Aqueous Chemistry and Toxicology of Copper in Marine Waters Such That Worst-Case Assumptions Over-Estimate Actual Toxicity

Water Effect Ratio = (Site Water LC50) / (Lab Water LC50)


Only Considers Short-Term Equilibration, Does Not Consider Total and Dissolved Slow Equilibration
Underestimates Water and Specific Chemical Form Impacts

Relationship Between Analytical Chemistry and Water Quality

Poor Relationship Between Analytically Measured Concentrations and Water Quality Impacts
Purpose of Water Pollution Control 



Protect and Where Degraded, Enhance Designated Beneficial Uses of Waterbody for Aquatic Life-Related Beneficial Uses


Cannot Use Chemical Analysis to Predict Toxicity



Must Use Bioassays - Toxicity Test as Primary Regulatory Tool


Need Research on Chemical Species Toxicity Test Results



 

Urban Stormwater Runoff Water Quality Impacts

New Regulatory Area
US EPA 1990 Stormwater Runoff Water Quality Management Program Requires Controlling Pollution of Receiving Waters for Stormwater Runoff to the Maximum Extent Practicable Using Best Management Practices (BMPs)

Urban Area Streets and Highway Stormwater Runoff Contains Several Heavy Metals Such as Cu, Pb, Cr, Zn, Hg and As at Excessive Concentrations Compared to US EPA Water Quality Criteria
If Urban Stormwater Runoff Regulated to the Same Degree as Domestic Wastewaters-No Exceedance of Water Quality Standard Outside of Mixing Zone, Will Cost Urban Dwellers $1 to $2 per Person per Day



Must More Reliably Evaluate Real Water Quality Impacts of Stormwater Runoff-Associated Constituents
Rarely Are the Heavy Metals In Stormwater Runoff from Urban Area Streets in a Toxic-Available Form



Independent Applicability Policy

US EPA Adopted Independent Applicability Policy in Early 1990s 



No Public Review 


Requires Attainment of Chemically-Based Water Quality Criteria/Standards Even If Biological Assessments - Toxicity and/or Organism Assemblages Show No Impacts Due to the Chemical Present in Excess of Criterion/Standard
Leads to Administrative Exceedances of Criterion/Standard Without Adverse Impacts on Beneficial Uses of Water



Technically Invalid and Wasteful of Public Funds
Focuses on Chemicals Rather than Chemical Impacts



Ignores Purpose of Water Quality Management



Protection of Beneficial Uses




US EPA Announced Proposed Rulemaking 



Possible Change Independent Applicability Policy









Suggested Regulatory Approach

Do Not Regulate Based on Worst-Case Criteria/Standards Where Exceedances Require Establishing TMDLs



Use Exceedance of Criterion as an Indicator of Potential Water Quality Problems
If Exceedance of Water Quality Criteria Found for Potentially Toxic Chemicals, Allow Discharger/Source Option of Complying With the National Chemical Criteria or Demonstrating Lack of Biological Impact-Toxicity



Problems With Conventional Water Quality Monitoring 

of Stormwater Runoff

Conventional Monitoring of Runoff/Discharge Water for Suite of Chemical Parameters Produces Little Useful Information on Water Quality Impacts
Focus on Exceedance of Water Quality Criteria 
Urbonas & Torno, ASCE Stormwater NPDES Related Monitoring Needs (1994) Conference Summary, 



"Very little meaningful monitoring is being directed toward measuring the actual effect of stormwater discharges on the short- or long-term health of the environment. Furthermore, there is no consensus on how this monitoring should be done."


Roesner in Same Conference Discussion,



"....the course we are taking with the NPDES stormwater permitting program is going to cost municipalities a lot of money, but is not going to result in any significant improvement in the quality of our urban receiving water systems."




Factors That Must Be Considered in Translating Runoff

Concentrations to Potential Aquatic Life Water Quality Impacts

Stormwater runoff

Need Information:
measured concentration of constituent during runoff event - concentration time profile

discharge of the runoff waters during runoff event - hydrograph
analytical chemistry of the method used for analyses - what chemical species are measured


Receiving waters
Physical factors - Need Information:

Currents, tides - transport-advection
Mixing-dispersion 

Biological factors - Need Information:


Duration of organism exposure to toxicant
Organism movement - locomotion
Diel migration



Sensitivity to toxicants
Organism assemblages - resident populations relative to habitat characteristics

Chemical factors - need information:


Aquatic chemistry





Kinetics and thermodynamics of reactions
Additive, synergistic and antagonistic reactions and impacts






Toxic and non-toxic, non-available forms 
Background concentrations of constituents of concern



Evaluation Monitoring As An Alternative to Conventional

Water Quality Monitoring and Management



Need Alternative Monitoring/Evaluation Approach to Determine if Real Water Quality Use Impairments Are Occurring in Receiving Waters for Urban Stormwater Runoff 



Metals and Many Other Constituents in Urban Area and Highway Stormwater Runoff in Particulate, Non-Toxic Forms
Episodic, Short-Term Exposures Occur with Stormwater Runoff Events


Rare that Real, Significant Water Quality Use Impairments Will Occur from Urban Area and Highway Stormwater Runoff-Associated Constituents

Evaluation Monitoring



Find a Real Water Quality Use Impairment in Receiving Waters for Stormwater Runoff that is Due to Stormwater Runoff-Associated Constituents

Rather Than Measuring Suite of Potentially Toxic Chemicals, Measure Toxicity in Runoff Waters and Receiving Waters


If Significant Toxicity Found, Determine Its Cause through TIEs 
Determine Sources of Toxic Constituents through Forensic Studies 
Develop Control Programs for Toxic Constituents at Source 


Technically Valid, Cost-Effective Approach












Possibility of Copper-Caused, Non-Detected, Subtle

Water Quality Impacts



While No Identified Water Quality Problems - Use Impairments Have Been Found - No One Can State With Certainty that No Subtle Problems Will Be Found in the Future
Evaluation Monitoring Requires that Funds Be Made Available to Search for Subtle Water Quality Use Impairments
Prioritize Water Quality Use Impairments - Focus on Most Important Problems



With Limited Financial Resources Available for Water Pollution Control, Focus the Funds Available on the Most Significant, Readily Discernible Water Quality Use Impairments



Search for More Subtle Problems





Conclusions





Traditional Regulatory Approaches for Heavy Metals Such as Copper Fail to Reliably Incorporate Aquatic Chemistry of Regulated Constituents into Regulatory Approach 
Leads to Over-Regulation and Waste of Public and Private Funds in Unnecessary Waste Treatment Facilities/Control Programs 
Need to Shift Regulatory Approach from Control of Chemicals to Managing Water Quality of Concern to the Public 
Use Toxicity Tests to Determine if Toxicity Present. If Present, Determine Cause band Sources 
Urban Stormwater Runoff New Regulatory Area Where There Is Need to Integrate Use of Aquatic Chemistry and Toxicology to Define Real Water Quality Problems 



References as:"Lee, G.F. and Jones-Lee, A., 'Regulating Copper in San Francisco Bay: Importance of Appropriate Use of Aquatic Chemistry and Toxicology,' Presented at Fourth International Conference on the Biogeochemistry of Trace Elements, Berkeley, CA, June (1997)."





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