Section  319
               NONPOINT SOURCE PROGRAM  SOCGESS STORY
 Fecal Coliform Levels Decline after Photographs and Stream Walks Help
 Pinpoint Failing Septic Systems
Waterbodies Improved   Bacte;'afromHfail"9 septictanksan'runofffr°m ani™',
                                  agriculture and urban areas caused Georgia s Jacks, Hopkins
 and Cedar creeks to exceed water quality standards for fecal coliform bacteria. As a result,
 Georgia's Department of Natural Resources (DNR) added three 4-mile-long segments—one each
 on the three creeks—to Georgia's  Clean Water Act (CWA) 2002 section 303(d) list of impaired
 waters. Using CWA section 319 funds, the Gwinnett County Department of Public Utilities
 (Gwinnett County) conducted a color infrared (CIR) aerial photography survey of the county. This
 CIR survey identified actively failing septic systems, which were referred to the Gwinnett County
 Environmental Health Department for enforcement action. As a result of those efforts, all three
 4-mile-long segments showed decreased levels of fecal coliform bacteria, prompting  Georgia
 DNR to remove them from the state's list of impaired waters for fecal coliform in 2008.
 Problem
 The three impaired creeks flow through Gwinnett
 County in north-central Georgia. Jacks Creek is a
 tributary of the Yellow River, while both Hopkins
 and Cedar creeks flow into the Alcovy River, just
 east of the Yellow River (Figure 1). All three creeks
 are in the Southern Outer Piedmont Ecoregion,
 which has lower elevations and less precipitation
 than other ecoregions to the north.

 Monitoring data  collected in 1999 show that Jacks,
 Hopkins and Cedar creeks violated water quality
 standards for fecal coliform in two of four geomet-
 ric mean sampling sets. The standard requires that
 fecal coliform levels not exceed a geometric mean
 (four samples collected over a 30-day period) of 200
 colony forming units (cfu) per 100 milliliters (ml)
 in the summer and 1,000 cfu/100 ml in the winter.
 Because the three creeks failed to meet criteria
 supporting theirfishing designated uses (Georgia's
 most stringent classification), Georgia DNR added
 the three 4-mile-long creek segments to Georgia's
 2002 CWA section 303(d) list of impaired waters
 for high fecal coliform levels. Georgia DNR identi-
 fied the primary  sources of fecal coliform as failing
 septic systems and animal waste from agricultural
 and urban runoff.

 Georgia DNR conducted a total maximum daily load
 (TMDL) study for pathogen loads in the Ocmulgee
                  Georgia's
                  Major River
                  Systems
Figure 1. Jacks
Creek flows into
the Yellow River
(noted in blue),
and Hopkins and
Cedar creeks flow
into Alcovy River
(noted in red).
River watershed; the U.S. Environmental Protection
Agency approved the TMDL in 2002. The TMDL
determined that the pathogen loads must be
reduced into Jacks Creek (by 15 percent), Hopkins
Creek (by 53 percent) and Cedar Creek (by 52 per-
cent) to meet water quality requirements for fishing.
Project Highlights
To accomplish the necessary reductions, Gwinnett
County implemented a countywide CIR septic
survey and developed a watershed improvement
plan (WIP) for the Yellow River watershed. As a
headwater tributary of the Yellow River, Jacks Creek

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            was included in the WIP. One of the elements of the
            WIP was to determine stream conditions and char-
            acteristics through field stream survey inventories.
            During the stream survey for Jacks Creek, Gwinnet
            County identified nine water quality concerns,
            including one illicit discharge, one failing septic
            system, five incidents of livestock in the stream and
            two kennels with uncontrolled runoff. As a supple-
            ment to this project, Gwinnett County addressed
            the sources by referring them to the appropriate
            regulatory agency or internal department.

            The county's CIR septic survey used aerial photog-
            raphy to identify actively failing septic systems.
            The photographic analysis process involves visually
            examining and  comparing  many components of
            individual photographs, including shadow, tone,
            color,  texture, shape, size, pattern and landscape.
            The photographic analyst identified signatures
            associated  with specific environmental conditions
            or events. After an analyst identified  possible failure
            sites through CIR, county staff members completed
            ground verification inspections to identify areas
            of surfacing effluent from failing septic systems
            (Figure 2). That effort helped to identify  18 fail-
            ing septic systems in the Jacks Creek watershed
      Figure 2. Two
    photographs of
    the same site in
    the Jacks Creek
 watershed indicate
     a failing septic
       system. The
standard photo (top)
  shows an isolated
 area of thick green
 grass. The red area
 seen in the infrared
    photo (bottom),
     shows that the
     isolated grassy
 area is also warmer
      than the area
     surrounding it.
and a combined 19 failing systems in the Hopkins
Creek and Cedar Creek watersheds. The county's
Environmental Health Department worked with
homeowners to repair the failing systems and edu-
cated them about maintenance to prevent future
failures. Those activities occurred between 2003
and 2007.
Results
Georgia DNR collected monitoring data on Jacks,
Hopkins and Cedar creeks in 2006, as part of a
larger effort to update the Ocmulgee River fecal
coliform TMDL. The data show that all segments of
Jacks, Hopkins and Cedar creeks now meet water
quality standards for bacteria (Table 1). On the basis
of the data, Georgia DNR removed all three seg-
ments of Jacks, Hopkins and Cedar creeks from the
state's list of impaired waters in 2008.

Table 1.  Data from 2006 show that Jacks, Hopkins
and Cedar creeks meet water quality standards
for fecal coliform bacteria (< 1,000  cfu/100 mL in
winter and < 200 cfu/100 mL in summer)
Waterbody

Jacks Creek
Hopkins Creek
Cedar Creek
Geometric mean (cfu/100 ml)
January 2006
116
32
57
July 2006
198
123
106
Partners and Funding
Partners implemented projects with support from
CWA section 319 funding, including $114,866 in the
Jacks Creek watershed, $1,558 in the Hopkins Creek
watershed and $1,964 in the Cedar Creek watershed.
Gwinnett County provided the remaining 40 percent
of project costs for a total of $191,444 in Jacks
Creek, $2,597 in Hopkins Creek and $3,273 in Cedar
Creek. Key partners in this effort were the Gwinnett
County Department of Public Utilities and Gwinnett
County Department of Environmental Health. The
partners provided technical expertise, labor and
enforcement of regulations when necessary.
I
                 U.S. Environmental Protection Agency
                 Office of Water
                 Washington, DC

                 EPA841-F-10-001N
                 August 2010
For additional information contact:
Jeff Linzer, II
Georgia Environmental Protection Division
404-675-1643 • Jeffrey_Linzer@dnr.state.ga.us
Laurie J. Hawks
Gwinnett County
678-376-6939 • laurie.hawks@gwinnettcounty.com

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