Whole Effluent Toxicity (WET) “The Canary in Your Coal Mine” 27 th Annual Region VI Pretreatment Workshop Irving, TX August 1-4, 2011 Paul Juarez, 6WQ-PP Whole Effluent Toxicity Coordinator US Environmental Protection Agency

What exactly is WET? (Whole Effluent Toxicity / Biomonitoring) WET, or biomonitoring, is the use of live test organisms to determine the potential toxic impacts of wastewater effluents, stormwater, or other water discharges, on aquatic life in receiving streams and lakes.

Ceriodaphnia dubia Daphnid - water flea Pimephales promelas Fathead minnow

Is WET required? If so, why? EPA (and State governments) require wastewater permits to include WET testing to ensure compliance with objectives of the Clean Water Act, federal regulations for NPDES permitting 40 CFR (d)(1), and State narrative water quality standards to protect aquatic life.

State Water Quality Standard for the Protection of Aquatic Life After allowing for mixing with receiving water upstream, there shall be no chronic toxicity outside the edge of the defined mixing zone. Chronic Toxicity — Toxicity which, after long- term exposure, exerts sublethal negative effects, or which is lethal to representative, sensitive organisms.

A facility must obtain a permit to discharge its wastewater. The permit defines what chemicals may be discharged, how much over what time period (mass limits and/or concentration limits). Permits also require whole effluent toxicity (WET) testing to determine if the effluent is toxic to aquatic life. If the effluent is toxic, permit limits on WET may be required.

But how can WET benefit my facility? Failing a WET test usually signals something has gone wrong with the treatment system – either a change in chemicals added, process, OR that the toxicity of your influent has increased for some reason – possibly a new discharger or a change in the effluent discharged by an existing customer. But, while the initial WET test failure may be a negative sign, WET is also a basic tool to find and correct the problem.

Pretreatment WET Testing Requirements Pretreatment permits issued by municipalities to their industrial users now include WET monitoring. Such permits usually include quarterly testing with increased frequency following a failure. A failure is defined as a significant lethal or sublethal effect at a critical concentration. That critical concentration is based on the industrial user’s proportion of the POTW’s influent.

Pretreatment – Primary Defense Can add additional levels of protection and influent/effluent toxicity control(s) Can add additional levels of protection and influent/effluent toxicity control(s) User survey analysis when performing a Toxicity Reduction Evaluation (TRE) User survey analysis when performing a Toxicity Reduction Evaluation (TRE) Provides initial points of reference outside the POTW Provides initial points of reference outside the POTW Systematic examination of the user collection system Systematic examination of the user collection system

Local Limits The goal in developing local limits is to implement pretreatment regulations that are technically and legally defensible. Local limits can include provisions for equitable recovery of costs associated with the toxicity source evaluations and local limits development.

WET Tools Historical WET test data review – “barely” passing/failing tests? Historical WET test data review – “barely” passing/failing tests? Internal/external surveys for new dischargers/chemicals/processes Internal/external surveys for new dischargers/chemicals/processes Toxicity data review for new/altered treatment compounds or suppliers Toxicity data review for new/altered treatment compounds or suppliers Upstream Sampling (no advance notice – toxicity may temporarily disappear) Upstream Sampling (no advance notice – toxicity may temporarily disappear) Streamlined WET tests (cheap, use to find toxic samples for toxicant analysis) Streamlined WET tests (cheap, use to find toxic samples for toxicant analysis)

Facility-Specific Information Industrial waste surveys Industrial user self-monitoring reports Industrial user operational schedules and flow patterns Waste hauler monitoring and manifests Hazardous waste inventories

System Inspections/Sampling System inspections System inspections Microtox, ELISA Microtox, ELISA Streamlined WET tests Streamlined WET tests Onsite facility inspections Onsite facility inspections Advance notice to users? Advance notice to users?

Detective Work What else is going on? Are there records that correlate WWTP / SIU activities and reduced/increased toxicity? What else is going on? Are there records that correlate WWTP / SIU activities and reduced/increased toxicity? Develop chemical usage profile for SIUs Develop chemical usage profile for SIUs Batch or seasonal processes/chemicals? Batch or seasonal processes/chemicals? Communicate Communicate Communicate Communicate Communicate Communicate

Uncovered storage or process areas

Cameras and “Sniffers”

TRE - T oxicity Reduction Evaluation A study to identify causes and controls for effluent toxicity – begin by gathering information: Historical effluent toxicity data Treatment plant design capabilities Operation and maintenance practices Industrial user permits Pretreatment inspection reports Monitoring and compliance reports RECENT CHANGES, UPSETS

Toxicity Reduction Evaluations (TREs) Resolution depends on toxicity magnitude / duration Many facilities have worked aggressively and resolved both lethal and sub-lethal toxicity issues Unresolved toxicity usually related to inexperience or sloppy work, sampling or lab Success is usually a result of good communications and coordinated efforts between the TRE/WET testing consultant, the permittee and the permitting authority

Commonly Found Toxicants: ChlorineAmmonia CopperZinc NickelTributyltin Total Dissolved Solids (TDS) (Potassium, Bicarbonate, Calcium) Organophosphate Pesticides (Diazinon, OXO-Diazinon, Chlorpyrifos) Pathogenic Interference – Not acceptable for POTWs, which are designed to treat for pathogens.

POTW was in violation of its WET limits >>> TRE In-house processes were reviewed and corrected, and toxicity was reduced but not eliminated A toxicant identification evaluation (TIE) revealed high levels of pesticides in the effluent and a pretreatment user review showed treatment inefficiencies at a pesticide manufacturer. The pesticide facility eventually found it had 2 problems: Pretreatment TRE Example

Example (Cont.) 1) Dye studies showed the settling pond with 4-7 days retention actually had only 1.5 hours retention 2)Storage barrel rinse water was dumped directly to the retention pond. Pesticide slugs were passed from the settling pond directly to the POTW influent The TRE established two control strategies: 1)Dredge the pond and install a baffle system to increase the retention time 2)Reroute storage barrel rinse water to treatment cycle

TRE / TIE A TRE is a study to determine the source(s) of toxicity in an effluent and identify potential treatment options. A TRE is a study to determine the source(s) of toxicity in an effluent and identify potential treatment options. A TIE is a set of effluent manipulations designed to identify pollutants. EPA recommends TIEs as part of a TRE. A TIE is a set of effluent manipulations designed to identify pollutants. EPA recommends TIEs as part of a TRE. The presence of toxicity in samples is a cornerstone of TRE success – this means increased testing frequency and obtaining adequate amount of sample for WET and chemical testing. The presence of toxicity in samples is a cornerstone of TRE success – this means increased testing frequency and obtaining adequate amount of sample for WET and chemical testing. TRE duration should be sufficient to perform the work. TRE duration should be sufficient to perform the work. Concerned parties should meet at start and end of the TRE. Concerned parties should meet at start and end of the TRE. Most R6 TREs have been successful. Inconclusive TREs occur – but even those have eventually been resolved. Most R6 TREs have been successful. Inconclusive TREs occur – but even those have eventually been resolved.

Planning is important

WET Test Data Review

Your permit explains your various WET reporting codes. A good WET test lab report should contain a page showing the results for each reporting code as well, plus the bench sheets raw data and the statistical analysis, for review by you or the permit authority. Example Permit, Part II, WET language, Reporting Section (Section 3 or 4) ii. Ceriodaphnia dubia 1. If the NOEC for survival is less than the critical dilution, enter a ‘1’; otherwise, enter a ‘0’ for Parameter No. TLP3B 1. Report the NOEC value for survival, Parameter No. TOP3B 2. Report the LOEC value for survival, Parameter No. TXP3B 3. Report the NOEC value for reproduction, Parameter No. TPP3B 4. Report the LOEC value for reproduction, Parameter No. TYP3B 5. If the No Observed Effect Concentration (NOEC) for reproduction is less than the critical dilution, enter a ‘1’; otherwise, enter a ‘0’ for Parameter No. TGP3B 1. Report the higher (critical dilution or control) Coefficient of Variation, Parameter No. TQP3B

Your lab’s WET report should always include a full statistical analysis of your WET data!

Your lab’s WET report should also always include the actual raw data sheets. Does your lab provide a full statistical analysis and the raw data sheets for each test? Permitting authorities will be looking for these any time they are reviewing your files.

Example of Graphed Chronic Test Data % Effluent Concentration # of young (Total = 33) Percent Effluent (log scale) NOEC Adjusted Number of Young 100% 33 50% 33 25% % % 13 0% 0 35 LOEC Note: As the concentration of effluent increases, reproduction decreases.

Now let’s look at some of the basic information you should be able to dig out of that 30-page WET test report…

Note CVs in Performance v Dilution Water v Low-Flow Concentrations: lower CVs = lower variability

All effluent concentrations passed, 1 organism died (56% effluent)

IC 25 analysis may or may not agree with NOEC analysis. Permits in Region 6 States stipulate NOEC as the test endpoint.

Example of a failed test. While the dose response isn’t pretty, it is obvious that something is going on with this effluent.

Example of a false positive. The data here was very tight. As a result, the effluent failed but it should not have. This situation was corrected by increasing to 5 replicates.

25% effluent concentration ‘passed’ with only 50% survival in 15% concentration. Example of a false negative, rarely reported. Corrected by revising the concentration series.

Because we all want our water to be ‘clean’…

Thank you for your attention today. Please feel free to ask any questions or contact me at: Thank you for your attention today. Please feel free to ask any questions or contact me (214)