at Cole and Ropes Parks Beaches in Corpus Christi Bay
Past CARP Members
Jace Tunnell,Environmental, Danielle Converse,
Coastal Bend Bays&Estuary Program City of Corpus Christi
Bill Green, Bob Blair,
City of Corpus Christi Business&Industry
Past CARP Alternates
Valerie Gray, Tim Stephens,
City of Corpus Christi Business&Industry
CARP Support
Teresa Carrillo, Lauren Young,
Center for Coastal Studies, Texas Commission on
Texas A&M University-Corpus Christi Environmental Quality
Brien Nicolau, Chris Loft,
Center for Coastal Studies, Texas Commission on
Texas A&M University-Corpus Christi Environmental Quality
Erin Hill, Ron Stein,
Center for Coastal Studies, Texas Commission on
Texas A&M University-Corpus Christi Environmental Quality
Roger Miranda,
Texas Commission on
Environmental Quality
Past CARP Support
Ismael Nava, Debbie Grimaldi,
Coastal Bend Bays Foundation Coastal Bend Bays Foundation
Daniel Ryne Lucio,
Coastal Bend Bays Foundation
In Memory of Peggy Sumner, 1955-2013, First CARP Chair
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Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
-
C
mow Implementation Plan for
mai Two Total Maximum Daily Loads
for Bacteria at Cole and Ropes Parks
Beaches in Corpus Christi Bay
Executive Summary
On date, the Texas Commission on Environmental Quality adopted Two Total
Maximum Daily Loads for Bacteria (TMDL) on Cole and Ropes Parks Beaches in
Corpus Christi Bay (Segment 2481). The TMDL was approved by the U.S.
Environmental Protection Agency (USEPA) on month, day, year.
Implementation activities within this plan specifically target beaches at Cole Park
(Segment 248 1CB_o3) and Ropes Park (Segment 248 1CB_o4) beaches located
along the southern shoreline of Corpus Christi Bay.
The Cole and Ropes Park Coordination Committee (CARP) is a group of
interested citizens, private organizations, local businesses and federal, state, and
local governments who work together to protect the health of Corpus Christi Bay
at Cole and Ropes Park. The CARP Bacteria Reduction Implementation Plan
Committee stakeholder group directing the I-Plan formed four work groups to
determine appropriate activities and schedules to accomplish the Management
Measures(MM) and Control Activities(CA) described in the plan.
Management Measures refer to strategies for reducing unregulated pollutants,
generally through voluntary Best Management Practices (BMPs), while Control
Actions refer to regulated source reduction strategies, generally through
Municipal Separate Storm Sewer System(MS4) permits.
The work groups formed were (1) City Infrastructure, (2) Education and
Outreach, (3) Ordinances and Regulations, and (4) Monitoring and Research.
Collectively, the CARP stakeholder group and work groups held 61 meetings to
develop this I-Plan.
The CARP Committee has identified Management Measure 3.2: Bacterial Source
Tracking as the first priority activity for implementation. Because many of the
Management Measures and Control Actions recommended in this I-Plan address
specific potential bacterial sources, results from bacterial source tracking will
guide the prioritization and implementation of subsequent activities and allow
for wise allocation of limited resources throughout the implementation of the I-
Plan.
Texas Commission on Environmental Quality 1 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
The ultimate goal of this I-Plan is to restore the contact recreation
uses in Segments 2481 CB_o3 and CB_o4 of the Cole and Ropes Parks
beaches by reducing concentrations of bacteria to levels established
in the TMDL. The TMDL identified potential regulated and
unregulated sources of the indicator bacteria Enterococcus.
This Implementation Plan, or I-Plan:
• describes the Management Measures and Control Actions the watershed
stakeholders and the TCEQ propose to implement with the ultimate goal
of the bacteria pollutant reductions necessary to restore and protect water
quality,
• identifies the means by which these activities may be implemented,
• proposes a schedule for implementation of these activities, and
• describes how stakeholders and the TCEQ propose to track
implementation of these activities and monitor improvements in water
quality.
This I-Plan includes 33 Management Measures with 6 Control Actions that may
be used to reduce bacteria in the Cole and Ropes Park watershed. Management
Measures are related to managing nonpoint sources (unregulated), such as
working to identify On Site Sewage Facilities (OSSFs) in the watershed. Control
Actions are related to point sources (regulated discharges), such as industrial or
domestic wastewater treatment facilities and permitted stormwater discharges.
Discharges from the City of Corpus Christi's Municipal Separate Storm Sewer
System (MS4) into Corpus Christi Bay at Cole and Ropes Parks beaches are
regulated under a Texas Pollutant Discharge Elimination System (TPDES)
permit.
Unregulated sources that could contribute to the bacteria load in the Cole and
Ropes Park watershed include nesting and loafing birds at the sample site and
beaches, and unmanaged pet and wildlife animal waste.
The TCEQ will track the progress of this voluntary I-Plan in restoring the affected
Recreational Beach use. Water quality data will continue to be collected by the
Texas General Land Office (GLO) who administers the Texas Beach Watch
Program (TBWP) and is responsible for notifying the public when water quality
standards for pathogens or pathogen indicators are exceeded. TCEQ is provided
with a compilation of all beach data collected and analyzed by GLO under the
TBWP and will continue to identify trends and compliance with the water quality
standard in order to protect human health by identifying beaches with persistent
advisories. If persistent advisories continue, and standards are not attained, the
Texas Commission on Environmental Quality 2 Peer Review Draft,Month, Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
TCEQ and watershed stakeholders should reevaluate the TMDL and the I-Plan
and take appropriate action. The TCEQ will report the results of implementation
tracking and evaluation in its biennial program status report and at regional
forums.
Management Measures (Voluntary Activities)
1. General Awareness
2. Leave It Better Than You Found It
3. Pet Waste Disposal
4. Prevent Intentional Dumping and Disposal
5. Slow the Flow(Low Impact Development)Initiative
6. Continue Sampling Enterococcus levels at Cole and Ropes Parks
7. Collect Rainfall Data Near Cole and Ropes Parks
8. Conduct Stormwater Outfall Flow Sampling
9. Evaluate Methods to Remove Bacteria with Green Infrastructure
10. Bacterial Source Tracking
11. Evaluate the Effectiveness of Public Utilities Programs and Projects in
Bacteria Reductions
12. Promote New Data Analysis Method for Regulatory Justification for
Listing Beaches on the 303 (d)List
13. Identify Water Flow Patterns in Corpus Christi Bay at Cole and Ropes
Parks by the use of Dye Testing
14. Change Sampling Date of Current Texas Beach Watch Program to be
More Protective of Public Health
15. Enhance Existing Fats, Oil&Grease (FOG)Program
16. Continue the Notification System for Monitoring Sanitary Sewer
Overflows(SSOs)
17. Expand Collection System Line Cleaning,Inspection,Repair and
Rehabilitation
18. Implement an Ongoing Inflow and Infiltration Study
19. Conduct Hydraulic Modeling of Collection System
20. Determine Effectiveness of Stormwater Retrofits to Remove Bacteria
21. Continue the Major Outfall Assessment and Repair Program as
Funding Allows
22. Support and Encourage the Adoption of Stormwater Master Plan
23. Residential Leaking/Broken Private Sewer Laterals Pre-Sale
Inspection/Testing Program
Texas Commission on Environmental Quality 3 Peer Review Draft,Month, Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
24. Commercial Cross-Connection Inspection Program
25. Commercial Leaking/Broken Sewer Laterals Pilot Inspection/Testing
Program
26. Improved Grease Trap Standards
27. Strengthen Current Animal Control Ordinances Relating to Removal
and Disposal of Pet Wastes
28. Implement Measures to Control Feral Cats,Rodents, and Nuisance
Animals
29. Install Additional Signage
3o. Develop Advisement Protocol to Warn the Public of Periodically
Elevated Bacteria Levels, as Anticipated by Weather Forecasts for
Rain, as well as Warnings During and Immediately After Rainfall
31. Restrict Access to Bay Waters from City Parks and Other Bayfront City
Properties During Periods of Public Health Risks
32. Adopt and Enforce Additional Ordinances
33. Explore Adoption of Additional "Low Impact Development"Standards
in Unified Development Code that will Reduce Volumes of Stormwater
Runoff From Areas of New Development or Significant Redevelopment
Control Actions (Regulatory Activities)
1. Continue Existing Fats, Oil&Grease(FOG)Program
2. Continue Monitoring Sanitary Sewer Overflows(SSOs)
3. Continue Collection System Line Cleaning,Inspection,Repair and
Rehabilitation
4. Continue Existing Stormwater Programs
5. Continue Drainage System Line Cleaning,Inspection,Repair and
Rehabilitation
6. Eliminate Residential Cross-connections
For each of the measures and actions, this plan identifies the responsible parties,
technical and financial needs, monitoring and outreach efforts, and a schedule of
activities. The time line for activities is by tiers; Tier 1 (1-5 years), Tier 2 (5-10
years), and Tier 3 (10-15 years). Implementation of the Management Measures
will largely be dependent upon the availability of funding.
The stakeholders and TCEQ will review progress under the TCEQ's adaptive
management process. The plan may be adjusted periodically as a result of
progress reviews.
Texas Commission on Environmental Quality 4 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Introduction
To keep Texas' commitment to restore and maintain water quality in impaired
rivers, lakes, and bays, the TCEQ works with stakeholders to develop an I-Plan
for each adopted TMDL.A TMDL is a technical analysis that:
• determines the amount of a particular pollutant that a water body can receive
and still meet applicable water quality standards, and
• sets limits on categories of sources that will result in achieving standards.
• TMDLs are the best possible estimates of the assimilative capacity of the
water body for a pollutant under consideration.
This I-Plan is designed to propose activities that may achieve the water quality
goals for the Cole and Ropes Parks beaches watershed as defined in the TMDL. It
is a voluntary, flexible tool that governmental and nongovernmental
organizations involved in implementation may use to guide their activities to
improve water quality. The participating partners may accomplish the activities
described in the plan through rule, order, guidance, or other appropriate formal
or informal action.
The Cole and Ropes Park Coordination Committee (CARP) is a group of
interested citizens, private organizations, local businesses and federal, state, and
local governments who work together to protect the health of Corpus Christi Bay
at Cole and Ropes Park. The CARP advised the TCEQ on the development of the
bacteria TMDL and continued to advise the TCEQ during development of this I-
Plan.
This I-Plan contains the following components:
i) A description of proposed Management Measures and Control Actions that
may be implemented to achieve the water quality standards.
2) A recommended schedule for implementing activities (Appendix A).
3) The responsible organization under which the participating agencies may
require implementation of the Control Actions.
4) A follow-up tracking and monitoring plan to determine the effectiveness of
the Control Actions and Management Measures undertaken.
5) Identification of measurable outcomes the TCEQ and stakeholders will use
to determine whether the I-Plan has been properly executed, water quality
standards are being achieved, or the plan needs to be modified.
6) Identification of the communication strategies the TCEQ will use to
disseminate information to stakeholders.
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Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
7) A review strategy that stakeholders will use to periodically review and
revise the plan to ensure there is continued progress in improving water
quality.
This I-Plan also includes possible causes and sources of the bacteria impairment,
Management Measure and Control Action descriptions, estimated potential load
reductions, technical and financial assistance needed, educational components
for each measure and action, schedule of implementation, measurable
milestones, indicators to measure progress, monitoring components, and
responsible organization outlined in the Nonpoint Source Program Grants
Guidelines for States and Territories (EPA, 2004). Consequently, projects
developed to implement nonpoint source (unregulated) elements of this plan that
also meet the grant program conditions may be eligible for funding under the
EPA's Section 319(h) incremental grant program.
Watershed Overview
In 2008, based on data collected under the Texas Beach Watch Program, EPA
took action to list Corpus Christi Bay (Segment 2481) on the 3o3(d) List of
Impaired Waters for bacteria and subsequently listed the entire water body in
Category 5a, meaning a TMDL will be scheduled. Upon request by TCEQ, EPA
reconsidered listing the entire Corpus Christi Bay segment and changed the
listing to include only beaches at Cole Park and Ropes Park, and designated them
into separate assessment units (Segment 2481CB_03 and 2481CB_04,
respectively) (Figure 1). In addition, the listing category changed to 5c, meaning
additional bacteria data were needed before a TMDL is conducted. These actions
resulted in establishment and TCEQ funding for the project: "TMDL
Investigation for Bacteria in Corpus Christi Bay Beaches". This I-Plan addresses
the impaired Assessment Units (AUs) and the watershed of the main area of
those AUs. There are twelve main sub-watersheds that affect Cole and Ropes
Park AU's, totaling 4415 acres of urban land that discharges to Corpus Christi
Bay.
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Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•
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` Cole Park i
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Ropes Park
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Figure 1.Location of Cole and Ropes Parks.
Cole Park
Cole Park, Segment 2481CB_03, is 43 acres in size and is owned and operated as
a public park by the City of Corpus Christi. The park sits on the edge of Corpus
Christi Bay (Figure 2). The park's facilities include 3 separate parking lots,
totaling approximately 25o parking spots, a skate park, new children's
playground, fishing pier, amphitheater, restroom facilities, and numerous park
benches and picnic tables. The shoreline consists of approximately 1,800 ft. of
rock rubble, 300 ft. of sandy beach, and the remainder consists of concrete
bulkhead with large rocks and obstructions with little to no access to the water.
There is one large (9.5 ft. high by 11 ft. wide) stormwater outfall located in Cole
Park that serves the Baldwin-Louisiana drainage basin. Three other stormwater
outfalls are present along the shoreline within the boundaries of the park.
Windsurfers and kite boarders utilize Oleander Point (south end) part of Cole
Park for bay access.
Ropes Park
Ropes park, Segment 2481CB_o4, is 3.5 acres in size and is owned and operated
as a public park by the City of Corpus Christi. This park also sits on the edge of
Corpus Christi Bay (Figure 3). The park's facilities include 6 parking spaces. The
park hosts a stairway down to the water and park benches for sitting. There is
almost 1,000 ft. of shoreline, including 26o ft. of sand with the remainder
comprised of large pieces of concrete rubble. The park sits on top of an
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approximately 3o ft. bluff overlooking the water. There are two small stormwater
outfalls located at this park. There is also a large (12 ft. high by ii ft. wide)
stormwater outfall located approximately 85o ft. south of Ropes Park which
serves the Horne-Brawner Drainage Basin. Ropes Park is commonly used by
windsurfers for bay access to launch their equipment.
410
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Louisiana Parkway
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Figure 2.Cole Park with Louisiana Parkway stormwater outfall and the Oleander Point location.
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Figure 3.Ropes Park and the location of the Brawner Parkway stormwater outfall.
Texas Beach Watch Program Bacteria Sampling
Currently, the Texas General Land Office (GLO) administers the Texas Beach
Watch Program (TBWP) and collects water samples through contract, from 164
stations at 62 recreational beaches along the Texas coast in Aransas, Brazoria,
Cameron, Galveston, Jefferson, Kleberg, Matagorda, Nueces, and San Patricio
Counties. Sample collection occurs weekly (one time at each station) during the
peak beach season from May through September and bi-weekly from October
through April with water samples collected at approximately o.6 m (2 ft.), or knee
depth. The GLO maintains a website at http://texasbeachwatch.com/ where
maps and bacteria water quality information are available. Bacteria results are
updated each time sample data are entered into the TBWP database. Local
government entities typically post Beach Watch advisory signs at beach access
points and issue advisories that warn the public not to swim in affected waters
when bacterial levels are exceeded.
TBWP advisories are recommended when a single sample exceeds EPA's
recommended Single Sample Maximum Density (SSMD) criteria of 104 colony-
forming units (CFU) or most probable number (MPN)/loo ml. Once issued, that
beach is subject to continued monitoring every 24 hours until bacteria levels fall
to <104 CFU or MPN/loo ml. Advisories last for 24 hours, and are extended if
bacteria levels continue to exceed SSMD recommended levels. All samples are
collected under a quality assurance project plan (QAPP) consistent with TCEQ
bacteria collection and analysis protocols and analyzed for enterococci bacteria
using EPA's Method i600 or the IDEXX Enterolert®system.
TCEQ is provided with a compilation of all beach data collected and analyzed by
GLO under the TBWP. Based on total number of samples for each beach and the
number of days each beach is under an advisory, TCEQ assesses each individual
year within the multi-year assessment period of record. For all available data, the
total number of advisory days is divided by the total number of samples collected.
If there are numerous sites monitored at one beach area, only one advisory is
counted per beach per day. All impairments identified using this method are
categorized as 5a (available data and/or information indicate at least one
designated or existing use is not being supported and necessary TMDLs are
underway or scheduled) due to human health considerations.
TCEQ proposes including the TBWP information in the 3o3(d)/3o5(b)
assessment process in order to protect human health by identifying beaches with
persistent advisories. Assessment would consist of identifying the percentage of
days each beach has an advisory. The recreation use is not supported if the
geometric mean of the samples collected over the assessment period exceeds the
criterion (35 CFU or MPN/ioo ml) or if the criteria for individual samples (104
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CFU or MPN/loo ml) are exceeded greater than 25 percent of the time. TCEQ
then categorizes the data according to the following scale;
Beach advisories <25%of the time—Fully Supporting
Beach advisories 20-25% of the time—Concern and Fully Supporting.
Beach advisories < 2o% of the time—Delisted and Fully Supporting.
Beach advisories >_ 25% of the time—Not Supporting.
Summary of TMDLs
This section summarizes sections of the Corpus Christi Bay Beaches Bacteria
TMDL. Additional background information, including the problem definition,
endpoint identification, source analysis, linkages between sources and receiving
waters, and seasonal variation can be found in the Corpus Christi Bay Beaches
Bacteria TMDL (TCEQ, 2016). Table 1 provides a summary of the water quality
inventory assessment data for bacteria in Corpus Christi Bay at Coles and Ropes
Parks.
Table 1. Water Quality Inventory Assessment Data.
Single
Geometric Sample
Mean Maximum %Single
Indicator Criterion Criterion Sample
Description Segment AU Bacteria (mpn/100mL) (mpn/100mL) Exceeded
Cole Park 2481 2481CB_03 Enterococci 35 104 25
Ropes Park 2481 2481CB_o4 Enterococci 35 104 25
Pollutant Sources and Loads
Potential Pollutant Sources
Pollutants may come from several sources, both point and nonpoint. Point source
pollution comes from a single definable point, such as a pipe, and is regulated by
permit under the TPDES. Wastewater and stormwater discharges from industries,
construction, and municipal separate storm sewer systems are considered point
sources of pollution. Nonpoint source (NPS) pollution originates from multiple
locations, usually carried into surface waters by rainfall runoff. Nonpoint sources
are not regulated by permit.
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1. Construction site discharges
Mobilized sediment associated with construction sites in the Cole and
Ropes Park watershed may be deposited in Corpus Christi Bay via surface
runoff or from stormwater runoff. Increased suspended solids in the form
of sediment have been correlated to increased bacteria levels in receiving
water bodies (Sawyer et al. 2010).
2. Bacteria regrowth
Studies have shown biofilm regrowth of enterococci does occur in street
gutters and storm drains and are contributors to elevated bacteria levels
during surface runoff events (Skinner et al. 2010).
3. Sediment re-suspension
Bacteria in natural waters exist in two forms, (1) free-living or (2) attached
and adsorbed to sediment particles (Yang, L et al. 2008). Bacteria in
bottom sediments can reenter the water column via perturbations that
cause sediment resuspension resulting in the reabsorption of bacteria onto
the surface of available suspended sediments. Perturbation that can cause
sediment resuspension in Corpus Christi Bay at Cole and Ropes Park
include wave conditions (i.e. calm conditions resulting in low bacteria
levels and rough wave conditions resulting in high levels), stormwater
inflow through drain pipes, surface runoff, human recreation, and
animals.
4. Dry weather discharges/illicit discharges into and from storm sewers
Illicit dry weather flows originate from many sources and may include
wastewater, industrial and commercial discharges, cross-connections
between stormwater and sanitary sewer systems, irrigation practices from
landscaping, illegal dumping, failing septic tanks, and vehicle maintenance
activities (i.e. car washing,waste oil).
5. Sanitary Sewer Overflows (SSOs)
SSOs are releases of untreated wastewater, including domestic,
commercial, and industrial wastewater. They are permit violations that
must be addressed by the responsible TPDES permittee. SSOs usually
occur as the result of a break, blockage, or exceedance of capacity in the
sanitary sewer conveyance system. SSOs have the potential to enter the
stormwater conveyance system and may be transported to Corpus Christi
Bay.
6. Stormwater Sources
Stormwater is regulated by the state and federal government only in
areas designated by the EPA as "Urbanized Areas" (UAs) belonging to
organizations regulated as Municipal Separate Storm Sewer Systems
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(MS4s). Best management practices (BMPs) and participation in existing
conservation and cost-share management programs is the most feasible
option to control these sources of pollution.
Promoting the use of BMPs and expanding participation in management
programs in Corpus Christi can help lower bacteria levels in waterways.
Promotion of BMPs could also help lower bacteria levels in the Cole and
Ropes Parks drainage basins where commercial and residential
development has occurred, as the density of pets (dogs and cats) is directly
linked to population and urbanization.
7. Animal Sources (Wildlife)
Bacteria loads from animal sources (birds, livestock, wildlife, etc.) are
identified in the Corpus Christi Bay Beaches TMDL report as nonpoint
sources of concern. Failure to properly manage these sources may increase
bacterial loads to Corpus Christi Bay in the future. Areas of concern include
the potential for bacteria to attach to sediments in stormwater runoff, and
animals' direct deposition of fecal waste on the beaches or in the
watershed.
8. Domestic Pets
The most common domestic pets are dogs and cats; however, there are
many other types of animals that are also kept as pets in the Coles and
Ropes Park watersheds. There are over 9052 dogs, 10,301 cats and
numerous other animals (goats, sheep, rabbits, ponies, etc.) in the CARP
watersheds. Pet waste contributes substantial amounts of bacteria to
surface waters. Feces left in parks,yards or on sidewalks gets washed off by
rain water and carried into storm drains. These storm drains lead directly
to Corpus Christi Bay and associated beaches. Water carried through these
drains may deposit feces, bacteria and other harmful pollutants into the
water where people recreate on the beaches at Coles and Ropes Park.
9. Domestic and Industrial Wastewater Treatment Facilities
In most cases, domestic and industrial wastewater treatment facilities may
be potential sources of pollutants. In this case, the watershed has been
serviced by a municipal sanitary sewer system since the 1940's and all
sanitary waste water is conveyed out of the watershed and is not discharged
to the beaches. The City of Corpus Christi has no plans to change this
system and the limited space within the watershed precludes the possibility
that a WWTF will be constructed within the watershed and sanitary
wastewater will be discharged to the beaches.
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Pollutant Load Allocation
The TMDL represents the maximum amount of a pollutant that the bay can
receive in a single day without exceeding water quality standards. The pollutant
load allocations for the selected scenarios were calculated using the following
equation:
TMDL= EWLA+ ELA+ MOS
Where:
E WLA= Sum of waste load allocation,the amount of pollutant
allowed by permitted or regulated dischargers
E LA= Sum of load allocation, the amount of pollutant allowed by
unregulated or unregulated sources
MOS = margin of safety
The equation is used to allocate loads among different sources of a pollutant.
Waste load allocations are determined for point sources. These point sources
include permitted stormwater runoff and other point sources. Load allocations
for nonpoint sources generally include background loads, upstream loads, any
stormwater runoff not subject to permit, on-site sewage facility loads, and other
nonpoint sources such as animal deposition and leaking wastewater
infrastructure. Allocated loads for all TMDLs covered by this document can be
found in Appendix B.
The MOS is designed to account for any uncertainty that may arise in specifying
water quality control strategies for the complex environmental processes that
affect water quality. Quantification of this uncertainty, to the extent possible, is
the basis for assigning an MOS.
Waste Load Allocation (WLA)
The waste load allocation is the sum of loads from regulated sources.
WWTFs
TPDES-permitted wastewater treatment facilities within the TMDL watershed
are allocated a daily waste load (WLAwwrF) based on the full permitted flow of
each facility. The TMDL watershed has been serviced by a municipal sanitary
sewer system since the 1940's. All sanitary waste water is conveyed out of the
watershed and is not discharged to the beaches. The City of Corpus Christi has no
plans to change this system and the limited space within the watershed precludes
the possibility that a WWTF will be constructed within the watershed and
sanitary wastewater will be discharged to the beaches. Because of this the waste
load allocation for each impaired beach will be:
WLAWwrF= O
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Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Table 2. Percentages of Each AU Designated as an Urbanized Area.
Total watershed area Percentage AU Permitted for
AU under MS4(acres) Stormwater
2481CB_o3 2041 too
2481CB_04 7 100
Sub-basins Influencing
AU's 2367 too
Total 4415 too
Table 3. MS4 Permittees in Corpus Christi Bay at Coles and Ropes Park.
AU Permit Number Permittee AU Feet
NPDES No.TXSoo6o1; City of Corpus 5897
2481CB_03 TPDES Permit No. Christi
WQoo04200000
NPDES No.TXS00601; City of Corpus
2481CB_04 TPDES Permit No. Christi 987
WQo0o4200000
Regulated Stormwater
The absence of WWTF discharges limits the TMDL allocations to regulated
stormwater (WLAsw) for MS4, industrial, and construction permits, unregulated
sources (LA), and the MOS. The WLAsw is calculated by subtracting the MOS and
LA from the TMDL:
WLAsw = TMDL-MOS - LA
The entire watershed for both impaired beaches, or AU, is covered under the City
of Corpus Christi's MS4 permit (NPDES No. TXSoo6oi; TPDES Permit No.
WQ0004200000). The LA is the result of bacteria loading and fate and transport
within the receiving water at the beaches and is estimated by using the watershed
loading model created for this TMDL.
In urbanized areas currently regulated by an MS4 permit, development and/or
re-development of land in urbanized areas must implement the control
measures/programs outlined in an approved Stormwater Management Program
SWMP. Although additional flow may occur from development or re-
development, loading of the pollutant of concern should be controlled and/or
reduced through the implementation BMPs as specified in both the National
Pollutant Discharge Elimination System (NPDES) or TPDES permit and the
SWMP.
An iterative, adaptive management approach will be used to address stormwater
discharges. This approach encourages the implementation of structural or non-
structural controls, implementation of mechanisms to evaluate the performance
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of the controls, and finally, allowance to make adjustments (e.g., more stringent
controls or specific BMPs) as necessary to protect water quality.
Load Allocation (LA)
The LA is the sum of loads from unregulated sources. As has been shown in the
TMDL, dry weather loading (DWL) is a significant contributor to water quality at
both Cole and Ropes Parks. Although the sources of this loading are not well
understood, they can be categorized as the non-permitted, non-point source
components of the TMDL. As such, dry weather loading represents the LA
portion of the TMDL calculation.
As shown in the TMDL (Appendix A, Step 5), DWL to the impaired beaches is
estimated from the following factors:
1. Area influenced by the DWL,
2. The volume of water in the area of the dry weather load,
3. The median concentration of bacteria in that area, and
4. The decay rate for the bacteria.
Allowance for Future Growth (FG)
The future growth component addresses the requirement of TMDLs to account
for future loadings that may occur as a result of population growth, changes in
community infrastructure, and development. Allowance for future growth is not
needed for these TMDLs because there are no permitted WWTF discharges to the
impaired AUs and there will be none in the future.
Total Maximum Daily Load (TMDL)
To achieve water quality standards in effect at adoption of this TMDL, the
following reduction in loads were calculated for both impaired beaches using the
TMDL equation:
TMDL= EWLA+ ELA+ MOS.
Cole Park - 248106_03
The TMDL for this segment is estimated at 1.007 x 1012 MPN/day, which is the
equivalent of a 95.9% reduction in Enterococcus load from runoff and an overall
load reduction of 94.4%.
Ropes Park - 2481 CB_04
The TMDL for this segment is estimated at 4.345 x 1012,which is the equivalent of
a reduction of a 74.0% in load from runoff and an overall load reduction of 73.1%.
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Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Table 4. TMDL Allocation Summary Corpus Christi Bay at Coles and Ropes Parks(in Billions
MPN/day.)
Future
Indicator WLA WI-Astor Growth
Segment Name AU Bacteria TMDL F mwater LA MOS (FG)
Corpus Christi 2 81CB_O Enterococci 10070
Bay 2481 4 3 555 273 179 na
Corpus Christi 2 81CB_O Enterococci
Bay 2481 4 4 4345 0 3537 146 662 na
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Implementation Strategy
This voluntary I-Plan documents 33 Management Measures and 6 Control
Actions to reduce bacteria levels. Management Measures are voluntary and
Control Actions are regulated. Management Measures and Control Actions were
selected based on feasibility, costs, support, and timing. Activities should be
implemented in phases based on the needs of the stakeholders, availability of
funding, and the progress made in improving water quality.
The Cole and Ropes Park (CARP) Bacteria Reduction Implementation Plan
Committee (CARP Committee) formed 4 work groups that identified 4 broad
categories of strategies to address reduction of bacteria levels at CARP beaches:
(i) Education and Outreach, (2) Monitoring and Research, (3) Wastewater and
Stormwater Infrastructure, and (4) Ordinances and Regulations. Voluntary and
regulated activities are recommended within the framework of each strategy, but
the CARP Committee recognizes that in order to be effective, activities across
several strategies should be implemented simultaneously or in conjunction with
each other. Some activities are necessary precursors to others, and the results
from some activities will lead to decision making in the planning process for
subsequent actions.
The CARP Committee has identified Management Measure 3.2: Bacterial Source
Tracking as the first priority activity for implementation. Because many of the
Management Measures and Control Actions recommended in this I-Plan address
specific potential bacterial sources, results from bacterial source tracking will
guide the prioritization and implementation of subsequent activities and allow
for wise allocation of limited resources throughout the implementation of the I-
Plan.
Adaptive Implementation
All I-Plans are implemented using an adaptive management approach in which
measures are periodically assessed for efficiency and effectiveness. This adaptive
management approach is one of the most important elements of the I-Plan. The
iterative process of evaluation and adjustment ensures continuing progress
toward achieving water quality goals, and expresses stakeholder commitment to
the process.
At annual meetings, TCEQ will direct an appropriate entity to facilitate
stakeholders to periodically assess progress using the implementation timeline
schedule, interim measurable milestones, water quality data, and the
communication plan included in this document. If periodic assessments find that
insufficient progress has been made or that implementation activities have not
improved water quality,the implementation strategy will be adjusted.
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Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Activities and Milestones
The Cole and Ropes Park (CARP) Bacteria Reduction Implementation Plan
Committee stakeholders and work groups: (i) Education and Outreach, (2)
Monitoring and Research, (3) Wastewater and Stormwater Infrastructure, and
(4) Ordinances and Regulations, determined appropriate activities and schedules
to accomplish the management and control activities in this I-Plan. Collectively,
the CARP stakeholder group and work groups held a total of 61 meetings to
develop this I-Plan.
This I-Plan includes surface water quality monitoring activities to identify
unregulated sources of bacteria, technical analysis of Management Measures and
Control Activities to predict efficiency of possible Best Management Practices
(BMPs), and stakeholder guidance to review possible activities and provide
recommendations to the TCEQ for future inclusion in the adopted I-Plan. In
addition, the I-Plan outlines potential effective partnerships with local entities to
implement the proposed Management Measures and control activities.
Each work group developed detailed, consensus-based action plans. The planned
implementation activities are described in the following section.
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Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Management Measures and Control Actions
The Cole and Ropes Park (CARP) Bacteria Reduction I-Plan includes [33]
Management Measures and [6] Control Actions.
Management Measures (Voluntary Activities)
1.o) Education and Outreach
1.1) General Awareness
1.2) Leave It Better Than You Found It
1.3) Pet Waste Disposal
1.4) Prevent Intentional Dumping and Disposal
1.5) Slow the Flow (Low Impact Development)Initiative
2.0) Monitoring
2.1) Continue Sampling Enterococcus Levels at Cole and Ropes Parks
2.2) Collect Rainfall Data Near Cole and Ropes Parks
2.3) Conduct Stormwater Outfall Flow Sampling
3.0) Research
3.1) Evaluate Methods to Remove Bacteria with Green Infrastructure
3.2) Bacterial Source Tracking
3.3) Evaluate the Effectiveness of Public Utility Programs and Projects
in Bacteria Reductions
3.4) Promote New Data Analysis Method for Regulatory Justification
for Listing Beaches on the 303 (d)List
3.5) Identify Water Flow Patterns in Corpus Christi Bay at Cole and
Ropes Parks by the use of Dye Testing
3.6) Change Sampling Date of Current Texas Beach Watch Program to
be More Protective of Public Health
4.0) Wastewater Collection Systems
4.1) Enhance Existing Fats, Oil&Grease (FOG)Program
4.2) Continue the Notification System for Monitoring Sanitary Sewer
Overflows(SSOs)
4.3) Expand Collection System Line Cleaning, Inspection, Repair and
Rehabilitation
4.4) Implement an Ongoing Inflow and Infiltration Study
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4.5) Conduct Hydraulic Modeling of Collection System
5.0) Stormwater Drainage System
5.1) Determine Effectiveness of Stormwater Retrofits to Remove
Bacteria
5.2) Continue the Major Outfall Assessment and Repair Program as
Funding Allows
5.3) Support and Encourage the Adoption of Stormwater Master Plan
6.0) Ordinances and Regulations
6.1) Residential Leaking / Broken Private Sewer Laterals Pre-Sale
Inspection/Testing Program
6.2) Commercial Cross-connection Inspection Program
6.3) Commercial Leaking / Broken Sewer Laterals Pilot Inspection/
Testing Program
6.4) Improved Grease Trap Standards
6.5) Strengthen Current Animal Control Ordinances Relating to
Removal and Disposal of Pet Wastes
6.6) Implement Measures to Control Feral Cats,Rodents, and Nuisance
Animals
6.7) Install Additional Signage
6.8) Develop Advisement Protocol to Warn the Public of Periodically
Elevated Bacteria Levels, as Anticipated by Weather Forecasts for
Rain, as well as Warnings During and Immediately After Rainfall
6.9) Restrict Access to Bay Waters from City Parks and Other Bayfront
City Properties during Periods of Public Health Risks
6.1o) Adopt and Enforce Additional Ordinances
6.11) Explore Adoption of Additional "Low Impact Development"
Standards in Unified Development Code that will Reduce Volumes
of Stormwater Runoff From Areas of New Development or
Significant Redevelopment
Control Actions (Regulated Activities)
1.o) Wastewater Collection Systems
1.1) Continue Existing Fats, Oil&Grease(FOG)Program
1.2) Continue Monitoring Sanitary Sewer Overflows(SSOs)
1.3) Continue Collection System Line Cleaning, Inspection, Repair and
Rehabilitation
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2.o) Stormwater Drainage System
2.1) Continue Existing Stormwater Programs
2.2) Continue Drainage System Line Cleaning, Inspection, Repair and
Rehabilitation
3.o) Ordinances and Regulations
3.1) Eliminate Residential Cross-Connections
Management Measure 1 .0: Education and Outreach
Since its frontier beginnings in 1519 and incorporation in 1852, the City of Corpus
Christi has always been a pathway to The Americas and is intrinsically linked to
its bays, rivers, creeks, estuaries and waterways. The Port of Corpus Christi
currently is the sixth largest U.S. port and deepest inshore port on the Gulf of
Mexico. To this day these waters play an increasingly important role in the
economic stability and success of the City of Corpus Christi. In 2005, it was
ranked as the 47th largest in the world by cargo tonnage, principally handling oil
and agricultural products. Corpus Christi Bay is also a significant draw for
tourism, both on the north shore as well as the downtown recreational areas,
particularly around Cole and Ropes Parks beaches.
In order to address the issue of excessive bacterial loading at Cole and Ropes
Parks beaches, the CARP Committee will need to engage the City of Corpus
Christi across all demographic aspects through sustained education and outreach
programs that specifically target environmental stewardship, green thinking and
cleanliness campaigns. These programs should address the critical aspects of
education and outreach. Educational programs need to be created so they adhere
to core learning objectives that reinforce knowledge and understanding of
environmental stewardship. Outreach programs should be created and adopted
to insure full coverage of the diverse demographic and socioeconomic
background that the City of Corpus Christi represents. Through enduring City
leadership, partnerships need to be established across government, public,
business, industry, non-profit organizations, community associations and
academic institutions that will strengthen and sustain commitment and
involvement for this plan.
The Education and Outreach workgroup recommends five implementation
activities with associated actions for the CARP implementation plan:
1.1) General Awareness
1.2) Leave It Better Than You Found It
1.3) Pet Waste Disposal
1.4) Prevent Intentional Dumping and Disposal
Texas Commission on Environmental Quality 21 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
1.5) Slow the Flow(Low Impact Development) initiative
Management Measure 1.1 : General Awareness
•WHAT: This activity is aimed at creating, implementing and sustaining
educational programs within the community that increase awareness of the
impact that human actions can have on the quality of local bodies of water.
.WHO: City leadership, CBBF, local environmental groups with support from
educational institutions (TAMUCC, Delmar, CCISD), Surfrider Foundation -
Texas Coastal Bend Chapter, Corpus Christi Convention and Visitors' Bureau,
Texas State Aquarium, Corpus Christi Caller Times, KEDT, other media outlets.
'WHERE: City of Corpus Christi, focusing on Cole and Ropes parks stormwater
outfall drainage area.
•GOAL: Improve community understanding of, "Where does the Water Go?",
this includes wastewater effluent and stormwater runoff. Provide the community
with an"Alert System"when beaches are safe or unsafe for contact recreation.
Create an introductory public education campaign about water quality in Corpus
Christi Bay. Topics will include, "Where does the Water Go?" related to
stormwater drainage and general information about the ways bacteria and other
pollutants can enter waterways. Target practices that can ensure clean water and
foster a sense of local pride related to quality of local waterways.
Produce a series of public service announcements educating the public about
water quality in Corpus Christi Bay. The topics should be similar and align with
the short-term milestone and strategy goals.
Develop community support system (funding,volunteers, partnerships with local
organizations) for the sponsoring of water quality improvement projects such as
clean-ups in affected stormwater drainage basins, "Beach to Bay Relay Marathon"
interpretive signage at Cole and Ropes parks, mobile kiosks to be used at
community events such as Earth Day Bay Day and others.
'WHEN: Tier 1 (1-5 Years).
'HOW: Media campaigns in the form of billboards, radio and TV advertising.
Develop educational information to be used as City utility bill stuffers and
website information. "Bay Walk" interpretive signage, water flow diorama, and
other educational materials will be developed. Coordination will be maintained
through existing partnerships.
'COSTS/SOURCE OF FUNDS: Costs to be determined/ various grant
programs and non-profit agencies.
Texas Commission on Environmental Quality 22 Peer Review Draft,Month, Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•RESPONSIBLE ORGANIZATION(S): None required.
•ACTIONS AND SCHEDULE:
Table 5. MM 1.1. General Awareness. Implementation timeline schedule.
Activity Tier 1 Tier 2 Tier 3
Create Public Education Materials x x x
Public Service Announcements(PSA) x x x
Public presentations x x x
Management Measure 1 .2: Leave It Better Than You Found It
•WHAT: A specific campaign targeted at reducing litter in the community.
Principle focus will be on reducing and discouraging litter from vehicles and by
individuals around restaurants, shopping areas, parks, beaches and all other
public use spaces.
•WHO: Possible partners include Beautify Corpus Christi Association, Coastal
Bend Council of Governments, Corpus Christi Convention and Visitors' Bureau,
City of Corpus Christi, Coastal Bend Bays Foundation, Coastal Bend Bays and
Estuaries Program,TCEQ.
•WHERE: Target areas should include all drainage basins which directly affect
the Cole and Ropes Parks.
•GOAL: Support the "Leave It Better Than You Found It" and "Don't Mess With
Texas Water" campaigns and increase community ownership for a clean and
healthy City.
•WHEN: Tier 1 (1-5 Years).
•HOW: Adopt educational programs for all age groups that target anti-litter and
environmental awareness. Develop outreach programs to engage local businesses
and residents to support and participate in the "Leave It Better Than You Found
It"campaign.
•COSTS/SOURCE OF FUNDS: Costs to be determined/ various grant
programs and non-profit foundations.
•RESPONSIBLE ORGANIZATION(S): None required
Texas Commission on Environmental Quality 23 Peer Review Draft,Month, Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•ACTIONS AND SCHEDULE:
Table 6. MM 1.2. Leave It Better Than You Found It. Implementation timeline schedule.
Activity Tier 1 Tier 2 Tier 3
Media campaign reinforcing"Leave It Better Than You
Found It" x
Increase support for GLO Adopt-A-Beach. Create: Adopt-
A-Bay,Watershed, etc.
Engage local leaders to address City wide litter problem x
Engage local businesses to support clean initiatives and
post"Leave It Better Than You Found It"campaign signs x
Management Measure 1 .3: Pet Waste Disposal
•'WHAT: Establish coordination with key stakeholders to facilitate the reduction
and eventual elimination of improper pet waste disposal. This will be
accomplished through the continued installation of pet waste disposal stations as
funding is secured, implementation of a public service announcement (PSA) and
other education initiatives including utilization of information booths or kiosks at
local events.
•WHO: City of Corpus Christi with support from CARP, Local Animal
Businesses, Local Veterinarian Clinics and Animal Rescue/Adoption Centers,
City Parks and Recreation(doggie pool day), other etc.
•WHERE: Local businesses and events. Specific locations for pet waste disposal
stations as identified and prioritized by City in the drainage basins that impact
Cole and Ropes parks.
•GOAL: Continue installation of pet waste disposal stations in affected drainage
basins as funding is secured. Develop and establish an information booth or table
at community events. Distribute educational materials and pet waste disposal kits
to pet associated businesses and service providers.
Complete dog waste pickup PSA with celebrity endorsement and video.
Example -Seattle PSA: http://www.youtube.com/watch?v=jDhl2w-jcfs
2018: Complete implementation activities and continue monitoring education
and outreach initiatives.
Texas Commission on Environmental Quality 24 Peer Review Draft,Month, Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
2020: Strive for i00% compliance with pet waste disposal ordinances.
'WHEN: Tier 1 (1-5 Years).
•HOW: Install additional pet waste disposal stations as funding is available.
Provide educational handout material to residents about pet waste at local events.
Create PSA using a local celebrity to engage pet owner population to take
responsibility for good water quality in the CARP watershed areas and
throughout the community. Technical assistance will be needed with production
of a short commercial video to capture essence and vitality, which may be
provided by a local TV station or production company.
'COSTS/SOURCE OF FUNDS: Various grant programs and non-profit
foundations.
•RESPONSIBLE ORGANIZATION(S): None required
•ACTIONS AND SCHEDULE:
Table 7.MM 1.3.Pet Waste Disposal. Implementation timeline schedule.
Activity Tier 1 Tier 2 Tier 3
Pet waste stations x x x
Public service announcement(PSA) x x x
Create info booth for local events x
Distribute educational materials&kits to pet
business and services x x x
Management Measure 1 .4: Prevent Intentional Dumping and
Disposal
'WHAT: Establish coordination with key stakeholders to develop education and
outreach programs to facilitate the reduction of improper waste disposal and
dumping. This strategy is aimed at educating the community on the effects of
illegal dumping. Illegal dumping and disposal harms watersheds, habitat and
creates unhealthy and unsafe conditions for people that work, live or recreate in
impacted areas. Intentional dumping and disposal are illegal and a crime.
•WHO: CARP, community partners and stakeholders.
•WHERE: Cole and Ropes Park watersheds.
Texas Commission on Environmental Quality 25 Peer Review Draft,Month, Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•GOAL: Increase awareness and education on the harm that illegal dumping and
disposal causes to our environmental health and economy. A greater
understanding of this is necessary so that commercial businesses and the public
will begin to take pride in their environment and watersheds. Create an extensive
awareness campaign to educate all ages and socioeconomic backgrounds on
illegal dumping and disposal.
•WHEN: Tier 1 (1-5 Years).
•HOW: Establish education and outreach programs targeted towards
community involvement with commercial business support to identify and report
instances of illegal dumping and disposal. Reference "General Awareness" and
"Keep It Clean" strategies (Appendix A). Encourage applicable stakeholders to
attend training workshops provided by the Texas Illegal Dumping Resource
Center (TIDRC) on illegal dumping regulations and how to address these issues.
The training is provided through grants from TCEQ to the Coastal Bend Council
of Governments (CBCOG).
•COSTS/SOURCE OF FUNDS: Various grant programs and non-profit
foundations.
•RESPONSIBLE ORGANIZATION(S): None required
•ACTIONS AND SCHEDULE:
Table 8.MM 1.4. Prevent Intentional Dumping and Disposal. Implementation timeline schedule.
Activity Tier 1 Tier 2 Tier 3
Sponsor TIDRC workshop in Corpus Christi x x x
Hunting and fishing organization education and
outreach x x x
Coordination with City Solid Waste Department
activities x x x
Management Measure 1.5: Slow the Flow (Low Impact
Development) Initiative
•WHAT: Educate and promote Low Impact Development (LID) by focusing on
practices that improve environmental conditions and water quality.
•WHO: Various professional, non-profit, academic and government
organizations, local gardening/landscaping centers and gardeners' community
organizations.
Texas Commission on Environmental Quality 26 Peer Review Draft,Month, Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•WHERE: Within the City of Corpus Christi
•GOAL: Provide training workshop to the design community demonstrating LID
techniques and benefits; promote LID on individual properties by demonstrating
the benefits through social media and educational presentations upon I-Plan
adoption. Incorporate LID techniques into City projects where feasible and
funding allows as demonstration projects.
•WHEN: Within one year of I-Plan adoption provide training workshop; upon
adoption of the I-Plan, begin promoting LID benefits through social media sites;
incorporate LID techniques into presentations to adult audiences within one year
of I-Plan adoption.
•HOW: Using existing materials such as those provided by the Ladybird
Johnson Wildflower Center promoting LID, create a half day workshop for design
community.
•COSTS/SOURCE OF FUNDS: Training workshop for designers and
engineers approximately$2500.00, source of funds to be determined.
•RESPONSIBLE ORGANIZATION(S): None required
•ACTIONS AND SCHEDULE:
Table 9.MM 1.5.Slow the Flow(Low Impact Development)Initiative. Implementation timeline
schedule.
Activity Tier 1 Tier 2 Tier 3
Provide LID workshop for local designers&
engineers x
Promote benefits of LID though social media x
Incorporate LID into presentations x
Texas Commission on Environmental Quality 27 Peer Review Draft,Month,Day,Year
D I :Liuta.ltlrk1.19rilkILKIL 1.1. iSaalrilil 1:rILLIMI>tir.lAaFMA11Fii�=r 1'
Table 10. Summary of Management Measure 1.0:Education and Outreach
Management Measure:Education and Outreach
Management Potential Technical and Education Schedule of Interim, Indicators of Monitoring Responsible
Measure Load Financial Component Implementation Measurable Progress Component Organizations)
Reduction Assistance Milestones
Needed
Education and Outreach
1.1.)General TBD TBD as funding Create an Tier 1-(years 1- Create Public Public Service Track public TBD
Awareness becomes introductory 5)on going Education Announcements. presentations
available public education Materials. and PSA's given
campaign about and number of
water quality in attendees and
Corpus Christi conduct surveys
Bay. on their
effectiveness
Produce a series Tier 1-(years 1- Public Service Count:number
of public service 5)on going Announcements. of
announcements classes/outreach.
educating the
public on water
quality in Corpus
Christi Bay.
Develop Tier 1-(years 1- Public Public
community 5)on going Presentation Presentations
support system Create Public
for water quality Education
improvement at Materials.
Cole and Ropes
Park.
1.2)Leave It TBD TBD as funding Adopt Tier 1-(years 1- Track and Media campaign Track public TBD
Better than becomes educational 5)on going measure reinforcing presentations
You Found It available programs for all number of "Leave It Better and PSA's given
age groups that citizens reached Than You Found and number of
target anti-litter (all media). It". attendees and
and conduct surveys
environmental Measure hours Increase support on their
awareness. and individual for TGLO Adopt- effectiveness
Develop involvement in A-Beach.Create:
outreach community Adopt-A-Bay,
programs to cleanup events. Watershed,etc.
Texas Commission on Environmental Quality 28 Peer Review Draft,Month,Day,Year
D ft I .1[auca ltliki ri aiatitti ot.l is it aJ c rr u-yiir111.F.iftALAL-sI1:r 1
Management Potential Technical and Education Schedule of Interim, , Indicators of Monitoring Responsible
Measure Load Financial Component Implementation Measurable Progress Component Organization(s)
Reduction Assistance Milestones
Needed
engage local
businesses and Measure Engage local
residents to number of leaders to
support and businesses address City
participate in the supporting wide litter
"Leave It Better "Leave It Better problems.
than You Found than You Found
It"campaign. It"campaign Engage local
initiatives and businesses to
increase or support clean
adjust outreach initiatives and
campaign goals post"Leave It
and targets. Better than you
Found It"
campaign signs.
1.3)Pet Waste TBD TBD as funding Distribute Tier 1-(years 1- Continue Count number of Track public TBD
Disposal becomes educational 5) installation of pet waste presentations
available material and pet Pet Waste stations installed and PSA's given
waste disposal disposal stations and count and number of
kits to pet in Cole and number of bags attendees and
associated Ropes Park used. conduct surveys
businesses and drainage basins. on their
service Survey the public effectiveness
providers. Develop and for the
establish an effectiveness of
information public service
booth or table at announcements
community and
events. informational
booths at local
Complete dog events.
waste pickup
PSA with For PSA and
celebrity informational
endorsement booths track
and video(Tier times aired or
3). used at events
Texas Commission on Environmental Quality 29 Peer Review Draft,Month,Day,Year
D - I .rta uamiu•_f_h____ ______:_____<.1.ra____l:__:r cf�c+ei ilLV i______i_ti-__1:t:r
Management Potential Technical and Education Schedule of Interim, Indicators of Monitoring Responsible
Measure Load Financial Component Implementation Measurable Progress Component Organization(s)
Reduction Assistance Milestones
Needed
1.4)Prevent TBD TBD as funding Establish Tier 1. Track attendance Sponsor TIDRC Track public TBD
Intentional becomes education and at TIDRC events. workshops in presentations
Dumping and available outreach Workshops will Corpus Christi and PSA's given
Disposal programs be provided Track attendance on an annual and number of
targeted towards annually. at education and basis. attendees and
community outreach events. conduct surveys
involvement i.e. Coordination Sponsor hunting on their
"General with the City Track number of and fishing effectiveness
Awareness"and Sold Waste meetings organization
"Keep It Clean" Department will stakeholders education and
strategies. be conducted attend with solid outreach.
quarterly. waste advisory
Provide training boards/ Coordination
and workshops committees. with City Sold
provided by the Waste
Texas Illegal Department
Dumping activities.
Resource Center
(TIDRC)on
illegal dumping
regulations.
1.5)Slow the TBD TBD as funding Provide training Tier i. Survey Provide low Track public TBD
Flow(Low becomes workshops to participants to impact presentations
Impact available promote low determine low development and PSA's given
Development) impact impact workshops for and number of
Initiative development development local designers attendees and
initiatives. support and and engineers. conduct surveys
survey for on their
positive feedback Promote benefits effectiveness
from social of low impact
media sites. development
through social
media.
Incorporate LID
into
presentations.
Texas Commission on Environmental Quality 30 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Management Measure 2.0: Monitoring
In order to assess progress towards reducing bacterial loading at Cole and Ropes
Parks beaches, the CARP Committee will need to evaluate the results of
monitoring on a regular basis. Evaluation of monitoring results will be used to
identify potential changes that could improve effectiveness of the I-Plan.
Monitoring and annual evaluation will determine if the I-Plan or any of its parts
are complete, must address a longer time frame, or require revision. Every five
years, as resources are available and with stakeholder participation, a more in-
depth evaluation will be completed.
Two types of monitoring are proposed:
i) Bacteria baseline (pre-event)water quality monitoring
2) Stormwater event (during/post-event) rainfall and flow of water quality
monitoring
These monitoring measures will form the basis for potential research projects
related to understanding the causes, sources, and solutions to high bacteria levels
at Cole and Ropes Park beaches. Conclusions derived from post-implementation
water quality monitoring data will be an important indicator of whether
implementation activities are resulting in the desired reduction of bacteria
loading. The results of this research will provide essential information to
determine strategic modifications to management actions and control measures
outlined in this plan.
Management Measure 2.1 : Continue Sampling Enterococcus
Levels at Cole and Ropes Parks
The purpose of this Management Measure is to identify improvements or
degradation of bacteria levels at these beaches and help in meeting the TCEQ
standard. Current program for sampling is the Texas Beach Watch Program that
is administered by the Texas General Land Office and funded through the U.S.
Environmental Protection Agency.
•WHAT: Growing concerns about the health risks posed by polluted bathing
beaches, increased beach closures, and scientific evidence indicating an increase
in infectious diseases caused by microbial organisms in recreational waters
prompted the EPA to create the National Beaches Environmental Assessment,
Closure, and Health (BEACH) Program. The goals of the BEACH Program are to
protect public health at the nation's beaches and to ensure the public is notified
when the risk for potential illness and disease is present. The GLO Office secured
Texas Commission on Environmental Quality 31 Peer Review Draft,Month, Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
and allocated Texas Coastal Management Program (CMP) funds for water quality
monitoring at beaches in six counties along the Texas coast. The project is the
Texas Beach Watch Program.
•WHO: For Nueces, Aransas, and San Patricio counties, the current grant is
administered by the laboratory at the Corpus Christi-Nueces County Public
Health District.
•WHERE: Samples are taken at 52 sites along the coast in San Patricio, Nueces,
and Aransas counties. Four sites are located at Cole Park and two at Ropes Park.
'GOAL: The goal of this water quality monitoring project is to provide the public
with information about water quality at recreational beaches.
'WHEN: Water samples are collected weekly during the beach season (currently
May-September) and biweekly during the off-season (October-April). Samples at
Cole and Ropes Parks are currently being collected on Tuesdays.
•HOW: This project involves the collection and testing of water quality samples
for the presence of Enterococcus bacteria and compared to EPA's recommended
Single Sample Maximum Density (SSMD) criteria of 104 colony forming units
(cfu)/ioo ml. If sample results exceed EPA's recommended criteria, the GLO will
notify local government representatives immediately and the required signs
warning of elevated bacteria levels will be posted at the affected beaches. In
addition, bacteria levels for each sample are posted in real time on the Texas
Beach Watch Program's public Internet site at www.TexasBeachWatch.com.
•COSTS/SOURCE OF FUNDS: EPA
•RESPONSIBLE ORGANIZATION(S): The local Beach Watch grant was
awarded to Nueces County and operated by the Corpus Christi-Nueces County
Public Health District. Local government representatives make the necessary
beach notifications upon receipt utilizing the provided signage.
•ACTIONS AND SCHEDULE:
Table 11.MM 2.1.Continue sampling Enterococcus levels at Cole and Ropes Parks.Implementation
timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Texas Beach Watch Sampling x x x
Texas Commission on Environmental Quality 32 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Management Measure 2.2: Collect Rainfall Data Near Cole and
Ropes Parks
•WHAT: The main sources of bacteria at Cole and Ropes Parks beaches may be
coming from non-point source runoff. The non-point source runoff may be (1)
from stormwater flowing into the stormwater collection system and through the
pipes into Corpus Christi Bay, (2) surface runoff from the land that flows directly
into Corpus Christi Bay, or(3) a combination of both(TMDL 2016).
Collecting accurate rainfall data within the Cole and Ropes Parks stormwater
basins and in close proximity to stormwater outfalls in Corpus Christi Bay may
provide better information to determine the relationship between stormwater
flows and bacteria exceedances at these beaches.
•WHO: The CARP envisions a cooperative effort including the City, local
universities, residents, and local research and data collections organizations (e.g.
Center for Coastal Studies, Coastal Bend Bays and Estuaries Program and others
to be determined).
•WHERE: Three major stormwater drainage channels should be the focus for
this monitoring effort: Louisiana Parkway, Brawner Parkway, and Carmel
Parkway. Real-time rain gauges should be installed at residences centrally located
along these drainage channels.
•GOAL: To develop a long term time series of rainfall information at Cole and
Ropes Parks. Data should be made available for use by researchers to correlate
rainfall levels with stormwater pipe flow and Enterococcus levels, to determine
the effect of varying amounts of rainfall with bacteria development in the bay.
Stormwater flow methodology will be decided prior to project development.
There are,however, many factors that affect bacteria development and growth.
•WHEN: Planning and implementation on a smaller sub-basin within the CARP
drainage basin to begin in Tier 1, continuing through the life of the I-Plan.
•HOW: Methods of data collection could include Doppler radar data analysis,
conventional rain gauges, and weather stations. Specific implementation
proposals should be developed by entities such as those listed in "WHO" section
above or other as appropriate.
•COSTS/SOURCE OF FUNDS: Will vary depending on data collection
methods,funding sources, and responsible parties.
•RESPONSIBLE ORGANIZATION(S): None required
Texas Commission on Environmental Quality 33 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•ACTIONS AND SCHEDULE:
Table 12.MM 2.2.Collecting Rainfall Data Near Cole and Ropes Parks. Implementation timeline
schedule.
Actions Tier 1 Tier 2 Tier 3
Planning and implementation in smaller x
pilot project area
x x x
Data Management and Maintenance
Management Measure 2.3: Conduct Stormwater Outfall Flow
Sampling
•WHAT: The main sources of bacteria at Cole and Ropes Parks beaches may be
coming from non-point source runoff. The non-point source runoff may be (1)
from stormwater flowing into the stormwater collection system and through the
pipes into Corpus Christi Bay, (2) surface runoff from the land that flows into
Corpus Christi Bay, or(3) a combination of both (TMDL 2016).
Measuring flow within the main stormwater pipes and correlating the flows with
bacteria levels in the bay might give the CARP Committee better information to
help develop timely public safety notifications at these beaches. Additionally,
along with rainfall data, stormwater flow data may be useful to better understand
the causes and sources of high bacteria levels at Cole and Ropes Parks, and for
implementing strategies to ultimately prevent further water quality degradation.
Data collected may also be used to help measure success of Management
Measures and Control Actions proposed elsewhere in the I-Plan.
•WHO: The CARP Committee envisions a cooperative effort including the City,
local universities, residents, and local research and data collection organizations
(i.e. Center for Coastal Studies, Coastal Bend Bays and Estuaries Program and
others to be determined).
•WHERE: The CARP Committee suggests a pilot project be installed within a
smaller sub-basin of the study area first, and then expanded to the Louisiana and
Brawner Parkway basins.
•GOAL: To collect stormwater flow data in order to correlate stormwater pipe
flow in cubic feet per second(cfs)with Enterococcus levels (cfu) to see if there are
any significant relationships. Ultimately, if a correlation is found, flow in the
stormwater system could be used as a proxy for alerting the public when to avoid
the water at Cole and Ropes Parks.
Texas Commission on Environmental Quality 34 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•WHEN: Planning and implementation within a pilot area could start upon
approval of the I-Plan and should be completed within Tier 1; evaluation of the
pilot project and application of methods the larger area should begin within Tier
1 to begin implementation in Tier 2. Data collection should continue throughout
the life of the I-Plan.
•HOW: Methods of data collection could include in-pipe laser flow meters,
Parshall Flumes, automated water flow meters, and other flow data collection
technology. Specific implementation proposals should be developed by entities
such as those listed in "WHO" section above or other as appropriate. The
influence of flow within the stormwater system should be taken into account
regardless of method of flow data collection. Detailed models of the effect of tides
on water levels through Corpus Christi Bay are available, and should be used in
conjunction with stormwater flow data to determine non-tidal portion of flow
within the system.
•COSTS/SOURCE OF FUNDS: Will vary depending on data collection
methods, funding sources, and responsible parties. Some equipment for this
purpose could be borrowed from the Center for Coastal Studies at no cost.
•RESPONSIBLE ORGANIZATION(S): To be determined
•ACTIONS AND SCHEDULE:
Table 13.MM 2.3. Conduct Stormwater Outfall Flow Sampling. Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Planning and Implementation of Pilot Project x
Planning for entire Cole and Ropes Parks basins x
Project Implementation for Entire Cole and x x
Ropes Parks Basins
Data Management and Maintenance x x x
Texas Commission on Environmental Quality 35 Peer Review Draft,Month,Day,Year
Table 14. Summary of Management Measure 2.0:Monitoring
Management Measure:Monitoring
Technical and
Financial Interim,
Management Potential Load Assistance Education Schedule of Measurable Indicators of Monitoring Responsible
Measure Reduction Needed Component Implementation Milestones Progress Component Entity
i
Monitoring
2.1)Continue TBD Grants Provide the Tier 1(1-5 years). Number of Continue current Continue EPA and TGLO
Sampling administered by public with samples Texas Beach bacterial
Enterococcus the laboratory at information collected. Watch Sampling monitoring at
Levels at Cole the Corpus about water Program. Cole and Ropes
and Ropes Christi-Nueces quality at Park.
Parks County Public recreational
Health District beaches.
2.2)Collect TBD Will vary Public Service Tier 1(1-5 years)- Develop a Planning and Collect accurate TCEQ
Rainfall Data depending on Announcements ongoing. database with implementation rainfall data in
Near Cole and data collection and create public rainfall and of rainfall close proximity to
Ropes Parks methods,funding education bacteria data. collection stormwater
sources,and material. program in a outfalls/drainage
responsible small pilot areas to provide
parties. project area to better
begin with and information on
then expand. the relationship
between bacteria
Data exceedances and
Management and stormwater flows.
Maintenance.
Texas Commission on Environmental Quality 36 Peer Review Draft,Month,Day.Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Ba
Technical and
Financial Interim,
Management Potential Load Assistance Education Schedule of Measurable Indicators of Monitoring Responsible
Measure Reduction Needed Component Implementation Milestones Progress Component Entity
2.3)Conduct TBD TBD Use data to alert Tier 1(1-5 years). Non-tidal flow Data is being Collect TBD
Stormwater public when data time series collected and stormwater flow
Outfall Flow bacteria levels After pilot project developed. reported(i.e. data in a pilot
Sampling may be high at plan and weekly,monthly, project area
Cole and Ropes implement quarterly) within Cole and
Park. program for Ropes Parks.
entire Cole and Data
Ropes Parks management and
basins. maintenance
Texas Commission on Environmental Quality 37 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Management Measure 3.0: Research
Bacteria levels at Cole and Ropes Parks (CARP) beaches are a concern for our
area, as reflected in the TMDL studies this I-Plan addresses. The TMDL study
provides a general description of the extent and character of bacteria exceedances
in the CARP area. Alone, however, this is not a sufficient basis for determining
the most cost-effective courses of action to achieve contact recreation standards
at these two beaches. This will undoubtedly be a dynamic process where we
continually expand our knowledge of the sources and effects of bacteria at these
beaches and where various management approaches are tested and refined. This
section identifies potential research topics that will be critical to this undertaking.
These topics are pertinent to the entire Corpus Christi Bay area, and are intended
to be implemented as resources become available. Research would be conducted
using appropriate methodology and quality assurance that have been developed
in consultation with TCEQ and EPA.
A variety of funding sources should be pursued,with a wide spectrum of partners.
It is unlikely that any one local entity will find it feasible to conduct this research
alone. Given the large-scale character of the undertakings, entities should look to
coordinate efforts with the various academic institutions in the area, federal and
state agencies like the EPA, Texas Department of State Health Services, water
and environmental research groups, and similar potential partners. A shared
project, the result of an inter-local agreement or similar instrument, may allow
local entities to feasibly investigate these issues. Parts of, or entire projects
described below could be undertaken by graduate students or researchers at local
universities and research institutions. Results of the following projects are
intended to be used for evaluation of the effectiveness of current and future I-
Plan Management Measures and Control Actions, as well as other measures
currently being undertaken by the City and other entities to reduce bacteria
loading in Corpus Christi Bay.
Because the results of the following research project will be instrumental in the
"adaptive-management" nature of this I-Plan, all research activities should begin
implementation as soon as possible in Tier 1. Results should be shared with the
CARP to be integrated into I-Plan revisions at the five-year review. The
applicability of this section for academic researchers' and graduate students'
research projects should not be overlooked.
The I-Plan's stakeholders identified six priority research topics which are listed
below:
Texas Commission on Environmental Quality 38 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Management Measure 3.1 : Evaluate Methods to Remove
Bacteria with Green Infrastructure
'WHAT: Green infrastructure is an approach that communities can choose to
maintain healthy waters, provide multiple environmental benefits and support
sustainable communities. Unlike single-purpose gray stormwater infrastructure,
which uses pipes to dispose of rainwater, green infrastructure uses vegetation
and soil to manage rainwater where it falls. By weaving natural processes into the
built environment, green infrastructure provides not only stormwater
management, but also flood mitigation, air quality management, bay debris
management, and much more. A green infrastructure feasibility study should be
completed for Cole and Ropes Parks to determine the impact of bacteria load
reduction at these beaches. Alternatives could include large and small scale
options from greenway redesign to rain gardens and rain water harvesting by
residents in single family homes.
•WHO: The City of Corpus Christi is the owner of the stormwater pipes, Cole
and Ropes Parks, Louisiana Parkway, Brawner Parkway, and should lead the
effort for initiating a green infrastructure feasibility study within these areas. An
engineering firm familiar with green infrastructure planning should be hired to
conduct the feasibility study.
'WHERE: A feasibility study looking at implementing green infrastructure
could be completed for the area surrounding Cole and Ropes Parks, including at
the major outfalls contributing flows at these beaches. Upstream areas (Louisiana
and Brawner Parkways) and possibly Brawner Parkway should also be included
in the study, as well as any small scale modifications and other viable concepts.
•GOAL: Complete a feasibility study in the Cole and Ropes Parks drainage
basins to implement green infrastructure concepts to reduce bacteria loading at
the beaches. Ultimately, if the study indicates to be cost-effective and significant
reduction in bacteria loads can be achieved through green infrastructure, then
the activities may be pursued for full construction implementation at appropriate
measures.
*WHEN: A feasibility study could be initiated and completed in Tier 1.
•HOW: Steps involved in this study could include the City of Corpus Christi
working with a contractor or researcher familiar with implementing green
infrastructure projects to conduct a feasibility study for Cole and Ropes Parks,
with the main goal of determining whether green infrastructure could be effective
at reducing bacteria loads at these beaches. The researcher should develop a list
of alternatives that could be implemented with an estimated percentage of
bacteria load reduction for each alternative and a cost associated with each. The
Texas Commission on Environmental Quality 39 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
CARP Committee could suggest next steps to the City staff and council based on
results from the feasibility study.
•COSTS/SOURCE OF FUNDS: Will vary depending on data collection
methods,funding sources, and responsible parties.
•RESPONSIBLE ORGANIZATION(S): None required
•ACTIONS AND SCHEDULE:
Table 15.MM 3.1. Evaluate Methods to Remove Bacteria with Green Infrastructure. Implementation
timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Initiate Feasibility Study _ x
at completion
Develop Recommendations of study
Management Measure 3.2: Bacterial Source Tracking
•WHAT: Further evaluate bacteria sources, persistence, and re-growth. To fully
comprehend the extent of contributions to bacterial loading at these beaches and
to focus future management actions targeting the largest sources of bacteria,
studies could use bacteria source tracking as a way to identify sources within the
CARP area.
•WHO: Personnel will collect the samples and ship them to an approved
Research and Testing Laboratory.
•WHERE: Sample the six TBWP sites pre and post rain events.
'GOAL: The goal of the study is to characterize the microbiome of the bay water
at the Cole and Ropes Parks locations and then compare the original samples
with samples collected after rain run-off to determine the biota of the organisms
and origin of the increased bacterial load. Results from this study will guide
implementation of subsequent bacteria reduction efforts.
'WHEN: Before a rain event and immediately post rain event. To be
implemented immediately upon approval of the I-Plan pending funding
availability;Tier 1.
•HOW:With use of the latest technology. To be determined.
•COSTS/SOURCE OF FUNDS: Funding is to be determined.
Texas Commission on Environmental Quality 40 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•RESPONSIBLE ORGANIZATION(S): None required
•ACTIONS AND SCHEDULE:
Table 16.MM 3.2. Bacterial Source Tracking.Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Sample collection; pre-rain event
x
Sample collection; post-rain event
x
Management Measure 3.3: Evaluate the Effectiveness of Public
Utilities Programs and Projects in Bacteria Reductions
•WHAT: Evaluation of the effectiveness of current and future public utility
programs and projects in the planning area will help demonstrate the relative
success of different management practices. This effort would draw from current
and proposed activities undertaken by the City of Corpus Christi's Phase 1 MS4
permit. The effectiveness studies would include both structural measures and
behavioral measures. Structural measures might be based on both traditional
drainage engineering, such as specifications for stormwater outfalls; and
sustainable infrastructure design methodologies, such as Green Infrastructure
and Low Impact Development. Behavioral measures might include, scope and
impact of public outreach, public reporting of illicit discharges, and other efforts
aimed at changing behaviors. The data collected and the results from the
comparative evaluations should be made available to all stakeholders.
•WHO: Researchers and/or consultants.
•WHERE: Within the watersheds of Cole Park, Ropes Park, and Brawner
Parkway.
•GOAL: To identify the effects of City programs on bacteria levels in the
watershed: Which City programs are the most and least effective in improving
water quality?
•WHEN: Tier 2.
•HOW: Record effectiveness of current stormwater programs and future
projects being implemented by using a list of success criteria for both structural
and behavioral measures.
•COSTS/SOURCE OF FUNDS: Will vary depending on data collection
methods,funding sources, and responsible parties.
Texas Commission on Environmental Quality 41 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi.
•ACTIONS AND SCHEDULE:
Table 17.MM 3.3. Evaluate the effectiveness of Public Utilities programs and projects in bacteria
reductions.Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Evaluate program and
project effectiveness x
through monitoring
Management Measure 3.4: Promote New Data Analysis Method
for Regulatory Justification for Listing Beaches on the 303(d)
List
Elevated bacteria levels at Cole and Ropes Parks during certain times of the year
(i.e. after rainfall events, etc.) pose a health risk to recreational users. For
regulatory use, a better methodology to justify the listing of these beaches on the
3o3(d) list should be considered rather than the current process of 25% of days
sampled. This Management Measure will provide two alternative methods for
analyzing data other than what is currently being implemented and should
provide better justification with regards to regulatory scrutiny.
•WHAT: Growing concerns about the health risks posed by polluted bathing
beaches, increased beach closures, and scientific evidence indicating an increase
in infectious diseases caused by microbial organisms in recreational waters
prompted the EPA to create the National BEACH Program. The goals of the
BEACH Program are to protect public health at the nation's beaches and to
ensure the public is notified when the risk for potential illness and disease is
present.
For regulatory purposes, (i.e. listing on the 3o3(d) list) the current sampling
regime is biased towards having higher days of elevated bacteria due to the
continuous return of daily sampling after bacteria levels are elevated until levels
have decreased below the threshold. For public safety this is a good sampling
method, but for listing beaches on the 3o3(d) list it is insufficient. There are a
couple of ways to address this: i) more sampling to account for"good" days when
bacteria levels are below the criteria or 2) count the series of sampling days in
row as an event, rather than separate days sampled. This would depict a more
accurate data set of high vs. low bacteria levels based on the current sampling
methodology.
•WHO: Cole and Ropes Parks Coordination Committee
Texas Commission on Environmental Quality 42 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•WHERE: State-wide
•GOAL: The goal is to improve and standardize listing methodology for
regulatory justification in listing beaches on the 3o3(d)list.
•WHEN: Tier 1 upon approval of the I-Plan.
•HOW: The CARP will request a review of statistical merit to the current data
analysis process of Texas Beach Watch Data for listing beaches on the 3o3(d) list.
Amendments to the way the TCEQ evaluates the listing of 3o3(d) beaches based
on TBWP data would need to be discussed and approved by both TCEQ and the
EPA. This change would affect the entire state of Texas and not just Cole and
Ropes Parks.
•COSTS/SOURCE OF FUNDS: Technical and legal assistance may be
required. Funding to be determined
•RESPONSIBLE ORGANIZATION(S): EPA, TCEQ, GLO, City of Corpus
Christi.
•ACTIONS AND SCHEDULE:
Table 18. MM 3.4. Promote new data analysis method for regulatory justification for listing beaches
on the 303(d)list. Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Change data review methodology for
regulatory purposes
Management Measure 3.5: Identify Water Flow Patterns in
Corpus Christi Bay at Cole and Ropes Parks by the Use of Dye
Testing
Water flow patterns within Corpus Christi Bay may have a significant effect on
the bacterial occurrence at Ropes and Cole Parks. Stormwater loading from the
Brawner and Louisiana Parkway outfalls may be the largest contributors of
bacteria to Corpus Christi Bay due to watershed size and geographic extent, and
location and size of their ultimate outfalls.
•WHAT: Rhodamine dyes have been used over the years in water flow and
particle research. By placing probes that can detect this dye north of the Brawner
drainage outfalls and adding this dye to the Brawner Parkway drainage system
prior to rain events.
•WHO: Texas A&M University-Corpus Christi has several departments and
divisions with researchers that have equipment and expertise to conduct a water
flow study using dye methods.
Texas Commission on Environmental Quality 43 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•WHERE: Two to four areas between Brawner Parkway outfall and Ropes Park.
•GOAL: The goal is to understand the impact of the Brawner Parkway outfall
discharges at Ropes Park on bacteria levels and ultimately focus resources toward
the area of most influence.
•WHEN: Ideally, the dye testing could be conducted during or immediately
following several rain events within the study area. The data required to establish
a correlation between the Brawner discharges and the sampling taken at Ropes
Park should determine the spatial and temporal criteria.
•HOW: Research contractors would develop a monitoring regime that should be
able to discern whether the large outfalls have a direct impact on the sampling
conducted at Ropes Park. Two to four probes could be placed within the study
area until data could be collected from rain events. These may need to be moved
at various times to provide a better picture of the water flow.
•COSTS/SOURCE OF FUNDS: Since there is not an abundance of public or
private funds, grant funding would be required. A project through the Coastal
Bend Bays&Estuaries Program (CBBEP) or CMP could be applied for to fund the
research conducted by an appropriate group from TAMUCC. Purchase and install
two to four probes that can be used with Rhodamine dye (approximately $3.7K
each), Collect data and move probes as needed to develop a good concept of water
flow during rain events ($ioK), develop report with conclusions on impact of
Brawner drainage outfall on GLO sampling locations at Ropes Park. Total cost is
estimated at $32K for the entire project.
•RESPONSIBLE ORGANIZATION(S): Dependent upon the organization
that conducts this study and if the grant or project funding requires approval of a
QAPP or similar plan.
•ACTIONS AND SCHEDULE:
Table 19.MM 3.5. Identify water flow patterns in Corpus Christi Bay at Cole and Ropes Parks by the
use of dye testing.Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Planning and Implementation of Dye Testing
Procedure
Management Measure 3.6: Change Sampling Date of Current
Texas Beach Watch Program to be More Protective of Public
Health
Elevated bacteria levels at Cole and Ropes Parks during certain times of the year
(i.e. after rainfall events, etc.) pose a health risk to recreational users. The public
Texas Commission on Environmental Quality 44 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
health issue that needs to be addressed is the time of week the beaches are
sampled for public health safety. Sampling of Cole and Ropes Parks needs to
occur closer to the weekend when the public will be using these beaches, rather
than on a Tuesday as is the current sampling protocol. This will help ensure
public safety.
•WHAT: Growing concerns about the health risks posed by polluted bathing
beaches, increased beach closures, and scientific evidence indicating an increase
in infectious diseases caused by microbial organisms in recreational waters
prompted the EPA to create the National BEACH Program. The goals of the
BEACH Program are to protect public health at the nation's beaches and to
ensure the public is notified when the risk for potential illness and disease is
present. The Texas Beach Watch Program currently samples Cole and Ropes
Parks beaches on Tuesday, when public use of these beaches is likely the lowest.
Changing the sampling of these beaches closer to the weekend (i.e. Thursday or
Friday) when the public is more likely to be utilizing these areas would ensure
more timely notification of elevated bacteria levels to the public.
•WHO: For Cole and Ropes Parks, the Texas Beach Watch Program is
administered by the laboratory at the Corpus Christi-Nueces County Public
Health District (CCNCPHD). The GLO would need to agree to changing sampling
days closer to the weekend for these beaches.
•WHERE: Four sites are located at Cole Park and two at Ropes Park.
•GOAL: The goal is to provide the public with better timed information about
water quality at the recreational beaches of Cole and Ropes Parks.
*WHEN: Water samples are collected weekly during the beach season (currently
May-September) and biweekly during the off-season (October-April). Samples at
Cole and Ropes Parks beaches are currently being collected on Tuesday. Change
the sampling days to Thursday or Friday.
•HOW: For Cole and Ropes Parks, the Texas Beach Watch Program is
administered by the laboratory at the CCNCPHD. The GLO would need to agree
to changing sampling days closer to the weekend for these beaches.
•COSTS/SOURCE OF FUNDS: Will vary depending on data collection
methods,funding sources, and responsible parties.
If collection days were changed to Thursday, then the results would be out on
Friday and would reflect the levels on Thursday and may better reflect weekend
values unless it rained after Thursday collection. This is important only after an
accurate analysis is conducted and documented that the primary contact
recreational users increase on weekends to a level for that site to remain as a
primary recreational water site.
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Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•RESPONSIBLE ORGANIZATION(S): The local Beach Watch grant was
awarded to Nueces County and operated by the Corpus Christi-Nueces County
Public Health District. Local government representatives make the necessary
beach notifications upon receipt utilizing the provided signage.
•ACTIONS AND SCHEDULE:
Table 20. MM 3.6. Change sampling date of current TX Beach Watch Program to be more protective
of public health. Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Texas Beach Watch sampling day change x
Texas Commission on Environmental Quality 46 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Ba
Table 21. Summary of Management Measure Research
Management Measure:Research
Technical
and
Financial Interim,
Management Potential Load Assistance Education Schedule of Measurable Indicators of Monitoring Responsible
Measure Reduction Needed Component Implementation Milestones Progress Component Entity
Research
3.1)Evaluate Methods TBD TBD Provide public Tier 1(1-5 After study is Initiate Feasibility No monitoring City of Corpus
to Remove Bacteria with activities Years). complete CARP Study Christi,CARP
with Green they can will recommend Modeling
Infrastructure implement at green Develop exercise
home to infrastructure Recommendations
reduce alternatives to
bacteria. City.
City will
implement
green
infrastructure
within the City.
3.2)Bacterial Source TBD TBD Provide public Tier 1(1-5) Utilize results Identify the Use identified TBD
Tracking with sources Years) to identify microbiome of bay source tracking
of bacteria possible water samples. methods to
and contamination evaluate
information sources. sources of
on they can bacteria
help reduce
bacteria
Texas Commission on Environmental Quality 47 Peer Review Draft,Month,Day.Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Technical
and
Financial Interim,
Management Potential Load Assistance Education Schedule of Measurable Indicators of Monitoring Responsible
Measure Reduction Needed Component Implementation Milestones Progress Component Entity
3.3)Evaluate the TBD TBD Notify public Tier 1-2(1-10 Measure the Evaluate program Gather City of Corpus
Effectiveness of Public of successful Years). effectiveness of and project pertinent Christi,
Utilities Programs and programs the program and effectiveness information on
Projects in Bacteria City is project and through activities for
Reductions implementing. modify monitoring. programs that
management could help
practices and reduce bacteria.
projects to
improve
effectiveness.
3.4)Promote New Data TBD EPA Notify public Tier 1-2(1-10 Date review Change data Review data TCEQ,EPA,
Analysis Method for of methods for Years). changed. review analyzing CARP
Regulatory evaluating methodology for method for
Justification for Listing beaches water Fewer beaches regulatory better
Beaches on the 303(d) quality. and water purposes. justification for
List bodies listed for characterizing
bacteria on the beach water
3o3d list due to quality.
more accurate
characterization
of conditions of
water body.
3.5)Identify Water TBD TBD Show visual Tier 1(1-5 Identify focus Identification of Implement dye TBD
Flow Patterns in maps of where Years). for future water flow testing during
Corpus Christi Bay at water flows action by City if patterns. rain events and
Cole and Ropes Parks along the Brawner outfall monitor flow.
by the use of Dye beach, can be shown to
Testing especially have large
after rain influence on
events. Ropes Park
sampling.
Texas Commission on Environmental Quality 48 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Ba
Technical
and
Financial Interim,
Management Potential Load Assistance Education Schedule of Measurable Indicators of Monitoring Responsible
Measure Reduction Needed Component Implementation Milestones Progress Component Entity
3.6)Change Sampling TBD TBD Already Tier t(1-5 Sampling days Texas Beach None City of Corpus
Date of Current Texas incorporated Years) changed so Watch sampling Christi,Texas
Beach Watch Program into the TBWP notifications day change. Beach Watch
to be More Protective which is the are more Program and
of Public Health TBWP website protective on Corpus Christi
weekends. Nueces County
Public Health
District
Texas Commission on Environmental Quality 49 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Management Measure 4.0: Wastewater Collection
Systems
Sanitary sewers can fail to function properly due to blockages,line breaks, defects
that allow stormwater and groundwater to overload the system, lapses in
operation and maintenance, inadequate design and construction, power failures,
deferred replacement, and vandalism. The EPA has concluded that sanitary sewer
overflows (SSOs) contribute to bacteria loading in almost all impaired streams,
but may or may not be a primary source of loading. EPA acknowledges that SSO
data is difficult to assess.
In general, implementation actions consist of encouraging improvements to
sanitary sewers through hydraulic modeling and completing an inflow and
infiltration study; reducing the amount of fats, oils, and grease entering the
system; continuing sanitary sewer line cleaning; and reporting of SSOs to the
TCEQ.These reports are public information and are available from the TCEQ.
Management Measure 4.1 : Enhance Existing Fats, Oil &
Grease Program
Fats, oil, and grease (FOG) are considered to be a leading cause of blockages in
sanitary sewers, and the EPA estimates that blockages account for nearly 5o
percent of all SSOs nationwide. This Management Measure enables the City of
Corpus Christi to determine the proper size and design for grease interceptors, to
inspect traps regularly, and to require grease interceptors be effectively
maintained by businesses.
•WHAT: Almost all of the City's Food Service Establishments (FSE) are required
to have a grease interceptor and this is initially enforced by Development Services
through the building permit process. Thereafter, FSEs are inspected annually by
the City's Pretreatment staff. Inspections include reviewing manifests for grease
interceptor cleaning frequency and analyzing Hexane Extractible Material (HEM)
levels,which cannot exceed 200 mg/l. The hexane solvent methodology is used to
measure total oils and grease. A Notice of Violation is sent to FSEs where
exceedance is observed, with a requirement to increase the interceptor cleaning
frequency. Continued exceedances may result in a requirement for a larger or
more effective interceptor.
On inserts included in City utility bills, at Earth Day Bay Day and similar events
throughout the City, residents receive information on problems associated with
disposing of grease down drains and are advised to avoid this practice. The City
provides fat trapper containers and bags at no charge to attendees at public
events.
Texas Commission on Environmental Quality 50 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•WHO: City of Corpus Christi Public Utilities, Corpus Christi- Nueces County
Health Department, Food Service Establishments (FSE Program).
•WHERE:All FSEs in the Cole and Ropes Parks contributing drainage areas.
•GOAL: Reduce or eliminate SSOs resulting from blockages caused by FOG
through monitoring and enforcement of the City's ordinances prohibiting grease
input into the wastewater collection system
•WHEN: Implementation beginning in Tier 1 and continuing.
•HOW: Through continuing efforts in the City's FOG program, enhanced by
increased enforcement.
•COSTS/SOURCE OF FUNDS: Approximately $400,000 annually, in the
range of Public Utilities operating budget.
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi Public Utilities
Department
•ACTIONS AND SCHEDULE:
Table 22.MM 4.1. Enhance existing Fats,Oil&Grease(FOG) program. Implementation timeline
schedule.
Actions Tier 1 Tier 2 Tier 3
Continue Food Service HEM Monitoring x x x
Continue Food Service Grease Interceptor
Maintenance Enforcement x x x
Management Measure 4.2: Continue the Notification System for
Monitoring Sanitary Sewer Overflows (SSOs)
•WHAT: All SSOs are reported by the City's Public Utilities Department to the
TCEQ. It is City policy that all reported overflows are repaired or addressed. The
intent of this Control Action is to continue the SSO reporting and notification by
the City of Corpus Christi to TCEQ. Other interested groups could be included in
the future.
•WHO: The City of Corpus Christi Public Utilities Department
•WHERE: The main priority area would be within the Cole and Ropes Park
drainage basin and include Brawner Parkway drainage basin.
•GOAL: Continue reporting of SSOs.
Texas Commission on Environmental Quality 51 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•WHEN: Implementation beginning in Tier 1 and ongoing.
•HOW: Continue reporting SSOs as is currently being done to date.
•COSTS/SOURCE OF FUNDS: The costs associated with SSO reporting to the
TCEQ by the City are included in the Public Utilities Department's annual
operating budget.
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi, a Municipal
Corporation with Home Rule Authority to act in all ways not specifically
prohibited by the State of Texas and State Constitution; TCEQ implementation of
federally delegated TPDES permitting authority under Texas Clean Water Act;
USEPA, National Pollutant Disposal Elimination System program, implementing
the federal Clean Water Act.
•ACTIONS AND SCHEDULE:
Table 23.MM 4.2.Continue and Expand the Notification System for Monitoring Sanitary Sewer
Overflows(SSOs). Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Continue SSO Reporting x x x
Management Measure 4.3: Expand Collection System Line
Cleaning, Inspection, Repair and Rehabilitation
The City of Corpus Christi has an on-going program of cleaning and televised
inspecting its wastewater collection system. This is part of the Wastewater
Department's maintenance and operation plan for improved performance.
Through cleaning and televising, the City can optimize repairs/rehabilitation
efforts to meet TCEQ permit requirements. In addition to continuing this
program, the CARP Committee recommends developing additional monitoring
techniques that may be more accurate or cost effective such as smoke detection.
'WHAT: Maintenance of lines is a Public Utilities Department function to assure
improved performance to its 83,000 customers who depend on this service every
day.
'WHO: The Public Utilities Department, along with competitively bid contracts,
provides the forces to maintain the City's collection system. Additional projects
(e.g. such as a smoke detection pilot project) could be undertaken by research
entities such as graduate students or local environmental groups.
•WHERE: Annually,the Public Utilities Department assesses areas of the City to
determine need for improved maintenance and repairs. Areas needing
replacement are placed on the Capital Improvements Program (CIP) plan for bid
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Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
solicitation. Also, database reviews occur to resolve problematic areas in the
system. Pilot projects or expansion of the current program should be focused on
the Cole and Ropes Parks drainage basins.
•GOAL: Prevent overflows and increase system capacity.
•WHEN: Implementation beginning in Tier 1 and continuing.
•HOW: Generally, through cleaning and closed circuit televising (CCTV), smoke
detection surveys, and customer complaints of affected areas, resolution of
problems and improvements of the systems are accomplished.
•COSTS/SOURCE OF FUNDS: Corpus Christi Public Utilities Department.
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi, a Municipal
Corporation with Home Rule Authority to act in all ways not specifically
prohibited by the State of Texas and State Constitution.
•ACTIONS AND SCHEDULE:
Table 24. MM 4.3. Expand Collection System Line Cleaning, Inspection, Repair and Rehabilitation.
Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Continue Customer Response x x x
Review Funding for Line Cleaning x x x
Increase Funding for Smoke Testing x x x
Management Measure 4.4: Implement an Ongoing Inflow and
Infiltration Study
The City of Corpus Christi has an on-going City—wide flow monitoring program
to prioritize ranking of sub-basins based on various factors such as Rainfall
Dependent Inflow/Infiltration (RDII), SSOs, and maintenance history. The
monitoring program is intended to address issues which may cause a negative
impact on human health and safety or the environment. The City is further
developing a program to determine needed wastewater infrastructure
modifications/improvements to ensure adequate collection system conveyance
capacity.
•WHAT: Rainfall Distribution analysis and recorded wet weather flow data, the
gallons of RDII and other variables will establish the magnitude of wet weather
inflow in order to prioritize sub-basins for future testing and rehabilitation.
Texas Commission on Environmental Quality 53 Peer Review Draft,Month,Day,Year
•
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•WHO: The Public Utilities Department, along with competitively bid contract
services, provides the forces to maintain the City's collection system.
'WHERE: All areas of the City to determine need for improved maintenance
and repairs.
'GOAL: Development of long-term Infiltration/Inflow (I/I) program to find and
fix system defects.
'WHEN: The I/I study is part of the CMOM (Capacity Assurance, Management,
Operation and Maintenance) self-audit, following EPA guidance criteria, an
ongoing SSO initiative project. It will precede and be incorporated into the
hydraulic modeling project.
•HOW: I/I studies will be conducted by the City.
'COSTS/SOURCE OF FUNDS: Funding for the I/I studies will be provided by
the City.
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi, a Municipal
Corporation with Home Rule Authority to act in all ways not specifically
prohibited by the State of Texas and State Constitution; TCEQ implementation of
federally delegated TPDES permitting authority under Texas CWA; USEPA,
NPDES program, implementing the federal CWA; state and federal Solid Waste
Acts to regulate wastewater collection, treatment, and disposal.
•ACTIONS AND SCHEDULE:
Table 25.MM 4.4. Implement an Ongoing Inflow and Infiltration Study. Implementation timeline
schedule.
Actions Tier 1 Tier 2 Tier 3
Identify Flow Monitoring Site Locations x x x
Conduct Flow Monitoring x x x
Data Collection and Analysis x x x
Management Measure 4.5: Conduct Hydraulic Modeling of
Collection System
The City of Corpus Christi has an on-going Capacity Assurance, Management,
Operation and Maintenance (CMOM- a self-audit process developed and
recommended for use by the EPA) program to address issues which may cause a
negative impact on human health and safety or the environment and is
developing a comprehensive City—wide hydraulic model of the wastewater
collection system. The hydraulic model will facilitate understanding the root
Texas Commission on Environmental Quality 54 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
causes of factors contributing to bacteria in the bay, aid in development of system
improvements, produce informational maps/exhibits, and will recommend the
system's response to future improvements.
•WHAT: A hydraulic wastewater system model will equip the wastewater
department with the tool for analyzing system conveyance capacities,
bottlenecks, and potential overflow locations.
•WHO: The Public Utilities Department, along with a competitively bid contract
provide the forces to maintain the City's wastewater collection system.
•WHERE: The modeling project will be broken into two phases based on the
treatment plant service areas of greatest priority. Phase 1 will consist of Oso,
Greenwood, and Broadway Wastewater Treatment Plants (WWTP) service areas.
'GOAL: The Goal is to prevent overflows and increase system capacity
•WHEN: The project is to be performed in a timely manner consistent with
sound professional practices. Both phases are anticipated to be complete in
future years.
'HOW: The hydraulic model will enable the City to assess any potential capacity
constraints and to develop strategies to optimize system performance to meet
TCEQ permit requirements. The professional engineering consultant, if needed,
should be chosen on the basis of competency rather than low bid.
•COSTS/SOURCE OF FUNDS: Funding Implementation for the Citywide
hydraulic model will be through A/E (Architecture/Engineer) professional
services engineering contracts in the amount of $2,000,000. Funding for this
Control Action is to be determined but may be provided by a grant from TCEQ or
EPA.
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi, a Municipal
Corporation with Home Rule Authority to act in all ways not specifically
prohibited by the State of Texas and State Constitution; TCEQ implementation of
federally delegated Texas Pollutant Disposal Elimination System permitting
authority under Texas Clean Water Act; USEPA, National Pollutant Disposal
Elimination System program, implementing the federal Clean Water Act; state
and federal Solid Waste Acts to regulate wastewater collection, treatment, and
disposal.
•ACTIONS AND SCHEDULE:
Table 26.MM 4.5. Conduct Hydraulic Modeling of Collection System. Implementation timeline
schedule.
Actions Tier 1 Tier 2 Tier 3
Texas Commission on Environmental Quality 55 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Phase 1 Modeling-Oso, Greenwood, and
Broadway WWTP Basins X
Data Analysis, Reporting, and
Recommendations X x
Texas Commission on Environmental Quality 56 Peer Review Draft, Month, Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Ba
Table 27. Summary of Management Measure:Wastewater Collection Systems
Management Measure:Wastewater Collection System
Technical
and
Potential Financial Interim,
Load Assistance Education Schedule of Measurable Indicators of Monitoring Responsible
Management Measure Reduction Needed Component Implementation Milestones Progress Component Entity
Wastewater Collection System
4.1.)Enhance Existing Fats, TBD City of Continue generator Tier 1-ongoing. Decreased Increased Food Service Continue to Partnership
Oil&Grease(FOG) 1 Corpus education directed Continue FOG Grease Interceptor monitor among City of
Program Christi to permitees and current program associated Maintenance Enforcement. FSE's. Corpus Christi
Public citizens. overflows. Public Utilities,
Utilities Food Corpus Christi-
, operating Service Nueces County
budget HEM Health
Monitoring. Department,
Food Service
Establishments
(FSE
Program).
4.2)Continue the TBD City of Notification to Tier 1-ongoing. TCEQ Continue reporting SSOs to Monitor City of Corpus
Notification System for Corpus TCEQ;this entity compliance. TCEQ number of Christi Public
Monitoring Sanitary Sewer Christi may choose further reported Utilities
Overflows(SSOs) Public outreach/education SSO's to Department
Utilities activities. TCEQ
operating
budget
Texas Commission on Environmental Quality 57 Peer Review Draft,Month,Day,Year
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Technical
and
Potential Financial Interim,
Load Assistance Education Schedule of Measurable Indicators of Monitoring Responsible
Management Measure Reduction Needed Component Implementation Milestones Progress Component Entity
4.3)Expand Collection TBD City of Notify public on Tier s-ongoing Continued Reduced number of overflow Continue City of Corpus
System Line Cleaning, Corpus collection system customer events. monitoring Christi
Inspection,Repair and Christi line cleaning. response. and
Rehabilitation Public response.
Utilities Funding for
operating line
budget cleaning
reviewed.
Funding for
smoke
testing
increased.
Number of
repaired
broken
lines.
4.4)Implement an Ongoing TBD City of Provide data Tier t-ongoing. Ranking of Determine flow monitoring Conduct City of Corpus
Inflow and Infiltration Corpus results from I/I meter sub- site locations. flow Christi
Study Christi study to the public. basins. monitoring
Public Conduct flow monitoring.
Utilities Preparation
operating of sanitary Data collection and analysis.
budget sewer
evaluation Analyze Flow and Infiltration
survey. Data to determined where
wastewater infrastructure
I/I study modifications/improvements
report to ensure adequate collection
completed. system conveyance capacity
are needed.
Texas Commission on Environmental Quality 58 Peer Review Draft,Month,Day,Year
is
Technical
and
Potential Financial Interim,
Load Assistance Education Schedule of Measurable Indicators of Monitoring Responsible
Management Measure Reduction Needed Component Implementation Milestones Progress Component Entity
4.5)Conduct Hydraulic TBD City of Provide data Tier 1 Reduction Data collection and analysis. Conduct Public Utilities
Modeling of Collection Corpus results from in sanitary Flow Department
System Christi hydraulic modeling sewer TCEQ compliance. Monitoring and
Public study to the public overflows. contractors.
Utilities Development of prioritized
operating Collection system improvement
budget system programs.
capacity
assurance
Ranking of
sub-basins
based on
I/I.
Texas Commission on Environmental Quality 59 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Management Measure 5.0: Stormwater Drainage
System
Existing requirements of Municipal Separate Storm Sewer System (MS4) permits
address some important elements of bacteria loading in stormwater, offering an
adaptive rather than prescriptive approach to bacteria reduction. Although not
required under the MS4, Structural Best Management Practices (BMPs), such as
modifications to stormwater outfalls may reduce bacteria through aeration,
treatment by sunlight, or physical removal of contaminants, and have the
potential to reduce bacteria loading into waterways. However, there is limited
data regarding how well such BMPs (i.e. green infrastructure) might reduce
bacteria loading. Therefore, the CARP Committee has identified the evaluation of
the effectiveness of green infrastructure as one of its priorities.
Management Measure 5.1 : Determine Effectiveness of
Stormwater Retrofits* to Remove Bacteria
Fecal indicator bacteria such as Enterococcus in urban stormwater originate from
feces of warm blooded animals deposited in the watershed. These bacteria may be
directly deposited into the receiving water or carried to the receiving water by
stormwater runoff. Bacteria may persist for extended periods of time outside of a
warm-blooded host in sediments, biofilms, and organic litter in stormwater
facilities, pipes and media. Understanding sources of bacteria is important in
selecting appropriate BMPs targeted to these sources. Managing the source
should be the first strategy implemented. A variety of guidance and techniques
exist for conducting bacteria source tracking, ranging from relatively straight
forward illicit discharge screening to complex microbial source tracking (MST)
studies.
As funding is identified and becomes available the City of Corpus Christi should
perform a small scale pilot program on a public improvement project using a site-
specific engineered stormwater retrofit in Cole and Ropes Park Stormwater
drainage basin. (*Retrofits are defined as "stormwater treatment practices in
stream corridors or upland areas to capture and treat stormwater runoff before it
flows into the receiving water".
(EPA 2007; www.cwp.org; www.stormwatercenter.net).
As part of this small scale pilot program, the City should undertake a detailed
survey of the stormwater collection system in one or two of the small drainage
basins in the study area, including either smoke testing or televising the
stormwater sewer lines, to determine whether illegal cross connections or
leaking/broken private sewer laterals are contributing sewage to the stormwater
collection system. Retrofits which may assist in reducing bacteria concentrations
Texas Commission on Environmental Quality 60 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
in stormwater include diverting flows through constructed wetlands, exposing
previously underground flows to sunlight, or diverting runoff to wet ponds. There
is a need for additional research into the effectiveness of removing bacteria from
stormwater runoff with retrofits to existing infrastructure in urban environments.
The results of this pilot project should be used to determine if retrofits to existing
infrastructure are effective in reducing Enterococcus levels in stormwater runoff.
•WHAT: The purpose of this implementation activity is to determine the
feasibility of reducing bacteria concentrations from urban runoff by retrofitting
existing infrastructure and evaluating the level of bacteria removal. When a
funding source becomes available, the City may perform a small scale pilot
program on a public improvement project using a site specific engineered
stormwater retrofit to determine if such retrofit is effective at reducing
Enterococcus bacteria.
•WHO:The City of Corpus Christi
•WHERE: Cole and Ropes Parks Stormwater drainage basin. The pilot project
should be developed on City-owned property. Site specific pilot project location
to be determined with assistance of an engineering consulting firm.
•GOAL: Determine if stormwater retrofit(s) can effectively reduce bacteria in
stormwater runoff.
•WHEN: Tier 1.
•HOW: The City of Corpus Christi should hire an engineer experienced in
designing stormwater retrofits for pollutant reduction. The City or the City's
designee will monitor the bacteria levels at the inflow and outflow of the retrofit
and report findings to the CARP committee.
•COSTS/SOURCE OF FUNDS: Estimated cost ($75,000). Source of funding
to be determined.
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi
•ACTIONS AND SCHEDULE:
Table 28.MM 5.1.Determine Effectiveness of Stormwater Retrofits to Remove Bacteria.
Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Conduct Pilot Project x
x
at
Develop Recommendations for Further completion x
Stormwater Retrofits of pilot study
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Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Management Measure 5.2: Continue the Major Outfall
Assessment and Repair Program as Funding Allows
There are eight major stormwater outfalls and more than 8o other outfalls that
allow stormwater runoff to flow into Corpus Christi Bay. In 2003, 13.5 miles of
these outfall structures were inspected and improvements and repairs were made
to four outfalls.
•WHAT: Continue the ongoing Major Outfall Assessment and Repair program
instituted by the City of Corpus Christi, as funding allows.
•WHO: The City of Corpus Christi
•WHERE: First priority should be outfalls in Cole and Ropes parks.
•GOAL: To continue the ongoing maintenance and repair, as needed, of
stormwater outfalls which may influence segments of Corpus Christi Bay at Cole
and Ropes Parks. Verifying the integrity and function of such outfall structures
will ensure the carrying capacity of the system is protected, while minimizing
sediment deposition due to physical defects and system failures. As funding and
technological advances become available, the City should evaluate the feasibility
of retrofitting structurally unsound outfalls to incorporate water quality
improvements.
•WHEN:As voters and City Council approve funding for the program.
•HOW: Continue existing Capital Improvement Program to assess the condition
of major outfalls. Condition assessments should rank and prioritize outfall
repairs or replacements needed. When major repairs or replacement are
warranted,the project should be evaluated to determine the feasibility of retrofits
for water quality improvements.The engineer should develop a list of alternatives
that could be implemented to project water quality improvements.
•COSTS/SOURCE OF FUNDS: To be determined by infrastructure condition
monitoring, source of funding for retrofits to be determined.
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi, a Municipal
Corporation with Home Rule Authority to act in all ways not specifically
prohibited by the State of Texas and State Constitution.
Texas Commission on Environmental Quality 62 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•ACTIONS AND SCHEDULE:
Table 29.MM 5.2.Continue the Major Outfall Assessment and Repair Program as Funding Allows.
Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Assess Outfalls Within CARP Area x
Develop Repair/Retrofit Recommendations x
Management Measure 5.3: Support and Encouraqe the
Adoption of Stormwater Master Plan
The City is proceeding with adoption of a stormwater master plan. In April 2013,
the Level of Service for the SWMP was presented and approved by Corpus Christi
City Council. The Level of Service, which is the first step in adopting the SWMP
and is a Council level policy approval item, allows City Departments the ability to
proceed with developing design standards and updating maps. The approved
Level of Service and the SWMP are predicates to amending existing development
and construction codes to reflect adopted changes. The City will be re-engaging
with a design consultant to assess the impact of the revised level of service and
feasibility of incorporating stormwater quality criteria in the master plan.
•WHAT: Encourage City leadership and staff to adopt the Stormwater Master
Plan, develop design standards and modify City Code of Ordinances as needed.
•WHO: The City of Corpus Christi's Development Services, Capital Programs
and Public Utilities Departments.
•WHERE: Within the corporate boundaries of the City of Corpus Christi
•GOAL: Adoption of a SWMP that incorporates water quality protection
incentives.
•WHEN: Tier 1. Within 5 years of the approval of this I-Plan and securing
funding for this activity.
•HOW: With the engagement of community groups and support of interested
stakeholders to be involved in Plan CC and other long-term City planning efforts.
•COSTS/SOURCE OF FUNDS: To be determined.
•RESPONSIBLE ORGANIZATION(S): CARP, CBBF, CBBEP, and other
similar interested organizations.
Texas Commission on Environmental Quality 63 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•ACTIONS AND SCHEDULE:
Table 30. MM 5.3. Support and Encourage the Adoption of Stormwater Master Plan. Implementation
timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Support and Encourage Stakeholder Activity
Leading to the Adoption of the Stormwater x x x
Master Plan
Hold Community-wide Workshop for x x x
Developing Stormwater Master Plan Support
Create a Stakeholder Master Plan Support
Team
Texas Commission on Environmental Quality 64 Peer Review Draft,Month, Day,Year
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Table 31. Summary of Management Measure:Stormwater Drainage System]
Management Measure.Stormwater Drainage System
Technical
and
Financial Interim,
Potential Load Assistance Education Schedule of Measurable Indicators of Monitoring Responsible
Management Reduction Needed Component Implementation Milestones Progress Component Entity
Stormwater Drainage System
5.1)Determine Effectiveness TBD TBD Educate public Tier 1 CARP will Initiate a Assess retrofits City of Corpus
of Stormwater Retrofits to on Stormwater develop pilot study annually to Christi
Remove Bacteria Retrofits recommendations for outfall determine if
based on the data assessments. repairs are
collected in the needed
pilot study.
Effective bacteria
removal.
5.2)Continue the Major TBD TBD Notify public Tier i Assessments Outfall Continue the City of Corpus
Outfall Assessment and about the completed. assessment assessment Christi
Repair Program as Funding repair program. program as
Allows program and funding permits
provide results Engineer to other basins
from the recommends affecting the
assessment alternatives CARP area.
to City
5.3)Support and Encourage TED City of Make the Tier 1 Adoption of a Improved Review City of Corpus
the Adoption of Stormwater Corpus Stormwater Stormwater Stormwater Stormwater Christi
Master Plan Christi Master Plan Master Plan management Master Plan
available to within the annually and
public once Evaluate the watershed determine if
adopted effectiveness from revisions are
a water quality needed
and cost
perspective
Texas Commission on Environmental Quality 65 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Management Measure 6.0: Ordinance and Regulation
Source tracking should be the FIRST implementation activity before any other
engineering solutions, etc. to determine how to order/prioritize further activities.
The information obtained in the pilot program described in 5.1 should be utilized to
determine whether illegal cross connections or broken or leaking wastewater laterals are
providing a source of bacteria within the target basins and whether Management
Measures 6.1-6.3 are needed.
Management Measure 6.1 : Residential Leaking/Broken Private
Sewer Laterals Pre-Sale lnspection/Testinq Program
•WHAT: Residential properties have been identified as a potential source of
wastewater and other wastes materials that could result in bacteria into the City's MS4.
Old, leaking, broken, or improperly installed or maintained private wastewater sewer
lines on the property that allow wastewater to infiltrate into the MS4 are a primary
concern.
Establish a targeted inspection program for private sewer lines, within the drainage
basins contributing flows to the TMDL program area, to test private sewer lines to make
sure they do not have any leaks or breaks, and require by law the repair of substandard
private sewer lines, also known as private laterals. Lateral failures are often latent
defects, not seen, until raw sewage reaches premises surfaces or floods the interior of a
home. Sellers can mask such problems or fail to disclose.
•WHO: City of Corpus Christi
•WHERE: Within drainage basins that discharge into the TMDL study area, and any
immediately adjoining drainage basins.
'GOAL: Within 10 years, reduce or eliminate all leaking or broken private sewer lines
within the drainage basins that discharge within the TMDL.
'WHEN: Develop, adopt and implement a targeted private sewer line inspection
program within five years of adoption of the I-Plan. Undertake and complete review of
City's Technical Construction Codes and Housing Standards Code, identify sections that
need to be amended to further the stated goal and prepare and present for adoption the
ordinances necessary to amend the codes during the next technical construction codes
update process.
• HOW: see a.) and b.)below
a. Leaking Private Sewer Line Inspection Program using Hydrostatic
or Televised Testing. Pilot Project. Utilizing the information obtained in the
Texas Commission on Environmental Quality 66 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
pilot program described in 5.1, determine whether broken or leaking private
wastewater lateral systems are providing a source of bacteria by infiltration into
stormwater collection systems in the target basins.
Establish an enhanced, targeted inspection program for private sewer lines,
within the drainage basins contributing flows to the TMDL program area, to test
private sewer lines to make sure they do not have any leaks or broken sewer lines,
and mandate repair of substandard private sewer lines, also known as private
laterals. (Note: Inspection program could be conducted by licensed plumbers or
other certified entities. This is an appropriate requirement prior to a change of
house ownership, to enable a new owner to be aware of an actual problem and
not be misled into an expensive surprise to correct failed plumbing. Often,
plumbing problems are ignored after a purchase because the new owner has no
budget to fund expensive corrections. The current system allows "latent" defects
to be passed on to a new owner.There is no leverage or requirement for plumbing
inspections.)
b. Code Updates. Update City's Building and Housing Standards Code,
especially, as they relate to the issue of leaking/broken underground sewer lines.
•COSTS/SOURCE OF FUNDS: Costs to the City of Corpus Christi are to be
determined. (Adopt by ordinance the necessary regulatory fees, to be charged to the
customer for costs of inspections, identification of needed repairs, and needed lateral
replacements, at rates designed to cover the total costs to the City to administer the
program. The City could also explore funding/tax abatement/incentives programs to
assist the City with program cost overruns as well as seek grants to cover costs of
inspections, needed repairs, and lateral replacements, especially for low income
property owners. Private inspections of residential lateral lines, accompanying a sale,
can likely be accomplished for under $ioo.00 to the parties involved, or for free if
additional plumbing work is scheduled by a seller or buyer. The City would need to
establish a disclosure filing fee to record inspection results associated with a sale.
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi Christi's Charter, the
Texas State Constitution, and other state,local and federal laws, as applicable.
•ACTIONS AND SCHEDULE:
Table 32.MM 6.1. Residential Leaking/Broken Private Sewer Laterals Pre-Sale Inspection/Testing Program.
Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
x
Prepare and Present to Council Ordinances at
Necessary to Establish Targeted Inspection completion
Program Within CARP Area of 5.1
Prepare and Present to Council Ordinances x
Necessary to Update City's Technical at
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Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Construction Codes to Address Illegal Cross- completion
connections of 5.1
Management Measure 6.2: Commercial Cross-Connection Inspection
Program
'WHAT: Commercial properties (including multi-family rental property, large
condominiums, retail establishments, and industrial properties) may be identified as
potential sources of wastewater and other waste materials that could result in
introduction of bacteria into the City's MS4. The primary concerns involve illegal cross-
connections between the private stormwater and wastewater sewer lines on the property
that allow wastewater to infiltrate into the MS4.
•WHO: City of Corpus Christi
'WHERE: Within drainage basins that discharge into the TMDL study area, and any
immediately adjoining drainage basins.
'GOAL: Reduce or eliminate all illegal cross-connections within the drainage basins
that discharge within the TMDL within 10 years.
•WHEN: Develop, adopt and execute an enhanced, targeted illegal cross-connection
inspection program in Tieri. Undertake and complete review of City's Technical
Construction Codes and Housing Standards Code, including unpermitted work by
homeowners within two years, which codes and amendments are intended for adoption
during the next technical construction codes update process.
•HOW: see a.) and b.)below
a. Illegal Cross-connections Pilot Inspection Program. Utilizing the
information obtained in the pilot program described in 5.1, determine whether
illegal cross connections between private wastewater systems and the stormwater
collection system are providing a source of bacteria within the Cole and Ropes
Parks stormwater basins.
Expand City's current inspection programs within drainage basins, contributing
flows into the TMDL program area, to locate unauthorized cross-connections on
commercial properties. This may include smoke testing wastewater and
stormwater lines.
b. Code Updates. Update City's Technical Construction Codes, especially as
they relate to the issue of cross-connections.
•COSTS/SOURCE OF FUNDS: Costs to the City of Corpus Christi are to be
determined. Adopt by ordinance the necessary regulatory fees, to be charged to the
customer for costs of inspections, identification of needed repairs, and needed lateral
Texas Commission on Environmental Quality 68 Peer Review Draft,Month, Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
replacements, at rates designed to cover the total costs to the City to administer the
program. The City could also explore funding/tax abatement/incentives programs to
assist with program cost overruns.
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi's Charter, the Texas
State Constitution, and other state,local and federal laws, as applicable.
•ACTIONS AND SCHEDULE:
Table 33.MM 6.2 Commercial Cross-connection Inspection Program.Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Illegal Cross-connections Pilot Inspection
Program x
x
at
Code Updates completion
of Pilot
Project
Management Measure 6.3: Commercial Leaking/Broken Sewer
Laterals Pilot Inspection/Testing Program
•WHAT: Commercial properties have been identified as a potential source of
wastewater and other waste materials that could result in the infiltration of bacteria into
the City's MS4. The primary concerns involve old, leaking, broken, or improperly
installed or maintained private wastewater lines on the property that allow wastewater
to infiltrate into the MS4.
Establishment of an inspection program to test private sewer lines to make sure they do
not have any leaks or breaks, and mandate repair of substandard private sewer lines,
also known as private laterals. (Note: Inspection program could be conducted by
licensed plumbers or other certified entities.) The problem seems more prevalent in
areas with older clay pipe, installed in the 30's, 40's, and 50's, and with cast iron pipes,
installed in 60's and do's, all before widespread use of PVC piping.
There should be an evaluation of the adequacy of the City's current certificate of
occupancy program to determine if necessary changes in a property's infrastructure are
being correctly installed and properly maintained, especially upon a change of
ownership or a change in tenants. This might necessitate the adoption of a business
permit system within the City.
•WHO: City of Corpus Christi.
•WHERE: Within drainage basins that discharge into the TMDL study area, and any
immediately adjoining drainage basins.
Texas Commission on Environmental Quality 69 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•GOAL: Within 10 years, reduce or eliminate leaking or broken private sewer lines
within the drainage basins that discharge within the TMDL area.
•WHEN: Propose to City Council to consider for approval and adoption a leaking and
broken private sewer inspection program. Undertake and complete review of City's
Technical Construction Codes, for adoption during the next technical construction codes
update process.
•HOW: see a.) and b.)below
a. Leaking or Broken Private Sewer Lateral Pilot Inspection Program.
Utilizing the information obtained in the pilot program described in 5.1,
determine whether broken or leaking commercial wastewater lateral systems are
providing a source of bacteria by infiltration into stormwater collection systems
in the target basins.
Establish an inspection program to test private sewer lines to make sure they do
not have any leaks or breaks, and mandate repair of substandard private sewer
lines, also known as private laterals, especially upon a change of ownership
and/or a change in tenants. (Note: Inspection program could be conducted by
licensed plumbers or other certified entities.)
b. Certificate of Occupancy. Evaluate the adequacy of the City's current
certificate of occupancy program to determine if necessary changes in a
property's infrastructure are being correctly installed and properly maintained,
especially upon a change of ownership and/or a change in tenants. This might
necessitate the adoption of a business permit system within the City.
•COSTS/SOURCE OF FUNDS: Costs to the City of Corpus Christi are to be
determined. Adopt by ordinance the necessary regulatory fees, to be charged to the
customer at rates designed to cover the program costs of inspections, identification of
needed repairs, and needed lateral replacements. The City could explore funding/tax
abatement/incentives programs to assist the City with program cost overruns.
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi's Charter, the Texas
State Constitution, and other state,local and federal laws, as applicable.
Texas Commission on Environmental Quality 70 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•ACTIONS AND SCHEDULE:
Table 34.MM 6.3 Commercial Leaking/Broken Sewer Laterals Pilot Inspection/Testing Program.
Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Leaking or Broken Private Sewer Lateral
Pilot Inspection Program x
x
at
Evaluate the Adequacy of the City's Current completion
Certificate of Occupancy Program of Pilot
Project
Management Measure 6.4: Improved Grease Trap Standards
•WHAT: Clogged, overloaded grease and grit traps and improperly operating oil/water
separators may result in contaminated runoff entering the City's MS4, encouraging the
growth of bacteria with the underground stormwater sewers. There is a need to review
the standards for oil, grease, and grit traps in City's current Technical Construction
Codes to verify they have adopted the best available technology, and to adopt new
standards for new and existing commercial properties.
•WHO: City of Corpus Christi
•WHERE: Within drainage basins that discharge into the TMDL study area, and any
immediately adjoining drainage basins.
•GOAL: Within 10 years, reduce or eliminate introduction of wastewater contributed by
undersized or malfunctioning grease interceptors and /or oil-water separators into the
MS4 from commercial properties within the drainage basins that discharge within the
TMDL area.
'WHEN: Undertake and complete review of City's Technical Construction Codes,
intended for adoption and amendment during the next technical construction codes
update process.
•HOW: Review the standards for grease interceptors and /or oil-water separators in
City's current Technical Construction Codes to verify they have adopted the best
available technology, and adopt new standards for new and existing commercial
properties. Existing installations should not be grandfathered, if they fail to meet the
current pre-treatment requirements, they should be afforded the opportunity to come
into compliance with new requirements after a reasonable amortization period.
•COSTS/SOURCE OF FUNDS: Costs to the City of Corpus Christi are to be
determined Adopt by ordinance the necessary regulatory fees, to be charged to the
Texas Commission on Environmental Quality 71 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
customer for costs of inspections, to identify needed repairs, and grease trap, grit trap,
and oil/water separator replacements, at rates designed to cover the total costs to the
City to administer the inspection program. The City could also explore funding/tax
abatement/incentives programs to assist the City with any program cost overruns.
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi
•ACTIONS AND SCHEDULE:
Table 35. MM 6.4 Improved Grease Trap Standards. Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Continue Grease Trap, Grit Trap, and
Oil/Water Separator Inspection Program
Undertake and Complete Review of City's
Technical Construction Code Provisions
Related to Grease Traps, Grit Traps, and X
Oil/Water Separators.
Management Measure 6.5: Strengthen Current Animal Control
Ordinances Relating to Removal and Disposal of Pet Wastes
•WHAT: Develop and present for adoption code amendments to strengthen current
ordinances that require pet owners to remove and properly dispose of pet wastes, such
as the "pooper scooper" requirements and the requirement to remove waste that has
accumulated on the ground from animals that are harbored on the property (premises).
This should also apply to free range chickens and livestock that are not related to a
commercial agriculture operation. Ordinance amendments would include, at a
minimum, new enforcement measures, stricter fines, and enhancements to improve
enforceability.
•WHO: City of Corpus Christi
•WHERE: Within drainage basins that discharge into the TMDL study area, and any
immediately adjoining drainage basins.
•GOAL: Reduce amount of pet wastes running off of private property and into the City's
MS4.
•WHEN: Adopt amendments to the animal control ordinances within two years.
•HOW: City staff should review animal control ordinances adopted in other
communities, draft appropriate proposed amendments to the Code of Ordinances,
submit the proposal to the City's Animal Control Board for review and recommendation,
and refer to City Council for adoption. Amendments should provide for enhanced
Texas Commission on Environmental Quality 72 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
enforcement capabilities, fines or increased fines, and consider fees and other
consequences for violating the law.
•COSTS/SOURCE OF FUNDS: Costs to the City of Corpus Christi are to be
determined. Adopt by ordinance the necessary regulatory fees, to be charged to the
violator for code enforcement costs, at rates designed to cover the total costs to the City
to administer the program
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi's Charter, the Texas
State Constitution, and other state,local and federal laws, as applicable.
•ACTIONS AND SCHEDULE:
Table 36.MM 6.5.Strengthen Current Animal Control Ordinances Relating to Removal and Disposal of Pet
Wastes. Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Review Animal Control Ordinances Adopted
in Other Communities and Draft Appropriate
Amendments to City's Animal Control
Ordinances
Management Measure 6.6: Implement Measures to Control Feral
Cats, Rodents, and Nuisance Animals
•WHAT: Consider adoption of measures to control feral cats, rodents, and nuisance
animals, such as possums, that property owners allow to take up residence on their
property.
•WHO: City of Corpus Christi
•WHERE: Within drainage basins that discharge into the TMDL study area, and any
immediately adjoining drainage basins.
•GOAL: Reduce amount of animal wastes running off of public and private property
and into the City's MS4.
'WHEN: Adopt amendments to the animal control ordinances within two years.
•HOW: City staff should review animal control ordinances adopted in other
communities, draft appropriate proposed amendments to the Code of Ordinances,
submit the proposal to the City's Animal Control Board for review and recommendation,
and refer to City Council for adoption. The City's police department, as well as code
compliance department, ought to be engaged in animal waste control enforcement.
Officers on bicycles are optimal contacts to warn the public of pet waste obligations.
Police department engagement will require a policy shift. Amendments should provide
M n h Day,Year
Texas Commission on Environmental Quality 73 Peer Review Draft, o t ,
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
for enhanced enforcement capabilities, fines or increased fines, and consider
administration fees and other consequences for violating the law.
•COSTS/SOURCE OF FUNDS: Costs to the City of Corpus Christi are to be
determined. Adopt by ordinance the necessary regulatory fees, to be charged to the
customer for costs of any inspections and code enforcement costs, at rates designed to
cover the total costs to the City to administer the program.
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi
•ACTIONS AND SCHEDULE:
Table 37. MM 6.6.Implement Measures to Control Feral Cats, Rodents,and Nuisance Animals.
Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Review Animal Control Ordinances Adopted
in Other Communities, and Present for
Adoption Appropriate Amendments to the x
Code of Ordinances
Management Measure 6.7: Install Additional Signage
•WHAT: Install appropriate signage to warn the public of potential public health risks
associated with contact recreation in bay waters when bacteria levels exceed state water
quality standards for contact recreation, which normally occur during and immediately
following heavy rain events.
•WHO: City of Corpus Christi
•WHERE: At access points in City parks and public areas, adjacent to the TMDL study
area; which are used to access bay waters for contact recreation.
•GOAL: Until such time as engineering solutions to the elevated bacteria levels in the
bay at Cole and Ropes Parks are implemented, reduce public health risks associated
with contact recreational use of bay waters adjacent to City stormwater outfalls, which
have elevated bacteria levels during and immediately following heavy rain events.
•WHEN: Within two years of adoption of the plan.
•HOW: In the interest of the economy, install permanent signage, which may or may
not be related to the Texas General Land Office Beach Watch Program, which advises
public of general risk of using bay waters for contact recreation during and immediately
after heavy rain events.
Texas Commission on Environmental Quality 74 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•COSTS/SOURCE OF FUNDS: Costs to the City of Corpus Christi are to be
determined.
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi's Charter, the Texas
State Constitution, and other state,local and federal laws, as applicable.
•ACTIONS AND SCHEDULE:
Table 38. MM 6.7. Install Additional Signage. Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Install Additional Signage. x
Within one
year of
adoption of
this plan
Management Measure 6.8: Develop Advisement Protocol to Warn the
Public of Periodically Elevated Bacteria Levels, as Anticipated by
Weather Forecasts for Rain, as well as Warnings During and
Immediately After Rainfall
•WHAT: Prepare and present to Council for adoption the ordinances that would devise
an advisement protocol to warn the public of periodically elevated bacteria levels, as
anticipated by weather forecasts for rain, as well as warnings during and immediately
after rainfall, and an advisement protocol to notify the public when elevated bacteria
levels are assumed to have fallen to permissible levels.
•WHO: City of Corpus Christi
•WHERE: Within drainage basins that discharge into the TMDL study area, and any
immediately adjoining drainage basins.
•GOAL: Until such time as implementation of an engineering solution to the bacterial
contamination created in the "first flush" of a heavy rainfall event, reduce public health
risks associated with contact recreational use of bay waters adjacent to City stormwater
outfalls, which have elevated bacteria levels during and immediately following heavy
rain events.
'WHEN: Within one year of adoption of the plan.
Texas Commission on Environmental Quality 75 Peer Review Draft,Month, Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
'HOW: By adoption of an ordinance, establish the standards for issuing general and
specific public health safety advisories on the contact recreational use of subject bay
waters when bacteria levels exceed contact recreation water quality standards.
'COSTS/SOURCE OF FUNDS: Costs to the City of Corpus Christi are to be
determined.
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi.
•ACTIONS AND SCHEDULE:
Table 39.MM 6.8. Develop Advisement Protocol to Warn the Public of Periodically Elevated Bacteria Levels,
as Anticipated by Weather Forecasts for Rain,as well as Warnings and Immediately After
Rainfall.Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Prepare and Present to Council for Adoption x
Ordinances Setting Standards for Issuing Prepare
General and Specific Public Health Safety ordinance
Advisories on the Contact Recreational Use within one year
of Bay Waters with Bacterial Contamination of adoption of
Following Major Rain Events implementation
plan and
obtaining
support of
affected
stakeholders
Management Measure 6.9: Restrict Access to Bay Waters from City
Parks and Other Bayfront City Properties During Periods of Public
Health Risks
•WHAT: Prepare and present to Council for adoption an ordinance that authorizes the
City Manager to close or deny contact access to recreational waters from City parks and
public spaces during periods when there is a risk to public health from elevated bacteria
levels in the bay. This ordinance proposal will be held in active abeyance during the first
implementation cycle of the I-Plan. During this abeyance period, recognized stakeholder
work groups, Ordinances/Regulations; Education/Outreach; and Monitoring/Research,
will meet to create specific language or elements for a proposed ordinance to direct
closure or direct advisories pertaining to the subject beaches during periods of risk to
the public health or safety.The goal of the ordinance will be to regulate or manage beach
access during periods of risk to public health or safety. The work groups will explore
conditions and progress made under the I-Plan that may affect the efficacy and
appropriateness of a beach access ordinance. Elements for work group consideration,
include, but are not limited to, creation of an exempted class of recreational user; the
use/non-use of the City's police powers in managing access; potential for penalties and
non-penal approaches to enforcement; education and outreach in lieu of enforcement or
to supplement enforcement; progress or new approaches to testing and evaluation; and
Texas Commission on Environmental Quality 76 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
any legal and scientific avenues appropriate to managing access to affected beaches for
benefit of the public health and safety. The participating work groups will, at their
discretion, as individual groups or a consolidated work group, vote a proposed
ordinance draft, or the elements of such, to the CARP committee for further action,
which committee may incorporate the ordinance draft or its elements as an adjunct to
the current I-Plan at any time the CARP committee may deem appropriate to accept or
decline the proposal. The ordinance will include language to exempt activities of
organized and individual windsurf/sailboard/kiteboard users, that rely
upon the launch site at Oleander Point within Cole Park, predicated upon
informed assumption of risk for this class of recreation user.
•WHO: City of Corpus Christi.
•WHERE: Within drainage basins that discharge into the TMDL study area, and any
immediately adjoining drainage basins.
•GOAL: Until such time as an implemented engineering solution to the elevated
bacteria levels in the bay waters adjacent to Cole and Ropes Park, reduce public health
risks associated with contact recreational use of bay waters adjacent to City stormwater
outfalls, which have excessive bacteria levels during and immediately following heavy
rain events.
•WHEN: Within two years of adoption of the plan.
•HOW: Adopt ordinance to authorize the City Manager to close or deny access to bay
waters for contact recreation from City parks and public spaces during periods when
there is a significant public health risk associated with the use of the subject bay area for
recreational contact when bay waters exceed state water quality standards for contact
recreation, which normally occur during and immediately following heavy rain events.
Closure or denial of access would be accomplished by posting appropriate signage and
installing barriers on physical access points, such as steps or pathways.
•COSTS/SOURCE OF FUNDS: Costs to the City of Corpus Christi are to be
determined.
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi's Charter, the Texas
State Constitution, and other state,local and federal laws, as applicable.
Texas Commission on Environmental Quality 77 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•ACTIONS AND SCHEDULE:
Table 40.MM 6.9. Restrict Access to Bay Waters from City Parks and Other Bay Front City Properties During
Periods of Significant Public Health Risks. Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Adopt Ordinance Authorizing City Manager x
to Restrict Access to Targeted Bay Waters Propose
for Contact Recreation When There is a ordinance
Significant Public Health Risk. within two
years of
adoption of(-
Plan and
based on
stakeholder
input.
Management Measure 6.10: Adopt and Enforce Additional
Ordinances
•WHAT: Solid waste, especially litter that contains or was associated with food and
beverages, that gets into the City's MS4, can contribute to the growth of bacteria within
the stormwater system. While the City currently has some ordinances to address litter at
food establishments, the current ordinances do not provide adequate requirement
related to the number and maintenance of outdoor trash receptacles in commercial
parking lots and public access areas to allow the public to properly dispose of waste that
has been generated as a result of the commercial activities on the property. Responsible
landlords and commercial owners, who invest in clean premises costs, are at a
competitive disadvantage against operators who ignore cleanliness to enjoy higher profit
margins. New and amended ordinances should provide:
a. More Receptacles. Increase the required number of waste receptacles on
commercial properties and public areas.
b. More Commercial Waste Service. Enhance a commercial owner's
maintenance obligations to service waste receptacles and clear parking lots of
loose debris, particularly, discarded used diapers and animal carcasses,with
special attention to dead birds and discarded food that attracts birds and bird
feces.
Texas Commission on Environmental Quality 78 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
c. Dumpsters. Enhanced ordinance obligations requiring contractors who
provide dumpsters to keep dumpster areas free of deleterious materials and
leakage. (Generally, sanitation obligations pertaining to dumpsters are not being
observed. More enforcement is needed).
d. Plastic. Support the current efforts to reduce plastic bag usage.
e. Relief from Fugitive Waste on City Service Routes. Updated and
enforceable secondary containment requirements for both automated and
manual routes,which secondary requirements are already in Chapter 21,
Garbage,Trash, and Other Refuse,but lack standards for required plastic and
paper container bags, and which regulations are further without enforcement
capability for lack of statement of offense. Enforcement of secondary
containment puts the citizen customer where he or she ought to be, in a
responsible position to assist the City in controlling fugitive wastes.
•WHO: City of Corpus Christi.
'WHERE: Within drainage basins that discharge into the TMDL study area, and any
immediately adjoining drainage basins.
•GOAL: Reduce volume of solid wastes that runoff or blow into the MS4 from
commercial properties.
•WHEN: Within two years of adoption of the implementation plan.
•HOW: City staff should review litter and property maintenance ordinances adopted in
other communities, draft appropriate proposed amendments to the Code of Ordinances,
submit the proposal to the City Council for adoption.
•COSTS/SOURCE OF FUNDS: Costs to the City of Corpus Christi are to be
determined. Adopt by ordinance the necessary regulatory fees, to be charged to the
customer for costs of any inspections and code enforcement costs, at rates designed to
cover the total costs to the City to administer the program.
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi's Charter, the Texas
State Constitution, and other state,local and federal laws.
•ACTIONS AND SCHEDULE:
Table 41.MM 6.10.Adopt and Enforce Additional Ordinances.Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Adopt Appropriate Ordinances. x
Throughout
the life of the
I-Plan
Texas Commission on Environmental Quality 79 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Management Measure 6.11 : Explore Adoption of Additional "Low
Impact Development" Standards in Unified Development Code that
will Reduce Volumes of Stormwater Runoff From Areas of New
Development or Significant Redevelopment
•WHAT: Review "low impact development" standards adopted by other communities
that will reduce volumes of stormwater runoff from areas of new development or
significant redevelopment.
•WHO: City of Corpus Christi.
•WHERE: Within drainage basins that discharge into the TMDL study area, and any
immediately adjoining drainage basins.
•GOAL: Reduce the volume of runoff generated from areas of new development or
significant redevelopment.
•WHEN: Target adoption of amendments to the Unified Development Code (UDC)
within three calendar years.
•HOW: Establish a special advisory committee to study issues and make
recommendations to the Planning Commission and City Council. Committee should
have broad public membership, and should include developers, residential and
commercial builders, consulting engineers, neighborhood homeowner association
representatives, and environmental interest.
•COSTS/SOURCE OF FUNDS: Costs to the City of Corpus Christi are to be
determined.
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi.
•ACTIONS AND SCHEDULE:
Table 42. MM 6.11. Explore Adoption of Additional"Low Impact Development"Standards in Unified
Development Code that will Reduce Volumes of Stormwater Runoff From Areas of New
Development or Significant Redevelopment.Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Establish Special Advisory Committee x
within three
years
Amend UDC to Encourage"Low Impact" x x x
Development. throughout
the life of the
I-Plan
Texas Commission on Environmental Quality 80 Peer Review Draft,Month,Day,Year
D . I dcfliva=u laMli>,i.AtiZ AIALi.1a_ t1:.t±1=11 yillt.litLFAIIAL I :1
Table 43. Summary of Management Measure:Ordinance and Regulation
Management Measure.Ordinance and Regulation
Technical
and
Potential Financial Schedule of Interim,
Load Assistance Education Implementati Measurable Indicators of Monitoring Responsible
Management Measure Reduction Needed Component on Milestones Progress Component Entity
Ordinance and Regulation
6.1)Residential TBD TBD Public will be Tier 1. Complete Prepare and Determine City of Corpus
Leaking/Broken Private educated on review of present to number of Christi
Sewer Laterals Pre-Sale sewer lateral current Council illegal cross-
Inspection/Testing Program inspection/tes technical
construction ordinances connections
ting program codes and necessary to identified vs.
adopt establish an number of
necessaryenhanced, illegal cross-
amendmnts targeted connections
during next inspection corrected
code revision program of
private sewer
process. lines within the
Take drainage basins
appropriatecontributing
flows to the
enforcement
action, TMDL program
if
area to test
property
private sewer
owners do not
make necessary lines to make
sure they do not
repairs to
havek leaks or
private sewer broken sewer
lines
lines
Determine#of Prepare and
broken/leaking present to
private sewer Council for
lines identified adoption the
vs.#of broken ordinances that
/leaking would update
private sewer City's technical
lines corrected. construction
codes to
address illegal
cross
connections
Texas Commission on Environmental Quality 81 Peer Review Draft,Month,Day,Year
•
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Ba
Technical
and
Potential Financial Schedule of Interim,
Load Assistance Education Implementati Measurable Indicators of Monitoring Responsible
Management Measure Reduction Needed Component on Milestones Progress Component Entity
6.2)Commercial Cross- TBD TBD Educated Tier t. Establish an Complete Determine City of
connection Inspection public on enhanced, ordinance number of Corpus
Program Cross- targeted review and illegal cross- Christi
connection inspection amendment connections
Inspection program adoption identified vs.
Program within the process number of
drainage Complete illegal cross-
basins inspection of connections
contributing target corrected.
flows to the drainage
TMDL basins within
program area to years
to locate
unauthorized Complete
cross- review of
connections current
on private technical
property, construction
which may codes and
include smoke adopt any
testing necessary
wastewater amendments
collection during the
lines and next code
stormwater revision
lines. process.
Update City's Take
technical appropriate
construction enforcement
codes to action,if
address illegal property
cross- owners do not
connections. make
necessary
repairs to
private sewer
lines.
Texas Commission on Environmental Quality 82 Peer Review Draft,Month,Day,Year
D . I dta1a1ifiaaa�rauiaati na1 ltilfiLl!!iM rd1r3-y/1VIII.F.ALu Lyil S
Technical
and
Potential Financial Schedule of Interim,
Load Assistance Education Implementati Measurable Indicators of Monitoring Responsible
Management Measure Reduction Needed I Component on Milestones Progress Component Entity
6.3)Commercial Leaking/ TBD TBD Educate Tier 1. Establish an Complete Determine City of
Broken Private Sewer public on enhanced, ordinance number of Corpus
Laterals Pilot Inspection/ Sewer Lateral targeted pilot review and broken/ Christi
Testing Program Inspection inspection amendment leaking
Program program of adoption private sewer
private sewer process within lines
lines within two years of identified vs.
the drainage adoption of number of
basins this broken/
contributing implementati leaking
flows to the on plan. private sewer
TMDL lines
program area Complete corrected.
to test private review of
sewer lines to current
make sure technical
they do not construction
have any leaks codes and
or broken adopt any
sewer lines. necessary
amendments
Update City's during the
technical next code
construction revision
codes to process.
address illegal
cross- Take
connections. appropriate
enforcement
action,if
property
owners do not
make
necessary
repairs to
private sewer
lines.
Texas Commission on Environmental Quality 83 Peer Review Draft,Month,Day,Year
D - I rita„ca__arir._i>______i._aa____c._:t. __ :__________________1______i_U_f:r._
Technical
and
Potential Financial I Schedule of Interim,
Load Assistance Education Implementati Measurable Indicators of Monitoring Responsible
Management Measure Reduction Needed I Component on Milestones I Progress Component Entity
6.4)Improved Grease Trap TBI) TBD Notify Public Tier 1. Continue and Implement Determine City of
Standards of new Grease Improve inspection number of Corpus
Trap grease trap, program grease traps, Christi
Standards grit trap,and ,within two grit traps,and
oil/water years of oil/water
separator adoption of separators
inspection the that do not
program. implementati operate at
on plan. appropriate
Undertake levels vs.
and complete Adopt any number of
review of necessary grease traps,
City's changes grit traps,and
Technical during the oil/water
•
Construction next technical separators
Code construction repaired or
provisions codes update replaced.
related to process.
grease traps,
grit traps,and Take
oil/water appropriate
separators. enforcement
action,if
property
'owners do not
replace or
make
necessary
repairs to
improperly
operating
grease traps,
grit traps,and
oil/water
separators.
Texas Commission on Environmental Quality 84 Peer Review Draft,Month,Day,Year
D I ai rinriii.IliMli>,t.tati:riariSag+ t-il:FMS:ca/l:11il tUtliM. iLLIil ri
Technical
and
Potential Financial Schedule of Interim,
Load Assistance Education Implementati Measurable Indicators of Monitoring Responsible
Management Measure Reduction Needed Component on Milestones Progress Component Entity
6.5)Strengthen Current TBD TBD Educate Tier i. Review Complete Number of City of
Animal Control Ordinances public on new animal ordinance complaints Corpus
Relating to Removal and animal control review and investigated. Christi
Disposal of Pet Wastes control ordinances amendment Number of
ordinances adopted in adoption enforcement
other process within actions taken
communities two years of (includes
and draft adoption of issuance of
appropriate this warnings,
amendments implementati notices of
to City's on plan. violation,and
animal citations).
control
ordinances.
Evaluate
number of
complaints
investigated
Texas Commission on Environmental Quality 85 Peer Review Draft,Month,Day,Year
D . I .1ta clgrrir,U=Il>rmti2.tt:ri,ci.h.isr, :il:� xnf,L3-ei,amF tiliklI
Technical
and
Potential Financial Schedule of Interim,
Load Assistance Education Implementati Measurable Indicators of Monitoring Responsible
Management Measure Reduction Needed Component on Milestones Progress Component Entity
6.6)Implement Measures to TBD TBD Educate Tier 1. Review Complete Number of City of
Control Feral Cats,Rodents, public on animal ordinance complaints Corpus
and Nuisance Animals measures they control review and investigated. Christi
could help ordinances amendment
control feral adopted in adoption Number of
cats,rodents, other process within enforcement
and nuisance communities, two years of actions taken
animals. and present adoption of (includes
for adoption this issuance of
appropriate implementati warnings,
amendments on plan. notices of
to the Code of violation,and
Ordinances. Complete citations).
policy change
Make pet within one
waste year of
enforcement a adoption of I-
policy Plan.
priority,or at
least a
function,
within the
City's police
department,
not limited to
code
compliance
department.
6.7)Install Additional TBD TBD Educate via Tier 1. Install Signs are Maintain City of
Signage signage additional installed signage Corpus
signage. Cluisti
Texas Commission on Environmental Quality 86 Peer Review Draft,Month,Day,Year
D . I .rta„Ia.Ir.»[ILM.1k.L rd[MiLaMaII>r311'e>r1 idALIsl,l'r3ni.
Technical
and
Potential Financial Schedule of Interim,
Load Assistance Education Implementati Measurable Indicators of Monitoring Responsible
Management Measure Reduction Needed Component on Milestones Progress Component Entity
6.8)Develop Advisement TBD TBD Public health Tiers. Ordinances Prepare and Evaluate how City of
Protocol to Warn the Public safety adopted present to many public Corpus
of Periodically Elevated advisories are within one Council for health safety Christi
Bacteria Levels,as issued as year of adoption advisories
Anticipated by Weather directed in the adoption of I- ordinances were issued as
Forecasts for Rain,as well as ordinance. Plan setting directed in the
Warnings During and standards for ordinance(s).
Immediately After Rainfall issuing
general and
specific public
health safety
advisories on
the contact
recreational
use of bay
waters with
bacterial
contaminatio
n following
major rain
events.
6.9)Restrict Access to Bay TBD TBD Notify public Tier i Adopted Number of Evaluate how City of
Waters from City Parks and of new within one Restrictions many public Corpus
Other Bayfront City beach/water year of advised. health safety Christi
Properties During Periods of restrictions adoption of I- advisories/res
Public Health Risks when bacteria Plan trictions were
levels are or issued.
can be a
health risk.
6.10)Adopt and Enforce TBD TBD Notify public Tier 1. Propose Adopt Evaluate the City of
Additional Ordinances of new ordinances for appropriate effectiveness Corpus
ordinances. adoption ordinances. of appropriate Christi
within 2 years ordinances
of adoption of that have
implementati been adopted.
on plan.
Texas Commission on Environmental Quality 87 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Ba
Technical
and
Potential Financial Schedule of Interim,
Load Assistance Education Implementati Measurable Indicators of Monitoring Responsible
Management Measure Reduction Needed Component on Milestones Progress Component Entity
6.11)Explore Adoption of TBD TBD Educate Tier 1. Adopt Amend UDC Evaluate the City of
Additional"Low Impact public of LID necessary to encourage effectiveness Corpus
Development"Standards in standards in ordinances "low impact" of new Christi
Unified Development Code unified within 3 years development. developments
that will Reduce Volumes of development of adoption of utilizing LIDs.
Stormwater Runoff From code. this
Areas of New Development implementati
or Significant on plan.
Redevelopment
Texas Commission on Environmental Quality 88 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Control Actions 1 .0: Wastewater Collection Systems
Sanitary sewers can fail to function properly due to blockages,line breaks, defects
that allow stormwater and groundwater to overload the system, lapses in
operation and maintenance, inadequate design and construction, power failures,
deferred replacement, and vandalism. The EPA has concluded that sanitary sewer
overflows (SSOs) contribute to bacteria loading in almost all impaired streams,
but may or may not be a primary source of loading. EPA acknowledges that SSO
data is difficult to assess.
In general, implementation actions consist of encouraging improvements to
sanitary sewers through hydraulic modeling and completing an inflow and
infiltration study; reducing the amount of fats, oils, and grease entering the
system; continuing sanitary sewer line cleaning; and reporting of SSOs to the
TCEQ.These reports are public information and are available from the TCEQ.
Control Action 1.1 : Continue Existing Fats, Oil & Grease (FOG)
Program
Fats, oil, and grease (FOG) are considered to be a leading cause of blockages in
sanitary sewers, and the EPA estimates that blockages account for nearly 5o
percent of all SSOs nationwide. This Control Action enables the City of Corpus
Christi to determine the proper size and design for grease interceptors, to inspect
traps regularly, and to require grease interceptors be effectively maintained by
businesses.
'WHAT: Almost all of the City's Food Service Establishments (FSE) are required
to have a grease interceptor and this is initially enforced by Development Services
through the building permit process. Thereafter, FSEs are inspected annually by
the City's Pretreatment staff. Inspections include reviewing manifests for grease
interceptor cleaning frequency and analyzing Hexane Extractible Material (HEM)
levels,which cannot exceed 200 mg/l. The hexane solvent methodology is used to
measure total oils and grease. A Notice of Violation is sent to FSEs where
exceedances are observed, with a requirement to increase the interceptor
cleaning frequency. Continued exceedances may result in a requirement for a
larger or more effective interceptor. In addition to notices in utility bills,
residents are advised to avoid putting grease in the drains at the annual World of
Water event at the Corpus Christi Museum of Science and History. The City
provides fat trapper containers and bags at no charge to attendees.
•WHO: City of Corpus Christi Public Utilities, Corpus Christi- Nueces County
Health Department, Food Service Establishments (FSE Program).
•WHERE: All FSEs in the Cole and Ropes Parks contributing drainage areas.
Texas Commission on Environmental Quality 89 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•GOAL: Reduce or eliminate SSOs resulting from blockages caused by FOG
through monitoring and enforcement of the City's ordinances prohibiting grease
input into the wastewater collection system
•WHEN: Implementation beginning in Tier 1 and continuing.
•HOW: Through continuing efforts in the City's FOG program.
•COSTS/SOURCE OF FUNDS: Approximately $400,000 annually, in the
range of Public Utilities operating budget.
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi Public Utilities
Department
•ACTIONS AND SCHEDULE:
Table 44.CA 1.1.Continue existing Fats,Oil&Grease(FOG)program. Implementation timeline
schedule.
Actions Tier 1 Tier 2 Tier 3
Food Service HEM Monitoring
x x x
Food Service Grease Interceptor
Maintenance Enforcement. x x x
Control Action 1.2: Continue Monitoring Sanitary Sewer
Overflows (SSOs)
•WHAT: Sanitary Sewer Overflows are accurately reported by the City's Public
Utilities Department to the TCEQ. It is City policy that all reported overflows are
repaired or addressed. The intent of this Control Action is to continue the SSO
reporting by the City of Corpus Christi.
•WHO: The City of Corpus Christi Public Utilities Department
•WHERE: The main priority area will be within the Cole and Ropes Park
drainage basin and include Brawner Parkway drainage basin.
•GOAL: Continue reporting SSOs.
•WHEN: Implementation beginning in Tier 1 and continuing.
•HOW: Continue reporting SSOs as is currently being done to date.
•COSTS/SOURCE OF FUNDS: The costs associated with SSO reporting to the
TCEQ by the City are included in the Public Utilities Department's annual
operating budget.
Texas Commission on Environmental Quality 90 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi, a Municipal
Corporation with Home Rule Authority to act in all ways not specifically
prohibited by the State of Texas and State Constitution; TCEQ implementation of
federally delegated Texas Pollutant Disposal Elimination System permitting
authority under Texas Clean Water Act; USEPA, National Pollutant Disposal
Elimination System program, implementing the federal Clean Water Act.
•ACTIONS AND SCHEDULE:
Table 45.CA 1.2.Continue Monitoring Sanitary Sewer Overflows(SSOs). Implementation timeline
schedule.
Actions Tier 1 Tier 2 Tier 3
Continue SSO reporting
x x x
Control Action 1.3: Continue Collection System Line Cleaning,
Inspection, Repair and Rehabilitation
The City of Corpus Christi has an on-going program of cleaning and televised
inspecting its wastewater collection system. This is part of the Wastewater
Department's maintenance and operation plan for improved performance.
Through cleaning and televising, the City can optimize repairs/rehabilitation
efforts to meet TCEQ permit requirements.
•WHAT: Maintenance of lines is a Public Utilities Department function to assure
improved performance to its 83,000 customers who depend on this service every
day.
•WHO: The Public Utilities Department, along with competitively bid contracts,
provides the forces to maintain the City's collection system.
•WHERE: Annually, the Public Utilities Department assesses all areas of the
City to determine need for improved maintenance and repairs. Areas needing
replacement are placed on the Capital Improvements Program (CIP) plan for bid
solicitation. Also, database reviews occur to resolve problematic areas in the
system.
•GOAL: Prevent overflows and increase system capacity.
•WHEN: Implementation beginning in Tier 1 and continuing.
•HOW: Generally, through cleaning and closed circuit televising (CCTV), smoke
detection surveys, and customer complaints of affected areas, resolution of
problems and improvements of the systems are accomplished.
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Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•COSTS/SOURCE OF FUNDS: The Public Utilities Department.
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi, a Municipal
Corporation with Home Rule Authority to act in all ways not specifically
prohibited by the State of Texas and State Constitution.
•ACTIONS AND SCHEDULE:
Table 46.CA 1.3.Continue Collection System Line Cleaning, Inspection,Repair and Rehabilitation.
Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Continue Collection System Line Cleaning,
Inspection, Repair and Rehabilitation x x x
Texas Commission on Environmental Quality 92 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ro.es Parks Beaches in Co .us Christi Ba
Table 47. Summary of Control Action Wastewater Collection Systems
Control Action:Wastewater Collection Systems
Technical
and
Financial Interim,
Potential Load Assistance Education Schedule of Measurable Indicators of Monitoring Responsible
Control Action Reduction Needed Component Implementation Milestones Progress Component Entity
Wastewater Collection Systems 1
1.1.)Continue Existing Fats,Oil 1 TBD City of Continue Tier 1.Continue Decreased Food Service Continue to Code of
&Grease(FOG)Program Corpus generator current program FOG Grease monitor FSE's. Ordinances of
Christi education associated with Interceptor the City of
Public directed to overflows Maintenance Food Service Corpus Christi
Utilities permittees and Enforcement. HEM Ordinances
operating domestics. Monitoring.
budget
1.2)Continue Monitoring TBD City of Educate public Tier 1-ongoing TCEQ Report SSOs Evaluate the City of Corpus
Sanitary Sewer Overflows Corpus on how they compliance. to TCEQ effectiveness of Christi
(SSOs) Christi can help and continue
Public reduce SSOs. Public public
Utilities notification for notification for
operating public health public health
budget and safety and safety.
TCEQ
compliance
1.3)Continue Collection System TBD City of Educate public Tier 1-ongoing Prevent Reduced Continue City of Corpus
Line Cleaning,Inspection, Corpus on collection overflows and number of monitoring and Christi
Repair and Rehabilitation Christi system line increase overflow response.
Public cleaning, system events.
Utilities inspection, capacity.
operating repair and
budget rehabilitation
program
Texas Commission on Environmental Quality 93 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Control Actions 2.0: Stormwater Drainage System
Existing requirements of Municipal Separate Storm Sewer System (MS4) permits
address some important elements of bacteria loading in stormwater, offering an
adaptive rather than prescriptive approach to bacteria reduction. Structural Best
Management Practices (BMPs), such as modifications to stormwater
infrastructure that may reduce bacteria through aeration, treatment by sunlight,
or physical removal of contaminants, have the potential to reduce bacteria
loading into waterways. However, there is limited data regarding how well such
BMPs (i.e. green infrastructure) might reduce bacteria loading. Therefore, the
CARP Committee has identified the evaluation of the effectiveness of green
infrastructure as one of its priorities.
Control Action 2.1 : Continue Existing Stormwater Programs
The City of Corpus Christi is permitted to discharge stormwater runoff by a Texas
Pollutant Discharge Elimination System (TPDES) Phase I Municipal Separate
Storm Sewer (MS4) Permit. To comply with this permit, the City employs
extensive stormwater pollution prevention programs, as well as land
development programs, some of which address bacteria sources identified in this
I-Plan. These programs shall be continued and modified as deemed appropriate
by the City. Examples of current programs are provided at
http://www.ccparkandrec.com/government/storm-water/index.
•WHAT: Continuation of existing Stormwater Management Programs
throughout the City will ensure the introduction of pollutants into the MS4 is
minimized to the maximum extent practicable.
•WHO: The City of Corpus Christi
•WHERE: Cole and Ropes Parks drainage basins.
•GOAL: Continue existing TPDES Permit Programs to reduce introduction of
pollutants into the MS4.
•WHEN: Continue the efforts of implementing TPDES Permit Programs.
•HOW: Utilize adaptive management techniques to adjust and modify changes
to existing programs.
•COSTS/SOURCE OF FUNDS: Public Utilities Department operating budget;
some programs by other City departments, included in their respective operating
budgets.
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi,TCEQ, EPA
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Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•ACTIONS AND SCHEDULE:
Table 48.CA 2.1.Continue Existing Stormwater Programs. Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Continue Existing Stormwater Programs x x x
Control Action 2.2: Continue Drainage System Line Cleaning,
Inspection, Repair and Rehabilitation
The City of Corpus Christi employs preventive maintenance of drainage lines as
stormwater best management practice to avoid or mitigate clogging of lines to
ensure operational effectiveness. On a periodic basis, as well as an on-going basis,
the City employs two vacuum crews to inspect and service inlets, manholes,
lateral lines and main lines on a planned and emergency schedule. Each of the
18,000+ inlets in the inventory is scheduled for servicing at least once every three
years; some areas, based on condition, are serviced more frequently. For
example, inlets in the downtown and uptown areas are serviced on a quarterly
basis. Additionally, inlets within a special events footprint, i.e., Buccaneer Days,
are cleaned as soon as practical after the conclusion of the event. This inlet,
manhole, and line servicing program, coupled with earthen and concrete-lined
drainage channels cleaning, prevents flooding, maintains drainage system
reliability, improves performance, as well as minimizes the discharge of debris
and other pollutants into the receiving waters.
•WHAT: Inlet cleaning, manhole, lateral line, and main line cleaning; and open-
channel maintenance
•WHO: The Public Utilities Department employs force account and contract to
maintain the City's stormwater drainage infrastructure.
•WHERE: The department routinely performs condition assessments of the
drainage infrastructure. Deficiencies, noted by the condition assessments and
repeated systems failures, but whose replacement/repair scope is outside
Operations and Maintenance funding ability, are placed on the Capital
Improvements Program(CIP)list to compete for Capital funding.
•GOAL: Maintain drainage system capacity and minimize the introduction of
pollutants into the drainage system
•WHEN: Continuously
'HOW: Through vacuum truck operations, lateral line cleaning, channel grading
and debris removal
Texas Commission on Environmental Quality 95 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
•COSTS/SOURCE OF FUNDS: The Department currently operates two (2)
vacuum trucks for cleaning inlets, manholes, lateral lines, and main lines.
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi, a Municipal
Corporation with Home Rule Authority to act in all ways not specifically
prohibited by the State of Texas and State Constitution; TCEQ implementation of
federally delegated Texas Pollutant Disposal Elimination System permitting
authority under Texas Clean Water Act; USEPA, National Pollutant Disposal
Elimination System program, implementing the federal Clean Water Act.
•ACTIONS AND SCHEDULE:
Table 49.CA 2.2. Continue Drainage System Line Cleaning, Inspection, Repair and Rehabilitation.
Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Continue Drainage System Line Cleaning,
Inspection, Repair and Rehabilitation x x x
Texas Commission on Environmental Quality 96 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Ba
Table 50. Summary of Control Action:Stormwater Drainage System]
Control Action:Stormwater Drainage System
Technical
and
Financial Interim,
Potential Load Assistance Education Schedule of Measurable Indicators of Monitoring Responsible
Control Action Reduction Needed Component Implementation Milestones Progress Component Entity
Stormwater Drainage System
2.1)Continue Existing TBD City of Educate public Tier 1-ongoing. City of Corpus Continue City stormwater City of Corpus
Stormwater Programs Corpus on the City's Christi's existing programs are Christi
Christi stormwater Stormwater TPDES evaluated
Public programs Programs are Permit annually by
Utilities continued. Programs to TCEQ through
Department reduce the MS4
Once programs are introduction permitting
evaluated by TCEQ, of pollutants process
implement into the MS4.
recommendation(s)
given by the TCEQ.
•
2.2)Continue Drainage TBD City of Educate public Tier 1-ongoing 'Improved flow Maintain Monitor, City of Corpus
System Line Cleaning, Corpus on drainage capacity and funding for inspect,and Christi
Inspection,Repair and Christi system line minimize line cleaning repair
Rehabilitation Public cleaning, introduction of
Utilities inspection, pollutants
Department repair and
rehabilitation
program.
Texas Commission on Environmental Quality 97 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Control Actions 3.0: Ordinance and Regulation
Source tracking should be the FIRST implementation activity before any other
engineering solutions, etc. to determine how to order/prioritize further activities.
Control Action 3.1 : Eliminate Residential Cross-Connections
•WHAT: Conduct a pilot project to determine if residential properties (including
duplexes, townhouses, and similar small multi-family residential units under individual
ownership with common areas) are sources of wastewater and other wastes materials
that result in the introduction of bacteria into the City's MS4 (Municipal Separate
Stormwater Sewer System, e.g., the stormwater sewer lines, drainage ditches, and street
curbs and gutters). A primary concern involves illegal cross-connections between the
private stormwater and wastewater sewer lines on the property that allow wastewater to
infiltrate into the MS4. If the pilot project determines there is a cross-connection
problem with residential homes the project should expand to other basins.
•WHO: City of Corpus Christi
•WHERE: Within drainage basins that discharge into the TMDL study area, and any
immediately adjoining drainage basins.
•GOAL: Reduce or eliminate all illegal cross-connections within the drainage basins
that discharge within the TMDL within 10 years.
•WHEN: Develop, adopt and institute a targeted inspection program for wastewater
and stormwater lines in the TMDL drainage basins in Tier 1. Undertake and complete
review of City's Technical Construction Codes and Housing Standards Code, identifying
all code sections relating to unpermitted work by homeowners. Identify which codes are
intended for adoption or amendment during the next technical construction codes
update process, and prepare and present for adoption ordinances required to update the
code to meet these goals.
• HOW:
a. Illegal Cross-connection Inspection Program. Establish an enhanced,
targeted inspection program, within the drainage basins contributing flows to the
TMDL program area, to locate unauthorized cross-connections on private
property to include smoke testing wastewater collection lines and stormwater
lines. Problem appears to occur more frequently during repairs, replacement of
underground piping, and homeowner repairs, rather than new installations
subject to more rigid inspections.
b. Code Updates. Review the City's technical construction codes and housing
standards codes, identifying all sections that pertain or relate to the issue of
Texas Commission on Environmental Quality 98 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
cross-connections. Prepare and propose to Council any ordinances necessary to
update the City's Technical Construction Codes and Housing Standards Code.
Amendments should provide for enhanced enforcement capabilities, fines or
increased fines, and consider fees and other consequences for violating the law.
c. Unpermitted Work. Review and identify all codes and criteria that allow a
homeowner to do work on on-site underground piping systems without a
plumbing permit. Determine how best to inform homeowners about plumbing
work standards for both permitted and unpermitted work. Reconsider, if deemed
appropriate, conditions under which unpermitted plumbing work is allowed.
•COSTS/SOURCE OF FUNDS: Costs to the City of Corpus Christi are to be
determined. Adopt by ordinance the necessary regulatory fees to be charged to the
customer for costs of inspections to determine needed repairs, and needed lateral
replacements at rates designed to cover the total costs to the City to administer the
program. The City should explore funding/tax abatement/incentives programs to assist
the City with program cost overruns in addition to grant funding of inspections, needed
repairs, and lateral replacements, especially for low income property owners. (Funding
issues concerning unpermitted homeowner work could be resolved by the fee being
charged through the City's plumbing inspections process.)
•RESPONSIBLE ORGANIZATION(S): City of Corpus Christi's Charter, the Texas
State Constitution and other federal, state and local laws, as applicable.
•ACTIONS AND SCHEDULE:
Table 51.CA 3.1. Eliminate Residential Cross-connections. Implementation timeline schedule.
Actions Tier 1 Tier 2 Tier 3
Conduct a Pilot Project to Determine if
Residential Properties(Including Duplexes,
Townhouses, and Similar Small Multi-Family
Residential Units Under Individual
Ownership with Common Areas)Are x
Sources of Wastewater and Other Wastes
Materials that Result in the Introduction of
Bacteria into the City's MS4(Municipal
Separate Stormwater Sewer System)
Establish an Illegal Cross-connection
Inspection Program x x x
Code Updates x x
Texas Commission on Environmental Quality 99 Peer Review Draft,Month,Day,Year
D I .rta_.aairiia.a.195:ani.a_t___a.r.lc.1.z.- ____n11.fitlit.ri'_lia. i�f.i�yil r
Table 52. Summary of Control Action:Ordinance and Regulation
Control Action:Ordinance and Regulation
Technical
and
Potential Financial Schedule of Interim,
Load Assistance Education Implementati Measurable Indicators of Monitoring Responsible
Control Measure Reduction Needed Component on Milestones Progress Component Entity
Ordinance and Regulation
3.1)Eliminate Residential TBD TBD Educate Tier 1. Conduct a Establish an Determine City of Corpus
Cross-Connections public on pilot project enhanced, number of Christi
residential to determine targeted illegal cross-
cross- if residential inspection connections
connections properties program identified vs.
(including within the number of
duplexes, CARP illegal cross-
townhouses, drainage connections
and similar basins. corrected.
small multi-
family Prepare and
residential present to
units under Council for
individual adoption the
ownership ordinances
with common that would
areas)are update City's
sources of technical
wastewater construction
and other codes to
wastes address illegal
materials that cross-
result in the connections
introduction and
of bacteria unpermitted
into the City's plumbing
MS4. work
Establish an Illegal cross-
enhanced, connection
targeted inspection
inspection program
program established
Texas Commission on Environmental Quality 100 Peer Review Draft,Month,Day,Year
D .ft I •rtanc,ictrt(c•ri1hr.ecaittr•rt :ta•T•I•r >r9 ic.�f=r r r i�c+yi•tir...r��i�.ic���tr
Technical
and
Potential Financial Schedule of Interim,
Load Assistance Education Implementati Measurable Indicators of Monitoring Responsible
Control Measure Reduction Needed Component on ( Milestones Progress Component Entity
within the
drainage Code updates
basins
contributing
flows to the
TMDL
program area
to locate
unauthorized
cross-
connections
on private
property,this
may include
smoke testing
wastewater
collection
lines and
stormwater
lines in pilot
or targeted
areas
Establish an
illegal cross-
connection
inspection
program
Implement
the enhanced,
targeted
program.
Complete
review of
current
technical
Texas Commission on Environmental Quality 101 Peer Review Draft,Month,Day,Year
D Ialautaar»c.1ifhlioc•1iRd«a1[.Et.].r-3-rjr aMIca.r la'3a+.v tiA�i�tiirl r�
Technical
and
Potential Financial Schedule of Interim,
Load Assistance Education Implementati Measurable Indicators of Monitoring Responsible
Control Measure Reduction Needed Component on Milestones Progress Component Entity
construction
codes.
Take
appropriate
enforcement
action if
property
owners do not
make
necessary
repairs to
private sewer
lines.
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Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Sustainability
The TCEQ and stakeholders in TMDL implementation projects periodically assess the
results of the planned activities, along with other information, to evaluate the
effectiveness of the I-Plan. Stakeholders evaluate several factors, such as the pace of
implementation, the effectiveness of BMPs, load reductions, and progress toward
meeting water quality standards. The TCEQ will document the results of these
evaluations and the rationale for maintaining or revising elements of the I-Plan.
The TCEQ and stakeholders will track progress using both implementation milestones
and water quality indicators.These terms are defined as:
• Water Quality Indicator—A measure of water quality conditions for comparison
to pre-existing conditions, constituent loadings, and water quality standards.
• Implementation Milestones —A measure of administrative actions undertaken
to affect improvement in water quality.
Water Quality Indicators
The Texas General Land Office Texas Beach Watch Program will continue sampling for
bacteria in water at Cole and Ropes Park during implementation. Additional funding
will be sought to conduct supplemental monitoring in the watershed.
The indicators that will be used to measure improvement in water quality are
improvements in bacteria levels at Cole and Ropes Park
Follow-up monitoring will be conducted within the watershed throughout the
implementation schedule. The monitoring strategy will consider the spatial and
temporal aspects necessary to characterize trends in water quality that result from
implementing the activities in this plan. Follow-up monitoring through the Texas Beach
Watch Program will also provide water quality data for evaluation of standards
attainment. The monitoring program is expected to consist of routine sampling
exercises that emphasize historical monitoring locations, with some potential
modifications as needed. Water quality monitoring and data collection will occur
routinely throughout the year. As stated in the TMDL report, the summer season
represents the critical condition, during which time the study area has the highest levels
of contact recreation. The TMDL and respective reductions are based on the critical
condition.
CCS, with support from the TCEQ, began a three-year monitoring regime in May 2011.
The objective of this monitoring was to provide data for characterizing Enterococcus
Texas Commission on Environmental Quality 103 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
bacteria loads at the impaired beaches. The project goals required the collection of
supplementary Enterococcus data in Corpus Christi Bay. Data collection specifically
targeted beaches at Cole Park (Segment 248iCB_03), Ropes Park (Segment
2481CB_o4), Emerald Beach (Segment 248iCB_07), McGee Beach (Segment
2481CB_o5), Poenisch Park (Segment 2481CB_o6), Corpus Christi Beach (Segment
2481CB_o2), and University Beach (Segment 2481CB_o8). Monitoring plan included
routine bacteria sampling, rain event sampling, rainfall data collection, sediment cores,
and beach use surveys.
(https://www.tceq.texas.gov/waterquality/tmdl/97-corpusbeachesbacteria.html)
The CCS was responsible for coordinating the monitoring activities for the TCEQ at
these beaches. The data from these activities are included in the TCEQ's Surface Water
Quality Monitoring database (SWQMIS), which houses the primary data used for the
state's biennial assessment of water quality. The CCS collected water samples as
described in the Quality Assurance Project Plan for the study area. The data was
analyzed by CCS and the TCEQ.
The TCEQ will assess Cole and Ropes Parks beaches every two years as part of updating
the Integrated Report. If the Texas Surface Water Quality Standards criteria for contact
recreation are revised or water quality changes at these beaches are observed, this plan
will be modified. This management strategy allows stakeholders to learn and adapt the
plan as progress is made. The ultimate goal is for the AUs of both Cole and Ropes Parks
beaches is to meet water quality standards for contact recreation. If sufficient reductions
in Enterococcus are not observed, the stakeholders will reevaluate the potential sources
identified in the TMDL and adapt the I-Plan as appropriate.
Implementation Milestones
Implementation tracking provides information that can be used to determine if progress
is being made toward meeting goals of the TMDL. Tracking also allows stakeholders to
evaluate actions taken, identify those which may not be working, and make any changes
that may be necessary to get the plan back on target. Schedules of implementation
activities and milestones for this I-Plan are included in Appendix A.
Communication Strategy
Communication is necessary to ensure stakeholders understand the I-Plan and its
progress in restoring water quality conditions. The TCEQ will disseminate the
information derived from tracking I-Plan activities to all interested parties,
organizations, and individuals.
The TCEQ will report results and evaluations from implementation tracking to
stakeholders as needed. The TMDL Program will summarize all actions taken to address
the impairment and will report trends observed in the water quality data collected to
Texas Commission on Environmental Quality 104 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
track the progress of implementation as needed. Responsible parties are committed to
providing appropriate information to the TCEQ to update these progress assessments
and communicating information at annual meetings.
In accordance with the Clean Water Act §319, the state must annually report to USEPA
on success in achieving the goals and objectives of the Texas Nonpoint Source
Management Program, including progress in implementing the NPS portion of TMDLs.
The TCEQ and TSSWCB jointly publish Managing Nonpoint Source Water Pollution in
Texas: Annual Report, which highlights the state's efforts during each fiscal year to
collect data, assess water quality, implement projects that reduce or prevent NPS
pollution, and educate and involve the public to improve the quality of water resources.
Information derived from tracking and review activities of this I-Plan will be reported in
each annual report. Previously published annual reports are available at
<www.tceq.texas.gov/waterquality/nonpoint-source/mgmt-plan/annual-reports.html>.
The TCEQ will host annual meetings for up to five years so stakeholders may evaluate
their progress. Stakeholders and responsible parties will continue to take part in annual
meetings over the five-year period to evaluate implementation efforts.At the completion
of the scheduled I-Plan activities, stakeholders will assemble and evaluate the actions,
overall impacts, and results of their implementation efforts.
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Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
References
EPA 2001. Protocol for Developing Pathogen TMDLs. <www.epa.gov/owow/tmdl/
pathogen_all.pdf>.
EPA 2003. Nonpoint Source Program and Grants Guidelines for States and Territories.
<www.epa.gov/fedrgstr/EPA-WATER/2oo3/October/Day-23/w26755.htm>.
EPA 2010. Implementing Agricultural Best Management Practices Improves Water
Quality.Nonpoint Source Program Success Story.
Sawyer, C.B., W.R. English, J.C. Hayes, L.W. Jolley, C.J. Post, W. C. Bridges, Jr. 2010.
Bacteria in Construction Site Sediment Basins. In Proceedings of the 2010 South
Carolina Water Resources Conference, October 13-14, 2010, Columbia Metropolitan
Convention Center. 5 pp.
Schueler„ T. D. Hirschman, M. Novotney, and J. Zielinski. 2007. Urban Stormwater
Retrofit Practices. Urban Subwatershed Restoration Manual No. 3, Version 1.o.
Prepared for Office of Wastewater Management, U.S. Environmental Protection Agency.
262 p.
Skinner, J.F., J. Kappeler, J. Guzman. 2010. Regrowth of Enterococci & Fecal Coliform
in Biofilm.
http://www.stormh2o.com/SW/Articles/Regrowth of Enterococci Fecal Coliform i
n Biofilm 11o64.aspx
TCEQ. 2016. Two Total Maximum Daily Loads for Bacteria in Corpus Christi Bay
(Recreational Beaches), Segment 2481CB, Assessment Units 2481CB_o3 and
2481CB_o4.Texas Commission on Environmental Quality. 79 pp.
Yang L., B. Lin, and R. A. Falconer. 2008. Modelling Enteric Bacteria Level in Coastal
and Estuarine Waters. In Proceedings of the Institution of Civil Engineers Engineering
and Computational Mechanics 161: 179-186.
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Appendix A.
I-Plan Matrix
Texas Commission on Environmental Quality 107 Peer Review Draft,Month, Day,Year
D • I .1- - . . P1. .1- . . R.. P. " - - .r t
Table A-1. CARP Watershed Monitoring and Assessment—Implementation Schedule and Tasks
Tier 1 Tier 2 Tier 3
Management Measure Activity
1-5 5-10 years 10-15 years
years
1.Education and Outreach
Create and Utilize Public Education Materials
1.1 General Awareness Create and Utilize Appropriate Public Service Announcements(PSA)
Conduct Public presentations
Reinforce and Support"Leave It Better Than You Found It"Media Campaign
•
Increase support for TGLO Adopt-A-Beach.Create Adopt-A-Bay,Watershed,etc.
1.2 Leave It Better Than you Found It •
Engage local leaders to address City wide litter problem
Engage local businesses to support clean initiatives and post"Leave It Better Than You Found
It"campaign signs
Pet Waste Stations
Public Service Announcements(PSA)
1.3 Pet Waste Disposal Awareness
Create info both for local events
Distribute educational materials and kits to pet businesses and services
Sponsor TIDRC workshop in Corpus Christi annually
1 4 Prevent Intentional Dumping and Hunting and fishing organization education and outreach annually
Disposal
Coordination with City Solid Waste Department quarterly
Provide LID workshop for local designers and engineers
Slow the Flow(Low Impact Promote benefits of LID through Social Media
1.5 Development)Initiative •
Incorporate LID into other outreach presentations
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Draft Implementation Plan for Cole and Roes Parks Beaches in Corpus Christi Bay
Tier 1 Tier 2 Tier 3
Management Measure Activity
1-5
years 5-10 years 10-15 years
2.Monitoring
2 1 Continue Sampling Enterococcus Texas Beach Watch Sampling
Levels at Cole and Ropes Parks
Collect Rainfall Data Near Cole and Planning and implementation in smaller pilot project area
2.2 Ropes Parks
Data management and maintenance
Planning and implementation in smaller pilot project area
Conduct Stormwater Outfall Flow Planning for entire Cole and Ropes Parks basin
2.3
Sampling Project implementation for entire Cole and Ropes Parks basins
Data management and maintenance
3.Research
Initiate feasibility study
3.1 Evaluate Methods to Remove Bacteria With Green Infrastructure Develop recommendations at completion of study
Sample collection;pre-rain event FIRST PRIORITY
3.2 Bacterial Source Tracking
Sample collection;post-rain event FIRST PRIORITY
Evaluate the Effectiveness of Public
3.3 Utilities Programs and Projects in Evaluate program and project effectiveness through monitoring
Reducing Bacteria
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Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Ba
Tier 1 Tier 2 Tier 3
Management Measure Activity
1-5 5-10 years 10-15 years
years
Promote New Data Analysis Method
3.4 for Regulatory Justification for Listing Recommend change to data review methodology for regulatory purposes
Beaches on the 303(d)List
Identify Water Flow Patterns in
3.5 Corpus Christi Bay at Cole and Ropes Planning and implementation of dye testing procedure
Parks by Use of Dye Testing
Change Sampling Date of Current
3.6 Texas Beach Watch Program to be TX Beach Watch sampling day change
More Protective of Public Health
4.Wastewater Collection Systems
Enhance Existing Fats,Oil&Grease Food service HEM monitoring
Al (FOG)Program
Food service grease interceptor maintenance enforcement
Continue the Notification System for Continue SSO reporting
4.2 Monitoring Sanitary Sewer Overflows Develop list-serve
(SSOs).
Create notification system
Expand Collection System Line Customer response on-going
4.3 Cleaning,Inspection,Repair,and Review funding for line cleaning through annual budget process
Rehabilitation
Increase funding for smoke testing through annual budget process
Determine flow monitoring site locations on-going
4 4 Implement an Ongoing Inflow and Conduct flow monitoring on-going
Infiltration Study
Perform data collection and analysis on-going
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•
Draft Implementation Plan for Cole and Ropes Parks Beaches in Co •us Christi Ba
Tier 1 Tier 2 Tier 3
Management Measure Activity
1-5
years 5-10 years 10-15 years
Rank sub-basins
Prepare sanitary sewer evaluation survey
Complete I/I study report
Phase 1:Oso,Greenwood,and Broadway WWTP basins:conduct flow monitoring
Phase 1:Oso,Greenwood,and Broadway WWTP basins:data collection and analysis
4 5 Conduct Hydraulic Modeling of Ranking of sub-basins based on UI
Collection System
Contract complete
Development of prioritized system improvement program
5.Stormwater Drainage System
Determine Effectiveness of Pilot project
5.1 Stormwater Retrofits to Remove
Bacteria Develop recommendations at completion of study
Continue Major Outfall Assessment Focused outfall assessment program within CARP drainage basins
5.2 and Repair Program as Funding
Allows Develop recommendations at completion of
ssessment
5.3 Support and Encourage Adoption of Adopt stormwater master plan
Stormwater Master Plan
6.Ordinance and Regulation
Residential Leaking/Broken Private Prepare and present for adoption ordinances necessary to establish pre-sale inspection daring next code
6.1 Sewer Laterals Pre-Sale program for private sewer lines within CARP drainage basins reopon process
Inspection/Testing Program
Complete review of current technical construction codes
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Tier 1 Tier 2 Tier 3
Management Measure Activity 1-5
years 5-10 years 10-15 years
Prepare and present for adoption ordinances to update City's technical construction codes to aurins next code
address illegal cross-connections revision process
Implement program
Determine number of broken/leaking private sewer lines identified vs number of broken/
leaking private sewer lines corrected
Complete ordinance review and amendment adoption process
Complete review of current technical construction codes
Prepare and present for adoption ordinances necessary to establish an enhanced,targeted
inspection program to locate unauthorized cross-connections for private sewer lines within during next code
CARP drainage basins which may include smoke testing wastewater collection lines and revision press
6.2 Commercial Cross-Connection stormwater lines
Inspection Program
Prepare and present for adoption ordinances to update City's technical construction codes to during next code
address illegal cross-connections revision process
Complete inspection of target drainage basins
Determine number of illegal cross-connections identified vs number of illegal cross-
connections corrected
thin
Complete ordinance review and amendment adoption process adopt 2 years of aoWon
Complete review of current technical construction codes during me
revision prr codeocess
Commercial Leaking/Broken Sewer Evaluate adequacy of City's current certificate of occupancy program to address property To begin with program
6.3 Laterals Pilot Inspection/Testing infrastructure issues,especially upon change of ownership or tenants;consider adoption of commencement
Program City business permit system
Prepare and present for adoption ordinances necessary to establish an enhanced,targeted within 2 years or i-Plan
pilot program to inspect for leaks and broken private sewer lines within CARP drainage basins edopnon
Prepare and present for adoption ordinances to update City's technical construction codes to during next code
address illegal cross-connections revision process
Texas Commission on Environmental Quality 112 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Ter 1 Tier 2 Tier 3
Management Measure Activity
1-5 5-10 years 10-15 years
years
Determine number of broken/leaking private sewer lines identified vs number of broken/ Evaluation win take
leaking private sewer lines correctedcmpPle e r study Is
Continue grease trap,grit trap,and oil/water separator inspection program on-going
Complete review of City's technical construction code provisions related to grease traps,grit
traps,and oil/water separators
6.4 improved Grease Trap Standards Prepare and present for adoption any necessary changes to the City's technical construction during next tochniwi
code provisions related to grease traps,grit traps,and oil/water separators update proc codes
update process
Determine number of grease traps,grit traps,and oil/water separators that do not operate at n
appropriate levels vs number of grease traps,grit traps,and oil/water separators repaired or too mbeginmenewloth p ogram
replaced
Review animal control ordinances adopted in other communities within 2 years of i-Pian
adoption
Strengthen Current Animal Control
6.5 Ordinances Relating to Removal and Willa!2 years of-Pian
Disposal of Pet Waste Prepare and present for adoption appropriate amendments to City's animal control ordinances adoption
Evaluate number of complaints investigated,number of enforcement actions taken to begin with program
commencement
Review animal control ordinances adopted in other communities within 2 rears of i-Plan
Implement Measures to Control Feral , Prepare and present for adoption appropriate amendments to City's animal control ordinances adoptioon
n ars otl-iron
6.6 Cats,Rodents,and Nuisance Animals
Make pet waste enforcement a policy priority,or at least a function,within the City's police within t year of I-Plan
department,not limited to code compliance department adoption
Evaluate number of complaints investigated,number of enforcement actions taken to begin with Program
commencement
6.7 Install Additional Signage Install additional signage edopbor year of i-Plan
Texas Commission on Environmental Quality 113 Peer Review Draft,Month,Day,Year
Tier 1 Tier 2 Tier 3
Management Measure Activity
1-5 5-10 years 10-15 years
years
Develop Advisement Protocol to Warn
the Public of Periodically Elevated
Prepare andpresent for adoption ordinances settingstandards for issuingw;min+rear of i-rlan
p p general and specific
Bacteria Levels,as Anticipated byadoption and obtaining
6.8 public health safety advisories on the contact recreational use of bay waters with bacterial
Weather Forecasts for Rain,as well contamination following major rain events support anot ores
as Warnings During and Immediately
After Rainfall.
Restrict Access to Bay Waters from
City Parks and Other Bay Front City Prepare and present for adoption an ordinance authorizing City Manager to restrict access to within 1 year of i-Plan
6'9
Properties DuringPeriods of Public targeted baywaters for contacts recreation when there is a significant public health risk adoption erbainput
Health Risk
Prepare and present for adoption ordinances related to solid waste that address:increased
6.10 Adopt and Enforce Additional receptacles on commercial and public properties,more commercial waste service,dumpster wthin 2 years of
Ordinances maintenance and sanitation,reduced plastic bag usage,and fugitive waste on City service adoption of i-a an
routes.
Explore Adoption of Additional"Low Review LID standards adopted by other communities. within a years of
Impact Development"Standards in adoption of f-flan
Unified Development Code that will
6.11 Reduce Volumes of Stormwater
Runoff from Areas of New
Development or Significant Prepare and present for adoption ordinances to amend City's Unified Development Code to w;u,in 3 years of
Redevelopment encourage LID. adoption of 1-Plan
Tier 1 Tier2 Tier3
Control Action Activity
1-5 years 5-10 years 10-15 years
1.Wastewater Collection Systems
Continue Existing Fats,Oil&Grease Continue current Food Service Hexane Extractible Material(HEM)monitoring program on-going
1.1 (FOG)program
Continue current Food Service Grease Interceptor maintenance enforcement on-going
Texas Commission on Environmental Quality 114 Peer Review Draft,Month,Day,Year
D . I 2alltautucafica.aLtA:tuc.eZ.�.ia>a tlti<Etat.l.c�yi.iit.�rtaja�t�tii�frr
Tier 1 Tier 2 Tier 3
Management Measure Activity 1-5
years 5-10 years 10-15 years
Continue Monitoring Sanitary Sewer Continue SSO reporting to TCEQ on-going
1.2 OverflowsSSOs
� ) Report SSOs to interested and affected groups
Respond to affected areas identified by cleaning,closed circuit television inspection,smoke
Continue Collection System Line detection surveys,and customer complaints on-going
1.3 Cleaning,Inspection,Repair,and
Rehabilitation Review funding for line cleaning through annual budget process
Increase funding for smoke testing through annual budget process
2.Stormwater Drainage System
2 1 Continue Existing Stormwater I Continue TPDES MS4 Programs I on-going
Programs
Continue maintenance stonnwater inlets,manholes,lateral lines,and main lines,as well as
Continue Drainage System Line open-channel maintenance according to service schedule,special events,emergency on-going
2.2 Cleaning,Inspection,Repair,and response,and customer response
Rehabilitation Maintain funding for line cleaning through annual budget process
3.Ordinance and Regulation
Complete ordinance review and amendment adoption process
Complete review of current technical construction codes
Prepare and present for adoption ordinances necessary to establish an enhanced,targeted
inspection program to locate unauthorized cross-connections for private sewer lines within
Eliminate Residential Cross- CARP drainage basins which may include smoke testing wastewater collection lines and
3.1 Connections storrnwater lines
nxt cod
Prepare and present for adoption ordinances to update City's technical construction codes to aonng e
n processa or
address illegal cross-connections and unpermitted plumbing work within 2 years of I-Plan
adoption
Texas Commission on Environmental Quality 115 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Tier 1 Tier 2 Ter 3
Management Measure Activity 1-5
ears 5-10 years 10-15 years
Conduct a pilot project to determine if residential properties(including duplexes,townhouses,
and similar small multi-family residential units under individual ownership with common areas)
are sources of wastewater and other wastes materials that result in the introduction of bacteria
into the City's MS4(Municipal Separate Stornwater Sewer System
Establish an enhanced,targeted inspection program within the drainage basins contributing .;;;
flows to the TMDL program area to locate unauthorized cross-connections on private property,
this may include smoke testing wastewater collection lines and stormwater lines in pilot or
targeted areas
Implement targeted program within CARP basins
Complete inspection of target drainage basins
Determine number of illegal cross-connections identrfied vs number of illegal cross-
connections corrected
Texas Commission on Environmental Quality 116 Peer Review Draft,Month,Day,Year
Draft Implementation Plan for Cole and Ropes Parks Beaches in Corpus Christi Bay
Appendix B.
Load Reduction Estimates
Texas Commission on Environmental Quality 117 Peer Review Draft, Month, Day, Year
Load Reduction Estimates
Table B-1. CARP Watershed Load Reduction Estimates
Cole Park Ropes Park
Measure/Action Description Targeted# Load Targeted# Load
Reduction Reduction
1.0.Education and Outreach
Management Measure 1.1 General Awareness TBD TBD TBD TBD
•
Management Measure 1.2 Leave It Better Than You Found It TBD TBD TBD TBD
Management Measure 1.3 Pet Waste Disposal TED TBD TBD TBD
Management Measure 1.4 Prevent Intentional Dumping and Disposal TBD TBD TBD TBD
Management Measure 1.5 Slow the Flow(Low Impact Development)Initiative TBD TBD TBD TBD
2.0.Monitoring
Management Measure 2.1 Continuing Sampling Enterococcus Levels at Cole and Ropes Park NA NA NA NA
Management Measure 2.2 Collect Rainfall Data Near Cole and Ropes Parks NA NA NA NA
Management Measure 2.3 Conduct Stormwater Outfall Flow Sampling NA NA NA NA
3.0 Research
Management Measure 3.1 Evaluate Methods to Remove Bacteria with Green Infrastructure TBD TBD TBD TBD
Management Measure 3.2 Bacterial Source Tracking TBD TBD TBD TBD
Management Measure 3.3 Evaluate the Effectiveness of Public Utility Programs and Projects in TBD TBD TBD TED
Bacteria Reductions
Management Measure 3.4 Promote New Data Analysis Method for Regulatory Justification for Listing TBD TBD TBD TBD
Beaches on the 303(d)List •
Management Measure 3.5 Identify Water Flow Patterns in Corpus Christi Bay at Cole and Ropes TBD • TBD TBD TBD
Texas Commission on Environmental Quality 118 Peer Review Draft,Month,Day,Year
•
D . 1 .rta.c 1rtrrtt.l�r�kl.tot.rl�.rt r.c:�:2.t.i tl mfr l of.r��iri�.t�.ntitd.t��ytl:r�.
Cole Park Ropes Park
Measure/Action Description Targeted# Load Targeted# Load
Reduction Reduction
Pars by the use of Dye Testing
Management Measure 3.6 Change Sampling Date of Current Texas Beach Watch Program to be TBD TBD TBD TBD
More Protective of Public Health
4.0.Wastewater Collection Systems
Management Measure 4.1 Enhance Existing Fats,Oil 8 Grease(FOG)Program TBD TBD TBD TBD
Management Measure 4.2 Continue the Notification System for Monitoring Sanitary Sewer Overflows TBD TBD TBD TBD
(SSO's)
Management Measure 4.3 Expand Collection System Line Cleaning,Inspection,Repair and TBD TBD TBD TBD
Rehabilitation
•
Management Measure 4.4 Implement an Ongoing Inflow and Infiltration Study TBD TBD TBD TBD
Management Measure 4.5 Conduct Hydraulic Modeling of Collection System TBD TBD TBD TBD
5.0.Stormwater Drainage System
Management Measure 5.1 Determine Effectiveness of Stormwater Retrofits to Remove Bacteria TBD TBD TBD TED
Management Measure 5.2 Continue the Major Outfall Assessment and Repair Program as Funding TBD TBD TBD TBD
Allows
Management Measure 5.3 Support and Encourage the Adoption of Stormwater Master Plan TBD TBD TBD TBD
6.0.Ordinances and Regulations
Management Measure 6.1 Residential Leaking/Broken Private Sewer Laterals Pre-Sale TBD TBD TBD TBD
Inspection/Testing Program
Management Measure 6.2 Commercial Cross-connection Inspection Program TBD TBD TBD TBD
Management Measure 6.3 Commercial Leaking/Broken Sewer Laterals Pilot Inspection/Testing TBD TBD TBD TBD
Program
Texas Commission on Environmental Quality 119 Peer Review Draft,Month,Day,Year
D - I .rts.rrs Teti r�ttui.]i?r.rtxo1:R.t.- P. B-. - •1 -1 itn-t41=tai
Cole Park Ropes Park
Measure/Action Description Targeted# Load Targeted# Load
Reduction Reduction
Management Measure 6.4 Improved Grease Trap Standards TBD TBD TBD TBD
Management Measure 6.5 Strengthen Current Animal Control Ordinances Relating to Removal and TBD TBD TBD TBD
Disposal of Pet Wastes
Management Measure 6.6 Implement Measures to Control Feral Cats,Rodents,and Nuisance TBD TBD TBD TBD
Animals
Management Measure 6.7 Install Additional Signage TBD TED TBD TBD
Management Measure 6.8 Develop Advisement Protocol to Warn the Public of Periodically Elevated TBD TBD TBD TBD
Bacteria Levels,as Anticipated by Weather Forecasts for Rain,as well as
Warnings During and Immediately After Rainfall
Management Measure 6.9 Restrict Access to Bay Waters from City Parks and Other Bayfront City TED TBD TBD TBD
Properties during Periods of Public Health Risks
Management Measure 6.10 Adopt and Enforce Additional Ordinances TBD TBD TBD TBD
Management Measure 6.11 Explore Adoption of Additional"Low Impact Development"Standards in TBD TBD TBD TBD
Unified Development Code that will Reduce Volumes of Stormwater
Runoff from Areas of New Development or Significant Redevelopment
1.0.Wastewater Collection Systems
Control Action 1.1 Continue Existing Fats,Oil&Grease(FOG)Program TBD TBD TBD TBD
Control Action 1.2 Continue Monitoring Sanitary Sewer Overflows(SSOs) TBD TBD TBD TBD
Control Action 1.3 Continue Collection System Line Cleaning,Inspection,Repair and TBD TBD TBD TBD
Rehabilitation
2.0.Stormwater Drainage System
Control Action 2.1 Continue Existing Stormwater Programs TBD TBD TBD TBD
Control Action 2.2 Continue Drainage System Line Cleaning,Inspection,Repair and TBD TBD TBD TBD
Rehabilitation
Texas Commission on Environmental Quality 120 Peer Review Draft,Month,Day,Year
D . I .Aaucaat ir•trfl[trst.1.a.A 1.1..U.J.zz t1'F�hx[da at.ti.ntitK.j ifcfr
Cole Park Ropes Park
Measure/Action Description Targeted# Load Targeted# Load
Reduction Reduction
3.0.Ordinances and Regulations
Control Action 3.1 Eliminate Residential Cross-Connections TBD TBD TBD TBD
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Appendix C.
Formal Support for the I-Plan
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Formal Support for the I-Plan
[Insert letters and resolutions]
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