Washington Certification Services Perspectives in Waterworks OpCert

StreamFest

 

6PPD-q, PFOA, PFOS ... it's raining alphabet soup!

Notes on the Washington Department of Ecology's (WECY) updates to Aquatic Life Toxics Criteria (ALTC) (WAC 173-201A), adopted 14 August 2024 and effective 14 September 2024 from Washington state sets newlimits for toxic chemicals in water.

"This rule update includes adding aquatic life criteria for 6PPD-q, the first numeric criteria in the country adopted to protect aquatic life from the harmful effects of this chemical that comes from tire wear. We are also adding criteria for PFOA and PFOS (part of the PFAS chemical group)."

There is much of interest in this latest round of rule making, including the incorporation of mathematical modeling (MLR or multiple linear regression models) to set protective freshwater criteria for certain metals. This will require further study …

At first glance, two major issues which I have concerns have been addressed in that - from the WECY update -

“We integrated methods used in EPA’s 6PPD-quinone screening level calculations that utilize time-weighted average median lethal concentrations (LC50s) and incorporated additional scientific studies released since the rule proposal, resulting in an increase (i.e., less stringent) in the 6PPD-quinone criterion.”

The adoption of a numeric standard will take some time to develop beyond the initial 5-years data collection requirement of the (new) stormwater permit. While studies have documented of the deleterious effects of this pollutant to Coho salmon "in the lab,” what-to-do about it where the rubber meets the road (pun intended) is another matter. There are hundreds of miles of roads in this state, and mitigating 6PPD-quinone is a task that will eclipse barriers to fish passage in comparison in effort and especially public expense. The regulatory aspects of setting numerical criteria will be interesting from both the environmental and regulatory will be interesting.

A tighter criteria - as advocated by WRIA8 in their 7 May 2024 letter to Ecology - that “… [g]iven the very high acute toxicity of 6PPD-q to coho salmon, we [WRIA8] strongly support using EPA’s 5th percentile of the species sensitivity distribution method to set criteria. A freshwater acute criterion of 8 ng/L will ensure coho salmon and other aquatic life are protected.” How they determined such a specific regulatory pollutant concentration to me is unclear … call it a sanity check, but if I could suggest modeling from an environmental services point of view, it would be to establish some realistic relationship of costs to retrofit public infrastructure (i.e. roads) vs. amount of mitigation required to satisfy the numerical concentration selected … fundamental Cost vs. Benefit analysis … a requirement under any regulatory framework as much as it is a political reality.

The PFOA and PFOS is of both national and state-wide concern as it has adverse impacts on drinking water and is an immediate public health concern. As our analytical abilities to detect and measure these toxics of emerging concern advances, this interplay of pollutant concentrations and costs to mitigate I think is at the forefront of public policy. Is too much ever enough?

edited & updated: 2024-08-22 @ 15:15

Global Water Watch (GWW) Stream Biomonitoring, Biological Monitoring & Water Chemistry Monitoring

... and the BIBI training (practical session) on August 6th ...

US EPA offers an educational series via the Watershed Academy

The US EPA offers an educational series via the Watershed Academy, the latest on Citizen Science and water quality monitoring in Leveraging Participatory Science to Advance Water Quality Reporting and Partnership-Building Part  2. Consisting of “show and tell” from various non-profits/NGOs around the country, Part 2 in this two-part series featured the work of Citizen Science in water quality monitoring organizations like the SnoKing Watershed Council.

The fourth presenter – NOAA’s Steve Morton of NCCOS Phytoplankton Monitoring Network – was of particular interest in both subject matter and the organizational structure of NCCOS. I found the monitoring marine phytoplankton and harmful algal blooms (HABs) useful. 

The two-part series can be found here, with the July 11th Part 2 to be posted to the EPA website shortly.

I’ve been completing web-based coursework and - for the most part - it’s been informative and well worth the effort. If you have the time, this “participatory science” series is quite interesting ...

An airing ... 6PPD-quinone

A FishyFriend recently observed “ …a disturbing report came my way today: a chemical industry analysis predicts sales of 6PPD to increase almost 5% per year in the foreseeable future [1].”

6PPD-quinone and it’s deleterious effects on Coho salmon hasn’t escaped the attention of researchers at WSU or ECY (the Washington State Department of Ecology), which is contemplating a rule-making process of a proposed revision to Ecology's Aquatic Life Toxics criteria to include 6PPD-quinone as a freshwater acute Aquatic Life Toxic pollutant (p18), with a freshwater acute concentration threshold of 0.008ug/L (1-hour exposure) (p.37). In fact, ECY is “... proposing to add sampling starting in year 3 of the permit for some transportation facilities.”. The discussion has been interesting …

While testing and monitoring for 6PPD-quinone is being proposed under ECY likely rulemaking, future mitigation to meet a maximum contaminant load will not be a fast or inexpensive proposition. Retrofitting infrastructure - much of it public roads and freeways - and nonpoint stormwater sources may prove a daunting task. In light of the fact that the area is already incurring tremendous costs simply accommodating the stormwater flows ...

Pending approval by the council, a new multi year business plan proposed by Public Utilities would set rates on a path to $325 per month for a typical house and $187 for a typical apartment by 2030, up from $245 for a house and $142 for an apartment today.

WRIA8 is urging Ecology to adopt the most stringent criteria (p37); while adding a sampling requirement in 3 years is the most likely outcome from the current process, what to do about it remains to be seen. In an age we find ourselves engaged in multi-year fish passage projects, nitrification from sewage treatment plants, and the usual water/sewer/SWRO maintenance, replacement and capacity expansion - the costs are spiraling completely out of control …

Well, while we could all stop driving or riding the bus. I’m thinking the solution may in large part be innovations in tire manufacturing. Tire companies add 6PPD to prevent tires from breaking down due to reactions with ozone and other reactive oxygen in the air. When 6PPD reacts with ozone, it forms 6PPD-quinone; tire particles are left on road surfaces and eventually get washed in the rain … making its way into lakes and streams where Coho salmon are exposed, leading to heightened pre-spawn mortality and other adverse effects. 

We wouldn’t simply accept unsafe tires which disintegrate in traffic any more than we will unaffordable infrastructure that breaks us financially.

NPDES

I recently completed the USEPA's National Pollutant Discharge Elimination System (NPDES) Permit Writers' Course. Meeting twice weekly virtually, the course consisted of recorded and live lectures, numerous quizzes and complex p-sets cumulating in the writing of an actual permit for the hypothetical All Charged Up Corp. battery manufacturing operations. The team-teaching by EPA regulators and consultants from the private sector was quite well done over the month-and-a-half class. I'm still working over parts of our completed permit.

Makes the hands-on, practical water monitoring lead by SnoKing directly applicable to this, my next adventure ...   

I've also added a new section of likes to useful NPDES resources under Bibliotheca pages