1. Management of threats to fish and wildlife from PBTs Scott Redman, Puget Sound Action Team Puget Sound Plankton - The Ultimate Seafood Experience, Jan Holmes

2. 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

3. Persistent, bioaccumulative toxins PBTs of concern in Puget Sound include: Halogenated hydrocarbons such as PCBs chlorinated dioxins & furans PBDEs DDT PAHs Methylmercury Lead

4. Herring Chinook Orcas Harbor Seals PBTs in Puget Sound fish and wildlife Herring WDFW & DFO data reported in 2007 PS Update

5. 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

6. Management of PBT pollution Decide what is protective Address problems Identify and characterize problems Water quality standards Sediment quality standards Water quality assessment Permitting Sediment clean up Contaminated sediment site list

7. 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)

8. 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)

9. 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

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

11. 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

12. 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

13. 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

14. 2004 Water Quality Assessment

15. 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

16. Other management authorities Sediment clean up –Identifying contaminated sites –Setting clean up levels Dredged material management –Evaluating disposal options PBT strategy –Chemical action plans

17. 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?

18. 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?

19. 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