Total Maximum Daily Load (TMDL) for
Phosphorus in Lake Carmel

Putnam County, New York

July 2016

Prepared for:

U.S. Environmental Protection Agency
Region 2
290 Broadway
New York, NY 10007

Prepared by:

NYSDEC
Division of Water
Bureau of Water Resource Management

newyork Department of

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STATE OF	F •	¦ ¦

opportunity environmental

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TABLE OF CONTENTS

1.0 INTRODUCTION	4

1.1.	Background	4

1.2.	Problem Statement	4

2.0 WATERSHED AND LAKE CHARACTERIZATION	5

2.1.	Watershed Characterization	5

2.2.	Lake Morphometry	10

2.3.	Water Quality	11

3.0 NUMERIC WATER QUALITY TARGET	12

4.0 SOURCE ASSESSMENT	12

4.1.	Models used to Analyze Phosphorus Contributions	12

4.2.	Sources of Phosphorus Loading	12

4.2.1.	Residential On-Site Septic Systems	15

4.2.2.	Point Source Discharges	16

4.2.3.	Urban and Residential Development Runoff	16

4.2.4.	Forest Land Runoff	17

4.2.5.	Groundwater Seepage	17

4.2.6.	Internal Loading	17

4.2.7.	Streambank Erosion	17

4.2.8.	Other Sources	18

5.0 DETERMINATION OF LOAD CAPACITY	18

5.1.	Lake Modeling Using the BATHTUB Model	18

5.2.	Linking Total Phosphorus Loading to the Numeric Water Quality Target	18

6.0 POLLUTANT LOAD ALLOCATIONS	20

6.1.	Wasteload Allocation (WLA)	20

6.2.	Load Allocation (LA)	21

6.3.	Margin of Safety (MOS)	22

6.4.	Critical Conditions	25

6.5.	Seasonal Variations	25

6.6.	Other Considerations	25

7.0 IMPLEMENTATION	25

7.1. Reasonable Assurance for Implementation	27

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7.1.1. Recommended Phosphorus Management Strategies for Septic Systems	28

7.1.2	Recommended Phosphorus Management Strategies for Wastewater Treatment Plants29

7.1.3	Recommended Phosphorus Management Strategies for Stormwater Runoff	29

7.1.5 Additional Protection Measures	32

7.1.5.1. Aquatic Plant Control	32

7.1.5.2 Blue Green Algae Blooms	38

7.2	Follow-up Monitoring	40

7.3	Summary	40

8.0 PUBLIC PARTICIPATION	42

9.0 REFERENCES	44

FIGURES

Figure 1: Lake Carmel Watershed	6

Figure 2: Aerial Image of Lake Carmel	7

Figure 3 Land use in the Lake Carmel Watershed	7

Figure 4: Land Use in the Lake Carmel Watershed	9

Figure 5: Bathymetric Map of Lake Carmel	10

Figure 6: Summer Mean Epilimnetic Total Phosphorus Levels in Lake Carmel	11

Figure 7: Estimated Sources of Total Phosphorus Loading to Lake Carmel	14

Figure 8: Observed vs. Modeled Average Phosphorus Concentrations (ug/l) in Lake Carmel	19

Figure 9: Total Phosphorus Loading Allocations for Lake Carmel Watershed	24

Figure 10: Location of Calibration & Verification Watersheds for the Original Northeast AVGWLF Model	46

Figure 11: Location of Physiographic Provinces in New York and New England	50

TABLES

Table 1: Land Use in the Lake Carmel Watershed	8

Table 2: Lake Carmel Characteristics	10

Table 3: Estimated Sources of Phosphorus Loading to Lake Carmel	13

Table 4: Residences Served by Septic Systems	16

Table 5: Total Phosphorus Transported via Groundwater	17

Table 6: Total Annual Phosphorus Load Allocations for Lake Carmel Watershed	23

Table 7: AVGWLF Calibration Sites for use in the New York TMDL Assessments	51

Table 8: Information Sources for MapShed Model Parameterization	52

Table 9: BATHTUB Model Input Variables: Model Selections	61

Table 10: BATHTUB Model Input: Global Variables	61

Table 11: BATHTUB Model Input: Lake Variables	61

Table 12: BATHTUB Model Input: Watershed "Tributary" Loading	61

Table 13: BATHTUB Model T-Statistics	62

APPENDIX A: AVGWLF Model Analysis
APPENDIX B: BATHTUB Model Analysis

APPENDIX C: Total Equivalent Daily Phosphorus Load Allocations

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1.0

INTRODUCTION

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In April of 1991, the United States Environmental Protection Agency (EPA) Office of
Water's Assessment and Protection Division published "Guidance for Water Quality-
Based Decisions: The Total Maximum Daily Load (TMDL) Process." In July 1992,
EPA published the final "Water Quality Planning and Management Regulation" (40 CFR
Part 130). Together, these documents describe the roles and responsibilities of EPA and
the states in meeting the requirements of Section 303(d) of the Federal Clean Water Act
(CWA) as amended by the Water Quality Act of 1987, Public Law 100-4. Section 303(d)
of the CWA requires each state to identify those waters within its boundaries not meeting
water quality standards for any given pollutant applicable to the water's designated uses.

Further, Section 303(d) requires EPA and states to develop TMDLs for all pollutants
violating or causing violation of applicable water quality standards for each impaired
waterbody. A TMDL determines the maximum amount of pollutant that a waterbody can
receive while continuing to meet the existing water quality standards. Such loads are
established for all the point and nonpoint sources of pollution that cause the impairment
at levels necessary to meet the applicable standards with consideration given to seasonal
variations and margin of safety. TMDLs provide the framework that allows states to
establish and implement pollution control and management plans with the ultimate goal
indicated in Section 101 (a)(2) of the CWA: "water quality which provides for the protection
and propagation of fish, shellfish, and wildlife, and recreation in and on the water,
wherever attainable" (USEPA, 1991).

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Lake Carmel (WI/PWL ID 1302-0006) is located in the Town of Kent, in Putnam County,
New York (Figure 1). Over the past few decades, the lake water quality has declined
and has affected the lake's recreational and aesthetic value. Lake Carmel was listed on
the Lower Hudson River Basin Priority Waterbodies List (PWL) in 2002 (NYS DEC, 2002).

Data collected by DEC and its monitoring programs indicated eutrophic (i.e. characterized
by nutrient enrichment, such as phosphorus, leading to excessive plant growth) conditions
in Lake Carmel. The concentration of phosphorus in the lake exceeded the state guidance
value for phosphorus (20 |jg/L or 0.020 mg/L, applied as the mean summer, epilimnetic
total phosphorus concentration), which increases the potential for nuisance summertime
algae blooms (see Figure 6 for Summer Mean Epilimnetic Total Phosphorus Levels in
Lake Carmel). In 2004, Lake Carmel was added to the New York State Department of
Environmental Conservation (NYS DEC) CWA Section 303(d) list of impaired waterbodies
as recreation is impaired due to algal/weed growth and nutrients, specifically phosphorus
as the lake does not meet New York's water quality guidance value for phosphorus.
Based on this listing, a TMDL for phosphorus is being developed for the lake to address
the impairment.

According to information provided by watershed residents who attended a public meeting

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on July 29, 2014, the lake is used for the following: swimming, boating, fishing, and its
aesthetic value. About half of the residents said they were able to use the lake the way
they wanted while the other half indicated either "no", "yes and no", or "did not use the
lake". Watershed residents expressed concerns about water clarity, sedimentation,
stormwater runoff, and nutrient pollution to Lake Carmel.

In August 2014 and again in July 2015, the Putnam County Department of Health closed
several beaches in the Lake Carmel Park District after visual tests showed an abundance
of blue-green algae. As of the writing of this TMDL, the Town intends to apply copper
sulfate to the lake as a temporary solution; officials are seeking longer-term alternatives
to treat the water. While reporting on the beach closure, a news reporter noticed "a
strong smell of sewage" at Lake Carmel's Beach 3.

A variety of sources of phosphorus are contributing to the reduced water quality in Lake
Carmel. The water quality of the lake is influenced by runoff from the watershed and
input from nearby residential septic systems. Runoff from the watershed is
caused by precipitation. Nutrients, such as phosphorus (naturally found in New York
soils) enter the lake from the surrounding watershed by way of streams, overland flow,
and subsurface (groundwater) flow. The nutrients are deposited and stored in the lake
bottom sediments and used by aquatic plants to grow.

Phosphorus is often the limiting nutrient in temperate lakes and ponds and can be thought
of as a fertilizer; a primary food for plants, including algae. When lakes receive excess
phosphorus, it "fertilizes" the lake by feeding the algae. Too much phosphorus can result
in algae blooms, excessive weed growth, and reduced water clarity which impacts the
ecology, aesthetics, and recreational uses of a lake. This may also affect the economy of
the community within the watershed.

2.0 WATERSHED AND LAKE CHARACTERIZATION

2.1. Watersh	acterization

Lake Carmel has a watershed of 8,150 acres (Figure 1). Watershed elevations range
from 1,332 feet above mean sea level (AMSL) to 619 feet AMSL at the lake surface.
Existing land use and land cover in the Lake Carmel watershed was determined from
digital aerial photography and geographic information system (GIS) datasets, and field-
verified by Department staff. Digital land use/land cover data were obtained from the 2006
National Land Cover Dataset (Homer, 2004). The NLCD is a consistent representation
of land cover for the conterminous United States generated from classified 30-meter
resolution Landsat thematic mapper satellite imagery data. High-resolution color
orthophotos were used to manually update and refine land use categories for portions
of the watershed to reflect current conditions in the watershed (Figure 2). Appendix A
provides additional detail about the refinement of land use for the watershed. Land use
categories (including individual category acres and percent of total) in Lake Carmel's
watershed are listed in Table 1 and presented in Figures 3 and 4.

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Figure 1: Lake Carmel Watershed

Legend

Lake Carmel Watershed
Lakes
Streams
~ Towns

PAWLING

KENT

BEEKMAN

EAST FISHKILL

PATTERSON

Lake
Carmel

0.5

Miles

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Figure 2: Aerial image of Lake Carmel


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Figure 3: Percent Land Use in the Lake Carmel Watershed

Wetland
3.0%

Table 1: Land Use in the Lake Carmel Watershed

Land Use Category

Acres

% of Watershed

Developed Land



27.3%

Low Intensity



25.9%

High Intensity



1.4%

Forest



69.8%

Wetlands



3.0%

Total

7,828

100%


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Figure 4: Land Use in the Lake Carmel Watershed

Landuse

Water

Low-density mixed urban
Low-density residential
High-density mixed urban
Forest
Wetland

0.5	1

H	1	1	1	1	h-

Miles


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2.2. Lake Morphometry

Lake Carmel is a 186 acre lake at an elevation of approximately 619 feet AMSL Figure
5 shows a bathymetric map for Lake Carmel based on data collected during the summer
of 2007. Table 2 summarizes key morphometric characteristics for Lake Carmel

Figure 5: Bathymetric Map of Lake Carmel

Lake Carmel

Legend

0-2 feet
2-4 feet
4-6 feet

G-8 feet

H 8~10 f<>et
10-12 feet
H 12-14 feet

¦Miles

N

0 1

0.2

0 4

0 6

08

Table 2: Lake Carmel Characteristics

Surface Area (acres)

186

Elevation (ft AMSL)

619

Maximum Depth (ft)

14

Mean Depth (ft)

7

Length (ft)

7,093

Width at widest point (ft)

2,266

Shoreline perimeter (miles)

4.5

Direct Drainage Area (acres)

8,150

Watershed: Lake Ratio

44:1

Mass Residence Time (days)

26

Hydraulic Residence Time (days)

25

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2.3. Water Quality

Water quality data was collected from Lake Carmel through the Citizen Statewide Lake
Assessment Program (CSLAP) by trained volunteers during the summers of 1986-1990 and
by DEC staff during the summer of 2013. Public perception of the lake indicates recreational
suitability to be very unfavorable, and is described as "substantially" impacted. The lake is
described as not supporting recreational uses ("recreation impossible"). Assessments have
noted that aquatic plants grow very close to the surface and are very dense. (DEC/DOW,
BWAM, CSLAP, 1996).

The concentration of phosphorus in the lake exceeded the state guidance value for
phosphorus (20 pg/L or 0.020 mg/L, applied as the mean summer, epilimnetic (the layer of
water above the thermocline) total phosphorus concentration, indicating eutrophic
conditions in Lake Carmel. Figure 6 shows the summer mean epilimnetic phosphorus
concentrations for phosphorus data collected during all sampling seasons.

NYS DEC's CSLAP is a cooperative volunteer monitoring effort between NYS DEC and
the New York Federation of Lake Associations (FOLA). For more information about
CSLAP, what water quality parameters are collected and how the data is used, visit DEC's
CSLAP web page. http://www.dec, nv.gov/chem ical/81576. htm I).

Information collected from Lake Carmel watershed residents at the informational session
on July 29, 2014 supports that lake uses have been impaired by nutrients. Watershed
residents identified weeds, algae and mucky bottom as impediments to lake use. However,
some residents still use the lake for swimming, boating, fishing and its aesthetic value.

Figure 6: Summer Mean Epilimnetic Total Phosphorus Levels in Lake Carmel

Phosphorus Water Quality Target (20 ug /L). The numbers above the bars indicate the number of data points
included in each summer's sampling

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3.0

NUMERIC WATER QUALITY TARGET

The TMDL target is a numeric endpoint specified to represent the level of acceptable water
quality that is to be achieved by implementing the TMDL. The water quality classification
for Lake Carmel is Class B, which means that the best usages of the lake are primary and
secondary contact recreation (i.e., swimming and boating) and fishing. The lake must also
be suitable for fish to reproduce and survive. New York State's narrative standard for
nutrients is "none in amounts that will result in growths of algae, weeds and slimes that will
impair the waters for their best usages" (6 NYSCRR Part 703.2). As part of its Technical
and Operational Guidance Series (TOGS 1.1.1 and accompanying fact sheet, NYS, 1993),
NYS DEC has advised that the epilimneticsummer average of total phosphorus levels
in waters classified as ponded (i.e., lakes, reservoirs and ponds, excluding Lakes Erie,
Ontario, and Champlain), should not exceed 20 |jg/L based on biweekly sampling,
conducted from June 1 to September 30. This guidance value of 20 |jg/L is the TMDL target
for Lake Carmel.

4.0 SOURCE ASSESSMENT

Models used to Analyze Phosphorus Contributions

The MapShed watershed model and the BATHTUB lake response model were used to
develop the Lake Carmel TMDL. MapShed determines the mean annual phosphorus
loading to the lake. BATHTUB defines how much this load must be reduced to meet the
water quality target. The datasets used include the most recent weather data from two
weather stations in Stormville and Yorktown, land cover data from a revised version of the
Multi-Resolution Land Characterization database, curve numbers from U.S. Soil
Conservation Service hydrologic studies, soil types from Natural Resource Conservation
Service data and estimated septic failure rates derived from 2010 US census data and real
parcel data.

Within the MapShed program, the GWLF model developed by Haith and Shoemaker
(1987) was used to simulate stormwater runoff and stream flow by a water-balance
method based on measurements of daily precipitation and average air temperature from
1986 through 2013. The GWLF model is appropriate for this TMDL analysis because it
simulates processes of concern, but does not have complex data requirements for
calibration. Appendix A discusses the setup, calibration, and use of the MapShed model for
lake TMDL assessments in New York.

4.2. -urces of Phosphorus Loading

MAPSHED was used to estimate long-term (1986-2013) seasonal phosphorus (external)
loading to Lake Carmel. The estimated mean growing season load of 2,711.2 lbs of total
phosphorus that enters Lake Carmel comes from the sources listed in Table 3 and shown
in Figure 7. Appendix A provides the detailed simulation results from MapShed.

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Table 3: Estimated Sources of Phosphorus Loading to Lake Carmel

Source

Total Phosphorus (Ib/yr)

Percent (%)

Stream Bank Erosion



32.6%

Wetland



0.2%

Forest



4.2%

Groundwater



14.9%

Septic Systems



22.6%

Internal Loading



18.8%

Putnam Nursing & Rehabilitation WWTF
SPDES# NY0028924



2.2%

Girl Scouts Heart of Hudson WWTF
SPDES #NY0102181



0.2%

Frangel Realty WWTF
SPDES#



0.3%

MS4 Developed Land:
T/Kent NYR20A346,
T/Patterson NYR20A140,
T/Pawling NYR20A472,
T/Beekman NYR20A365,
TIE. Fishkill, NYR20A183



3.7%



2,711.2

100%

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Figure 7: Estimated Sources of Total Phosphorus Loading to Lake Carmel

Forest
113.8 Ib/yr.

Wetlands
6.2 Ib/yr

Internal Loading
511.0 Ib/yr

Developed Land MS4
100.6 Ib/yr

Groundwater
404.4 Ib/yr

WWTF - Frangel
Realty
9.1 Ib/yr

WWTF - Putnam
Nursing &
Rehabilitation
60.9 Ib/yr

WWTF - Girl Scouts
Heart of Hudson
5.0 Ib/yr

Stream Bank
Erosion
886.3 Ib/yr

Septic Systems
613.9 Ib/yr

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4,2.1. Residential On-Si' ;ic Systems

All houses in the Lake Carmel Watershed are served by private septic systems. Lake
Carmel is intensely developed and many of the parcels are served by septic systems and
individual wells on lots as small as 4,000 square feet. These houses were constructed
originally as summer cottages, and like many lake side developments, have over the
decades been converted to year-round residences. Additionally, many of the property
owners have constructed additions, including increasing the number of bedrooms and
bathrooms, and kitchen renovations including the addition of washing machines and
dishwashers that discharge into their septic systems. Many of these septic systems manifest
deficiencies during the wetter periods throughout the year. Residents report smelling
effluent while driving or walking near the lake. Leaching of effluent upward from
malfunctioning septic fields washes onto roads, nearby properties and streams by rainfall
runoff, resulting in potential contamination of nearby shallow wells that are constructed near
the lake front.

Residential on-site septic systems contribute an estimated 613.9 Ib/yr of total phosphorus
to Lake Carmel, which is 22.6% of the total loading to the lake. The introduction of
phosphorus into lakes from septic systems is a major concern. While that source may not
be the largest component of the total phosphorus load, the impacts can be substantial
because it is in a soluble form, readily available to algae. The soluble phosphorus is
immediately available to plants and algae, and would effectively fertilize a lake by orders of
magnitude more than an equal amount of particulate phosphorus entering from a stream.
Residential septic systems discharge dissolved phosphorus to nearby waterbodies when
they malfunction. In properly functioning systems, phosphates are adsorbed and retained
by the soil as the wastewater travels through the soil to the groundwater. A septic system
may malfunction if there is not sufficient permeable soil for the wastewater to travel through.
The wastewater may then discharge to the ground surface. These system malfunctions are
characterized as "ponding". A septic system in close proximity to surface waters may
malfunction when the effluent is not sufficiently treated because the groundwater table is
too shallow and/or there is insufficient separation distance from the septic system to the
waterbody. The effluent from the septic system laterals may then discharge directly to
groundwater, rather than being filtered through intermediary soil first. These system
malfunctions are characterized as "short-circuiting". Both of these types of septic system
malfunctions can contribute high phosphorus loads to the lake.

The Department used the proximity of septic systems to Lake Carmel to estimate septic
system malfunction. This method is consistent with other TMDLs developed for small lakes
that have numerous lake front properties and reflects the conclusion that groundwater
tables adjacent to waterbodies are typically too high to allow for the effective functioning of
a septic system. Further support for this determination is contained in a recent near shore
septic study by the Otsego Lake Watershed Council which determined a 50% malfunction
rate for septic systems within 500 feet of Otsego Lake.

Using this method, septic systems serving houses that are within 50 feet of Lake Carmel or
a tributary of the lake were categorized as short-circuiting. For houses between 50 and 250
feet of Lake Carmel or a tributary of the lake, 25% of the septic systems were categorized
as short-circuiting and 10% were categorized as ponding systems. Analysis of

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orthoimagery for the Lake Carmel watershed shows 38 houses within 50 feet of Lake
Carmel or a tributary of the lake and 316 houses between 50 and 250 feet of Lake Carmel
or a tributary of the lake; all of these houses are assumed to have septic systems. To
convert the estimated number of septic systems to the population served, an average
household size of 2.6 people per dwelling was used based on the 2010 United States
Census Bureau estimate for number of persons per household in New York State. To
account for seasonal variations in population, information obtained from the Town of Kent
was used. Approximately 98% of the homes around the lake are reported to be year-round
residences, while 2% are seasonally occupied (i.e., June through August only). The
estimated population in the Lake Carmel watershed served by normal and malfunctioning
systems is summarized in Table 4.

Table 4: Residences Served by Septic Systems



Normally
Functioning

Ponding

Short Circuiting

Total

September - May





I

3,446

June - August

3,468

31

117

3,516

4.2.2. Point Source Discharges

There are three permitted wastewater treatment facility (WWTF) dischargers in the Lake
Carmel watershed. The combined design flow of the three WWTPs is 26,260 gallons per
day. The phosphorus discharge limits of these three WWTFs are currently 1.0 mg/l each,
per NYC Watershed Rules and Regulations. Additionally, all five Towns that comprise the
Lake Carmel watershed are designated MS4s, because they are located within the larger,
impaired, NYC East of Hudson Watershed.

4.2.3. Urban and Residential Development Runoff

Developed land comprises 2,135 acres (27%) of the Lake Carmel watershed. Stormwater
runoff from developed land contributes 100.6 Ib/yr of phosphorus to Lake Carmel, which is
3.7% of the total phosphorus loading to the lake. This load does not account for
contributions from malfunctioning septic systems.

In addition to the contribution of phosphorus to the lake from overland urban runoff,
phosphorus originating from developed lands is leached in dissolved form from the surface
and transported to the lake through subsurface movement via groundwater. The process
for estimating subsurface delivery of phosphorus originating from developed land is
discussed in the Groundwater Seepage section.

Phosphorus runoff from developed areas originates primarily from human activities.
Shoreline development, in particular, can have a large phosphorus loading impact to
nearby waterbodies in comparison to its relatively small percentage of the total land area
in the watershed.

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4.2.4. Forest Land Runoff

Forested land comprises 5,461 acres (70%) of the lake watershed. Runoff from forested
land is estimated to contribute 113.8 Ibs/yr of phosphorus loading to Lake Carmel, which is
4.2% of the total phosphorus loading to the lake. Phosphorus contribution from forested
land is considered a component of background loading.

4.2.5. Groundwater Seepage

In addition to nonpoint sources of phosphorus delivered to the lake by surface runoff, a
portion of the phosphorus loading from nonpoint sources seeps into the ground and is
transported to the lake via groundwater. Groundwater is estimated to transport 404.4 Ibs/yr
(14.9%) of the total phosphorus load to Lake Carmel. With respect to groundwater, there
is typically a small "background" concentration from various natural sources. In the Lake
Carmel watershed, the model- estimated groundwater phosphorus concentration is 0.01
mg/L. The GWLF manual provides estimated background groundwater phosphorus
concentrations for >90% forested land in the eastern United States, which is 0.006 mg/L.
Consequently, about 60% of the groundwater load (255 Ibs/yr) can be attributed to natural
sources, including forested land and soils.

The remaining amount of the groundwater phosphorus load likely originates from developed
land sources (i.e., leached in dissolved form from the surface). It is estimated that the
remaining 170 Ibs/yr of phosphorus transported to the lake through groundwater originates
from developed land. Table 5 summarizes this information.

Table 5: Total Phosphorus Transported via Groundwater



Total Phosphorus (Ibs/yr)

% of Total Groundwater Load

Natural Sourcesl

242.6

60%

Developed Land|

161.8

40%

TOTAL

404.4

100%

4.2.6.	Internal Loading

Lake Carmel is known to exhibit excessive aquatic plant growth and measurements have
shown periods of low dissolved oxygen in the bottom waters of the lake. An internal load of
0.6 mg/m2 /day of phosphorus was estimated using the BATHTUB lake model. This loading
rate produced good agreement between the measured and modeled in-lake total
phosphorus concentrations during the BATHTUB model calibration. This corresponds to a
growing season load of 511 lb of phosphorus, or about 18.8% of the total.

4.2.7.	Streambank Erosion

Two streams feed Lake Carmel: the Middle Branch Croton River and Stump Pond Stream.
The source of the Middle Branch is a small pond just west of the Kent Town Hall across
State Route 52. From there the stream runs along Route 52 in a southerly direction for
approximately one mile before emptying into Lake Carmel. The source of Stump Pond

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Stream is Ludington Lake in the Town of Beekman. From there Stump Pond Stream runs
southerly for approximately seven miles, through Lake Dutchess, Browns Pond and Stump
Pond before emptying into Lake Carmel.

The rate of streambank erosion is estimated in the Mapshed model by first calculating an
average watershed-specific lateral erosion rate. This lateral erosion rate is a function of
watershed slope, soil type and land use, all of which are calculated by region-specific data
layers utilized by Mapshed. After the lateral erosion rate has been computed, the total
sediment load generated via streambank erosion is calculated by multiplying the lateral
erosion rate by the total length of streams in the watershed, an average streambank height,
and an average soil bulk density value. Modeling of the Lake Carmel watershed indicates
streambank erosion is a primary source of sedimentation and total phosphorus loading in
Lake Carmel. The streambank erosion component of the total phosphorus load to Lake
Carmel is estimated to be 886.3 Ib/yr or 32.6% of the total watershed phosphorus loading.

4,2.8, Other Sources

Atmospheric deposition, wildlife, waterfowl, and domestic pet excrement are also potential
sources of phosphorus loading to the lake. All of these smaller sources of phosphorus
have been incorporated into the land use loadings as identified in the TMDL analysis (and
therefore accounted for). Further, the deposition of phosphorus from the atmosphere over
the surface of the lake is accounted for in the lake model, though it is also small in
comparison to the external loading to the lake.

5.0 DETERMINATION OF LOAD CAPACITY

Late Mode 		. 	I

BATHTUB was used to define the relationship between phosphorus loading to the lake
and the resulting concentrations of total phosphorus in the lake. The U.S. Army Corps of
Engineers' BATHTUB model predicts eutrophication-related water quality conditions (e.g.,
phosphorus, nitrogen, chlorophyll a, and transparency) using empirical relationships
previously developed and tested for reservoir applications (Walker, 1987). BATHTUB
performs steady-state water and nutrient balance calculations in a spatially segmented
hydraulic network. Appendix B discusses the setup, calibration, and use of the BATHTUB
model.

5.2. 	 osphorus Loading to tl 1 1 1 Water Qual

In order to estimate the loading capacity of the lake, simulated phosphorus loads from
MapShed were used to drive the BATHTUB model to predict water quality in Lake Carmel.
MapShed was used to derive a mean annual phosphorus loading to the lake for the period
1990-2013. Using this load as input, BATHTUB was used to simulate water quality in the
lake. The results of the BATHTUB simulation were compared against the lake's observed
summer mean phosphorus concentration for 1986-1990 and 2013. In 1987 and 2013 the

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observed values were substantially higher than modeled values, however overall the
modeled and observed values fit well. (See Table 13 in Appendix B, p. 53 for validation
results showing 28 year simulated value within 97% of six years of monitoring data.
The conclusion is that the combined use of MapShed and BATHTUB provides a decent
fit to the observed data for Lake Carmel (Figure 8).

Figure 8: Observed vs. Modeled Average Phosphorus Concentrations (ug/l) in Lake Carmel

Simulated P

Observed P

^or^oowOrHrMpr)^-m^or^oowOrHrMpr)^-m^or^oowOrHrMpr)
oooooooocncncncncncncncncncnoooooooooo*--i<—i<—i<—i
CTCTCTCTCTCTCTCTCTCTCTCTCTCTOOOOOOOOOOOOOO
t—It—It—It—It—It—It—It—It—It—It—It—It—It—ir\ir\ir\ir\ir\ir\ir\ir\ir\ir\ir\ir\ir\ir\l

The BATHTUB model was used as a "diagnostic" tool to determine the total phosphorus
load reduction required to achieve the phosphorus target of 20 pg/L. The loading
capacity of Lake Carmel was determined by running BATHTUB iteratively, reducing the
concentration of the watershed phosphorus load until model results demonstrated
attainment of the water quality target. The maximum concentration that results in
compliance with the TMDL target for phosphorus is used as the basis for determining the
lake's loading capacity. This concentration is converted into a loading rate using simulated
flow from MapShed.

The maximum annual phosphorus load (i.e., the annual TMDL) that will maintain
compliance with the phosphorus water quality goal of 20 pg/L in Lake Carmel is a mean
annual load of 1,230 Ibs/yr. The daily TMDL 3.37 lbs/day was calculated by dividing the
annual load by the number of days in a year. Lakes and reservoirs store phosphorus in
the water column and sediment, therefore water quality responses are generally related to

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the total nutrient loading occurring over a year or season. For this reason, phosphorus
TMDLs for lakes and reservoirs are generally calculated on an annual or seasonal basis.
The use of annual loads, versus daily loads, is an accepted method for expressing nutrient
loads in lakes and reservoirs. This is supported by EPA guidance such as The Lake
Restoration Guidance Manual (USEPA 1990) and Technical Guidance Manual for
Performing Waste Load Allocations, Book IV, lakes and Impoundments, Chapter 2
Eutrophication (USEPA 1986). While a daily load has been calculated, it is recommended
that the annual loading target be used to guide implementation efforts since the annual
load of total phosphorus as a TMDL target is more easily aligned with the design of best
management practices (BMPs) used to implement nonpoint source and stormwater
controls for lakes than daily loads. Ultimate compliance with water quality standards for
the TMDL will be determined by measuring the lake's water quality to determine when the
phosphorus guidance value is attained.

8.0 POLLUTANT LOAD ALLOCATIONS

The objective of a TMDL is to provide a basis for allocating acceptable loads among
all of the known pollutant sources so that appropriate control measures can be
implemented and water quality standards achieved. Individual waste load allocations
(WLAs) are assigned to discharges regulated by State Pollutant Discharge Elimination
System (SPDES) permits (commonly called point sources) and unregulated loads
(commonly called nonpoint sources) are contained in load allocations (LAs). A TMDL is
expressed as the sum of all individual WLAs for point source loads, LAs for nonpoint source
loads, and an appropriate margin of safety (MOS), which takes into account uncertainty
(Equation 1).

. Waste!©. 	 ocatic	

WWTF Dischargers:

There are three permitted wastewater treatment facility (WWTF) dischargers in the Lake
Carmel watershed. The combined design flow of the three WWTFs is 26,260 gallons per
day.

Girl Scouts Heart of Hudson SPDES # NY0102181 is a seasonal facility operating between
May 1 and October 31 and has a design flow of 3,260 GPD and discharge limit of 1.0 mg/l.
The annual phosphorus load from this WWTF is 5.0 #/yr.

Putnam Nursing and Rehabilitation SPDES # NY0028924 has a design flow of 20,000 GPD
and discharge limit of 1.0 mg/l. The annual phosphorus load from this WWTF is 60.9 #/yr.

Frangel Realty SPDES # NY0143863 has a design flow of 3,000 GPD and discharge limit
of 1.0 mg/l. Effluent currently flowing to Frangel Realty WWTP has been diverted and is
now being treated at Kent Manor WWTF in the Palmer Lake Watershed.

The current phosphorus discharge limits for the Girl Scouts Heart of Hudson and Putnam

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Nursing and Rehabilitation WWTFs are 1.0 mg/l each, per NYC Watershed Rules and
Regulations. The Department intends to modify the phosphorus discharge limits in the
SPDES permits for Putnam Nursing and Rehabilitation WWTF to 0.2 mg/l, and for Girl
Scouts Heart of Hudson WWTF to 0.4 mg/l.

MS4s

The Lake Carmel Watershed is located in five towns, Kent, Patterson, East Fishkill, Pawling
and Beekman, all of which are designated MS4s. As part of this designation, the Towns
are subject to the MS4 Permit "Heightened Requirements" because they are located in the
NYC East of Hudson (Middle Branch Reservoir) Watershed. As noted in Section 7, these
MS4s are subject to reductions resulting from the Middle Branch TMDL. The Lake Carmel
TMDL assumes a 10% reduction in MS4 developed land phosphorus loading because of
implementation of the MS4 Permit requirements, including the enhanced MS4 permit
requirement that all septic systems in the MS4 be inspected and tanks pumped once every
five years and, where necessary, repaired. Additional reductions in developed land can be
anticipated due to implementation of the Nutrient Runoff Law, which restricts the use of
lawn fertilizer and prohibits phosphorus in dishwashing detergents sold in NY State.

An enhanced surveying and testing program, above and beyond the requirements of the
MS4 Permit requirements, could be implemented to document the location of septic systems
and verify failing systems, requiring replacement in accordance with the NY State Sanitary
Code. Property owners should be educated on proper maintenance of their septic systems
and encouraged to make preventative repairs.

Lo 	:	

Nonpoint sources that contribute total phosphorus to Lake Carmel include malfunctioning
septic systems, stream bank erosion, groundwater, open land, forest and wetlands.

Table 6 lists the current loading for each source and the load allocation needed to meet the
TMDL; Figure 9 provides a graphical representation of this information. Phosphorus
originating from the natural sources mentioned above (including forested land and
wetlands) is assumed to be a minor source of loading that is unlikely to be reduced further
and therefore the load allocation is set at current loading.

The largest loads are from Internal Loading, Streambank Erosion and Septic Systems, and
the TMDL can be met only with substantial reduction or elimination of these loads.

Septic systems contributing phosphorus to the lake should be sewered, which will reduce
the loading completely if the WWTF discharges to the outlet of the lake or outside of the
Lake Carmel watershed. The TMDL calls for the sewering of the near lake properties and
the discharge of the wastewater treatment facility effluent to the outlet of the lake, in order
to completely eliminate the septic load from the lake.

After reducing the waste load allocation to the maximum extent possible, and allowing for a
margin of safety, the remaining Load Allocation is 1,002.4 Ibs/yr. The Stream Bank Erosion

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allocation is 478 Ib/yr. Internal loads were allocated in Lake Carmel under the assumption
that the internal load will decrease proportionally to decreases in external loads, and are
set at zero. The Septic load will be eliminated once the near lake properties are connected
to a WWTF.

Ma 1	OS)

The margin of safety (MOS) is explicitly accounted for during the allocation of loadings. That
is, the individual model inputs contain no MOS, but 10% of the estimated total loading
capacity, (123 Ibs/yr) was allocated as a MOS to account for uncertainty.

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Table 6: Total Annual Phosphorus Load Allocations for Lake Carmel Watershed



Current

Allocated

Reduction

% Reduction

Stream Bank Erosion

886.3

478.0

408.3

46%

Wetland

6.2

6.2

0

0

Forest

113.8

113.8

0

0

Groundwater

404.4

404.4

0

0

Septic Systems

613.9

0

613.9

100%

Internal Loading

511

0

511

100%

LOAD ALLOCATION TOTAL

2,535.6

1,002.4

1,533.2

40%

WWTF: Girl Scouts Heart of Hudson
SPDES # NY0102181

5.0

2.0

3.0

60%

WWTF: Putnam Nursing and Rehabilitation

SPDES # NY0028924

60.9

12.2

48.7

80%

WWTF: Frangel Realty
SPDES# NY143863

9.1

0

9.1

100%

MS4 Developed Land:
T/Kent SPDES #NYR20A346
T/Patterson SPDES #NYR20A140
T/Pawling SPDES #NYR20A472
T/Beekman SPDES #NYR20A365
TIE. Fishkill SPDES #NYR20A183

100.6

90.4

10.2

10%

WASTELOAD ALLOCATION TOTAL

175.6

104.6

75.9

42%

LA + WLA

2,711.2

1,107

-

-

10% Margin of Safety

-

123

-

-

TOTAL

2,711.2

1,230

1,604.2

59%

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Figure 9: Total Phosphorus Loading Allocations for Lake Carmel Watershed

Putnam
Nursing and
Rehabilitation
WWTF 12.20
Ib/yr

Girl Scouts
Heart of
Hudson
WWTF
2.00 Ib/yr

Streambank Erosion 478.0 Ib/yr

Groundwater 404.4 Ib/yr

Wetland 6.2 Ib/yr

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iditions

TMDLs must take into account critical environmental conditions to ensure that the water
quality is protected during times when it is most vulnerable. Critical conditions were taken
into account in the development of this TMDL. In terms of loading, spring runoff periods
are considered critical because wet weather events transport significant quantities of
nonpoint source loads to lakes. However, the water quality ramifications of these nutrient
loads are most severe during middle or late summer. Therefore, BATHTUB model
simulations were compared against observed data for the summer period only.
Furthermore, MapShed takes into account loadings from all periods throughout the
year, including spring loads.

	mom ations

Seasonal variation in nutrient load and response is captured within the models used for
this TMDL. In BATHTUB, seasonality is incorporated in terms of seasonal averages for
summer. Seasonal variation is also represented in the TMDL by taking 24 years of daily
precipitation data when calculating runoff through MapShed, as well as by estimating
septic system loading inputs based on residency (i.e., seasonal or year-round). This takes
into account the seasonal effects the lake will undergo during a given year.

iderations

Some phosphorus sources are more problematic than others. For example, as previously
discussed, the phosphorus contained in the effluent from septic systems is in a soluble
reactive form. This means that the phosphorus is immediately available to plants and
algae, and will effectively fertilize a lake by orders of magnitude more than an equal
amount of phosphorus that enters the lake in particulate form suspended in stormwater
runoff or as streambank erosion.

This factor was considered in the reductions and allocations because the source of the
most troublesome impairments (excessive weed growth and algae blooms). For this
reason, to alleviate these impairments most effectively requires that phosphorus loading
due to septic failure be addressed.

7.0 IMPLEMENTATION

Effective implementation of TMDL phosphorus load reduction requirements is the most
important part of the TMDL process, and should involve the participation of all
stakeholders. Watershed residents are the primary force behind improving the water
quality in the lake. Additionally, there are some tasks that local government is required to
take. For example, Towns are required to implement measures to reduce sediments and
nutrients in urban runoff under their MS4 permit. But the majority of actions needed to
restore the lake's water quality, habitat and aesthetics are voluntary. In most cases,
residents are not required to implement specific management practices. The success of
the TMDL implementation plan relies on the initiative of residents to bring people together

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as well as to seek out technical assistance and funding where required.

This document is the beginning of a process. It points residents in the direction of working
together with agencies to improve the water quality of the lake. Polluted runoff, including
the nutrient and sediment problems identified in this TMDL, comes from several sources.
Everyone in the watershed contributes to the problem or the solution-how household and
landscaping chemicals and automotive fluids are used and disposed of, how water is
conserved or wasted, disposal of green waste, maintenance of residences and
businesses, use of garbage disposals, etc. A successful program requires broad
participation.

This implementation strategy emphasizes the importance of citizen involvement in setting
short- and long-term goals, tracking progress, and adapting to future research and
monitoring. Regardless of the main cause or causes, many of the solutions are the same.
They can range from traditional conservation practices that reduce soil erosion on
construction sites and other areas of exposed soil to innovative practices and programs
that increase water storage on the land, to decrease the intensity of erosive effects of
stormwater runoff, to more stringent point source control.

There are presently three (3) WWTFs in the Lake Carmel watershed. Effluent from one
WWTF (Frangel Realty) has been redirected to be treated by Kent Manor WWTF, located
in the adjacent Lake Carmel watershed; its flow is therefore not included in the wasteload
allocation. DEC will revise the SPDES permits for the remaining two WWTFs in the Lake
Carmel watershed which are both currently permitted to discharge phosphorus at a
concentration of 1.0 mg/l, to more stringent limits.

Each Town in the Lake Carmel watershed is responsible for enforcing the terms of the
SPDES Construction Permit and ensuring that owners or operators of all construction
activities that involve soil disturbances between five thousand (5,000) square feet and one
(1) acre of land must obtain coverage under the Construction Permit.

The Towns are also responsible for complying with the enhanced criteria specified in the
MS4 General Permit, including the requirement to develop a local law requiring
homeowners to inspect and pump septic systems at least once every five years. A
substantial portion of the phosphorus load to Lake Carmel comes from deficient septic
systems close to the lake. DEC recommends that septic effluent from houses closest to
the lake be treated by a WWTF.

The Town of Kent, where Lake Carmel is located, has installed hydrodynamic separators
(HDS) to filter stormwater before it enters the lake. The HDS units are located across Rt
52 from the bottom of Barrett Hill Road and at Putnam Road. The HDS units collect
sediment that would otherwise enter the lake. The units periodically fill up and require
maintenance. The Town of Kent Highway Department continues to maintain the units on
an annual basis and as needed.

Additionally, a key component of the larger Croton Watershed TMDL Implementation
Plan, NYSDEC 2009, is a non-point source load reduction requirement that was allocated
to each MS4 in the Croton Watershed to be obtained through the construction of
stormwater retrofits. The Town of Kent has, in conjunction with other Croton Watershed

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Towns, constructed several stormwater retrofits to intercept stormwater runoff before it
reaches Lake Carmel. These retrofits are designed to reduce sedimentation and
phosphorus loading to the lake and should positively affect the lake's water quality.

The East of Hudson Watershed Corporation, a coalition of MS4s formed in 2011 to
collectively respond to the Department's MS4 mandates and that include the Towns of
Kent, Pawling and Patterson, has implemented stream bank stabilization practices for
which DEC has awarded phosphorus reduction credit toward the Towns' MS4 stormwater
retrofit phosphorus reduction requirement. These practices should be implemented along
appropriate segments of the Middle Branch Croton River and Stump Pond Creek. The
Department will allow phosphorus reduction credits to the EOHWC where stream
stabilization practices are sited in the Lake Carmel watershed and are attributable to
excessive stormwater runoff.

East Fishkill and Beekman are not members of the EOHWC and do not obtain credits for
the collective actions of the group's members. These two municipalities have independent
obligations under the Croton Watershed TMDL Implementation Plan, NYSDEC 2009, and
should consider implementation of projects in the Lake Carmel basin that would benefit
both Lake Carmel and the overall Croton watershed.

	asonable Assurance	1 nentation

The phosphorus load reduction required to meet the TMDL is calculated to be 1,609 Ib/yr
(59% reduction).

TMDL modeling indicates that lake sedimentation due to stream bank erosion, along with
septic systems and stormwater runoff are principal sources of phosphorus loading in the
Lake Carmel watershed.

The elimination of septic system loading may be accomplished by providing sewer service
for lake-front and near lake-front properties. The Lake Carmel watershed comprises over
62% of the watershed of the immediate downstream waterbody, the Middle Branch
Reservoir, and the phosphorus load from Lake Carmel constitutes 52% of the total load to
the Middle Branch Reservoir. This reservoir will experience a significant reduction in
phosphorus loading once the Lake Carmel TMDL is fully implemented. Notably, in Section
4.4 of the 2000 Middle Branch Reservoir TMDL, a 1987 Lake Carmel Study is discussed,
commissioned by the Town of Kent that estimated a "significant number of failing septic
systems- up to 50% failure rate". The septic systems referenced, near-shore Lake Carmel
systems, are now 30 years older and, except in cases where repairs may have been
implemented, those systems may be even less functional/effective. Sewering the lake
properties would have a substantial positive impact on the lake water quality and the water
quality of the Middle Branch Reservoir as well.

Stream bank erosion is a more complex problem because the causes of this erosion are
not as easily determined. Typically, however, land with a high percentage of impervious
surfaces that drain into the streams increases the rate and intensity of stormwater runoff,
which can increase erosion of a stream channel. High impervious surface coupled with
steep slopes and more intense storm events will further erode the stream corridors and
result in loss of habitat and soil over time.

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The TMDL implementation strategy also includes implementation of stormwater control
provisions in permits now in effect, as described below. The proposed load reductions
also include an assumption that septic loading will decrease due to compliance with the
New York State (NYS) Household Detergent and Nutrient Runoff Law.

smmenclecl Phosphorus Management Strategies for Septic Systems

This TMDL recommends eliminating phosphorus loading from deficient near-lake septic
systems by sewering the near-lake developed parcels in the watershed and instituting a
management system to assure proper design and operation of any remaining individual
systems.

The Towns in the Lake Carmel watershed all have passed local laws in conformance with
the enhanced MS4 General Permit provisions requiring that all septic systems be
inspected and pumped out at least once every 5 years, and where necessary, remediated.
The MS4 Permit provisions that requires an investigation and inspection references the
EPA Publication "Illicit Discharge Detection and Elimination: A Guidance Manual for
Program Development and Technical Assessment", which outlines various procedures to
conduct such an investigation and inspection to satisfy the requirement. The Department
requires that the field investigation and inspection include both the septic tank and the
disposal field.

New homes are required to have septic systems conforming to NYS Department of
Health's 10NYCRR Appendix 75-A (75-A) which define the criteria for wastewater
treatment standards for residential onsite wastewater treatment systems. Alternatively,
residences may connect to municipal wastewater systems. As per 75-A, a 100 ft setback
is required from waterbodies to leachfields. Homes with a cesspool are required to
upgrade to a septic system conforming to 75-A whenever a bedroom is added to the
house.

Homeowners may conduct dye tests for the purpose of identifying cesspool overflows and
determining if wastewater is being discharged to the lake. If dye released in a toilet later
appears in the lake water, then there is a discharge of wastewater to the lake. The Lake
Carmel community in partnership with PCHD should conduct an assessment of septic
systems and cesspools within 100 feet of the lake or a tributary stream in the Lake Carmel
watershed to determine where deficient systems occur, educate homeowners on
management practices for septic systems and cesspools and options for improving
wastewater treatment, and order upgrades where needed. Properties adjacent to the lake
are the highest priority for dye testing. The assessment should develop a database of
wastewater systems in proximity to Lake Carmel and tributary streams.

Watershed load reductions are also attributed to the anticipated benefits of the recent
passage of Chapter 205 of the NYS Laws of 2010, the Household Detergent and Nutrient
Runoff Law (amending section 35-105 and adding a new Title 21 to Article 17 of the
Environmental Conservation Law) which was signed into law on July 15, 2010. This law
restricts the sale and application of fertilizers containing phosphorus for lawns and limits
the phosphorus content of automatic dishwashing detergent. This legislation will reduce
phosphorus in dishwashing detergents sold in NY State and this should reduce the

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phosphorus contribution from on-site wastewater systems, especially those in
substandard condition.

immenclecl Phosphorus Management Strategies for Wastewater Treatment Plants

The New York City Watershed Rules and Regulations (WR&Rs) require all wastewater
treatment facilities (WWTFs) in the East of Hudson Watershed to remove phosphorus
using best management practices (BMPs) as specified in SPDES permit limits.

There are three WWTFs in the Lake Carmel watershed. Flow from one WWTF (Frangel
Realty) has been re-directed as part of a consolidation of flows into a newly constructed
WWTF that discharges outside the Lake Carmel watershed. Additional phosphorus
reduction from the other two point sources (Girl Scouts Heart of Hudson and the Putnam
Nursing and Rehab) will be obtained by modifying those SPDES permits to require
phosphorus limits of 0.4 mg/l for Girl Scouts Heart of Hudson WWTF and 0.2 mg/l for
Putnam Nursing and Rehab WWTF.

DEC will modify the SPDES permits for Girl Scouts Heart of Hudson (#0102181) and
Putnam Nursing and Rehabilitation Center (#0028924). The two WWTFs are both
currently permitted to discharge at 1.0 mg/l. The current calculated load for the three
WWTFs is 79.9 Ib/yr. With these SPDES permit modifications and the removal of the
Frangel Realty WWTF the phosphorus reduction to Lake Carmel is calculated to be 60.8
Ib/yr. The waste load allocation for Lake Carmel is therefore set at 14.2 Ib/yr.

NYCDEP is obligated per their WR&Rs to pay for capital improvements and associated
operation and maintenance at WWTFs within their drinking water watershed, including
phosphorus removal to meet the limits provided in SPDES permits for such facilities. As
per the Lake Carmel TMDL, the phosphorous limits for Putnam Nursing and Girl Scouts
Heart of Hudson will be reduced to 0.2 mg/l and 0.4 mg/l respectively. Development of
these limits was based on NYCDEP agreement to continue to provide funding to meet the
revised permit limits.

smmenclecl Phosphorus Management Strategies for Stormwater Runoff

NYS DEC issued SPDES general permits GP-0-10-001 for construction activities, and GP-
0-10-002 for stormwater discharges from MS4s.

The MS4 General Permit requires MS4s to institute minimum measures, including:

• Public education, more specifically:

o Sensible lawn care, specifically reducing fertilizer use or using phosphorus-free
products, now readily available to consumers. The previously mention
phosphorus legislation, restricts the sale and application of lawn fertilizers
containing phosphorus,
o Cleaning up pet waste, and

o Discouraging waterfowl congregation near waterbodies, by restoring natural
shoreline vegetation.

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•	Illicit discharge and detection requirements, such as mapping the sanitary sewersheds
and septic pumpout, inspection, and where required, remediation every five years;

•	Construction site and post construction stormwater runoff control:

o Ordinance, inspection and enforcement programs, and

o Assurance of no net increase of pollutants from the MS4 taking into account
construction.

•	Pollution prevention practices for road and ditch maintenance

•	Management practices for the handling, storage and use of deicing products.

The MS4 permit also requires that MS4s in the NYC East of Hudson watershed must
develop or modify their stormwater treatment plans to address additional phosphorus
reduction requirements.

All of the Towns in the Lake Carmel watershed are part of the New York City East of
Hudson (EOH) Watershed and are designated as MS4s (Kent, Paterson, Pawling,
Beekman and East Fishkill). Each of these Towns has a phosphorus reduction
requirement to be obtained by implementing stormwater retrofits to the MS4 conveyance
systems. Retrofit work is ongoing throughout the East of Hudson watershed including
several retrofits constructed in the Lake Carmel basin, which are expected to improve
Lake Carmel water quality. Consideration should be given to siting a retrofit project in the
Lake Carmel watershed for the purpose of compliance with the EOH retrofit program
requirement and to benefit Lake Carmel water quality.

As stated in Section 7.1.1, phosphorus load reductions are attributable to implementation
of the Household Detergent and Nutrient Runoff Law restricting the sale and application
of fertilizers containing phosphorus for lawns. For example, the City of Ann Arbor enacted
an ordinance in 2007 to limit phosphorus application to lawns, resulting in an estimated
22% reduction in phosphorus entering the Huron River.

smmenclecl Phosphorus Management Strategies for Streambank Erosion

Addressing the problem of streambank erosion requires an understanding of both stream
dynamics and the management of streamside vegetation. Soil erosion and stream bank
erosion can occur due to construction activities, road projects, drainage projects and urban
runoff. Dramatic increases in stormwater runoff through the stream channel will cause
accelerated streambank erosion (the process of a stream seeking to reestablish a stable
size and pattern due to an external change). An increase in runoff within a stream channel
will result in the stream channel adjusting to the additional flow, which will increase
streambank erosion. Any land use changes in a watershed, such as clearing land or
development, can increase stream bank erosion. The damage or removal of streamside
vegetation reduces bank stability and can cause an increase in stream bank erosion. A
degraded streambed results in higher and often unstable, eroding banks. Stream stability
is an active process, and while streambank erosion is a natural part of this process, human
development activities often accelerate erosion. Streambank erosion increases the

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amount of sediment transported by the stream, resulting in the loss of fertile stream bed
causing a decline in the quality of riparian and stream habitat, in addition, depositing
excess sediment and phosphorus to Lake Carmel, where much of the sediment eventually
settles.

Many of the methods for dealing with streambank erosion, stabilization and restoration are
expensive to install and maintain. Solutions such as rock riprap or gabions (wire baskets
filled with rock) may solve the erosion problem, but may not improve stream habitat or its
aesthetic value. Natural channel design principles look to nature for the blueprint to restore
a stream to an appropriate dimension, pattern and profile. Soil bioengineering practices,
native material revetments and in stream structures help to stabilize eroding banks. The
following techniques may be used to move a stream toward a healthy, naturally stable and
self-maintaining system.

Soil Bioengineering Practices

Bioengineering uses plant materials in a structural way to reinforce and stabilize eroding
streambanks. This technique relies on the use of dormant cuttings of willows, shrub
dogwoods and other plants that root easily. Bioengineering practices range from simple
live stakes to complex structures such as fabricated lifts incorporating erosion control
blankets, plants and compacted soil.

Native Material Revetments

These practices use native materials, wood and stone, to armor streambanks and deflect
flow away from them. Low rock walls and log cribwalls can be used to armor the bank.
Rootwads armor the bank and provide protection downstream by deflecting the flow away
from the bank.

In-Stream Structures

Rock and logs can be used to construct a variety of structures that stabilize the streambed
and banks. Cross vanes are rock structures that stabilize the streambed while aiding in
streambank stabilization. Rock or log vanes redirect stream flow away from the toe of the
streambank and help to stabilize the bank upstream and downstream from the structure.
Where these practices are used, the protection should last long enough to allow
appropriate vegetation to become established and provide for long term bank stability.
The streamside vegetation improves habitat on the land and in the stream by providing
shade, cover and food. Several of the streambank stabilization structures, such as root
wads, are also excellent fish habitat improvement structures.

Riparian Buffers

A riparian buffer is any land near a stream where the vegetation acts as a buffer to the
flow of often pollutant-laden stormwater. These areas usually contain native grasses,
flowers, shrubs and trees that line the stream banks. A healthy riparian area is evidence
of wise land use management.

Riparian areas help to prevent sediment, nutrient and other pollutants from reaching a
stream. Riparian buffers are most effective at improving water quality when they include
a native grass or herbaceous filter strip along with deep rooted trees and shrubs along the
stream. Riparian vegetation is a major source of energy and nutrients for stream
communities. They are especially important in small, headwater streams where up to 99%

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of the energy input may be from woody debris and leaf litter.

Riparian vegetation slows floodwaters, thereby helping to maintain stable streambanks
and protect downstream property. By slowing down floodwaters and rainwater runoff, the
riparian vegetation allows water to soak into the ground and recharge groundwater.
Slowing floodwaters allows the riparian zone to function as a site of sediment deposition,
trapping sediments that build stream banks and would otherwise degrade our streams
and rivers.

Degraded riparian buffers reduce water quality values, reduce wildlife and fish
populations, cause serious property damage (bank erosion) and loss of valuable
agricultural lands. Removal of riparian vegetation results in increased water temperatures
and decreased dissolved oxygen. The loss of shade exposes soils to drying out by wind
and sunlight and reduces the water storage capacity of the riparian area. Loss of riparian
vegetation causes streambank erosion. Eroding banks contribute to sedimentation and
lead to a wide shallow stream with little habitat value. These factors result in significant
reductions in aquatic stream life.

Rehabilitating riparian buffers is key to restoring natural stream functions and aquatic
habitats. There are many economic benefits derived from increased riparian habitat,
channel stabilization, improved water quality, improved wildlife and fish populations,
improved aesthetics, and other associated values. Depending on the surrounding land
use and area topography, riparian buffers should range from 25 to 100 feet wide on each
side of the stream.

Runoff can be directed towards riparian buffers and other undisturbed natural areas
delineated in site planning to infiltrate runoff, reduce runoff velocity and remove pollutants.
Natural depressions can be used to temporarily detain and infiltrate water, particularly in
areas with more permeable soils. Preserving steep slopes and building on flatter areas
helps to prevent soil erosion and minimizes stormwater runoff; helps to stabilize hillsides
and soils and reduces the need for cut-and-fill and grading.

additional Protection Measures

Measures to further protect water quality and limit the growth of phosphorus load that
would otherwise offset load reduction efforts should be considered. The basic protections
afforded by local zoning ordinances could be enhanced to limit non-compatible
development, preserve natural vegetation along shorelines and tributaries and promote
smart growth. Identification of wildlife habitats, sensitive environmental areas, and key
open spaces within the watershed could lead to their preservation or protection by way of
conservation easements or other voluntary controls.

Aquatic Plant Control

Lake Carmel is presently used for swimming, boating, fishing and other uses such as
wildlife viewing. Lake Carmel is relatively shallow and contains various weeds and algae
which interfere with the present uses of the lake. Although aquatic plants are an important

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to lake ecosystems and to fish and wildlife, excessive weeds usually indicate a larger
problem such as excessive sedimentation and nutrients as well as the potential
introduction of invasive species, most of which cannot be eradicated.

Lake Carmel currently contains various aquatic plants, including the following:

Invasive (exotic) plants

-	Eurasian watermilfoil

-	Brittle naiad

•	Nuisance (native) plants

-	Coontail

-	Duckweed

•	Beneficial (native) plants

-	Water lilies

-	Water net

Eurasian Watermilfoil (Myriophyllum spicatum)- Eurasian watermilfoil has slender
stems up to 3 m long. The submerged leaves are usually between 15-35 mm long and
are borne in pinnate (feather-like) whorls of four, with numerous thread-like leaflets
roughly 4-13 mm long. Flowers are produced in the leaf axils (male above, female below)
on a spike 5-15 cm long held vertically above the water surface, each flower
inconspicuous, orange-red, 4-6 mm long. Eurasian water milfoil has 12- 21 pairs of
leaflets.

In lakes or other aquatic areas where native aquatic plants are not well established,
Eurasian watermilfoil can quickly spread. It has been known to crowd out native plants
and create dense surface canopies or dense stands within the water that interfere with
recreational activity. Eurasian watermilfoil can grow from broken off stems which
increases the rate in which the plant can spread and grow.

i

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Brittle naiad (Najas minor)- is an annual aquatic plant which prefers calm waters, such as
ponds, reservoirs and lakes and is capable of growing in depths up to 4 meters. Brittle
Naiad grows in dense clusters and has highly branched stems. These stems fragment
easily and this plant is capable of propagation from stem fragments or from small seeds
which grow along its stem. The small flowers are located in clusters along the leaf axils.
The leaves of the plant are opposite, unbranched, strap-shaped, and are around 4.5
centimeters in length. The leaves have serrations which are visible to the naked eye.

The presence of this plant is a problem because its dense growth covers wide areas,
inhibiting the growth of native species of aquatic macrophytes. The thick, clustering
growths of brittle naiad can make fishing access or the operation of a boat difficult in a
pond or lake. Brittle naiad may spread to new areas by stem fragments carried on a boat's
hull, deck, propeller or trailer, and it does particularly well in lakes with varying water
levels or disturbed bottom characteristics, since the reproductive seeds are usually
resistant to these disturbances. This plant is less likely than Eurasian watermilfoil to create
recreational problems.

Coontail (Ceratophyllum dersum) - grows in still or very slow-moving water. The stems
reach lengths of 1-3 m, with numerous side shoots making a single specimen appear as a
large, bushy mass. The leaves produced in whorls of six to twelve, each leaf 8-40 mm
long, simple, or forked into two to eight thread-like segments edged with spiny teeth; they
are stiff and brittle. It is monoecious with separate male and female flowers produced on
the same plant. The flowers are small, 2 mm long, with eight or more greenish-brown
petals; they are produced in the leaf axils. Its dense growth can outcompete native
underwater vegetation, particularly in turbid water, leading to loss of biodiversity.

However, this is a native plant that would be considered more valuable than Eurasian
watermilfoil or brittle naiad for a health aquatic plant community.

Duckweed (Lemnoideae) - Duckweeds, or water lens, are flowering aquatic plans which
float on or just beneath the surface of still or slow-moving bodies of fresh water and
wetlands. These plants are very simple, lacking an obvious stem or leaves. The greater
part of each plant is a small organized "thallus" or "frond" structure only a few cells thick,
often with air pockets that allow it to float on or just under the water surface. Duckweeds
tend to be associated with fertile, even eutrophic conditions. Duckweed is an important
high-protein food source for waterfowl. The tiny plants provide cover for fry of many
aquatic species. The plants are used as shelter by pond water species such as bullfrogs

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and bluegills. Although at times growing at nuisance levels, this plant is another native
species preferred to Eurasian watermilfoil or brittle naiad.

Many lakes with aquatic invasive species plants have a weed problem. While nutrients
can contribute to a weed problem, removing the nutrients will not solve the weed problem.
As such, most weed management strategies involve the removal of the aquatic invasive
species plants- in the case of Lake Carmel, Eurasian watermilfoil and, to a lesser extent,
brittle naiad.

Some plant management tools may create significant impacts and as such, the benefits
may not outweigh risks. Consideration should be given to selecting actions with lesser
side effects. The method or methods chosen should be dictated by the goals desired to
be obtained. Potential goals for weed management in Lake Carmel include surface
reduction of weeds to: 1) improve boating; 2) clear edges for anglers; and 3) clear whole
sections for swimming. Decisions need to be made as to whether to manage weeds in:
1) part of or the whole lake; 2) in the early summer or the entire summer; and the desired
duration of control (e.g. short term, long term).

Other factors include how much money is available for weed management, and whether
consultant services are necessary or if it can be done with citizen volunteers.

The first and best line of defense is PREVENTION:

•	Visual inspection - assume all dangling plants are invasive

•	Disinfection - Hot water, disinfectant

•	Quarantining - Delay entering lake until any transported plants have
been dried or inactivated

•	Intercepting - Remove plants before they leave other infected lakes

•	Regulating their sale and transport

Management actions are discussed in detail in Diet for a Small Lake which is available on
NYSDEC website (http://www.dec.ny.gov/ chemical/82123.html). Chapter 6 discusses
each aquatic plant management option in detail.

Options for weed control in Lake Carmel - Overview

If the goal is to manage relatively small areas (swimming area, boat channels), it is
possible to implement the following techniques with citizen volunteers.

-	Hand harvesting

-	Benthic barriers

If the goal is to manage a large area (whole lake), a consultant would need to be retained
and consideration could be given to the following techniques:

-	Herbicides- EWM only- triclopyr; EWM and coontail- fluridone

-	Grass carp

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Listed below is a comprehensive table of potential weed control options for Lake Carmel
including the recommended techniques noted above:

Control Options

Is it possible?

How effective at
controlling bad
plants?

How will it damage
good plants?

How much does it
cost?

Permits
needed?

Can we do it
ourselves?

Do Nothing

Yes

Not Applicable

Not applicable

Pay Later

None

Yes

Hand/diver
Harvesting

Yes

Will control any
plant in easy-to-
pluck patches

May remove good
plants by accident

Whole lake—approx
$65k Swimming
area(s)—approx. $10k

No (unless
whole lake)

Yes

Bcnthic Barrier

Yes, but
limited to
swimming or
boating
channel

Will control
plants under the
barriers

Will also eliminate
good plants under
barrier

Whole—not used
Swimming areas—
approx. 10k

No (unless
whole lake or
barriers
permanent)

Yes

Cutting
Shading

Yes
Yes

Not very
effective with
Eurasian
Watermilfoil and
coontail

Not very
effective

Good plants may be
cut by accident

If it works, will
impact good plants
too

Whole lake—not
viable

Swimming areas=
labor only

Whole lake—approx
$40k

Swimming areas—not
viable

No

Yes, if certain
products are
used

Yes (but be
careful)

Yes, if
landscaping
product used
No, if

pesticides used

Herbivorous
insects

Yes

Not effective
with Eurasian
Watermilfoil

Will not damage
good plants

Whole lake—approx.
$200k

Swimming areas—not
likely restricted to area

Yes, Article 11
(Possess?)

No, authorized
applicator
through permit

Drawdown

No

Somewhat
effective, but
some exotics will
increase

May remove good
plants by accident

Whole lake—no cost
Swimming areas—not
possible

Maybe, Article
15 (Protection
of Waters
Permit**)

Not possible
as plant
control tool

Mechanical
harvesting

Aquatic
herbicides

Grass Carp

Probably not
Yes

Yes, if outlet
can be
screened

Effective

Eurasian
watermilfoil-very
effective
Coontail—fairly
effective

Fairly effective

Good plants will be
removed too

Less effective on
lilies, duckweed
Depends on herbicide
used

Some good plants
may be damaged

Whole lake—approx.
$ 150k to purchase
Swimming areas—not
likely

Whole lake—approx.
$125k

Swimming areas—not
likely to stay in area

Whole lake—approx.
$60k

Swimming areas—fish
will wander

Probably not
Yes

Yes, Article 11

No

No, need

licensed

applicator

No, need

licensed

applicator

Dredging

Probably not

Fairly effective

Good plants will be
removed too

Whole lake—prob. not
feasible

Swimming areas-
$300k?

Yes

No

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Other alternatives include utilizing Integrated Plant Management (IPM), (combining two or
more management techniques). IPM can target any/all invasives and is often viewed as a
more comprehensive approach as it can combine local and lakewide management
techniques. Care should be taken to ensure that techniques are compatible so there are
no side effects. The costs and need for permits will depend on the management
techniques chosen.

Decision trees help guide initial decision-making process based on the key factors for
each infestation. Key factors may include: Management objectives, permitting, side
effects, longevity and cost. A decision tree for watermilfoil control follows:

Decision Tree for Eurasian Watermilfoil Control

Milfoil bed less than 100
square feet or only in isolated
shoreline plots?

Just rip it out?

Yes

No

Lake / Pond
less than 10 acres?

Yes > No	No	1 Yes

» \ r V

Renovating or
Hydroraking

Milfoil bed
less than 50
square feet?



Yes

ir

No

1

r

Is it later than
August 15?



Plants more
than 3 feet
tall?





Dam on lake
capable of
deep draw-
down?

Shading

Yes

No

~

Control on
lake surface or

throughout
water column?

^^r^wdowrj

Other
Options..

Surface	Whole

Only	Water

Column

/ V



Try again



next year

Mechanical
Harvesting

Immediate or
long term
control?



Yes



Grass Carp,



Public

Insects or



opposition to

Dredging



herbicides?

Triclopyr, 2, 4-D
or Fluridone

Long-term
but delayed

JrJi

Immediate
but short term

No

No 	

	#

Public
opposition to
herbicides?

v„

Out of luck - Need
more hands for hand
harvesting

37


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se Green Algae Blooms

During summer 2014 and summer 2015 the Putnam County Department of Health
closed several Lake Carmel beaches due to an abundance of blue-green algae. Blue
green algae can release toxins that affect people through skin exposure and
gastrointestinal or asthma-like symptoms, including nausea, vomiting, diarrhea, skin or
throat irritation, allergic reactions or breathing difficulties. Swimming can also be affected
by the ugly appearance and smell from algae that accumulated along the surface or
shoreline. People and pets should avoid swimming in heavily discolored water or
surface scums, and they should also not handle algae material-scums or algae covering
weeds along the shoreline.

Lake residents can reduce the likelihood of algae blooms in Lake Carmel by reducing the
amount of nutrients (phosphorus and nitrogen) that enter the lake. This can be
accomplished by:

•	sewering the lake properties,

•	limiting lawn fertilization,

•	maintaining shoreline buffers,

•	maintaining and pumping out septic tanks,

•	reducing stream bank erosion and stormwater runoff, and

•	maintaining water movement in the lake.

Algae Control Management actions are discussed in detail in Diet for a Small Lake
which is available on NYSDEC website (http://www.dec.ny.gov/ chemical/82123.html)
(Chapter 7 discusses each aquatic plant management option in detail).

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Algae Control Options for Lake Carmel

Control Options Is it possible?

Pros

Cons

How much
does it cost?

Permits
needed?

Can we do it
ourselves?

Barley Straw

Yes

Cheap, Easy,
DIY, No
Evidence of
Harm, Some
Anecdotal
Evidence It
Works

Only Anecdotal
Evidence,
Removal of
Spent Bales

Whole Lake =

$5-6k

None or Not
Swimming areas Allowed
= $500 (if
placed near
edge, outside

Yes

Algeacides

Yes -Chemically
Wipe Out Algae
by Contact

Short Term

Control,

Immediate,

Usually

Effective

Non-Target
Impacts,
Controversial,
Some Limits on
Use, Can Push
Toxins Into
Water

Whole lake—
approx $12-15k.
Swimming
areas—$3-$5k
(usually done as
whole lake)

ECL Article
15/Part 327,
Article
17/SPDES
General Permit,
Article 24)

No - need

licensed

applicator

Biomanipulation

Yes - stock fish
to eat algae (or
to eat fish that
eat zooplankton
that eat algae)

Can be
effective.
One and Done,
"Natural",
Improve Fishery

Unclear as to
how effective
Disrupt
Fish/food web
Community,
Hard To

Reverse, Highly

Variable

Success;

Assume

BB/Carp

Dominate Lake

$100-200/ 100
fish; 100-1000
fish/acre

Article 11

No - need

permit

applicator

39


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Lake Management Resources

Diet for a Small Lake

(http://www.dec.ny.gov/chemical/82123.htmn

•	Chapter 6 discusses each aquatic plant management option in detail

•	Chapter 7 discusses each algae control option in detail
Harmful Blue-green Algae Blooms

•	General information— http://www.dec.ny. gov/chemical/77118.html

•	Bloom Notices— http://www.dec.ny. gov/chemical/83310.html

•	Frequently Asked Questions— http://www.dec.ny.gov/chemical/91570.html
Invasive Species

•	General information about invasive species—http://www.dec.ny.gov/animals/265.html

•	Aquatic invasive species in NYS— http://www.dec.ny.gov/animals/50121 .html

•	How to prevent the spread of aquatic invasive species—
http://www.dec.ny.gov/animals/48221.html

Citizens Statewide Lake Assessment Program (CSLAP)

•	Need to be a member of the NY Federation of Lake Associations—http://www.nvsfola.org/

•	Apply to NYSFOLA for 2015

•	General information about CSLAP— http: //www, dec. ny. gov/chemi cal/815 76. html

	Hoi ¦ Monitoring

A targeted post-assessment monitoring effort is necessary to determine the effectiveness
of the implementation plan associated with the TMDL. Annual growing season monitoring
of the pond and watersheds would inform the implementation process. Lake Carmel
should be sampled in the summer growing season (June through September) on 8
sampling dates at its deepest location. Grab samples should be collected at a 1.5 meter
depth. The samples should be analyzed for the phosphorus series (total phosphorus, total
soluble phosphorus, and soluble reactive phosphorus). The Secchi disk depth should be
recorded. A simple macrophyte survey should also be conducted once during midsummer.

7.3 Summary
Septic Systems:

Residential septic systems discharge effluent containing dissolved phosphorus to nearby
waterbodies when they are malfunctioning. A septic system can malfunction if there is not
sufficient permeable soil for the wastewater to travel through and the wastewater is forced
upward to discharge to the ground surface. A septic system in close proximity to surface
waters can malfunction because the groundwater table is high and there is insufficient
treatment of effluent before it reaches the groundwater. Often where these septic systems
are located close to waterbodies the laterals discharge directly to the groundwater without
any treatment. This contributes significant phosphorus loads to the waterbody. As a
result, malfunctioning septic systems can contribute high phosphorus loads to nearby
waterbodies.

The most effective solution to eliminate the phosphorus loading from the deficient septic

40


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systems that surround Lake Carmel is to connect these properties to a Waste Water
Treatment Facility that will operate according to the phosphorus limits contained in the
NYC Watershed Rules and Regulations.

Streambank Erosion:

As watershed areas are developed for residential, commercial, industrial, and
transportation land uses the amount of impervious surfaces increases. The increase in
impervious surfaces changes the timing and volume of storm water that is delivered to
nearby streams. In addition, changes in stream volume between storms, the height of
groundwater tables, and the rate and volume of stream erosion are likely outcomes of
increased watershed imperviousness.

The development of land to build houses, stores, parking lots and roads all create these
impervious surfaces that effectively seal surfaces, repel water and prevent rainfall and
snow melt from infiltrating into the soil. The result is increased volume and intensity of
stormwater runoff that can often cause MS4 conveyances (which include unimproved
roadside ditches) and other receiving waters and streams to erode. When the velocity of
the runoff decreases sufficiently, this eroded soil ultimately settles out, usually where
streams enter still water. Where the tributaries of Lake Carmel (Middle Branch Croton
River and Stump Pond Stream) enter the lake, excessive amounts of sediments have
accumulated. This was verified by DEC staff at the north end of Lake Carmel in December
2014 and expressed as a concern by the lake community residents at the public meeting
on July 29th.

The rate of sedimentation and resultant phosphorus loading to the lake can be reduced
by:

•	Working with the East of Hudson Watershed Corporation (EOHWC) to stabilize the
stream channels that empty into Lake Carmel; i.e. providing toe protection, native
or non-invasive vegetative cover, drop structures, armoring stream banks with
materials that combine structure with vegetation. This work will both improve the
water quality of the lake as well as provide phosphorus reduction credit toward the
EOHWC MS4 Permit requirement. Working with EOHWC to site stormwater retrofits
that reduce stormwater runoff from developed land from adversely affecting the
lake, through the construction of infiltration and filtration stormwater practices.

•	Work with EOHWC to identify large areas of impervious cover which currently
discharge directly to waterbodies during runoff events and attempt to install runoff
reduction practices to reduce the rate of runoff and therefore reduce in-stream
erosion. These practices would also potentially reduce the phosphorous being
discharged to the Lake Carmel watershed.

•	Establishing protected riparian buffer strips along the stream to filter pollutants and
debris in runoff before it enters the stream channel via regulatory land use changes.

•	Maintaining a regular practice of street sweeping to reduce sediment-laden
stormwater from reaching the streams that feed Lake Carmel.

MS4:

The municipal separate stormwater systems (MS4s) in the Lake Carmel watershed all
contribute phosphorus to Lake Carmel via the collection of stormwater from roadways and
other impervious surfaces. This stormwater is discharged into tributaries and from there

41


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into the lake. Recent field work revealed extensive sedimentation at the north end of Lake
Carmel, visible because the water level was low due to lack of recent rainfall. This
sedimentation and the resultant phosphorus loading to the lake can be reduced by:

•	Limiting the creation of pavement and other impervious surfaces through local land
use regulatory changes.

•	Creating conservation easement areas to limit further development.

•	Limit clearing and grading of sites being developed to the minimum amount needed
for development.

•	Enforcing the terms of the SPDES Construction General Permit and the SPDES
MS4 General Permit.

•	Installing stormwater retrofit practices.

8.0 PUBLIC PARTICIPATION

The Department held an informational meeting on July 29th, 2014 in the Town of Kent, to
engage the interested public in discussion, answer lake management questions and to hear
the community's water quality and water use goals for Lake Carmel.

Notice of availability of the proposed TMDL was made to local government
representatives and interested parties. The proposed TMDL was public noticed in the
Environmental Notice Bulletin on June 1, 2016. A 30-day public review period was
established for soliciting written comments from stakeholders prior to the finalization and
submission of the TMDL for EPA approval. Comments were accepted until close of
business on July 1, 2016. Written comments received and the Department's responses
are published below:

NYC DEP:

"The Lake Carmel watershed encompasses two-thirds of the Middle Branch Reservoir
watershed and was modeled as providing more than 50% of the phosphorus to the
reservoir during the development of the Phase II TMDLs. Accordingly, the potential
impact this TMDL could have on downstream waterbodies should be briefly discussed."

DEC:

The impact this TMDL will have on the Middle Branch Reservoir, if the
recommendations of the Implementation Section are carried out, would be a
significant reduction in phosphorus loading to that reservoir. In Section 4.4 of the
2000 NYC Middle Branch Reservoir TMDL, a 1987 Lake Carmel Study is discussed,
commissioned by the Town of Kent that estimated a "significant number of failing
septic systems- up to 50% failure rate". These septic systems are now 30 years
older and, except in cases where repairs may have been implemented, those
systems may be less effective. Sewering the lake properties in particular, along
with implementation of stream bank erosion protection, would have a substantial
positive impact on the lake water quality and the water quality of the downstream
Middle Branch Reservoir as well.

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NYC DEP:

"The Report should explain that different methodologies and datasets have been used
over time to calculate phosphorus loads for the Phase II NYC Reservoir TMDLs, the MS4
retrofit requirements, and the current Lake Carmel TMDL."

DEC:

The methodology this Report used to calculate stormwater phosphorus loading to
Lake Carmel was utilization of the watershed model Mapshed, which estimates
watershed loading using real weather data. The Department allowed the use of the
Simple Method formula to calculate phosphorus loading for proposed BMPs in the
Retrofit Program, which multiplies drainage area, stormwater phosphorus
concentration and runoff volume to estimate phosphorus loading from a given
subwatershed. The NYC TMDLs used a phosphorus export coefficient to calculate
stormwater runoff phosphorus loading, which multiplies a fixed coefficient (kg/ha)
by land use area, and which is independent of rainfall. All methods approximate
phosphorus loading from stormwater runoff, but the Department utilized real
rainfall data in an effort to produce a more accurate estimation of phosphorus
loading.

For septic loading estimates, the Department utilized census data to estimate per
parcel loading to Lake Carmel, and considered all septic systems that are located
within 250 feet of Lake Carmel as contributors of phosphorus, a methodology used
in other studies, and as cited in the body of the TMDL report. The NYC Middle
Branch Reservoir TMDL counted phosphorus contributions from septic systems
within 100 feet of that reservoir, estimating that any septic systems greater than 100
feet from the reservoir were not contributing phosphorus to the reservoir. This
difference in methodology accounts for the larger value in the Lake Carmel TMDL
for septic loading than that articulated in the NYC Middle Branch Reservoir TMDL
(614 Ib/yr vs 86 kg/yr (190 lb/yr)). The septic systems that surrounded Lake Carmel
are now all thirty years older than when the NYC Middle Branch Reservoir TMDL
was written, and except where rehabilitated, are nearing if not past their design
lives, so septic loading may be more of a factor now.

Internal loading estimates for the Lake Carmel TMDL were derived from the
difference between the modeled and monitored lake phosphorus concentration.
The NYC Middle Branch Reservoir TMDL estimated internal loading in a similar
manner, and referenced (in Section 4.4) a 1987 Lake Carmel Study, commissioned
by the Town of Kent that reported a significant number of failing septic systems
("up to 50% failure rate") and a "missing phosphorus load" in the Lake Carmel
loading estimate, stating that "this missing load, a combination of septic systems
and/or sediments, can be estimated by calculating the amount of phosphorus
required to bring the modeled phosphorus concentration from 14 ug/l to the
observed 19 ug/l". The "missing" phosphorus load in the NYC Middle Branch
Reservoir TMDL was calculated to be 38% of the total load to Lake Carmel. (The
Lake Carmel TMDL modeled septic + internal loading combined to 39.4% of the total
load to Lake Carmel).

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NYC DEP:

"The phosphorus loading from streambank erosion is identified as an even greater source
of phosphorus, estimated as 33% of the total load to Lake Carmel. This seems unusual for
this watershed and should be independently validated."

DEC:

Phosphorus loading due to streambank erosion was calculated to be 3,708
tons/year, or 947 Ib/ac-yr. The modeled value utilizes slope, digital elevation data,
stream length and size of watershed relative to waterbody size to determine this
loading estimate. The Lake Carmel watershed is highly developed, with steep
slopes and high watershed to waterbody ratio. When the Mapshed model
developers were consulted, they agreed that, given the nature of the Lake Carmel
watershed, the calculated streambank erosion value was reasonable.

9.0 REFERENCES

ASCE Task Committee on Definition of Criteria for Evaluation of Watershed Models of
the Watershed Management Committee, Irrigation and Drainage Division, 1993. Criteria
for evaluation of watershed models. Journal of Irrigation and Drainage Engineering, Vol.
199, No. 3.

Day, L.D., 2001. Phosphorus Impacts from Onsite Septic Systems to Surface Waters in
the Cannonsville Reservoir Basin, NY. Delaware County Soil and Water Conservation
District, Walton, NY, June, 2001.

Evans, B.M., D.W. Lehning, K.J. Corradini, Summary of Work Undertaken Related
to Adaptation of MapShed for Use in New England and New York. 2007.

Evans, B.M., D.W. Lehning, K.J. Corradini, G.W. Petersen, E. Nizeyimana, J.M.

Hamlett, P.D. Robillard, and R.L. Day, 2002. A Comprehensive GIS-Based Modeling
Approach for Predicting Nutrient Loads in Watersheds. Journal of Spatial Hydrology,
Vol. 2, No. 2.

Haith, D.A. and L.L. Shoemaker, 1987. Generalized Watershed Loading Functions for
Stream Flow Nutrients. Water Resources Bulletin, 23(3), pp. 471-478.

Homer, C. C. Huang, L. Yang, B. Wylie and M. Coan. 2004. Development of a 2001
National Landcover Database for the United States. Photogrammetric Engineering and
Remote Sensing, Vol. 70, No. 7, July 2004, pp. 829.

National Atmospheric Deposition Program (NRSP-3). 2007. NADP Program Office,
Illinois State Water Survey, 2204 Griffith Dr., Champaign, IL 61820.

New York State, 2004. New York State Water Quality Report 2004. NYS Department
of Environmental Conservation, Division of Water, Bureau of Watershed
Assessment and Management.

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New York State, 1998. 6 NYS Codes Rules and Regulations, Part 703.2, Narrative
Water Quality Standards.

New York State, 1993. New York State Fact Sheet, Ambient Water Quality Value for
Protection of Recreational Uses, Substance: Phosphorus, Bureau of Technical Services
and Research. NYS Department of Environmental Conservation.

Sherwood, D.A., 2005, Water resources of Monroe County, New York, water years 2000-
02— atmospheric deposition, ground water, streamflow, trends in water quality, and
chemical loads in streams: U.S. Geological Scientific Investigations Report 2005-5107,
55 p.

United States Army Corps of Engineers, Engineer Research and Development Center.,

2004.	Flux, Profile, and BATHTUB: Simplified Procedures for Eutrophication
Assessment and Prediction, .

USEPA. 2002. Onsite Wastewater Treatment Systems Manual. EPA/625/R-00/008.
February 2002

USEPA, 1999. Protocol for Developing Sediment TMDLs (First Edition). EPA
841-B-99-004. Office of Water (4503F), United States Environmental Protection
Agency, Washington, DC.

USEPA. 1990. The Lake and Reservoir Restoration Guidance Manual. 2nd Ed. and
Monitoring Lake and Reservoir Restoration (Technical Supplement). Prepared by North
American Lake Management Society. EPA 440/4-90-006 and EPA 440/4-90-007.

USEPA. 1986. Technical Guidance Manual for Performing Wasteload Allocations,
Book IV: Lakes, Reservoirs and Impoundments, Chapter 2: Eutrophication. EPA 440/4-
84-019, p. 3-8.

United States Census Bureau, Statistical Abstract of the United States: 2012, Table
61. Households and Persons Per Household by Type of Household: 1990-2010

Watts, S., B. Gharabaghi, R.P. Rudra, M. Palmer, T. Boston, B. Evans, and M. Walters,

2005.	Evaluation of the GIS-Based Nutrient Management Model CANWET in Ontario.
In: Proc. 58th Natl. Conf. Canadian Water Resources Assoc., June 2005, Banff, Canada.

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APPENDIX A. MAPSHED MODELING ANALYSIS

The MapShed model was developed in response to the need for a version of AVGWLF
that would operate in a non-proprietary GIS package. AVGWLF had previously been
calibrated for the Northeastern U.S. in general and New York specifically. Conversion of
the calibrated AVGWLF to MapShed involved the transfer of updated model coefficients
and a series of verification model runs. The calibration and conversion of the models is
discussed in detail in this section.

Northeast AVGWLF Model

The AVGWLF model was calibrated and validated for the northeast (Evans et al., 2007).
AVGWLF requires that calibration watersheds have long-term flow and water quality data.
For the northeast model, watershed simulations were performed for twenty-two (22)
watersheds throughout New York and New England for the period 1997-2004 (Figure 22).
Flow data were obtained directly from the water resource database maintained by the U.S.
Geological Survey (USGS). Water quality data were obtained from the New York and New
England State agencies. These data sets included in-stream concentrations of nitrogen,
phosphorus, and sediment based on periodic sampling.

Figure 10: Location of Calibration & Verification Watersheds for the Original Northeast AVGWLF Model

46


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Initial model calibration was performed on half of the 22 watersheds for the period 1997-
2004. During this step, adjustments were iteratively made in various model parameters until
a "best fit" was achieved between simulated and observed stream flow, and sediment and
nutrient loads. Based on the calibration results, revisions were made in various AVGWLF
routines to alter the manner in which model input parameters were estimated. To check the
reliability of these revised routines, follow-up verification runs were made on the remaining
eleven watersheds for the same time period. Finally, statistical evaluations of the accuracy
of flow and load predictions were made.

To derive historical nutrient loads, standard mass balance techniques were used. First, the
in-stream nutrient concentration data and corresponding flow rate data were used to
develop load (mass) versus flow relationships for each watershed for the period in
which historical water quality data were obtained. Using the daily stream flow data
obtained from USGS, daily nutrient loads for the 1997-2004 time period were subsequently
computed for each watershed using the appropriate load versus flow relationship (i.e.,
"rating curves"). Loads computed in this fashion were used as the "observed" loads against
which model-simulated loads were compared.

During this process, adjustments were made to various model input parameters for the
purpose of obtaining a "best fit" between the observed and simulated data. With respect to
stream flow, adjustments were made that increased or decreased the amount of the
calculated evapotranspiration and/or "lag time" (i.e., groundwater recession rate) for sub-
surface flow. With respect to nutrient loads, changes were made to the estimates for sub-
surface nitrogen and phosphorus concentrations. In regard to both sediment and nutrients,
adjustments were made to the estimate for the "C" factor for cropland in the USLE equation,
as well as to the sediment "a" factor used to calculate sediment loss due to stream bank
erosion. Finally, revisions were also made to the default retention coefficients used by
AVGWLF for estimating sediment and nutrient retention in lakes and wetlands.

Based upon an evaluation of the changes made to the input files for each of the calibration
watersheds, revisions were made to routines within AVGWLF to modify the way in which
selected model parameters were automatically estimated. The AVGWLF software
application was originally developed for use in Pennsylvania, and based on the calibration
results, it appeared that certain routines were calculating values for some model
parameters that were either too high or too low. Consequently, it was necessary to make
modifications to various algorithms in AVGWLF to better reflect conditions in the Northeast.
A summary of the algorithm changes made to AVGWLF is provided below.

•	ET: A revision was made to increase the amount of evapotranspiration calculated
automatically by AVGWLF by a factor of 1.54 (in the "Pennsylvania" version of
AVGWLF, the adjustment factor used is 1.16). This has the effect of decreasing
simulated stream flow.

•	GWR: The default value for the groundwater recession rate was changed from 0.1
(as used in

Pennsylvania) to 0.03. This has the effect of "flattening" the hydrograph within a given
area.

•	GWN: The algorithm used to estimate "groundwater" (sub-surface) nitrogen
concentration was changed to calculate a lower value than provided by the

47


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"Pennsylvania" version.

•	Sediment "a" Factor: The current algorithm was changed to reduce estimated
stream bank- derived sediment by a factor of 90%. The streambank routine in AVGWLF
was originally developed using Pennsylvania data and was consistently producing
sediment estimates that were too high based on the in-stream sample data for the
calibration sites in the Northeast. While the exact reason for this is not known, it's
likely that the glaciated terrain in the Northeast is less erodible than the highly
erodible soils in Pennsylvania. Also, it is likely that the relative abundance of lakes,
ponds and wetlands in the Northeast have an effect on flow velocities and sediment
transport.

•	Lake/Wetland Retention Coefficients: The default retention coefficients for sediment,
nitrogen and phosphorus are set to 0.90, 0.12 and 0.25, respectively, and changed at
the user's discretion.

To assess the correlation between observed and predicted values, two different statistical
measures were utilized: 1) the Pearson product-moment correlation (R2) coefficient and
2) the Nash-Sutcliffe coefficient. The R2 value is a measure of the degree of linear
association between two variables, and represents the amount of variability that is explained
by another variable (in this case, the model- simulated values). Depending on the strength
of the linear relationship, the R2 can vary from 0 to 1, with 1 indicating a perfect fit between
observed and predicted values. Like the R2 measure, the Nash- Sutcliffe coefficient is an
indicator of "goodness of fit," and has been recommended by the American Society of Civil
Engineers for use in hydrological studies (ASCE, 1993). With this coefficient, values equal
to 1 indicate a perfect fit between observed and predicted data, and values equal to 0
indicate that the model is predicting no better than using the average of the observed data.
Therefore, any positive value above 0 suggests that the model has some utility, with
higher values indicating better model performance. In practice, this coefficient tends to be
lower than R2 for the same data being evaluated.

Adjustments were made to the various input parameters for the purpose of obtaining a "best
fit" between the observed and simulated data. One of the challenges in calibrating a model
is to optimize the results across all model outputs (in the case of AVGWLF, stream flows,
as well as sediment, nitrogen, and phosphorus loads). As with any watershed model like
GWLF, it is possible to focus on a single output measure (e.g., sediment or nitrogen) in
order to improve the fit between observed and simulated loads. Isolating on one model
output, however, can sometimes lead to less acceptable results for other measures.
Consequently, it is sometimes difficult to achieve very high correlations (e.g., R2 above 0.90)
across all model outputs. Given this limitation, it was felt that very good results were
obtained for the calibration sites. In model calibration, initial emphasis is usually placed on
getting the hydrology correct. Therefore, adjustments to flow-related model parameters are
usually finalized prior to making adjustments to parameters specific to sediment and nutrient
production. This typically results in better statistical fits between stream flows than the other
model outputs.

For the monthly comparisons, mean R2 values of 0.80, 0.48, 0.74, and 0.60 were obtained
for the calibration watersheds for flow, sediment, nitrogen and phosphorus, respectively.
When considering the inherent difficulty in achieving optimal results across all measures as
discussed above (along with the potential sources of error), these results are quite good.

48


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The sediment load predictions were less satisfactory than those for the other outputs, and
this is not entirely unexpected given that this constituent is usually more difficult to simulate
than nitrogen or phosphorus. An improvement in sediment prediction could have been
achieved by isolating on this particular output during the calibration process; but this would
have resulted in poorer performance in estimating the nutrient loads for some of the
watersheds. Phosphorus predictions were less accurate than those for nitrogen. This is not
unusual given that a significant portion of the phosphorus load for a watershed is highly
related to sediment transport processes. Nitrogen, on the other hand, is often linearly
correlated to flow, which typically results in accurate predictions of nitrogen loads if stream
flows are being accurately simulated.

As expected, the monthly Nash-Sutcliffe coefficients were somewhat lower due to the
nature of this particular statistic. As described earlier, this statistic is used to iteratively
compare simulated values against the mean of the observed values, and values above
zero indicate that the model predictions are better than just using the mean of the observed
data. In other words, any value above zero would indicate that the model has some utility
beyond using the mean of historical data in estimating the flows or loads for any particular
time period. As with R2 values, higher Nash-Sutcliffe values reflect higher degrees of
correlation than lower ones.

Improvements in model accuracy for the calibration sites were typically obtained when
comparisons were made on a seasonal basis. This was expected since short-term
variations in model output can oftentimes be reduced by accumulating the results over
longer time periods. In particular, month-to- month discrepancies due to precipitation events
that occur at the end of a month are often resolved by aggregating output in this manner
(the same is usually true when going from daily output to weekly or monthly output).
Similarly, further improvements were noted when comparisons were made on a mean
annual basis. What these particular results imply is that AVGWLF, when calibrated, can
provide very good estimates of mean annual sediment and nutrient loads.

Following the completion of the northeast AVGWLF model, there were a number of ideas
on ways to improve model accuracy. One of the ideas relates to the basic assumption
upon which the work undertaken in that project was based. This assumption is that a
"regionalized" model can be developed that works equally well (without the need for
resource-intensive calibration) across all watersheds within a large region in terms of
producing reasonable estimates of sediment and nutrient loads for different time
periods. Similar regional model calibrations were previously accomplished in earlier
efforts undertaken in Pennsylvania (Evans et al., 2002) and later in southern Ontario
(Watts et al., 2005). In both cases this task was fairly daunting given the size of the areas
involved. In the northeast effort, this task was even more challenging given the fact that
the geographic area covered by the northeast is about three times the size of
Pennsylvania, and arguably is more diverse in terms of its physiographic and ecological
composition.

As discussed, AVGWLF performed very well when calibrated for numerous watersheds
throughout the region. The regionalized version of AVGWLF, however, performed less
well for the verification watersheds for which additional adjustments were not made
subsequent to the initial model runs. This decline in model performance may be a result
of the regionally-adapted model algorithms not being rigorous enough to simulate

49


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spatially-varying landscape processes across such a vast geographic region at a
consistently high degree of accuracy. It is likely that un-calibrated model performance
can be enhanced by adapting the algorithms to reflect processes in smaller geographic
regions such as those depicted in the physiographic province map in Figure 23.

Fine-tuning & Re-Calibrating the Northeast AVGWLF for New York
State

For the TMDL development work undertaken in New York, the original northeast
AVGWLF model was further refined by The Cadmus Group, Inc. and Dr. Barry Evans to
reflect the physiographic regions that exist in New York. Using data from some of the
original northeast model calibration and verification sites, as well as data for additional
calibration sites in New York, three new versions of AVGWLF were created for use in
developing TMDLs in New York State. Information on the fourteen (14) sites is summarized
in Table 20. Two models were developed based on the following two physiographic regions:
Eastern Great Lakes/Hudson Lowlands area and the Northeastern Highlands area. The
model was calibrated for each of these regions to better reflect local conditions, as well as
ecological and hydrologic processes. In addition to developing the above mentioned
physiographic-based model calibrations, a third model calibration was also developed.
This model calibration represents a composite of the two physiographic regions and is
suitable for use in other areas of upstate New York.

Figure 11: Location of Physiographic Provinces in New York and New England


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Table 7; AVGWLF Calibration Sites for use in the New York TIVIDL Assessments

Site

Location

Physiographic Region

Owasco Lake

NY

Eastern Great Lakes/Hudson Lowlands

West Branch

NY

Northeastern Highlands

Little Chazy River

NY

Eastern Great Lakes/Hudson Lowlands

Little Otter Creek

VT

Eastern Great Lakes/Hudson Lowlands

Poultney River

VT/NY

Eastern Great Lakes/Hudson Lowlands & Northeastern
Highlands

Farmington River

CT

Northeastern Highlands

Saco River

ME/NH

Northeastern Highlands

Squannacook

MA

Northeastern Highlands

Ashuelot River

NH

Northeastern Highlands

Laplatte River

VT

Eastern Great Lakes/Hudson Lowlands

Wild River

ME

Northeastern Highlands

Salmon River

CT

Northeastern Coastal Zone

Norwalk River

CT

Northeastern Coastal Zone

Lewis Creek

VT

Eastern Great Lakes/Hudson Lowlands

Conversion of the AVGWLF Model to MapShed and Inclusion of RUNQUAL

The AVGWLF model requires that users obtain ESRI's ArcView 3.x with Spatial Analyst.
The Cadmus Group, Inc. and Dr. Barry Evans converted the New York-calibrated
AVGWLF model for use in a non-proprietary GIS package called MapWindow. The
converted model is called MapShed and the software necessary to use it can be obtained
free of charge and operated by any individual or organization who wishes to learn to use
it. In addition to incorporating the enhanced GWLF model, MapShed contains a revised
version of the RUNQUAL model, allowing for more accurate simulation of nutrient
and sediment loading from urban areas.

RUNQUAL was originally developed by Douglas Haith (1993) to refine the urban
runoff component of GWLF. Using six urban land use classes, RUNQUAL differentiates
between three levels of imperviousness for residential and mixed commercial uses.
Runoff is calculated for each of the six urban land uses using a simple water-balance
method based on daily precipitation, temperature, and evapotranspiration. Pollutant
loading from each land use is calculated with exponential accumulation and washoff
relationships that were developed from empirical data. Pollutants, such as phosphorus,
accumulate on surfaces at a certain rate (kg/ha/day) during dry periods. When it rains,
the accumulated pollutants are washed off of the surface and have been measured to
develop the relationship between accumulation and washoff. The pervious and
impervious portions of each land use are modeled separately and runoff and contaminant
loads are added to provide total daily loads. RUNQUAL is also capable of simulating the
effects of various urban best management practices (BMPs) such as street sweeping,
detention ponds, infiltration trenches, and vegetated buffer strips.

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Set-up of the New York MapShed Model

Using data for the time period 1990-2007, the calibrated MapShed model was used to
estimate mean annual phosphorus loading to the ponds. Table 21 provides the sources
of data used for the MapShed modeling analysis. The various data preparation steps
taken prior to running the final calibrated MapShed Model for New York are discussed
below the table.

Table 8: Information Sources for MapShed Model Parameterization

WEATHER.DAT file

Data

Source or Value



Historical weather data from Rochester, NY and
Albion, NY National Weather Service Stations

TRANSPORT.DAT file

Data

Source or Value

Basin size

GIS/derived from basin boundaries

Land use/cover distribution

GIS/derived from land use/cover map

Curve numbers by source area

GIS/derived from land cover and soil maps

USLE (KLSCP) factors by source

GIS/derived from soil, DEM, & land cover

ET cover coefficients

GIS/derived from land cover

Erosivity coefficients

GIS/ derived from physiographic map

Daylight hrs. by month

Computed automatically for state

Growing season months

Input by user

Initial saturated storage

Default value of 10 cm

Initial unsaturated storage

Default value of 0 cm

Recession coefficient

Default value of 0.1

Seepage coefficient

Default value of 0

Initial snow amount (cm water)

Default value of 0

Sediment delivery ratio

GIS/based on basin size

Soil water (available water capacity)

GIS/derived from soil map

NUTRIENT.DAT file

Data

Source or Value

Dissolved N in runoff by land cover

Default values/adjusted using GWLF Manual

Dissolved P in runoff by land cover

Default values/adjusted using GWLF Manual

N/P concentrations in manure runoff

Default values/adjusted using AEU density

N/P buildup in urban areas

Default values (from GWLF Manual)

N and P point source loads

Derived from SPDES point coverage

Background N/P concentrations in

Derived from new background N map

Background P concentrations in soil

Derived from soil P loading map/adjusted using
GWLF Manual

Background N concentrations in soil

Based on map in GWLF Manual

Months of manure spreading

Input by user

Population on septic systems

Derived from census tract maps for 2000 and
house

Per capita septic system loads (N/P)

Default values/adjusted using AEU density

52


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Land Use

The 2001 NLCD land use coverage was obtained, recoded, and formatted specifically
for use in MapShed. The New York State High Resolution Digital Orthoimagery (for the
time period 2003 -2005) was used to perform updates and corrections to the 2001 NLCD
land use coverage to more accurately reflect current conditions. Each basin was
reviewed independently for the potential need for land use corrections; however
individual raster errors associated with inherent imperfections in the satellite imagery
have a far greater impact on overall basin land use percentages when evaluating smaller
scale basins. As a result, for large basins, NLCD 2001 is generally considered adequate,
while in smaller basins, errors were more closely assessed and corrected. The
following were the most common types of corrections applied generally to smaller basins:

1)	Areas of low intensity development that were coded in the 2001 NLCD as other land
use types were the most commonly corrected land use data in this analysis.
Discretion was used when applying corrections, as some overlap of land use pixels
on the lake boundary are inevitable due to the inherent variability in the aerial position
of the sensor creating the image. If significant new development was apparent (i.e.,
on the orthoimagery), but was not coded as such in the 2001 NLCD, than these
areas were re-coded to low intensity development.

2)	Areas of water that were coded as land (and vice-versa) were also corrected.
Discretion was used for reservoirs where water level fluctuation could account for
errors between orthoimagery and land use.

3)	Forested areas that were coded as row crops/pasture areas (and vice-versa) were
also corrected. For this correction, 100% error in the pixel must exist (e.g., the
supposed forest must be completely pastured to make a change); otherwise, making
changes would be too subjective. Conversions between forest types (e.g., conifer
to deciduous) are too subjective and therefore not attempted; conversions between
row crops and pasture are also too subjective due to the practice of crop rotation.
Correction of row crops to hay and pasture based on orthoimagery were therefore not
undertaken in this analysis.

In addition to the corrections described above, low and high intensity development land
uses were further refined for some lakes to differentiate between low, medium, and high
density residential; and low, medium, and high density mixed urban areas. These
distinctions were based primarily upon the impervious surface coverage and residential
or mixed commercial land uses. The following types of refinements were the focus of the
land use revision efforts:

1) Areas of residential development were identified. Discretion was used in the
reclassification of small forested patches embedded within residential areas. Care
was taken to maintain the "forest" classification for significant patches of forest
within urban areas (e.g. parks, large forested lots within low-density residential
areas). Individual trees (or small groups of trees) within residential areas were
reclassified to match the surrounding urban classification, in accordance with the land
use classifications described in the MapShed manual. Areas identified as lawn
grasses surrounding residential structures were reclassified to match the
surrounding urban classification, in accordance with the land use classifications in the

53


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MapShed manual.

2)	Areas of medium-density mixed development were identified. Discretion was used
during the interpretation and reclassification of urban areas, based on the land use
classification definitions in the MapShed manual. When appropriate, pixels were
also reclassified as "low" or "high" density mixed development.

3)	Golf courses were identified and classified appropriately.

Total phosphorus concentrations in runoff from the different urban land uses was
acquired from the National Stormwater Quality Database (Pitt, et al., 2008). These data
were used to adjust the model's default phosphorus accumulation rates. These
adjustments were made using best professional judgment based on examination of
specific watershed characteristics and conditions.

Phosphorus retention in wetlands and open waters in the basin can be accounted for in
MapShed. MapShed recommends the following coefficients for wetlands and pond
retention in the northeast: nitrogen (0.12), phosphorus (0.25), and sediment (0.90).
Wetland retention coefficients for large, naturally occurring wetlands vary greatly in the
available literature. Depending on the type, size and quantity of wetland observed, the
overall impact of the wetland retention routine on the original watershed loading
estimates, and local information regarding the impact of wetlands on watershed loads,
wetland retention coefficients defaults were adjusted accordingly. The percentage of the
watershed area that drains through a wetland area was calculated and used in
conjunction with nutrient retention coefficients in MapShed. To determine the percent
wetland area, the total basin land use area was derived using ArcView. Of this total basin
area, the area that drains through emergent and woody wetlands were delineated to yield
an estimate of total watershed area draining through wetland areas. If a basin displays
large areas of surface water (ponds) aside from the water body being modeled, then this
open water area is calculated by subtracting the water body area from the total surface
water area.

On-site Wastewater Treatment Systems ("septic tanks")

MapShed, following the method from GWLF, simulates nutrient loads from septic
systems as a function of the percentage of the unsewered population served by normally
functioning vs. three types of malfunctioning systems: ponded, short-circuited, and direct
discharge (Haith et al., 1992).

•	Normal Systems are septic systems whose construction and operation
conforms to recommended procedures, such as those suggested by the EPA design
manual for on-site wastewater disposal systems. Effluent from normal systems
infiltrates into the soil and enters the shallow saturated zone. Phosphates in the
effluent are adsorbed and retained by the soil and hence normal systems provide
no phosphorus loads to nearby waters.

•	Short-Circuited Systems are located close enough to surface water (~15 meters)
so that negligible adsorption of phosphorus takes place. The only nutrient removal
mechanism is plant uptake. Therefore, these systems are always contributing to
nearby waters.

54


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• Ponded Systems exhibit hydraulic malfunctioning of the tank's absorption field and
resulting surfacing of the effluent. Unless the surfaced effluent freezes, ponding
systems deliver their nutrient loads to surface waters in the same month that they
are generated through overland flow. If the temperature is below freezing, the
surfacing is assumed to freeze in a thin layer at the ground surface. The accumulated
frozen effluent melts when the snowpack disappears and the temperature is above
freezing.

Direct Discharge Systems illegally discharge septic tank effluent directly into
surface waters.

MapShed requires an estimation of population served by septic systems to generate
septic system phosphorus loadings. In reviewing the orthoimagery for the lake, it
became apparent that septic system estimates from the 1990 census were not reflective
of actual population in close proximity to the shore. Shoreline dwellings immediately
surrounding the lake account for a substantial portion of the nutrient loading to the lake.
Therefore, the estimated number of septic systems in the watershed was refined using a
combination of 1990 and 2000 census data and GIS analysis of orthoimagery to account
for the proximity of septic systems immediately surrounding the lake. If available, local
information about the number of houses within 250 feet of the lakes was obtained and
applied. Great attention was given to estimating septic systems within 250 feet of the lake
(those most likely to have an impact on the lake). To convert the estimated number of
septic systems to population served, an average household size of 2.61 people per
dwelling was used based on the circa 2000 USCB census estimate for number of persons
per household in New York State.

MapShed also requires an estimate of the number of normal and malfunctioning septic
systems. This information was not readily available for the lake. Therefore, several
assumptions were made to categorize the systems according to their performance.
These assumptions are based on data from local and national studies (Day, 2001;
USEPA, 2002) in combination with best professional judgment. To account for
seasonal variations in population, data from the 2000 census were used to estimate the
percentage of seasonal homes for the town(s) surrounding the lake. The failure rate for
septic systems closer to the lake (i.e., within 250 feet) were adjusted to account for
increased loads due to greater occupancy during the summer months. If available, local
information about seasonal occupancy was obtained and applied. For the purposes of
this analysis, seasonal homes are considered those occupied only during the month of
June, July, and August.

Groundwater Phosphorus

Phosphorus concentrations in groundwater discharge are derived by MapShed.
Watersheds with a high percentage of forested land will have low groundwater
phosphorus concentrations while watersheds with a high percentage of agricultural land
will have high concentrations. The GWLF manual provides estimated groundwater
phosphorus concentrations according to land use for the eastern United States.
Completely forested watersheds have values of 0.006 mg/L. Primarily agricultural
watersheds have values of 0.104 mg/L. Intermediate values are also reported. The

55


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MapShed -generated groundwater phosphorus concentration was evaluated to ensure
groundwater phosphorus values reasonably reflect the actual land use composition of the
watershed and modifications were made if deemed unnecessary.

Point Sources

Permitted point sources in the watershed were identified and verified by NYS DEC and
an estimated monthly total phosphorus load and flow was determined using SPDES
permitted design flow.

Municipal Separate Storm Sewer Systems (MS4s)

Stormwater runoff within Phase II permitted Municipal Separate Storm Sewer Systems
(MS4s) is considered a point source of pollutants. Stormwater runoff outside of the
MS4 is non-permitted stormwater runoff and, therefore, considered nonpoint sources of
pollutants. Permitted stormwater runoff is accounted for in the wasteload allocation of a
TMDL, while non-permitted runoff is accounted for in the load allocation of a TMDL.

MapShed Model Simulation Files:

Transport Data Editor

Urban Land

LD Mixed

Area (ha)

:669

%lmp CNI

; 015 j92

CNP

74 "





Month

Ket

Adjust
XET

Day
Hours

Glow

Seas

Eros
Coef

Stream
1 Htrant

Ground
Extract

IvjD Mixed

10

So.o

•0

.0





j Jan

10.7

h.o

lG.8

•0

,0.18'

|0.0

io.o

HD Mixed

|44

•0.87

i 98

79





Feb

;o.?6

'1.0

[8.9

jo

'018

joo

io.o

LD Residential

1151

(0.15

192

74





i Mar

10.73

h.o

jll.5

10

•0 28

10.0

jo.o

MD Residential

;o"

io.o"

io

,0





\ Apr

10.92

hjo

j14J

1

,0.28

[0.0

joo

HD Residential

icf "

;0.0

! 0

0





I 1

h.o'

11.04

iio
11.0

jl66
117.8

1
:1

jO.28
'0.28

:0 0

ioo

joo
io.o

Rural Land

Area (ha)

CN

K

LS

c

p

Jul

i1.06

|1.0

'17 2

ii

0.28

0 0

joo

Hay/Pasture

jo

Io"

j'o 0

'0.0

(o.o

'o.o

i Aug

ii.08 '

il.O

115'T

,1""

;b 28'

Too

fdo"

Cropland

10

0

10.0

:o.o

!oo

'o.o

! Sep

•1.09 "

h.o

j12 5

,V

•018

jo.o

joo

Forest

|2210

'73

0 224

i!1.639

JO 002

0 52

i Oct

10.98

Il.O

19.7

,0

0.18

>0.0

jO.O "

Wetland

194' '

87

i0 224

:d.305''

|0.01"

]01"

Nov

i0 92

H.o

I7.4

io

:o.18

joo

io.o

Disturbed

!0

0

!ao

,0.0

i0 0~

:o.o"

i Dec

jO. 88

!i.o

SG.2

j0

,0.18

:o.o

ioo

Turf/Golf

10

io

,'o.o

;o.o

ioo

'o.6

















Open Land
Bare Rock
Sandy Areas
Unpaved Road

io

io

10

io'

•0

'o

,0
,0

jo.o

{0.0
•0 0
jo.o'

jo.o'

;0.0
0.0
sO.O

'0 0

jo.o

!0.0
i'o.o

•oo

,0.0

'o.o

'0.0 '

Sediment A Factor 1 4107E-03
Sed A Adjustment 1.0
Avail Water Cap (cm) 3.038

Values 0 -1

GW Recess Coeff 0 06
GW Seepage Coeff 0 0
X Tile Drained (Ag) 0 0

Sed Delivery Ratio

'0156

Save File I xi«nt In .111 ii

Uuse

56


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Nutrient Data Editor

Dissolved Runoff Coefficients (mg/L)

Rural Runoff C SS3 N D ssive: F

Nitrogen and Phosphorus Loads from Point Sources and Septic Systems

- Point Source Loads/Discharge-

- Septic System Populations ^





j0



Month

kg N

K3 F

vec





S'« c»



Hay/Pasture

.0.0



Jan



!0.026





[304

		

io





'0.0

3.08

[8759

<78

|o

Cropland

!o











>8759

	



Forest

¦0.19

;0.01



Feb

=0.0 ' '

2.78

; 0.026"

78

i304

|o















Wetland

, 0.19

0.01



Mar

so.o

3.08

'0.026

,8759

!78

i304

io

Disturbed

;0

.0



Apr

• 0.0

2.98

10.026™

¦8759

;78

,304'

io

Turf/Golf

io

0.095 "

16.015

•0 33

[0.0095 i 0.0021

¦0.4

[2.

8

!o.

MD Mixed

|0



io

'c

;o

lb

0

,'o'

io



;o

HD Mixed

144



50.11

10.015

10.33

; 0.0115 ;0 0021

!0.4

12.

8

;o.

LD Residential

jl51



|0.095

0.015

To. 28

i 0.0095 10.0019

10.37

[2.

5

ii.

MD Residential

i'o



So

>0

0

|o

_ l°

'o

[0



io"

HD Residential

lo



I'o

0

>0

io

|o

;0"

[0



i'o







Sav

e File

Export to JPEG:

Close |









57


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APPENDIX B. BATHTUB MODELING ANALYSIS

Model Overview

BATHTUB is a steady-state (Windows-based) water quality model developed by the
U. S. Army Corps of Engineers (USACOE) Waterways Experimental Station.
BATHTUB performs steady- state water and nutrient balance calculations for spatially
segmented hydraulic networks in order to simulate eutrophication-related water quality
conditions in lakes and reservoirs. BATHTUB'S nutrient balance procedure assumes
that the net accumulation of nutrients in a lake is the difference between nutrient loadings
into the lake (from various sources) and the nutrients carried out through outflow and the
losses of nutrients through whatever decay process occurs inside the lake. The net
accumulation (of phosphorus) in the lake is calculated using the following equation:

Net accumulation = Inflow - Outflow - Decay

The pollutant dynamics in the lake are assumed to be at a steady state, therefore, the
net accumulation of phosphorus in the lake equals zero. BATHTUB accounts for
advective and diffusive transport, as well as nutrient sedimentation. BATHTUB predicts
eutrophication-related water quality conditions (total phosphorus, total nitrogen,
chlorophyll-a, transparency, and hypolimnetic oxygen depletion) using empirical
relationships derived from assessments of reservoir data. Applications of BATHTUB
are limited to steady-state evaluations of relations between nutrient loading,
transparency and hydrology, and eutrophication responses. Short-term responses and
effects related to structural modifications or responses to variables other than nutrients
cannot be explicitly evaluated.

Input data requirements for BATHTUB include: physical characteristics of the watershed
lake morphology (e.g., surface area, mean depth, length, mixed layer depth), flow and
nutrient loading from various pollutant sources, precipitation (from nearby weather
station) and phosphorus concentrations in precipitation (measured or estimated), and
measured lake water quality data (e.g., total phosphorus concentrations).

The empirical models implemented in BATHTUB are mathematical generalizations about
lake behavior. When applied to data from a particular lake, actual observed lake water
quality data may differ from BATHTUB predictions by a factor of two or more. Such
differences reflect data limitations (measurement or estimation errors in the average
inflow and outflow concentrations) or the unique features of a particular lake (no two
lakes are the same). BATHTUB'S "calibration factor" provides model users with a
method to calibrate the magnitude of predicted lake response. The model calibrated to
current conditions (against measured data from the lakes) can be applied to predict
changes in lake conditions likely to result from specific management scenarios, under
the condition that the calibration factor remains constant for all prediction scenarios.

Model Set-up

Using descriptive information about Lake Carmel and its surrounding drainage area,
as well as output from MapShed, a BATHTUB model was set up for Lake Carmel. Mean

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annual phosphorus loading to the lake was simulated using MapShed for the period
1990-2004. After initial model development, NYS DEC sampling data were used to
assess the model's predictive capabilities and, if necessary, "fine tune" various input
parameters and sub-model selections within BATHTUB during a calibration process.
Once calibrated, BATHTUB was used to derive the total phosphorus load reduction
needed in order to achieve the TMDL target.

Sources of input data for BATHTUB
include:

•	Physical characteristics of the watershed and lake morphology (e.g., surface area,
mean depth, length, mixed layer depth) - Obtained from CSLAP and bathymetric
maps provided by NYS DEC or created by the Cadmus Group, Inc.

•	Flow and nutrient loading from various pollutant sources - Obtained from MapShed
output.

•	Precipitation - Obtained from nearby National Weather Services
Stations.

•	Phosphorus concentrations in precipitation (measured or estimated), and measured
lake water quality data (e.g., total phosphorus concentrations) - Obtained from NYS
DEC.

Tables 9-12 summarize the primary model inputs for Lake Carmel. Default model
choices are utilized unless otherwise noted. Spatial variations (i.e., longitudinal
dispersion) in phosphorus concentrations are not a factor in the development of the
TMDL for Lake Carmel. Therefore, division of the lake into multiple segments was not
necessary for this modeling effort. Modeling the entire lake with one segment provides
predictions of area-weighted mean concentrations, which are adequate to support
management decisions. Water inflow and nutrient loads from the lake's watershed were
treated as though they originated from one "tributary" (i.e., source) in BATHTUB and
derived from MapShed.

BATHTUB is a steady state model, whose predictions represent concentrations
averaged over a period of time. A key decision in the application of BATHTUB is the
selection of the length of time over which water and mass balance calculations are
modeled (the "averaging period"). The length of the appropriate averaging period for
BATHTUB application depends upon what is called the nutrient residence time, which is
the average length of time that phosphorus spends in the water column before settling or
flushing out of the lake. Guidance for BATHTUB recommends that the averaging period
used for the analysis be at least twice as large as nutrient residence time for the lake. The
appropriate averaging period for water and mass balance calculations would be 1 year
for lakes with relatively long nutrient residence times or seasonal (6 months) for lakes
with relatively short nutrient residence times (e.g., on the order of 1 to 3 months). The
turnover ratio can be used as a guide for selecting the appropriate averaging period. A
seasonal averaging period (April/May through September) is usually appropriate if it
results in a turnover ratio exceeding 2.0. An annual averaging period may be used
otherwise. Other considerations (such as comparisons of observed and predicted
nutrient levels) can also be used as a basis for selecting an appropriate averaging
period, particularly if the turnover ratio is near 2.0.

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Precipitation inputs were taken from the observed long term mean daily total precipitation
values from the Stormville, NY and Yorktown, NY National Weather Service Stations for
the 1990-2013 period. Evapotranspiration was derived from MapShed using daily weather
data (1990-2013) and a cover factor dependent upon land use/cover type. The values
selected for precipitation and change in lake storage have very little influence on model
predictions. Atmospheric phosphorus loads were specified using data collected by NYS
DEC from the Moss Lake Atmospheric Deposition Station located in Herkimer County,
NY. Atmospheric deposition is not a major source of phosphorus loading to Lake
Carmel and has little impact on simulations.

Lake surface area, mean depth, and length were derived using GIS analysis of
bathymetric data. Depth of the mixed layer was estimated using a multivariate
regression equation developed by Walker (1996). Existing water quality conditions in
Lake Carmel were represented using the average observed summer mean phosphorus
concentration for the years 1986-1990, and 2013. These data were collected through
CSLAP (1986-1990) and NYSDEC (2013). The concentration of phosphorus loading to
the lake was calculated using the average annual flow and phosphorus loads simulated
by MapShed. To obtain flow in units of volume per time, the depth of flow was multiplied
by the drainage area and divided by one year. To obtain phosphorus concentrations, the
nutrient mass was divided by the volume of flow.

Internal loading rates reflect nutrient recycling from bottom sediments. Internal loading
rates are normally set to zero in BATHTUB since the pre-calibrated nutrient retention
models already account for nutrient recycling that would normally occur (Walker,
1999). Walker warns that nonzerovalues should be specified with caution and
only if independent estimates or measurements are available. In some studies,
internal loading rates have been estimated from measured phosphorus accumulation in
the hypolimnion during the stratified period. Results from this procedure should not be
used for estimation of internal loading in BATHTUB unless there is evidence the
accumulated phosphorus is transported to the mixed layer during the growing season.
Specification of a fixed internal loading rate may be unrealistic for evaluating response to
changes in external load. Because they reflect recycling of phosphorus that originally
entered the reservoir from the watershed, internal loading rates would be expected to
vary with external load. In situations where monitoring data indicate relatively high
internal recycling rates to the mixed layer during the growing season, a preferred
approach would generally be to calibrate the phosphorus sedimentation rate (i.e., specify
calibration factors < 1). However, there still remains some risk that apparent internal
loads actually reflect under-estimation of external loads.

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Table 9: BATHTUB Model Input Variables: Model Selections

Water Quality Indicator

Option

Description |

Total Phosphorus |

0

2nd Order Settling Velocity*

Phosphorus Calibration

01

Decay Rate*

Error Analysis

0

Model and Data*

Availability Factors

00

Ignore*

Mass Balance Tables

0

Use Estimated Concentrations*

* Default model choice

Table 10: BATHTUB Model Input: Global Variables

Model Input

Mean

CV

Averaging Period (years) |

0.5

NA

Precipitation (meters)

0.65

0.2*

Evaporation (meters)

0.263

0.3*

Atmospheric Load (mg/m2-yr)- Total P

4.87

0.5*

Atmospheric Load (mg/m2-yr)- Ortho P

2.61

0.5*

* Default model choice

Table 11: BATHTUB Model Input: Lake Variables

Morphometry

Mean

CV

Surface Area (km2)

0.75

NA

Mean Depth (m)

2.27

NA

Length (km)

2.16

NA

Estimated Mixed Depth (m)

2.27

0.12

Observed Water Quality

| Mean

CV

Total Phosphorus (ppb)

39.3

0.5

* Default model choice

Table 12: BATHTUB Model Input: Watershed "Tributary" Loading

Monitored

Mean

CV

Total Watershed Area (km2)

32.9

NA

Flow Rate (hm3/yr)

23.33

0.1

Total P (ppb)

37.6

0.2

Organic P (ppb)

18.01

0.2

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Model Calibration

BATHTUB model calibration consists
of:

1.	Applying the model with all inputs specified as above

2.	Comparing model results to observed phosphorus data

3.	Adjusting model coefficients to provide the best comparison between model
predictions and observed phosphorus data (only if absolutely required and with
extreme caution.

Several t-statistics calculated by BATHTUB provide statistical comparison of
observed and predicted concentrations and can be used to guide calibration of
BATHTUB. Two statistics supplied by the model, T2 and T3, aid in testing model
applicability. T2 is based on error typical of model development data set. T3 is based on
observed and predicted error, taking into consideration model inputs and inherent model
error. These statistics indicate whether the means differ significantly at the 95%
confidence level. If their absolute values exceed 2, the model may not be appropriately
calibrated. The T1 statistic can be used to determine whether additional calibration is
desirable. The t-statistics for the BATHUB simulations for Lake Carmel are as follows:

Table 13: BATHTUB Model T-Statistics

Year

Observed

Simulated

T1

T2

T3

1986

33.0

34



-0.11

-0.33

1987

56.6

33



2.06

6.46

1988

22.8

36



-1.72

-5.06

1989

38.9

33



0.60

2.01

1990

34.4

33



0.14

0.48

2013

63.4

31



2.62

9.09

28 yr average

41.5

39



0.07

0.21

In cases where predicted and observed values differ significantly, calibration coefficients
can be adjusted to account for the site-specific application of the model. Calibration to
account for model error is often appropriate. However, Walker (1996) recommends a
conservative approach to calibration since differences can result from factors such as
measurement error and random data input errors. Error statistics calculated by
BATHTUB indicate that the match between simulated and observed mean annual water
quality conditions in Lake Carmel is quite good for 1986 and 1990, fairly good for 1988
and 1989 and moderately accurate for 1987 and 2013.

In average, BATHTUB is sufficiently calibrated for use in estimating load reductions
required to achieve the phosphorus TMDL target in the lake.

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APPENDIX C. TOTAL EQUIVALENT DAILY PHOSPHORUS LOAD ALLOCATIONS

Stream Bank Erosion

Current Allocated Reduction % Reduction

2.428

1.310

1.119

46%

Wetlanc

0.017

0.017

0

0

Foresl

0.312

0.312

0

0

Groundwatei

1.108

1.108

0

0

Septic Systems

1.682

0

1.682

100%

Internal Loading

1.400

0

1.400

100%

LOAD ALLOCATION TOTAL

6.947

2.746

4.201

40%

WWTF: Girl Scouts Heart of Hudsor
SPDES # NY0102181

0.014

0.005

0.009

60%

WWTF: Putnam Nursing and Rehabilitation

SPDES # NY0028924

0.167

0.033

0.133

80%

WWTF: Frangel Realty
SPDES# NY143863

0.025

0

0.025

100%

MS4 Developed Land: T/Kent NYR20A346,
T/Patterson NYR20A140, T/Pawling
NYR20A472, T/Beekman NYR20A365,
TIE. Fishkill, NYR20A183

0.276

0.248

0.028

10%

WASTELOAD ALLOCATION TOTAL

0.481

0.286

0.195

42%

LA + WLA

7.428

3.033

-

-

10% Margin of Safety

-

0.337

-

-

TOTAL

7.428

3.370

4.396

59%

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