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green algae along lakeshore | oregon

Health Canada Releases Draft Guideline Technical Documents

Guidance and Best Management Practices for Harmful Algae Blooms

Vessel General Permit Finalized by EPA

EPA Delivers the RTCR

SprINg 2013

[2] SDWA Newsletter | HDR

RegulAtioNS

the Revised total Coliform Rule (RtCR) has finally landed, with publication in the Federal Register on Feb. 13, 2013 (78 FR 10272). the RtCR applies to all public water systems regardless of size or source water type. While the effective date (when systems must comply) is not until April 1, 2016, utilities need to understand the revisions and prepare for compliance.

the RtCR regulatory development process began back in 2002 when the ePA began collaborating with the drinking water community to develop a group of white papers addressing various distribution system issues. the following year, as part of the six-rear review of regulations, the ePA decided to revise the current tCR to improve the effectiveness of the rule.

Deciding to revise a rule does not mean that the revisions are simple to define. in fact, the regulatory development process included a broad range of stakeholders in a consensus-building effort between 2007 and 2008 to detail the agreement-in-principal that formed the basis for the RtCR. the rule was proposed in 2010 (75 FR 35870), with the final version following early this year.

Major Changes to the TCRthe RtCR establishes a health goal (maximum contaminant level goal, or MClg) and an MCl for E. coli of zero. E. coli is a more specific indicator of fecal contamination and potential harmful pathogens than total coliforms. the RtCR replaces the MClg and MCl for total coliforms with a treatment technique for coliforms that requires assessment and corrective action.

Based on regulatory triggers, systems must conduct assessments that look for any potential problems contributing to total coliform occurrence, including sanitary defects or defects in distribution system coliform monitoring practices. the rule defines a sanitary defect as a “defect that could provide a pathway of entry for microbial contamination into the distribution system or that is indicative of a failure or imminent failure of a barrier that is already in place.” the idea is to find and fix the problem.

treatment triggers for a level 1 assessment are: a) for systems taking 40 or more samples, the system exceeds 5 percent positive total coliform samples in a month, or b) for systems taking less than 40 samples a month, two or more samples are total coliform positive in a month.

A level 1 assessment can be completed by the water system in accordance with state requirements and must be submitted to the state within 30 days of learning that the trigger has been exceeded. Some elements included in the assessment are a review of atypical events that could affect distributed water quality, changes in distribution system operations or maintenance, source and treatment, monitoring data, and sampling sites and protocols.

the assessment has to describe sanitary defects found, corrective actions completed, and a timetable for additional corrective actions that are not done. Note that a sanitary defect has to be found in order to be corrected.

treatment triggers for a level 2 assessment include an E. coli MCl violation, a second level 1 trigger within a rolling 12-month period, or a level 1 trigger in two consecutive years. level 2 assessments must be completed by the state or someone approved by the state. the content of the assessment is similar to a level 1 assessment, but a more extensive investigation and review of available information, both internal and external to the utility, is required.

the nuts and bolts of the assessment forms for both assessment levels are up to the state to develop as part of their application for primacy. A significant change in the RtCR is the elimination of public notification based only on the presence of total coliforms, which serve as an indicator of a potential pathway of contamination into the distribution system but by themselves do not present a public health threat.

EPA Delivers the RTCR By Sarah Clark, P.E.Sarah.Clark@hdrinc.com

[3]www.hdrinc.com

RegulAtioNS

latitude to plan repeat sampling that gives the system improved information about water quality. Sampling plans are subject to review by the state.

What to Do NowBecause each state will develop its own assessment framework and requirements, utilities that want to have an impact on how the RtCR is implemented in their state should get involved in helping to develop the assessment forms through stakeholder processes or other means. Sections of AWWA may have committees that get involved in the local regulatory implementation programs. v

the complete RtCR can be found at http://www.gpo.gov/fdsys/pkg/FR-2013-02-13/pdf/2012-31205.pdf

The drought map speaks for itself, with more than half of the country in dry to extreme drought conditions. Utilities in the western half of the US are highly concerned about the deficit in the snowpack in this second year of drought. Water conservation requirements are already being invoked in many communities.

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The Drought Monitor focuses on broad-scale conditions.Local conditions may vary. See accompanying text summaryfor forecast statements. Released Thursday, April 25, 2013

Author: Eric Luebehusen, U.S. Department of Agriculture

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Drought Impact Types:

S = Short-Term, typically <6 months(e.g. agriculture, grasslands)

L = Long-Term, typically >6 months(e.g. hydrology, ecology)

Delineates dominant impacts

this change should reduce the amount of unnecessary public notification. instead, the RtCR requires public notification when an E. coli MCl violation occurs, indicating a potential health threat, or when a system fails to conduct the required assessment and corrective action.

the RtCR links monitoring frequency to compliance monitoring results and system performance. For reduced monitoring, the RtCR provides criteria that well-operated small systems must meet to qualify for and stay on reduced monitoring.

on the flip side, the RtCR also requires increased monitoring for high-risk small systems with unacceptable compliance histories and mandates some new monitoring requirements for seasonal systems such as state and national parks.

Systems must develop a written sample siting plan by March 31, 2016, that identifies sampling sites and a sample collection schedule that represents water throughout the distribution system. Samples are then supposed to be collected according to the plan.

if a system decides to take additional samples to investigate an issue in the distribution system, they must be included in the calculation for meeting the treatment technique only if the samples are taken in accordance with the sampling plan.

Repeat sample sites must be identified in the sampling plan, but systems can propose alternative locations (other than upstream/downstream) or criteria for selecting alternative locations based on a standard operating procedure that focuses on determining the extent of contamination. this provides some

SDWA Newsletter | HDR[4]

iNvASive SPeCieS CoNtRol

the discharge rate and constituent concentrations of ballast water will vary by vessel type, ballast tank capacity, quality of and constituents contained in the ambient source waters, efficacy of any treatment applied to the discharge of ballast water, type of deballasting equipment, and other factors. volumes of ballast water discharged are significant and can range from several hundred to many thousands of cubic meters of water.

Ballast water discharge has been cited as one of the primary sources (or vectors) for the spread of aquatic invasive species, also known as aquatic nuisance species (ANS) (Carlton, 1985; Carlton and geller, 1993; gollasch et al., 2002; Kasyan, 2010).

to reduce the risk of introducing invasive species, the permit includes a more stringent numeric technology-based discharge standard that limits the release of non-indigenous invasive species in ballast water. the vgP also contains requirements to ensure ballast water treatment systems are functioning correctly. All vessels with ballast water tanks must have a ballast water management plan that is specific for that vessel and assigns responsibility to the master or appropriate official to understand and execute the ballast water management strategy for that vessel.

Additional environmental protection for the great lakes, which have suffered disproportionate impacts from invasive species, is expected from the alignment of federal standards with many great lakes states by requiring certain vessels to take additional precautions to reduce the risk of introducing new invasive species to u.S. waters.

the final vgP improves the efficiency of several administrative requirements, including electronic recordkeeping, annual reporting, and reduced inspection frequency for vessels that are idle over long periods. v

For additional information, please go to http://www.epa.gov/npdes/vessels

in late March, the united States environmental Protection Agency (ePA) issued a final vessel general Permit (vgP) regulating discharge from commercial vessels, including ballast water, to protect national waters from ship-borne pollutants and reduce the introduction of invasive species.

the permit covers commercial vessels greater than 79 feet long, excluding military and recreational vessels, and replaces the 2008 general permit that expires Dec. 19, 2013. there are 27 specific discharge categories addressed by this new permit, including deck washdown, bilge water, ballast water, boiler blowdown, propeller hydraulic fluid, gray water, and Ro brine.

the intention of the permit revision is to reduce discharge concentrations of aquatic nuisance species, nutrients, pathogens, metals, and conventional and non-conventional pollutants.

According to the ePA, ballast water typically consists of ambient water taken onboard to maintain vessel draft, trim, stability and stresses, regardless of how it is carried. large commercial vessels normally have ballast tanks dedicated to this purpose, and some vessels also may put ballast water in empty cargo holds.

Vessel General Permit Finalized by EPA By Sarah Clark, P.E.Sarah.Clark@hdrinc.com

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[5]www.hdrinc.com

HeAltH guiDeliNeS

in December 2012, Health Canada released two guideline technical documents for public comment. these were Nitrate and Nitrite in Drinking Water and Ammonia in Drinking Water. the purpose of these documents is to provide technical justification for Health Canada’s guidelines for nitrate, nitrite and ammonia in drinking water.

Although the comment period for the documents closed at the end of February 2013, both documents provide an excellent synopsis of the sources, occurrence, health risks and treatment methods for these contaminants. the draft guideline document on ammonia is a particularly valuable resource because of the frequent occurrence of ammonia in groundwater and the increase in the number of drinking water systems practicing chloramination for residual disinfection.

Nitrate and Nitrite in Drinking Waterthe guideline technical document proposes no change to the current maximum acceptable concentration (MAC) of 45 mg/l (10 mg/l as N) for nitrate and 3 mg/l (1 mg/l as N) for nitrite. these guidelines are identical

to the maximum contaminant levels (MCl) for nitrate and nitrite in the united States.

Similar to the u.S. environmental Protection Agency (ePA), Health Canada justifies these recommendations on the possibility of methaemoglobinemia occurring in bottle-fed infants exposed to nitrate/nitrite in drinking water. the document stresses that while the MAC is protective of the most sensitive subpopulations, nitrate/nitrite levels should be kept as low as reasonably practical because of uncertainties in health effects data.

Ammonia in Drinking Waterthe guideline technical document proposes that no MAC for ammonia is necessary because of ammonia’s low toxicity at concentrations found in drinking water. Again, this recommendation is similar to that in the united States, where no regulation for ammonia is considered necessary by the ePA.

However, the guideline technical document clearly points out how the presence of ammonia can have adverse effects on distribution system water quality.

these effects are the result of ammonia’s role in promoting nitrification. Nitrification causes the formation of nitrite and nitrate in the distribution system, along with the loss of disinfectant residual.

Health Canada recommends that drinking water systems maintain free ammonia levels of no more than 0.1 mg/l and ideally less than 0.05 mg/l at the entry point to the distribution system. the document also provides extensive evidence of frequent and, at times, unexpected occurrence of ammonia in groundwater samples in Canada, along with an excellent overview of ammonia treatment techniques. v

the documents can be found at: Nitrate/nitrite: http://www.hc-sc.gc.ca/ewh-semt/consult/_2012/nitrite-nitrite/draft-ebauche-eng.php Ammonia: http://www.hc-sc.gc.ca/ewh-semt/consult/ _2012/ammonia-ammoniac/draft-ebauche-eng.php

Health Canada Releases Draft Guideline Technical Documents By Phil Brandhuber, Ph.D.Philip.Brandhuber@hdrinc.com

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SDWA Newsletter | HDR[6]

guiDANCe

Summer is coming, and with it could be the concern of a harmful algae bloom, or HAB, if you are a drinking water provider. HABs occur when cyanobacteria, also known as “blue-green algae,” are able to grow in excess, forming “blooms” when certain conditions are present.

these conditions include sunlight, warm weather, high nutrient levels, low salinity, and lack of turbulence in the water body, which is generally a reservoir or lake source. these blooms may present a number of problems for drinking water providers. Among other things, they can clog up screens and filters, form scum in treatment basins, and cause taste and odor problems.

HABs are becoming more of a concern, however, because a number of blue-green algae species have the ability to develop and release cyanotoxins. these cyanotoxins present a threat to public health for both recreational and drinking water because they’re capable of impairing liver or nervous system functions or react with skin, causing rashes or allergic reactions.

to help water providers understand, identify and mitigate the impacts of HABs, the u.S. environmental Protection Agency (ePA) and World Health organization (WHo) offer resources and guidelines which are identified at the end of this article. the WHo establishes action levels and standards for concentrations of cyanobacteria that exceed a risk level that could represent a public health threat (table 1).

in general, monitoring for HABs should be designed to identify if a bloom is occurring, determine if the bloom is a HAB, and if it is associated with the release of cyanotoxins. Monitoring will help systems establish measures to prevent or remove algae cells and toxins at the treatment facility and to effectively communicate with the public in the event of a HAB.

the State of oregon recently published a document, “Best Management Practices for Harmful Algae Blooms for Drinking Water Providers,” which provides helpful information on preparing a monitoring plan. it also outlines steps that should be taken to identify and mitigate for HABs. the following is a summary of oregon’s guidance for drinking water providers:

1. Identify who is monitoring the water body for HABs. Monitoring entities may be state or federal agencies, county park and recreation departments, power companies, and/or municipal agencies. Reach out to these agencies to determine what monitoring they do and establish communications protocols to share monitoring information and coordinate sampling efforts.

2. Consider developing your own monitoring plan. the monitoring program should address the following:a. Identify when an algae bloom is occurring.

this involves visual observations in the water body as well as source water and raw water testing of water quality parameters. these include taste and odor, temperature, pH, chlorophyll-a, nutrient and organics concentrations, and color.

b. Collect samples for identification and enumeration following identification of a bloom. once a bloom has been observed, collect a sample from the bloom and identify the type and concentration of cyanobacteria present.

c. Evaluate samples from the bloom or from raw water for the presence of cyanotoxins. if the cyanobacteria exceeds WHo cell count action levels in table 1, and is a species that is identified as a toxin producer, then toxin testing at the bloom should occur. if the water body owner is

Guidance and Best Management Practices for Harmful Algae BloomsBy Anna Zaklikowski, P.E. | Anna.Zakilkowski@hdrinc.com Kim Swan, Clackamas River Water Providers

Table 1. WHO Cyanobacteria Cell Count Action Levels that Trigger Toxin Sampling for Drinking Water

Species Action Level

Microcystis spp. 2,000 cells/ml

Combination of all potentially toxic cyanobacteria species present 15,000 cells/ml

guiDANCe

www.hdrinc.com

not testing for toxins, the drinking water provider may choose to conduct the test themselves. Numeric guideline values or standards for toxin concentrations in drinking water have not been established by WHo or the ePA; however, oregon has published the following guideline values for four cyanotoxins based on guidance provided by other countries and/or available toxicological research studies.

3. Take steps to respond to and control HABs at the treatment plant. upon identification or notice of cyanobacteria and toxins in the source water, take the following steps to further assess the impact and implement control methods at the treatment plant:a. Collect samples from raw and finished water for

testing of toxins.b. If practical, implement the following strategies

to prevent introduction of cyanobacteria to the treatment process. temporarily discontinue recycle of backwash water, remove plant from service and clean basins and affected areas, and/or switch to a different source, such as groundwater or an alternative/emergency intertie.

c. Adjust treatment methods to reduce lysing of algae cells, thereby preventing the release of cyanotoxins. Suggested methods include refraining from or reducing pre-oxidation and adjusting pre-treatment and filtration processes by optimizing chemical dosages, reducing filtration rates, and increasing backwash frequency.

d. Absorb or remove toxins from the treatment process. Powdered or granular activated carbon is effective in absorbing algal toxins during pre-treatment, and soluble toxins that pass through physical treatment barriers can be destroyed by oxidants, such as chlorine and oxidants. See the resources provided at the end of this article for recommended contact time and oxidant doses found to be effective at removing microcystin.

4. Notify the public. Work with stakeholders to develop a public communications plan to address customer concerns. in the event cyanotoxins are

detected in levels exceeding guideline values or other values thought to be detrimental to public health, provide notice to your customers as soon as practical. Provide repeat or follow-up notices if the situation is ongoing or once the toxin concentrations have dropped to safe levels. Notices may be mailed directly, delivered by hand, and/or published in local media. the notice should address the following:a. Clearly state that the notice is a “Do Not Drink

Water Advisory.”b. Briefly describe the nature of the problem, how

the HAB occurred and was detected, and what the potential health impacts are upon human consumption, including language advising customers to avoid drinking and cooking with the water until further notice.

c. Describe the steps that are being taken to control the problem, which could include coordination with local and state health departments, discontinued use of source, source monitoring frequency, and other steps.

d. Provide contact information at agency or utility responsible for HABs communications.

Because the type and prevalence of HABs varies regionally and even within each watershed, it is important to understand the risk of HABs in your water supply and know where to find information on their occurrence and level of toxicity. Consult your state or local health department for more information, or get in touch with HDR for assistance in finding additional resources.

HAB guidance and monitoring is rapidly evolving as test methods improve and we learn more about blooms, so look for updated guidance as it becomes available.

Resources on HABs in WateruS ePA Cyanobacterial Harmful Algal Blooms:http://www2.epa.gov/nutrient-policy-data/cyanobacterial-harmful-algal-blooms-cyanohabs

(continued on back cover)

Table 2. Oregon Provisional Health-based Water Guideline Values for Four Cyanotoxins (µg/L)

Water Use Anatoxin-a Cylindrospermopsin Microcystins Saxitoxins

Drinking Water 3 1 1 3

Non-drinking and non-cooking uses 20 6 10 100

SDWA EditorSarah Clark, P.E., is the editor of SDWA. Please contact her with any comments or questions regarding this publication at (303) 764-1560. To join, change an address or be removed from the SDWA mailing list, please send requests

to SDWA@hdrinc.com.

Drinking Water Operations Wall Chart AvailableThe Drinking Water Operations wall chart is available from HDR’s website, www.hdrinc.com/OpChart. This poster-sized chart is designed to assist utility personnel

with the operation and maintenance of their water systems. It includes a combination of reference tools and guidance information designed to improve system performance and achieve optimal water quality for both water treatment and distribution systems.

13th Edition SDWA Wall Chart Now AvailableThe SDWA Update wall chart is available from HDR’s website, www.hdrinc.com/SDWA. The poster-sized chart provides an easy- to-use reference to all drinking water

regulations, including a detailed listing of contaminants and maximum contaminant levels, health effects and monitoring requirements.

WaterscapesWaterscapes is another technical publication produced and distributed by HDR. It focuses on the latest innovations and technical issues facing the water and wastewater markets. You can view Waterscapes on our

website at: www.hdrinc.com/waterscapes. If you would like to join our Waterscapes mailing list, please send an e-mail to waterscapes@hdrinc.com.

Career OpportunitiesFor information on career opportunities at HDR, please visit www.hdrinc.com/careers.

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A TECHNICAL PUBLICATION BY HDR’S WATER AND NATURAL RESOURCES GROUP SPRING 2013

WASTEWATER AND NUTRIENT MANAGEMENT

Front Cover Photo: Caption Text caption text...

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Guidance and Best Management Practices for Harmful Algae Blooms(continued from inside back cover)

the 1999 World Health organization, toxic Cyanobacteria in Water: A guide to their public health consequences, monitoring and management:http://www.who.int/water_sanitation_health/resources/toxicyanbact/en/

oregon Drinking Water Services Best Management Practices for Harmful Algae Blooms for Drinking Water Providers: http://public.health.oregon.gov/HealthyEnvironments/DrinkingWater/Operations/Treatment/Documents/algae/BMP-HABs.pdf v

Front Cover Photo: Harmful algae blooms are a major concern for drinking water providers in many parts of the united States and around the world. the cover photo illustrates this problem, even in low water situations due to drought, at a lakeshore in oregon. “Best Management Practices for Harmful Algae Blooms for Drinking Water Providers” is a document recently published by the state of oregon to provide helpful information on preparing a monitoring plan and outline steps to take for identification and mitigation of HABs.

© iStockphoto.com/HDR