2.6.1. Description and Significance
Fecal bacteria, wastewater treatment, and the Clean Water Act
Fecal coliform bacteria are natural components of digestive systems of birds and mammals. They aid in digestion, and most strains are not harmful. In fact, sewage wastewater has been used to fertilize crops and replenish nutrients from depleted soils since ancient times (Shuval et al. 1990). But due to discoveries that sewage wastewater spreads disease, sewage wastewater is treated and released back into natural waters.
Over the last four decades, the standards for sewage treatment have become ever more stringent, particularly with the passage of the clean water act in 1977. As the EPA website notes:
Growing public awareness and concern for controlling water pollution led to enactment of the Federal Water Pollution Control Act Amendments of 1972. As amended in 1977, this law became commonly known as the Clean Water Act. The Act established the basic structure for regulating discharges of pollutants into the waters of the United States. It gave EPA the authority to implement pollution control programs such as setting wastewater standards for industry. The Clean Water Act also continued requirements to set water quality standards for all contaminants in surface waters (EPA 2008).
This law required the nation’s publicly owned sewer systems to remove 90% of the solid matter, and to disinfect the effluent (Shabecoff 1988), which was usually done with chlorine, to protect streams and rivers. The COJ passed Environmental Protection Board (EPB) Rule 3 to improve water quality in Duval County (1987), which led to a phase-out of the existing but less reliable local wastewater treatment plants, many of which were unable to meet the higher standards. Consolidation into larger regional treatment plants helped meet the higher standards.
Fecal coliform as indicator organisms
Measurement of the effectiveness of wastewater treatment has historically involved the measurement of fecal coliform bacteria, among other water quality parameters. Fecal coliform bacteria are essentially indicator organisms that provide evidence of whether human waste and therefore associated pathogens, such as bacteria and viruses, are being sufficiently removed by wastewater treatment. Relatively few coliform bacteria are pathogenic themselves. One shortcoming of using fecal coliform bacteria as an indicator of wastewater treatment is that some species of fecal coliform bacteria can grow and multiply in sediment long after the initial wastewater discharge occurred (Anderson et al. 2005), so a high fecal coliform reading may not indicate an active, current discharge of untreated wastewater.
Sources of fecal coliform bacteria in natural waters include wastewater treatment facility outflows, but these are only one type of many sources. Fecal coliform bacteria reach the river from natural sources such as wildlife. Other sources include sanitary sewer overflows, domestic animal and pet contamination, human contamination from failing septic tanks, runoff, and agricultural wastes from intensive animal farming and pasturelands. Wastewater outflows and sanitary sewer overflows are often called point sources because large amounts of waste can enter the river or tributary at a single point such as an outfall pipe. Nonpoint sources, in contrast, such as runoff after rain, enter the watershed from a broad area.
Fecal coliform criteria for recreational waterbodies
The mainstem and tributaries of the LSJR are designated as Class III recreational waters, suitable for ‘fish consumption, recreation, propagation and maintenance of a healthy, well-balanced population of fish and wildlife.’ Until recently, the Florida fecal coliform exceedance criteria standards for recreational waters stated that fecal coliform counts (CFU) per 100 mL should adhere to all three of the following:
- not exceed a monthly average of 200 (requires 10 samples in a 30-day period)
- not exceed 400 in 10% of samples
- not exceed 800 on any one day
These fecal coliform criteria for recreational water quality were based on 1976 EPA recommendations (EPA 1976), which were based on studies that found an increase in gastrointestinal illnesses after swimming in waterways that had about 400 coliform bacteria or more per 100 milliliters of water (EPA 1986). For protective measures, the number was halved to 200 fecal coliform bacteria per 100 milliliters as a threshold value for the monthly average value in the criteria. In 1986, based on additional studies, the EPA shifted away from fecal coliform to recommending that E. coli and enterococci be used as the indicator organisms for human sewage (EPA 1986) and in 2012 the USEPA refined the 1986 recommendations for using E. coli and enterococci (EPA 2012a). The FDEP has recently changed standards to fit the 2012 recommendations (see below).
The focus on tributaries of the LSJR
Under the FDEP “River-at-a-Glance” program through 2008, the mainstem of the LSJR (at several sites from Welaka to Arlington (in Jacksonville), was found to be largely in compliance for fecal coliform (Appendix 2.6.1). Since the tributaries were largely not in compliance, and the mainstem was in compliance, the sampling of the mainstem was discontinued and the focus became the tributaries, which is the focus of the rest of this section.
2.6.2. Current Status
Status Rating: Unsatisfactory
Trend Rating: Conditions Unchanged
Seventy-five tributaries are impaired for fecal coliform (FDEP 2016). Of these, thirty-six tributaries have final TMDLs for fecal coliform, and fecal coliform BMAPs are in place for twenty-five of them (Table 2.1).
Table 2.1 LSJRB Tributaries with final fecal coliform TMDLs. Tributaries with BMAPs are indicated in bold.
|Big Davis Creek||Craig Creek||Greene Creek||Little Black Creek||Newcastle Creek||Sherman Creek|
|Big Fishweir Creek||Deep Bottom Creek||Greenfield Creek||McCoy Creek||Open Creek||Strawberry Creek|
|Block House Creek||Deer Creek||Grog Branch||Mill Creek||Ortega River||Terrapin Creek|
|Butcher Pen Creek||Durbin Creek||Hogan Creek||Miller Creek||Peters Creek||Trout River (Middle and Lower)|
|Cedar River||Fishing Creek||Hopkins Creek||Miramar Creek||Pottsburg Creek||Wills Branch|
|Cormorant Branch||Goodbys Creek||Julington Creek||Moncrief Creek||Ribault River||Williamson Creek|
Percent exceedances are far from goals
As noted above, Florida statute has required that monthly averages must be calculated from at least 10 samples per 30 days. However, most impaired tributaries do not undergo fecal coliform testing that frequently. Therefore, the criterion stating that no more than 10% of samples may exceed 400 CFU/100 mL (criterion #2 above) is the metric being used by the FDEP to assess improvement. The goal is to have no more than 10% of the samples for each tributary be more than 400 fecal coliform per 100 milliliters. No tributary has reached this goal, and most are not even close (Table 2.2A), with 23% exceedance as the lowest value, and 95% as the highest value for the most recent 7.5-year period (2010-2017). When comparing the three most recent 7.5-year averages (Table 2.2A), 21 of the tributaries show no substantial changes in percent exceedances, and 2 of the tributaries have increased by more than 10 percentage points (Table 2.2A; pink). Some progress has been made in Miramar, and Deep Bottom Creeks, which have exceedance percentages that have decreased 10 percentage points (Table 2.2A; blue), but are still far from compliance.
Magnitude of exceedances are far from goals but have made progress
While the percent exceedances for the majority of the tributaries have made no progress in declining, there has been considerable success in bringing down the magnitude of the exceedances when the 1996-2003 and 2010-2014 data sets are compared (last two columns in Table 2.2A). Ideally, the fecal coliform counts will continue to decrease to where the tributaries are no longer exceeding the 10% percent exceedance maximum as well as the single day criterion (criterion #3 above) of 800 fecal coliform on any day.
Table 2.2A Fecal coliform exceedances of LSJRB Tributaries. Percent exceedances show 7.5-year rolling averages for the last four periods, with the most recent time-period in bold. Pink indicates tributaries whose exceedances increased by at least 10 percentage points and light blue indicates tributaries that have decreased by at least 10 percentage points when comparing the first time-period to the last time-period. Exceedance median shows the magnitude of exceedances for two separate time-periods (TMDL period is 1996-2003; BMAP period is 2010-2014).
2.6.3. Progress and Outlook
BMAPs, Walk the WBID, and activities to address fecal coliform exceedances
Generally, Basin Management Action Plans (BMAPs) lay out projects and plans intended to reduce loading of the identified pollutant, to be executed by the key responsible parties. For fecal coliform BMAPs in this set of 25 tributaries, the responsible parties are COJ, JEA, the Florida Department of Transportation, the Florida Department of Health, Naval Station Mayport, and other relevant municipalities including the Cities of Atlantic Beach, Jacksonville Beach, and Neptune Beach. FDEP also plays a role in implementation of BMAP projects. For these 25 tributaries, a coordinating body called the Tributaries Assessment Team organizes these groups in terms of information review and taking next steps.
Because the primary sources of fecal coliform are stormwater, wastewater, and septic tanks, the projects undertaken to reduce fecal coliform usually address these types of water streams. Examples of projects undertaken to reduce fecal coliform include wastewater infrastructure and treatment improvements, construction of stormwater retention ponds, removal of illicit wastewater connections to waterbodies, and septic tank phase-out and replacement by connection to municipal sewage services. Dozens of projects on these tributaries have been completed since the start of these BMAPs.
Yet, despite these projects, many of which have certainly decreased the amount of human waste entering the watershed, the above results indicate that the tributaries remain significantly impaired for fecal coliform. Stakeholders have conducted an intensive effort to investigate sources of fecal coliform. For the Tributaries I group, Maps on the Table (MOT) and Walk the WBID (WTW) exercises were conducted in 2014. MOT is a process by which stakeholders with local knowledge of the WBID (water body) meet and review a map of the WBID to identify possible sources and issues needing further study. These were followed by WTW days, in which stakeholders actually hike along the banks of the water body to observe and note potential problem areas. After these events, follow-up activities were identified, and both long-term and short-term solutions to this problem are being sought. The Tributaries II group was examined by slightly scaled-back MOT and WTW exercises in April 2015 by a coordinated inter-agency effort. During these walks, a few short-term issues were discovered and quickly addressed by the appropriate agency. Future long-term efforts generally involve maintenance activities, modified or expanded inspections, educational outreach, and basin-specific cleanup strategies.
Rule changes: Switching from fecal coliform testing to E. coli and enterococcus testing
As explained above, Florida’s fecal coliform criteria are based on 1976 USEPA recommendations, which have since been updated twice by the USEPA. Recently, new bacteria criteria to replace the fecal coliform standards were developed by FDEP. These criteria adopt Recreational Water Quality Criterion (RWQC) promulgated by U.S. EPA in 2012 (EPA 2012b). This new RWQC is specific for E. coli and enterococci, rather than fecal coliform, a broader class of organisms. It was found that enterococci and E. coli are superior indicators of fecal contamination than simply fecal coliform, because a) the correlation between swimmer disease and bacteria levels is stronger for these specific bacteria than for the larger class of fecal coliform bacteria (EPA 2012a), and b) fecal coliform testing can also measure the presence of some bacteria that did not come from feces (Jin et al. 2004). E. coli will now be used for fresh waters, and enterococci will be used for saline waters.
Recent data for 10 tributaries using these new criteria are compared to data for the old criteria (Table 2.2B). Percent exceedances of fecal indicator bacteria using the new criteria are noticeably lower for 7 of the tributaries and higher for 2 of the tributaries compared to the larger fecal coliform data set (Table 2.2B). Future editions of this Report will expand on these new criteria as Florida incorporates them and as more data on E. coli and enterococci come available.
Table 2.2B Fecal coliform exceedances compared to E. coli and enterococci exceedances. Percent exceedances for old criteria encompass 1/1/2010 – 6/30/2017, and for new criteria are from 2016 and 2017 only. Pink indicates tributaries whose exceedances are at least 20 percentage points greater and light blue indicates tributaries whose exceedances are at least 20 percentage points lower when comparing the new criteria to the old criteria.
Since human waste has a higher health risk than wildlife, livestock, and pet wastes, FDEP and COJ have begun investigating human contributions to fecal coliform populations. This approach seeks to determine whether or not the source of the bacteria is human, using a technique called qPCR (quantitative polymerase chain reaction) to measure genetic signatures from human bacteria. FDEP also analyzes samples for sucralose and acetaminophen, to narrow down whether human sources are from a variety of human waste sources or specifically from septic tanks.
Sucralose, an artificial sweetener with common trade name Splenda, is not broken down by the body or by wastewater treatment. Therefore, the presence of sucralose in waterways indicates that the water being analyzed includes some type of wastewater effluent (septic tanks or from wastewater treatment plants), either treated or not. In contrast, most acetaminophen, a pain reliever often trade-named Tylenol, is removed from wastewater during treatment processes (septic tank or sanitary wastewater), so high concentrations of acetaminophen in a water sample indicates a recent raw human wastewater source.
By combining the results of the different analyses, scientists can begin to determine whether the fecal coliform bacteria in a tributary are from humans or not, whether they are from treated or untreated sewage, and whether the introduction of the fecal coliform bacteria into the waterway was recent or not. For example, if a water sample has high levels of fecal coliform, high levels of human bacteria as assessed by qPCR, and high levels of acetaminophen, then raw human wastewater is suspected, so the source must be determined and remedied. If a water sample has high levels of fecal coliform, but low levels of human bacteria as assessed by qPCR, and low levels of acetaminophen, then raw human wastewater is not suspected. In this case, the water body may not be a priority, as the source of the fecal coliform may be from wildlife, or the fecal coliform may have come from humans in the past, but is now just growing and living in the tributaries, with no associated human pathogens present, and thus is not an indication of a health risk.
This approach is much more complicated than explained here, and can include the analysis of sediments to check for fecal coliforms growing on their own as opposed to more recent introduction by human waste. These tracking methods hold much promise for determining why the tributaries continue to have such high levels of fecal coliform.
An intensive pilot study to track down the sources of human waste
Using the new tools described above, an intensive pilot study was carried out by the FDEP in collaboration with municipalities in 2017 (DEP 2018b). Hopkins Creek, Miller Creek, and Butcher Pen Creek were part of the study that also included waterbodies at other locations across the state. The goal was to narrow down sources of the fecal bacteria in each water body, which is difficult for many reasons, including underground locations of many sewage pipes. Sources for Miller Creek and Hopkins were identified, but these may not be the only sources. A prioritization tool is being developed by FDEP using the results of this study. FEDP will take samples from every fecal-impaired WBID that has a BMAP, analyze them using the suite of new tools, and these results will then be analyzed with the prioritization tool to help determine which waterbodies to focus on.
Fecal bacteria are a significant problem in the tributaries of the LSJRB, and considerable effort is being made to remedy this problem by way of the state TMDL and BMAP processes. Many tributaries with elevated fecal coliform levels have undergone large reductions, which is an encouraging sign. However, despite making large reductions, actual fecal coliform levels in many tributaries are persistently higher than the current rules for the water quality criteria, and the percent exceedances are very high. Results from the new criteria where E. coli and enterococci are analyzed may be showing lower exceedances in some instances compared to the historic fecal coliform criteria. As agencies obtain more data with the new criteria, implement source tracking, and continue to invest in improving sewage infrastructure, our understanding of fecal bacteria in the LSJRB should become clearer, and reductions in this problem should continue to be made.