Management of threats to fish and wildlife from PBTs

Scott Redman, Puget Sound Action Team

Puget Sound Plankton - The Ultimate Seafood Experience, Jan Holmes

Goals of this presentation

• Describe current management approach– note limitations for management of PBTs

• Describe opportunities for improved management

• Share thoughts about what regional science efforts can do to help

Persistent, bioaccumulative toxins

• PBTs of concern in Puget Sound include:• Halogenated hydrocarbons such as

• PCBs • chlorinated dioxins & furans• PBDEs• DDT

• PAHs• Methylmercury• Lead

Herring

Chinook

OrcasHarbor Seals

PBTs in Puget Sound fish and wildlife

Herring

WDFW & DFO data reported in 2007 PS Update

Fish and wildlife harm from PBTs

• Liver lesions and reproductive impairment in English sole from urban bays– WDFW & NWFSC studies suggest harm from PAHs, PCBs,

unknown hormone disruptors

• Immune suppression in salmon migrating out of urban estuaries and in marine mammals– NWFSC, WDFW & DFO studies suggest harm from

organochlorines

• Suspected impaired development, growth, and reproduction; altered behavior; and cancer in birds– CWS and USFWS studies suggest harm from organochlorines

Management of PBT pollution

Decide what is protective

Address problems

Identify andcharacterize

problems

Water qualitystandards

Sediment qualitystandards

Water qualityassessment

Permitting

Sedimentclean up

Contaminatedsediment site list

What is protective and acceptable in Washington State?

• Water quality standards• Narrative criteria• Numeric criteria

• Sediment quality standards (SQS)• Chemical concentration criteria• Biological effects criteria (for confirming designations

of contaminated sediments)• Other toxic substances criteria (narrative protection

for substances without numeric criteria)

Narrative water quality criterion expresses intent to protect fish & wildlife

• Toxic “concentrations must be below those which have the potential, either singularly or cumulatively, to … cause acute or chronic conditions to the most sensitive biota dependent upon those waters….”

WAC 173-201-260(2)(a)

Numeric water quality criteria offer limited protection to fish & wildlife

• Mercury – Washington criterion:– uses 1980s EPA criterion which found 1 mg/kg FDA limit

protective of fish & wildlife– 1.25 to 30x BC guidelines

• PCBs – Washington criterion– uses 1980s EPA criterion (basis?)– 300x BC guidelines– 30,000x criteria recommended by USFWS in New Jersey

to protect raptors

• PAHs & PBDEs– no Washington criteria for aquatic life

Consideration of fish and wildlife health in the numeric criteria portion of Washington State’s water quality standards

PBTs of concern to fish and wildlife in Puget Sound1

WA numeric criteria re: chronic effects to aquatic life in marine waters

Basis for WA criterion2 Analysis relative to BC guideline or other criterion or guideline

Lead 8.1 ug/L Includes marine conversion factor of 0.951

BC guidelines = 80% of values below 2 ug/L and max value below 140 ug/L

Mercury 0.025 ug/L Set at water concentration thought to protect FDA tissue level of 1 mg/kg – fish and wildlife effect levels reviewed in 1980s were higher than this level

BC guidelines include 0.033 mg/kg in fish to protect wildlife consumers; this is 1/30 of Washington’s criterion. BC marine aquatic guidelines also include 0.00125 to 0.02 ug/L depending on %Hg present as MeHg; this suggests BC guideline is 4/5 to 1/20 of Washington’s criterion.

Total PCBs (sum of congeners, sum of Aroclors, etc.)

0.030 ug/L Based on final residue value method (but not able to find information on toxicity or bioconcentration information used to develop the FRV).

BC guideline for marine aquatic life = 0.0001 ug/L; this is 1/300 of Washington’s criterion. To protect a food chain reaching to raptors, USFWS recommended (in 1990s) a criterion of 0.000001 ug/L for NJ (1/30,000 of WA level)

PAHs No numeric criteria N/A BC does have guidelines DDT (as DDT and/or its metabolites)

Set at water concentration thought to protect brown pelicans (assumed to consume N. anchovy at 8% lipids) from DDT accumulation above a level with observed reproductive (?) effects

No BC guidelines

2,3,7,8-TCDD and other dioxins and furans

No numeric criteria N/A No B.C. guidelines

Total PBDEs (sum of congeners to be normalized as part of the project)

No numeric criteria N/A No B.C. guidelines

1 Cadmium is not included in this list because Puget Sound concerns about this chemical relate not to harm to fish and wildlife but to human health risks from exposure to cadmium accumulations in bivalve shellfish. 2 As discussed in relevant U.S. Environmental Protection Agency water quality criteria document. These are 1980s publications for ……

Chemical concentration criteria in SQS do not protect fish & wildlife

• Criteria set by AET approach– concentrations at/above which biological

effects in benthic infauna are always observed

• No consideration of food chain exposures

Biological effects criteria in SQS do not protect fish & wildlife

• By definition in WAC 173-204-320(1)(a)– sediment demonstrating no adverse effects in

a specified set of tests “will result in … no acute or chronic adverse effects on biological resources”

• Specified tests evaluate only endpoints related to direct exposures to benthic infauna – no food chain exposures

What are the problems in Puget Sound?

• Water quality assessment identifies areas where – water quality is impaired by human causes and– clean up plan or other approach is needed

• Identification of impairment relies on sufficient, credible data to – evaluate conditions against numeric criteria– demonstrate “environmental alteration” and “impairment

of an existing or designated use” in the same segment

2004 Water Quality Assessment

Permitting the discharge of PBTs

• Permits can specify limits on the discharge of PBTs

– WQ-based limit only if reasonable potential to exceed numeric criteria

– Technology-based effluent limit – depends on type of discharger

Other management authorities

• Sediment clean up– Identifying contaminated sites– Setting clean up levels

• Dredged material management– Evaluating disposal options

• PBT strategy– Chemical action plans

Improved management - 1

• What is protective?– Modeling to relate water and

sediment concentrations to exposures experienced by sensitive upper trophic organisms

– Investigate and document toxic contaminant effects on upper trophic organisms, populations, and communities

– Revise water quality standards and sediment quality standards?

Improved management - 2

• What are the problems of PBTs?• Submit fish and wildlife data for evaluation via water

quality assessment?

• Revise listing policy?• Marine segmentation?

• Evaluations against narrative criteria?

• Bypass 303d listing in favor of alternative approach?

• Revise procedures for identifying contaminated sediment sites and dredged material management?

Improved management - 3

• Revise permitting• WQ-based effluent limits

• Reconsider use of mixing zones for PBTs

• Technology-based effluent limits• Update & emphasize on AKART – all known

available and reasonable methods of prevention, control, and treatment