OKLAHOMA: CITY OF TULSA

   City of Tulsa's Comprehensive Watershed Management
   Approach

   Background

   The City of Tulsa established a stakeholder-based comprehensive Watershed
   Management Team that implemented a regionally coordinated approach and reduced
   water quality degradation from poultry farms in Arkansas and Oklahoma for a surface
   water source that supplies drinking water to over 400,000 residents.

   The Tulsa Metropolitan Utility Authority (TMUA) supplies water to over 400,000 residents
   in the City of Tulsa and in 17 other cities and 11 rural water districts. Nearly twenty
   percent of Oklahoma's citizens rely on Tulsa's drinking water. Tulsa draws
   approximately 50 MGD from the Lake Oologah system and roughly 60 MGD from the
   Eucha/Spavinaw double reservoir system. The Eucha/ Spavinaw watershed straddles
   Oklahoma and Arkansas in the Ozark and Central Plains ecoregions of the Ozark
   Plateau.

   A Clean Water Act Section 314 Diagnostic And Feasibility Study (Phase I Clean Lakes
   Study) on Lake Eucha indicated the watershed was experiencing unprecedented growth
   of poultry production, and that the dramatic increase in poultry litter application to
   pastures in the watershed was the most likely sources of excess nutrients feeding into
   Lake Eucha (a later study also confirmed this for downstream Spavinaw Lake) resulting
   in eutrophication.  Both lakes are listed as Nutrient Limited Watersheds (NLW) due to
   excessive nutrient loading.  A second follow-up study equivalent to the required
   impairment study for NLWs determined that both lakes are impaired for dissolved
   oxygen (due to excessive algal growth). Both lakes are currently listed as Category Five
   (impaired beneficial uses requiring development of a TMDL) on Oklahoma's Integrated
   Water Quality Assessment Report. Since the early 1990's, excessive algal growth has
   resulted in a steady decline in drinking water quality from the Eucha/Spavinaw system
   (Tulsa has documented recent avoidance of using both lakes during heavy algae
   blooms).

   Priority Contamination Threat

   The priority contamination threat is nutrient loading from poultry farms.

   Local Involvement and Developing the Protection Plan

   In an effort to reduce nutrient loads and protect water quality, in 1997, the TMUA
   established a stakeholder-based comprehensive Watershed Management Team to
   develop a regionally coordinated approach to addressing water quality degradation in
   the Eucha/Spavinaw Watershed.  Participants were drawn from both Arkansas and
   Oklahoma and included poultry growers, poultry litter haulers and applicators,
   representatives of poultry companies, concerned citizens, non-profit organizations, the
   Indian Nations Council of Governments, as well as State (Arkansas and Oklahoma) and
   Federal agencies.
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   Three technical working groups were established to focus on technical issues and build
   a sound scientific and economic basis for water quality protection efforts.  The
   Monitoring, Assessment, and Evaluation Working Group was led by the Indian Nations
   Council of Governments and focused on water-quality sampling and monitoring within
   the watershed. The Nutrient Management Working Group, led by the Foundation for
   Organic Resources Management, Inc. FORM), focused on improved nutrient
   management on farms within the watershed.  The Nutrient Export and Marketing
   Working Group led by FORM focused on watershed-scale export and marketing of
   poultry litter.

   The Watershed Management Team and the three working groups were very active and
   over the course of four years made significant advances in characterizing the nature and
   causes of the water quality impairments in the watershed and in identifying potential
   mitigation strategies.  Major accomplishments included the development of an interactive
   GIS (available to the public), five scientific studies,  Quality Assurance Project Plan
   (reviewed by Region VI EPA and determined  to be consistent with systems funded as
   EPA water quality projects), a poultry litter export hotline, a common data reference
   library, and the development of Oklahoma's first Watershed Restoration Action Strategy
   (WRAS). The Oklahoma Conservation Commission developed several projects that
   have installed best management practices (BMP) to minimize non-point source pollution
   in the watershed.  Many of the 15 goals established by the WRAS were met, including:

   1.  Establish a Watershed Management Team and technical Work Groups to support all
   water quality and nutrient management activities.

   2.  Establish Quality Assurance Goals for all  Tulsa funded research, and  require that all
   Tulsa funded data collection projects develop a peer reviewed and approved  QAPP for
   all project activities.

   3.  Establish a Project Management Database to be used by Tulsa for project
   management, scheduling, planning, funding and reporting of all watershed activities.

   4.  Improve raw water treatment methods to  control Taste and Odor problems at
   Mohawk TP by researching and establishing  state of the art treatment and control
   practices.

   5.  Reduce non-point source nutrient loadings to Eucha /  Spavinaw watershed and
   lakes by supporting and implementing appropriate nutrient management strategies and
   Public Outreach initiatives.

   6.  Coordinate with the appropriate authorities in Arkansas to develop a preliminary
   TMDL for nutrients for the Eucha / Spavinaw  watershed based upon results from current
   water quality studies, and recommend future  TMDL strategies after completion of the
   preliminary TMDL.

   7.  Work with the appropriate authorities in Arkansas to encourage the modification of
   municipal NPDES permit allocations, as necessary, for nutrients.

   8.  Conduct intensive studies of Spavinaw Creek and its tributaries and Lakes Eucha,
   Spavinaw and Yahola to address nutrient related water quality problems.  Focus efforts
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   to identify and quantify different sources of nutrients and sub-basins as potential nutrient
   sources, quantify nutrient loadings to the lakes, assess impacts on lake water quality
   and algae production, and set lake nutrient target values for proper watershed
   management to improve lake water quality.

   9. Support collection of soils and land use data for use with water quality assessments
   and development of Animal Waste and Nutrient Management Plans.

   10.  Create a common database for all water quality data and other information, provide
   backup to all databases, and link all data geospatially into a GIS system.

   11.  Establish a water quality Trend Monitoring Program after completion of intensive
   studies.

   12.  Develop a Comprehensive Watershed Management Plan or other similar
   watershed planning tool (e.g. WRAS) to establish water quality improvement goals,
   schedules,  activities, milestones, outputs, funding and resource options, participants,
   and education goals.

   13.  Implement Best Management Practices (BMPs) and other Point Source and Non-
   Point Source  control strategies to control nutrients in the lakes and watershed.

   14.  Support  litter export and nutrient management activities in the watershed, including
   development  of market-based litter uses as a value-added product, creation of effective
   litter availability hotlines and other communication venues, cultivate commercial
   enterprises that use litter as a raw material, support delays in poultry house clean-outs to
   protect water quality, support development of water quality based Animal Waste
   Management Plans, investigate options for controlling  nutrient levels  in litter (e.g. by
   increasing use of phytase and alumand reductions in phosphorus in feed), support
   incentive payments through EQIP programs, and support other programs as they
   become viable.

   15.  Develop and  support Public Outreach and Education programs in the watershed to
   promote implementation of nutrient management strategies and awareness of water
   quality issues.

   Numerous intensive studies were completed to address nutrient-related water quality
   problems by quantifying nutrient loadings, assessing impacts on water quality and algae
   production, and setting nutrient target values for proper watershed management.

   Management  Measures

   Given the resistance to implementation of certain key recommendations of the WRAS by
   entities contributing to the nutrient (phosphorus) loading in the Eucha/Spavinaw
   Watershed, the City of Tulsa concluded that the cooperative approach initially taken was
   failing, and  as a result felt that legal action was necessary. Supported with the Phase II
   Clean Lakes study, the City of Tulsa filed a lawsuit against six poultry companies and
   the City of Decatur, Arkansas in December 2001.  The lawsuit was settled out of court in
   2003 for the development of a joint phosphorus index between Arkansas and Oklahoma
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   to control nonpoint sources; a moratorium on land application of chicken litter until the
   development and implementation of the phosphorus index; and, established point source
   phosphorous limits. In 2004, the District Judge issued a phosphorous order approving a
   phosphorous index allowing land application of litter at levels significantly lower than
   historical trends for both point and non-point sources. Conditions of the settlement
   include; (1) appointment of a Special master to implement the settlement agreement; (2)
   hiring and training of four Watershed Management Team members to assist poultry
   growers in developing Nutrient Management Plans; (3) development of a new Risk
   Based Phosphorus Index (PI) by Oklahoma State University and University of Arkansas
   staff; (4) creation of a non-profit organization to identify potential assistance and
   solutions in reducing litter application; and, (5) a phosphorous limit and compliance
   schedule in the City of Decatur's POTW NPDES  Permit.

   Since the establishment of the Watershed Management Team in 2003 numerous
   ongoing projects, programs, and activities have been launched by a variety of
   governmental, academic, and non-profit organizations. These projects, programs, and
   activities are designed for implementation of BMPs, watershed monitoring, education
   and outreach, watershed assessment and computer modeling studies. Funding for
   these projects, programs, and activities has been obtained through a variety of sources,
   including USEPA Clean Water Act Section 319 grants, the U.S.  Department of
   Agriculture, the States of Oklahoma and Arkansas, the City of Tulsa, the poultry industry,
   and others.

   Results for the Eucha/Spav watershed including the Watershed Restoration
   Stratecy (WRAS) and Beaty and Spavinaw Creek Watershed Implementation 319
   Project are identified below:

   Watershed Restoration Action Strategy (WRAS)

   1. Established a Watershed Management Team and technical Work Groups made up of
   stakeholders.

   2. Established Quality Assurance Goals to ensure legally defensible and scientific based
   data. Developed EPA approved Quality Assurance Project Plan.

   3. Established a Project Management Database to include web based access to reports
   and water quality data.

   4. Improved water treatment methods to control Taste and Odor problems to include
   installation of granular activated carbon filters, cupric sulfate injection  during algal bloom
   events, aggressive early warning monitoring system for algae and taste and odor
   compounds.

   5. Conducted numerous intensive studies of Eucha/Spavinaw Watershed to address
   nutrient related water quality problems by quantifying nutrient loadings, assess impacts
   on water quality and algae production, and set nutrient target values for proper
   watershed management.

   6. Supported collection of soils and land use data for use with water quality assessments
   and development of Animal Waste and Nutrient Management Plans.
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   7. Created a common database for all water quality data and other information, provide
   backup to all databases, and link all data geospatially into a GIS system.

   8. Established an ongoing water quality Trend Monitoring Program.

   9. Developed a Comprehensive Watershed Management Plan.

   10.  Implemented Best Management Practices (BMPs) control strategies to control
   nutrients in the watershed.

   11.  Supported litter export and nutrient management activities in the watershed.

   12.  Developed and supported Public Outreach and Education programs in the
   watershed.

   Beaty and Spavinaw Creek Watershed Implementation 319 Project

   1) implemented agricultural BMPs designed to reduce nutrient loading into Beaty and
   Spavinaw Creek through cost share programs

   2) Best Management Practices addresses pollutants from the sources identified in the
   303(d) list, the 305(b) Report, and pollutants identified in recent monitoring programs.

   In addition, a lawsuit between Oklahoma and Arkansas resulted in favorable outcomes
   for the watershed and water supply, including establishing a Phosphorus Index Team
   consisting of an equal number of representatives from Oklahoma State University and
   the  University of Arkansas and developing a Risked Based P-lndex that will achieve the
   least amount of total phosphorus loading attainable from each application site to the
   water supply while still meeting the agronomic requirements for the  growth of grasses,
   crops and other desirable plant life; Tulsa hiring a special Master to recruit, train and
   oversee a Watershed Monitoring Team (WMT); the WMT monitoring and/or gathering
   necessary data for each tract of poultry grower land; preparing Nutrient Management
   Plans (NMP), which shall include an assigned P-lndex number for each company poultry
   farm; a reduction in poultry litter application to one-third of historical application rates in
   the  Eucha/Spavianw watershed; and reduced point source effluent phosphorus
   concentration to < 1 mg/L.

   Contingency Planning

   The City of Tulsa developed a plan to provide an emergency water supply from Lake
   Hudson during a serious water quality degradation event (taste and odor, algal toxins,
   etc.) in Lake Eucha and Spavinaw Lake.  Lake Hudson is southwest of lakes Eucha and
   Spavinaw and is in the Grand Lake Watershed.   From late 2000 through early 2001, a
   severe taste and odor episode occurred and Tulsa discontinued withdrawal from the
   Eucha/Spavinaw system and began drawing water from Lake Hudson for over two
   months.
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   Measuring Program Effectiveness

   The City of Tulsa and the U.S. Geological Survey have an intensive ongoing reservoir
   and stream-monitoring program in the Eucha/Spavinaw watershed (18 monitoring sites),
   collecting weekly, monthly, and storm-event water quality data and continuous
   hydrologic data. The USGS will continue to calculate nutrient loads and yields in the
   watershed. The Oklahoma Conservation Commission will also continue to monitor the
   effectiveness of the BMP installations.

   For further information, contact:
   Roy W. Foster, Manager
   Quality Assurance Section
   City of Tulsa
   707 S. Houston, Room 507
   Tulsa, OK 74127
   918-596-1344-office
   918-596-2483-fax

   rfoster(5)ci.tulsa.ok.us
Office of Water (4606M)                       816F10038                             January 2010

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