Mercury TMDL Development in San Francisco Bay

1
Mercury TMDL Developmentin San Francisco Bay

• Whats New?
• Whats Next?
• TMDL Elements
• Proposed actions and alternatives
• Proposed Implementation
• Just do we expect to achieve?

2
The usual caveats...

• This discussion is not about
• The will or intent of the Regional Board, the
  State Board, or the State of California
• The anticipated outcome of any public process

• This discussion is about
• Published historic accounts
• Public information (hearings, staff reports,
  peer-reviewed science)
• Staff recommended actions

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Goals

• Reduce mercury concentrations in fish
• Focus on resident species
• Stop ongoing pollution
• Using existing water quality objectives
• Implement a new fish tissue objective
• Using sound science and whole-watershed approach
• Predict the Bays recovery rate
• Communicate to the public through Use
  Attainability Analysis

4
The history...

• 1994 First RMP fish tissue survey
• 1996 Bay listed as impaired for mercury
• 1998 First Staff report - northern reach
• 1999 Mercury Watershed council convened
• Series of meetings and workgroups, 1999 - present
• 1999 Regional Board staff form TMDL team
• Staff commit to submission of TMDL report to U.S.
  EPA by April 2000
• 2000 TMDL Report submitted to U.S. EPA
• Transmittal letter and resolution commits to TMDL
  adoption by early 2002

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The Future
(Months)
No LATER than January 2002
Regional Board Hearing
Public Comment
2
Responses to Comments
Regional Board Adoption
State Board Hearing
2-6
Public Comment
Responses to Comments
State Board Approval
2-6
OAL Approval
EPA Approval
2-6
June 2002 - August 2003
Total 8-20 Months
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Whats New? (Since June 2000)

• NAS review of mercury risk assessment
• EPA mercury tissue residue criterion
• RMP fish consumption study
• RMP 3rd fish tissue survey
• RMP pilot air deposition study
• All dischargers begin ultra-clean mercury
  measurements
• FSSD begins near-field methylmercury monitoring
• BASMAA fuels study
• BADA - Sustainable Conservation fluorescent lamp
  report
• CALFED methylmercury survey in Bay and Delta
• U.S. EPA EMAPS survey in Bay
• CVRWQCB Clear Lake numeric targets report
• Urban runoff program sediment monitoring
• USFWS NRDA in Guadalupe River Watershed
• Guadalupe River Flood Control Project
  Collaborative
• Guadalupe Creek restoration EIR / Engineers
  Report

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Hey, Ive been no sluggard!

• New Idria Manuscript published in EST
• First author Priya Ganguli, SFEP (Lead field
  staff on Gambonini post cleanup monitoring)
• Presented at
• Environmental Council of States, St. Louis
• California Waste Management Association, Berkeley
• Water Environment Federation Pollution Prevention
  Symposium, Monterey (Cori Traub, Clean Water
  Action presented on same panel)
• EPA Mercury in Mines Conference, San Francisco
• California Water Environment Association mercury
  workshop, San Jose

8
NAS Methylmercury Review

• Report released in July 2000
• Validated U.S. EPA reference dose
• Significant implications for risk assessment

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U.S. EPA mercury tissue residue criterion

• Published in Fed Register December, 2000
• Based on consumption rates
• Recommends 0.3 ppm for 17.5 g fish / day
• Recommends States develop site-specific criteria
  using local consumption data
• U.S. EPA expects states to adopt tissue-based
  criteria

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RMP fish consumption study

• Most recent of several available
• Good response rate
• Pier fishers and party boats
• Available at www.sfei.org

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RMP 3rd fish tissue survey

• Conducted in 2000
• Continue monitoring every 3 years
• Mercury data available soon, will be incorporated
• Will be available at www.sfei.org
• Contact Jay Davis (jay_at_sfei.org)

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RMP pilot air deposition study

• Measured ambient airborne mercury
• Measure wet deposition rates
• Modeled dry deposition rates
• Ambient air concentrations very close to global
  ambient conditions
• Ambient rainwater 5-20 ng/L total Hg
• Contact Pam Tsei, Don Yee SFEI
• www.sfei.org

13
Ultra-low detection limits for mercury in
wastewater

• Ordered by Regional Board staff in 1999
• Purpose was to improve mass load estimates for
  wastewater
• June 2000 report estimated 20-40 kg/yr
• Revised estimate is lt 15 kg / yr
• Average concentration 13 ng/L

14
Near-Field Methylmercury Monitoring

• Permit provision for Fairfield Suisun
• Measured dissolved methylmercury, unfiltered
  methylmercury, dissolved mercury, total mercury,
  TSS, other metals
• High-quality data set

15
BASMAA Fuels Study

• Began as study of mercury levels in fuels
• Additional air deposition monitoring to
  complement SFEI study
• Low (1 ppb) Hg concentrations in refined fuels
• Where is missing mass? (1 ppm in crude)
• Confirmed that mercury air deposition is from
  remote, not regional sources.

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BADA - Sustainable Conservation fluorescent lamp
report

• Requested of BADA by Regional Board staff
• Evaluated potential for eliminating mercury in
  electric light through reformulation
• Estimate 20 Years to new technologies
• Recycling is our best option
• Terminal disposal is a significant barrier to
  recycling programs
• Regional direction consistent with national
  trends
• Partnership results stunned ECOS participants

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CALFED methylmercury survey in Bay and Delta

• 3-year CALFED grant to study mercury
  bioaccumulation in Delta
• SFRWQCB supplemented funds to extend sediment
  survey into Central, South Bay
• Surprises
• Delta is a methylmercury sink
• San Joaquin drainage is a bioaccumulation
  hot-spot
• No surprises
• Methylmercury in our bay highest in margins,
  especially where total mercury exceeds sediment
  target

18
U.S. EPA EMAPS survey in Bay

• Stratified random sampling of the Bay
• Provides statistically robust data set
• Complements RMP, CALFED data sets, which are
  site-focused sampling designs
• Data expected within next 3-6 months

19
CVRWQCB Clear Lake numeric targets report

• Region 5 is developing a TMDL for mercury in
  Clear Lake
• Numeric Target Report implements U.S. EPA
  guidance to develop fish tissue target
• Contacts Janice Cooke or Chris Foe, CVRWQCB

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Urban runoff program sediment monitoring

• Ordered by Regional Board staff for TMDL
  development
• Approach is to characterize mercury and PCB
  concentrations in urban and non-urban stormwater
  conveyances (80 Samples this year)
• Intent is to use data for evaluation of target
  attainment, characterize concentrations by
  land-use, identify any major controllable
  sources, estimate pollutant loads
• Preliminary reports expected in February
• Excellent, innovative work by all urban runoff
  programs
• Kudos to Andy Gunther (AMS), Dan Cloak (EOA),
  BASMAA Program managers

21
USFWS NRDA in Guadalupe River Watershed

• Natural Resource Damage Assessment conducted by
  U.S Fish and Wildlife Services
• Assesses value of lost natural resources due to
  mercury pollution in Guadalupe River watershed
• Public agencies and private companies identified,
  brought to table
• Interim, cooperative agreement established
• Has potential to assign accountability for
  remediation
• Extremely litigation sensitive
• Contact Jim Haas, USFWS

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Guadalupe River Flood Control Project
Collaborative

• Not really new, the collaborative has been in
  effect as a settlement agreement for years
• To date, environmental issues focussed on habitat
  restoration
• Regional Board staff now helping to incorporate
  mercury remediation in project designs
• Partnership approach with SCVWD staff

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Guadalupe Creek Restoration

• Mitigation for downtown flood control project
• 1.7 miles of stream
• Downcut 8 feet in 30 years
• 20-30 ppm mercury in soils
• Project will arrest erosive loss of in-stream
  mercury
• EIR produced excellent methylmercury assessment
• First step in a journey of a thousand miles

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SO.

• Yes, we are fighting mercury pollution in our
  watersheds
• Yes, the stakeholders are involved
• In fact, they are doing all the work
• Yes, the partnership approach can work
• But we still have to memorialize our commitment
  to action through a public process, in the form
  of a TMDL...

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The Game Plan

• Reduce watershed pollutant loads by enforcing
  existing water quality objectives
• Build partnerships that promote pollution
  prevention
• Commit to establishing a new objective for
  mercury in fish tissue within ten years
• Conduct a UAA concurrent with new fish tissue
  objective to predict time to attainment

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Elements of a TMDL
Status in SF Bay

• Problem Statement
• Numeric Targets
• Source Assessment
• Linkage Analysis
• TMDL, Load and Waste Load Allocations
• Margin of Safety, Seasonal Variations, Critical
  Conditions
• Implementation Plan

Proposed in June 30, 2000 report to U.S.
EPA Received substantial stakeholder input Needs
scientific peer review
Concepts in place Needs formal public process to
adopt
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Problem Statement How many grams per day is
fishable?
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Problem Statement Pull over, son, youre over
the limit
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• Why?
• Watershed and air sources
• Historic sources
• Complex cycling in the environment

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• What increases mercury in water?
• Increasing amounts of sediment in the water
• mercury sticks to dirt
• Increasing amount of mercury in sediment

polluted sediments
Mercury Concentration in Water
background sediments
Suspended sediments in water
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What increases mercury in SF Bay water?
Data from the San Francisco Estuary Regional
Monitoring Program for Trace Substances.
http//www.sfei.org
32
Polluted Sediments
Data from the San Francisco Estuary Regional
Monitoring Program for Trace Substances.
http//www.sfei.org
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Phase 1 TargetMercury in Sediments

• Most of the sediment in SF Bay comes from the
  Central Valley
• Our sediment should resemble that of Central
  Valley Source
• There is usually more mercury in fine clay than
  in coarse sand

Over Target
Mercury in Sediment
Target
Sand
Clay
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Evaluation of Sediment Target
Data from the San Francisco Estuary Regional
Monitoring Program for Trace Substances.
http//www.sfei.org
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Proposed Action

• Regulate to Sediment target in first phase
• Set Sediment Target at current watershed
  background concentration

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Proposed Action

• Set fish tissue target as success criterion in
  first phase
• Develop load allocations based on fish tissue
  target in second phase

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Alternative Actions

• Set sediment target below current watershed
  background level
• Calculate load allocations based on fish tissue
  target

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Source Assessment
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Linkage Analysis
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Forget modeling, lets measure it
Methylmercury concentrations in sediments (ng/g)
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Phase 1 Action stop feeding the methylation
machinery on the margins
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Allocate loads based on effect on sediment target
This
Sum of these
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Clean Water Act requires that we express the load
in terms of mass per unit time
Load Allocation
Target allocation x Sediment Load


Kg Hg / yr
mg Hg/kg sed
kg sed / yr
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Happy now?
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Implementation Plan for Wastewater

• 50 kg total
• Concentration goals
• annual average
• 25 ng/L deep water
• 15 ng/L shallow
• Based on twice current flow
• Credit for
• Reclamation
• Stormwater treatment
• Air emission controls
• Offset proposals
• Dont forget cooling water!

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Implementation Plan for Urban Runoff Programs

• Continue sediment monitoring for five years
• After five years, submit a report telling
  Regional Board
• Do any catchments cause exceedance of target
  allocation? (0.32 ppm in fine sediments)
• Submit action plans for largest exceedances,
  considering
• What is the total mercury mass flux?
• Is exceedance due to upstream source requiring
  Regional Board or other agency action?
• What is effect of airborne deposition?
• Are there opportunities for pollution prevention?
• Are there potential benefits from reduction of
  other pollutants? (e.g., PCBs)
• Is conveyance cleanout a potential solution?
• Is treatment the only alternative?
• What are economic impacts?
• What are environmental benefits?

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Goal of urban runoff programs

• Identify your biggest outliers
• Tell us what it takes to eliminate them
• Tell us, once that is done, will the net impact
  of all watershed inputs be less than the target
  allocation?
• Are there added benefits due to other pollutants?

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Economic Impacts
Effluent loads
Watershed loads
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Implementation Plan for Dredgers

• Continue to Use LTMS cover / no cover guidelines
• Consistent with 0.4 ppm target
• Supported by linkage analysis - dont put red-hot
  sediments in a wetland, duh!
• Develop Best Management Practices for minimizing
  methylation potential in constructed and managed
  wetlands

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Pollution Prevention

• Encourage municipalities to adopt virtual
  elimination policies, take-back programs
• Work with BADA, BASMAA, municipalities to ensure
  100 recycling of fluorescent lights
• Work with CDA, POTWs to maximize recovery of
  dental amalgam
• Regulatory leverage is EO approval of pollution
  prevention plans
• Adopt a resolution supporting a national terminal
  disposal strategy

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The Big Picture
(A)
Total amount of bioavailable mercury in Bay and
its margins (Kg)
assimilative capacity
(B)
(C)
Time