Cyanotoxins in US Drinking Water: Occurrence, Case Studies and State Approaches to Regulation September 2016

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Cyanotoxins in US Drinking Water Occurrence, Case Studies and State Approaches to Regulation September 2016

The American Water Works Association is the largest nonprofit, scientific and educational association dedicated to managing and treating water, the world’s most important resource. With approximately 50,000 members, AWWA provides solutions to improve public health, protect the environment, strengthen the economy and enhance our quality of life.

This publication was funded by the Water Industry Technical Action Fund managed by AWWA (Project #656). The Water Industry Technical Action Fund is managed by the Water Utility Council to support projects, studies, analyses, reports and presentations in support of AWWA’s legislative and regulatory agenda. WITAF is funded by a portion of every organizational member’s dues.

The authors, contributors, editors, and publisher do not assume responsibility for the validity of the content or any consequences of their use. In no event will AWWA or the Water Research Foundation be liable for direct, indirect, special, incidental, or consequential damages arising out of the use of the information presented in this publication. In particular, AWWA and the Water Research Foundation will not be responsible for any costs, including, but not limited to, those incurred as a result of lost revenue.

American Water Works Association Steering Committee 6666 West Quincy Avenue Keith Cartnick, Suez Denver, CO 80235-3098 Ruth Marfil-Vega, American Water 303.794.7711 Dean Reynolds, City of Alliance, OH www.awwa.org AWWA Staff Support Primary Authors Adam Carpenter Environmental Engineering & Technology, Inc. Sean Garcia Corona Environmental Consulting Steve Via

CONTENTS

List of Tables ...... iii List of Figures ...... iv Executive Summary ...... v Introduction ...... 1 Global Approach to Cyanotoxins in Drinking Water ...... 3 United States Approach to Cyanotoxins in Drinking Water ...... 4 Occurrence Background ...... 6 Trends in Cyanotoxin Occurrence ...... 6 Global Overview ...... 6 Historical Occurrence Data in the US ...... 6 Recent occurrence Data in the US ...... 8 Ohio Cyanotoxin Data ...... 13 Ohio Recreational Water Data ...... 13 Ohio Drinking Water Data...... 14 Regulatory Implications in Ohio ...... 16 Utility Responses to Cyanotoxin-Producing Algal Blooms ...... 17 Detection of Cyanotoxins ...... 18 Modifications to Operations and Treatment ...... 20 Operational Strategies during a Cyanotoxin Event ...... 20 Utilities’ Experiences during the 2015 bloom season ...... 21 Impacts to Utilities ...... 25 2016 DND/DNB Order ...... 26 Recommended Next Steps ...... 28 References ...... 29

ii List of Tables

Table 1. International cyanotoxin guidance and regulation summary ...... 4 Table 2. States guidance for cyanotoxins summary ...... 4 Table 3. State approaches to USEPA Health Advisories ...... 5 Table 4. Summary of state data ...... 9 Table 5. Detection limit range of each cyanotoxin ...... 9 Table 6. List of cyanotoxins tested for in each state ...... 10 Table 7. Cyanotoxin detections in Ohio source water ...... 16 Table 8. Cyanotoxin detections in Ohio treated drinking water ...... 16

iii List of Figures

Figure 1. 2007 National Lake Assessment microcystin data ...... 7 Figure 2. Cyanotoxin occurrence data in drinking and recreational water ...... 10 Figure 3. Recreational and source water microcystin data from 2006 to 2016 ...... 11 Figure 4. Microcystin concentration histogram ...... 12 Figure 5. Microcystin detection limit histogram ...... 13 Figure 6. Microcystin occurrence data in Ohio recreational water ...... 14 Figure 7. Microcystin occurrence data in Ohio drinking water 2010 to 2015 ...... 15

iv Executive Summary

Cyanotoxins have long been recognized as potential sources of contamination for drinking water supplies. Despite this, cyanotoxins are not regulated under the Safe Drinking Water Act (SDWA). However, there are indications that cyanotoxins may be regulated under the SDWA in the future.

In August 2014, the City of Toledo, Ohio issued a Do Not Drink/Do Not Boil (DND/DNB) order because of detections of the cyanotoxin microcystin in their finished water. Nearly 500,000 people were impacted during the weekend-long DND/DNB order, which was the largest cyanotoxin-related DND/DNB order in United States history. This event has put renewed emphasis on cyanotoxins in drinking water, and resulted in Congress directing the United Sates Environmental Protection Agency (USEPA) to prepare a strategic plan for algal toxin risk assessment and management in drinking water. Related to these efforts, USEPA has issued Health Advisories (HAs) for two cyanotoxins: microcystins and cylindrospermopsin. These HAs are not Federal standards nor are they legally enforceable; instead, they are intended to provide public health officials with information regarding the concentration of a contaminant in drinking water at which adverse health effects are not anticipated. In addition to issuing the HAs for microcystins and cylindrospermopsin, USEPA has also proposed adding several cyanotoxins (microcystins, nodularin, anatoxin-a, and cylindrospermopsin) to the compounds included in the next round of Unregulated Contaminant Monitoring Rule (UCMR 4) monitoring.

Since cyanotoxins are not regulated, there was little data available prior to the 2015 bloom season regarding the ability of public water systems (PWSs) to meet the HA levels for microcystins and cylindrospermopsin issued by USEPA. There were several unknowns going into the 2015 bloom season: 1) how many PWSs would have source waters contaminated with cyanotoxins, and to what extent; 2) would any cyanotoxin-related DND/DNB orders be issued, and what would the impact of such orders be; and 3) how would PWSs adjust treatment to remove cyanotoxins and what would the impact of those modifications be? Recognizing these unknowns, the American Water Works Association’s (AWWA) Government Affairs Office initiated a study through the Water Industry Technical Action Fund (WITAF) to develop a spreadsheet of cyanotoxin occurrence in source and treated drinking water and to catalogue the impact of USEPA’s HAs on PWSs.

As part of that effort, the project team identified data sources for cyanotoxin concentration, collected available data and analyzed those data. This report provides: background information describing the guidance in place for cyanotoxins in drinking water, data sources used for collecting cyanotoxin occurrence and concentration data, currently available data, case studies about utilities that have been treating water containing cyanotoxins and recommendations for future data collection and analysis efforts.

Most of the state primacy agencies that responded for this study do not plan to take action on the USEPA HAs on microcystins and cylindrospermopsin because it is not regulation. Some state representatives cited legal concerns over enforcing a standard that is not in regulation. Only

v Ohio, Maryland, Rhode Island and South Carolina definitively intend to take action when sample results indicate levels over the HA. However, many of the PWSs contacted were aware of the potential for cyanotoxin contamination and were targeting finished water cyanotoxin concentrations below the HA limits.

Determining the occurrence of cyanotoxins across the United States is difficult due to the lack of data collection and reporting in many states. However, prior studies indicate that cyanotoxins may be widespread. Previously the United State Geological Survey (USGS), in conjunction with the USEPA National Lake Assessment, determined that microcystin was present in 33 percent of samples collected from 1,028 lakes, reservoirs and ponds in 2007. Cylindrospermopsins and saxitoxins were less prevalent, with detections in 5 and 8 percent of the samples respectively. Geographical trends were apparent in the occurrence data. Microcystin detections were common in the Midwest, while saxitoxins occurred most in the upper Midwest and south. Texas, Florida and the Ohio, Indiana and Kentucky region had the most cylindrospermopsin detections (Graham and Loftin 2014). No treated drinking water samples were collected in this study.

More recent cyanotoxin occurrence data do not capture the full extent of cyanotoxin occurrence in the United States for several reasons. First, the majority of states do not require cyanotoxin monitoring in drinking water. In states with testing programs, the monitoring data are not in a consistent format from state to state. Since there is no USEPA requirement for testing, various analytical methods are used and often the method used is not indicated when data are reported. Despite these limitations, there is value in examining the available data to determine the current state of knowledge and the most beneficial next research steps.

Recreational water use and drinking water cyanotoxin data from six states were incorporated into an occurrence spreadsheet. The majority of the data are from Ohio. Detections of microcystin are possible year-round, however, there is a seasonal trend to the data with the highest concentrations occurring in the late summer and early fall.

All of the treated water cyanotoxin detections were from Ohio. Treated drinking water samples were generally collected on the same day as the source water samples (throughout this report, “source water” refers to water collected at or shortly prior to entry into a water treatment facility, which will be treated to become drinking water). Although 43.9 percent of source water drinking water samples in Ohio exceeded the microcystin USEPA Health Advisory of 0.3 µg/L, 1.16 percent of treated drinking water samples exceeded that same threshold. This demonstrates the ability of the treatment processes in place at the Ohio plants to reduce microcystin levels in drinking water while maintaining other treatment priorities with the circumstances seen during the monitoring period. The 2014 Toledo event included 15 treated water detections that occurred between August 1st and August 19th. This accounts for 57 percent of the detections above 0.3 µg/L in treated drinking water among all Ohio samples. Under the current health advisory framework Toledo would have likely had to issue a second DND/DNB in mid-August 2014, in addition to the notice that was in effect August 2nd through the 4th. There were no other locations where a DND/DNB would have been considered.

vi Utilities with cyanotoxin detections in their surface water sources were contacted in an effort to understand how PWSs respond during a cyanotoxin-producing algal bloom event. Sixteen PWSs agreed to be interviewed and provide information, including twelve in Ohio, two in Oregon, and PWSs in Kentucky and Texas. Interview questions focused on: 1) how the PWS detected the presence of cyanotoxins and what toxins were detected, 2) how did the PWS modify operations and treatment to limit the impact from the cyanotoxins, and 3) what were the impacts to the utility (financial, public relations, etc.) from the cyanotoxin-producing algal bloom event?

All of the PWSs that were interviewed detected cyanotoxins in their source water, and all were able to adequately remove the influent toxins so as to avoid DND/DNB orders. Standard operating procedures (SOPs) for monitoring and responding to cyanotoxin-producing algal bloom events varied between PWSs. Microcystin was the only cyanotoxin detected in Ohio, while cylindrospermopsin was detected in both Texas and Oregon. Anatoxin-a was also detected in Oregon. PWSs in Ohio predominantly used the (all-S, all-E)-3-amino-9-methoxy-2,6,8-trimethyl- 10-phenyldeca-4,6-dienoic acid (ADDA)-based enzyme-linked immunosorbent assay (ELISA) laboratory method, while the PWSs in other states relied on liquid chromatography tandem mass spectrometry methods (LC/MS/MS).

Three of the PWSs that were interviewed were able to adequately treat the influent cyanotoxins without modifying plant operations. Two of these three included biologically active treatment components (slow sand filters or granular activated carbon (GAC) filter caps that are biologically active), while the third plant sees cyanotoxins throughout the year and treats using a combination of ozone and GAC contactors. The other 13 PWSs that were interviewed modified operations to increase cyanotoxin removal. The process modifications included the addition of powdered activated carbon (PAC), increase in disinfection oxidant dosages, and changes to pre- filtration oxidant dosages. Only one system reported detection of microcystin in their finished water, which was not confirmed by follow up sampling. In all, the process modifications performed by the PWSs proved effective in removing cyanotoxins, although in some instances this raised challenges with other treatment needs such as disinfection byproducts (DBPs).

It proved difficult for most PWSs to assess the impact that responding to the cyanotoxin- producing bloom event had on their plants. While all of the interviewed utilities were impacted in some way by the presence of cyanotoxins in their surface water sources, financial costs incurred primarily related to additional chemical usage. Other cost factors, such as operator overtime, additional monitoring and analysis costs, etc. were generally not available.

Following data collection and review, the project team identified a 2016 DND/DNB order due to microcystin contamination issued by the City of Ingleside, Texas. A sample of discolored water collected by one of their customers from their in-home plumbing was identified as containing microcystins. Subsequent sampling identified a localized concentration of microcystins in an area of the City’s distribution system, but not in the wholesale water provider’s system. This, together with identification of unprotected cross-connections, indicates the microcystins were introduced via a cross-contamination event. Following detection, the City issued a DND/DNB order for all customers in the affected area of the distribution system and implemented flushing and installed

vii new reduced pressure zone backflow preventers to attempt to alleviate the problem. Four days after the initial DND/DNB order was issued, microcystin concentrations had reduced substantially but spread further throughout the distribution system. This led the City to lift the initial DND/DNB order, but to issue a citywide DND order for children under the age of 6 and immunocompromised individuals. Thirteen days after the initial DND/DNB order, the City lifted the citywide DND order after three consecutive rounds of sampling failed to detect microcystins.

Recommendations

In retrospect, the 2015 bloom season was handled remarkably well by PWSs in the United States. No DND/DNB orders were issued in 2015, despite favorable conditions towards cyanotoxin formation in much of the country and two extremely large blooms in Lake Erie and the Ohio River that impacted utilities in multiple states.

After reviewing the data that was compiled and speaking to utilities, a few trends are apparent that should be investigated further:

1. In many instances, detections of cyanotoxins in the finished water are not replicated in follow up sampling. It is not clear from the data if these detections represent false positives, actual detections that are not repeated due to changes in plant operation, or some other phenomena. It would be useful to investigate why there are so many “single data point” detections reported in finished water.

2. The utilities that were interviewed for this project generally had not fully quantified the cost of responding to the cyanotoxin-producing algal bloom. Most of the utilities could document the cost of additional treatment chemical (PAC, coagulant, pre-oxidant, etc.) that was used during the bloom, but none of the utilities fully captured other costs incurred such as staff overtime, additional monitoring and analysis, etc. Better methods of capturing costs are needed to document the impact that responding to cyanotoxin- producing bloom events has on the industry.

3. By far, the majority of the analyses for cyanotoxins during the 2015 bloom season were for microcystins. It is not clear if this fully captures the risk of cyanotoxin contamination, or if it is appropriate for most utilities to increase monitoring beyond microcystins to include other cyanotoxins including β-N-methylamino-L-alanine (BMAA) and 2,4- diaminobutyric acid dihydrochloride (DABA).

4. Analytical methods and sampling methodologies were not uniform amongst the states. For example, the minimum detection limit for microcystins varied between 0.01 to 0.6 μg/L, making comparability across data sets difficult. In some instances, the analytical methods used were not listed. This posed challenges in analysis and could prove challenging for utilities seeking to monitor their source and/or finished water, and increased standardization and validation of methods and sampling techniques is warranted.

viii INTRODUCTION Cyanotoxins, a broad group of phycotoxins produced by cyanobacteria, have long been recognized as potential sources of contamination for drinking water supplies. As far back as 1930, there have been suspected links between algal blooms in municipal water supply source waters and gastroenteritis outbreaks (Dillenberg and Dehnel 1960). These blooms contained both Microcystis and Anabena species, both of which are genera in the cyanobacteria phylum. Although cyanobacteria are prokaryotes and are generally considered distinct from algae, which in modern taxonomy is reserved for eukaryotes, in the literature and in practice cyanobacterial blooms are commonly referred to as algal blooms.

Algal blooms can contribute to a number of potential issues in surface water treatment plants including release of taste- and odor-causing compounds, filter clogging, and depletion of dissolved oxygen in reservoirs (Yoo, et al. 1995). In addition to these issues cyanobacteria can also release a range of compounds, referred to collectively as cyanotoxins, that act as either neurotoxins, hepatoxins, or contact irritant-dermal toxins (Carmichael 2001). The toxins produced by a specific bloom depend on the type and species of cyanotoxins present. This project focused specifically on the toxicological aspect of cyanobacterial blooms, and did not include consideration of aesthetic or operational challenges that may also occur during an algal bloom event.

Although the industry was aware of the potential for toxins to be released during algal bloom events, it wasn’t until the 1970s that researchers began investigating the potential for drinking water treatment processes to treat for cyanotoxins (Hoffman 1976). In 1996 the potential risk of algal toxins in municipal drinking water supplies was unfortunately realized when 50 hemodialysis patients in Brazil died from liver failure resulting from exposure to the cyanotoxin microcystin1 in the water used for dialysis (Jochimsen, et al. 1998). Despite these risks, however, cyanotoxins have not historically been regulated in the United States. Although cyanobacteria and their toxins have been identified as microbial contaminant candidates on every Drinking Water Contaminant Candidate List (CCL) that the United States Environmental Protection Agency (USEPA) has issued under the Safe Drinking Water Act (SDWA) to date, cyanotoxins have not been included in any of the three Unregulated Contaminant Monitoring Rules (UCMRs) that resulted from the CCL development, although 10 cyanotoxins have been identified for inclusion on the next round of UCMR testing (UCMR4) which is scheduled to begin sampling in 2018. Beyond this UCMR4 sampling, there are not currently any regulations under SDWA that deal with cyanotoxins in drinking water. This certainly could change in the future.

In August 2014, the City of Toledo, Ohio issued a Do Not Drink/Do Not Boil (DND/DNB) notice to all customers served by their water system because of a detection of microcystin in their treated water that exceeded the lifetime chronic exposure threshold concentration of 1 μg/L established by the Ohio Environmental Protection Agency (OEPA) at that time. This weekend-long DND/DNB

1 Microcystin is thought to be the most commonly occurring toxin in a class of toxins termed cyanotoxins. Cyanotoxins are potent toxins produced by some species of cyanobacteria.

1 impacted nearly 500,000 residents and businesses served by the City of Toledo, and was the largest DND/DNB order caused by cyanotoxin contamination in United States history. This event was quickly followed by regulatory efforts to manage the risk of algal toxins in drinking water. On January 8, 2015 a bill known as the “Drinking Water Protection Act” was introduced into US House of Representatives to amend SDWA to require USEPA to develop a strategic plan for assessing and managing risks associated with algal toxins in drinking water provided by public water systems (H.R. 212). Although this bill did not specify or require regulatory limits for cyanotoxins, it emphasized the need for a plan to manage cyanotoxins at the federal level.

In the summer of 2015, prior to ratification of H.R. 212, USEPA issued health advisories (HAs) for two specific cyanotoxins: microcystins and cylindrospermopsin. Health advisories are intended to provide information for public health officials on pollutants that are not regulated under the Safe Drinking Water Act but are capable of affecting drinking water quality. HAs do not establish regulatory limits, but instead identify the concentration of a contaminant in drinking water at which adverse health effects are not anticipated to occur over specific exposure durations. USEPA also developed a Health Effects Support Document for the antitoxin-a, but concluded that available toxicity data were inadequate for deriving a health-based value for that cyanotoxin (USEPA 2015a).

For both microcystins and cylindrospermopsin, USEPA established two ten-day HA levels based on age ranges: a lower HA value was established for bottle-fed infants and young children of pre- school age, while a higher HA value was established for school age children and adults (USEPA 2015b, USEPA 2015c). The microcystin and cylindrospermopsin HA levels for children under the age of 6 were set at 0.3 μg/L and 1.6 μg/L respectively. For children over the age of 6 and adults, the HA level was set at 1.6 μg/L for microcystins and 3.0 μg/L for cylindrospermopsin.

In response to the Drinking Water Protection Act, USEPA released an Algal Toxin Risk Assessment and Management Strategic Plan for Drinking Water in late 2015 (USEPA 2015d). This strategic plan describes a number of current and future initiatives that USEPA is pursuing or plans to pursue to understand and manage risk from cyanotoxin-producing algal blooms. Perhaps most importantly from a regulatory perspective is the inclusion of microcystin-LR, cylindrospermopsin, and anatoxin-a as priority contaminants in the fourth CCL (currently in draft), and the publication of two liquid chromatography tandem mass spectrometry (LC/MS/MS) methods for cyanotoxin analysis (USEPA 2015e, USEPA 2015f). Cyanotoxins were not included in the first three UCMRs because cyanotoxin analytical methods were insufficient (USEPA 2015d)); with the development of the new analytical methods and the identification of cyanotoxins as priority contaminants in the draft CCL 4, it appears likely that cyanotoxins will be included in UCMR 4, which could eventually lead to development of MCLs for microcystins, cylindrospermopsin, and/or anatoxin- a.

Based on the above considerations, and recognizing the scarcity of currently existing data regarding how frequently public water systems (PWSs) experience cyanotoxin contamination in their source water and what the impact of such contamination might be, AWWA initiated this study to investigate the observed levels and associated impacts of cyanotoxins on PWSs during

2 the 2015 cyanotoxin-producing bloom season. The purpose of the study is to provide hard data to support development of state guidance and to set the stage for future data collection efforts. To achieve that purpose the project team identified data sources for cyanotoxin concentration, collected available data and analyzed those data. This report provides: background information describing the guidance currently in place for cyanotoxins in drinking water, the data sources used for collecting cyanotoxin occurrence data, currently available data, case studies about utilities that have been treating water containing cyanotoxins and recommendations for future data collection and analysis efforts. GLOBAL APPROACH TO CYANOTOXINS IN DRINKING WATER The most common bloom-forming genus of cyanobacteria is Microcystis, which produces toxic microcystins (Yoo, et al. 1995). There are approximately 100 known congeners of microcystin (congeners are compounds that are related to each other by origin, structure, or function). Of these, the most common and the most studied congener is microcystin-LR, which contains and is named for the amino acids leucine (L) and arginine (R). In much of the literature and guidance documentation, microcystin-LR is used as a surrogate for all other microcystin congeners.

The World Health Organization (WHO) derived a guidance for microcystin-LR as follows (WHO 1998): A 13-week study in mice with microcystin-LR (Fawell, James, and James 1994) is considered the most suitable for the derivation of a guideline value. In this study, a NOAEL of 40 µg/kg of body weight per day was determined for liver pathology. A TDI of 0.04 µg/kg of body weight per day can be calculated by applying an uncertainty factor of 1000 (100 for intra- and interspecies variation, 10 for limitations in the database, in particular lack of data on chronic toxicity and carcinogenicity) to the NOAEL. An allocation factor of 0.80 is used for the proportion of daily exposure arising from drinking-water, because there is little exposure from any other source and route. The resulting guideline value for total microcystin-LR (free plus cell-bound) is 1 µg/litre (rounded figure) in drinking-water.

The WHO did not develop guidance for any other congeners because there were insufficient health effects data.

In fourteen of the sixteen countries with microcystin guidance or regulation, the WHO guidance level of 1 μg/L is utilized (USEPA 2015b, Chorus 2013). Canada and Australia established slightly different levels using the same underlying Tolerable Daily Intake (TDI) value, but different factors in the calculation of the advisory level (Government of Canada, Health Canada and the Public Health Agency of Canada 2002, Austrailian Government 2011). A summary of international guidance and regulation for a variety of cyanotoxins is shown in Table 1.

3 Table 1. International cyanotoxin guidance and regulation summary

a -

(μg/L)

Microcystin (μg/L) Cylindrospermo psin Anatoxin (μg/L) Nodularin (μg/L) Saxitoxin (μg/L) Range 1 – 1.5 1 - 15 1 - 6 1 3 Number of countries with 16 2 22 1 3 regulation or guidance 3 1 Some of the guidance and regulation is for microcystin-LR, and others are for all microcystins. Countries include Australia, Brazil, Canada, Czech Republic, Denmark, France, Finland, Germany, Italy, Netherlands, New Zealand, Singapore, Spain, Turkey, Uruguay and South Africa. 2 The Providence of Quebec, Canada limit is included, although it does not apply to all of Canada 3 Excluding the US

Cylindrospermopsin, anatoxin-a, nodularin and saxitoxin have guidance or regulation in a handful of countries, but similar to the U.S., the international focus has been on microcystins. UNITED STATES APPROACH TO CYANOTOXINS IN DRINKING WATER As discussed previously, cyanotoxins are not currently regulated at the federal level. However, state primacy agencies are free to issue their own guidance or regulations for cyanotoxins in drinking water. To date, three states have proactively issued guidance or regulation for cyanotoxins in drinking water. These values are summarized in Table 2 (Minnesota Department of Health 2015, USEPA 2015b, Oregon Health Authority 2012).

Table 2. States guidance for cyanotoxins summary Microcystins Cylindrospermopsin Anatoxin-a Saxitoxin State (μg/L) (μg/L) (μg/L) (μg/L) Minnesota 0.1 1 NG2 NG NG Ohio 3 0.3 0.7 20 0.2 Ohio 4 1.6 3.0 20 0.2 Oregon 3, 5 0.3 0.7 0.7 0.3 Oregon 4 1.6 3 3 1.6 1 Microcystin –LR 2 No guidance 3 Children under 6 and sensitive populations 4 Children 6 and older and adults 5 Oregon previously used WHO recommended levels for Microcystins, switching to USEPA levels due to HAs

Ohio and Oregon have guidance values for anatoxin-a, saxitoxin, and cylindrospermopsin in addition to microcystins. In Table 2, Ohio values have been separated onto two lines to reflect that OEPA has established different guidance values for children and sensitive populations for microcystins. These values are consistent with the HA issued by USEPA in 2015. The Minnesota

4 and Ohio values were modified in 2015 (OEPA 2014, USEPA 2015b, Minnesota Department of Health 2015). Previously Ohio had a microcystin guideline of 1 µg/L and Minnesota had a guideline of 0.04 µg/L for Microcystin-LR only.

States are taking a variety of approaches for responding to the HA. As part of this project, state primacy agencies were contacted to determine how they were approaching the issue of cyanotoxins in drinking water. This data was collected independently from the Association of State Drinking Water Administrators (ASDWA) survey of states. A detailed spreadsheet summarizing the various states approaches can be found in Appendix A. A simplified version of the information is presented in Table 3, however many of the states have subtle clarifications on one or more topics. No algal toxin expert was reached in 14 states. There were 5 states that were currently reviewing or developing their approach to addressing cyanotoxins in drinking water when this report was compiled.

Table 3. State approaches to USEPA Health Advisories Written Action on Monitoring Intend to guidance States HA? required? collect data? complete, or in development? OH, RI Yes Yes Yes Yes MD Yes No Yes Yes AL, CO, CT, IL, KS, No No Yes Yes MA, ME, NH, OR, VT SC Yes No Yes No CA, WI No No No Yes AR, IA, UT No No Yes No AK, AZ, DE, FL, HI, MN, MT, NC, NM, No No No No NV, OK, PA GA, ID, IN, KY, LA, MI, MS, NE, ND, SD, No algal toxin expert was reached. TN, VA, WA, WV Currently reviewing or developing their approach to addressing MO, NJ, NY, TX, WY cyanotoxins in drinking water.

Most states that responded do not plan to take action on the HA because the USEPA advisories are not regulations. Some state representatives cited legal concerns over enforcing a standard that is not in regulation. Ohio is taking the most proactive steps. Most states are not tracking this issue very closely.

5 OCCURRENCE BACKGROUND

Trends in Cyanotoxin Occurrence

In general, there appears to be an intensification in occurrence of cyanotoxin-producing algal blooms worldwide (de Figueiredo, et al. 2004). While there is still much that is unknown regarding cyanobacteria ecology, an increase in cyanotoxin-producing algal blooms in the past has been linked to two major factors. The first is the eutrophication of freshwater sources caused by nutrients, primarily nitrogen and phosphorus (Dolman, et al. 2012, Yuan, et al. 2014). The other is the impact of climate change that is producing a warming trend in the majority of lakes (O'Reilly, et al. 2015). Warming trends may lead to increases in Harmful Algal Blooms (HABs) that, in turn, have a significant impact on monitoring and management of bloom events (Paerl and Paul 2012, Backer and Moore 2010, Delpla, et al. 2009).

Global Overview

In many countries, cyanotoxins have been viewed primarily as a recreational water issue. However, there is a growing awareness of the public health risk cyanotoxins pose in drinking water and thus the need to monitor and remove cyanotoxins in the drinking water treatment process. Many studies report only low (below WHO or local guidelines) or undetectable levels of cyanotoxins in treated drinking water even when cyanotoxins are present in the source water (Chorus 2013, Rapala, et al. 2006, Szlag, et al. 2015, Bogialli, et al. 2012, Hoeger, Hitzfeld and Dietrich 2005, Hoeger, Shaw, et al. 2004).

Not all studies on cyanotoxins in drinking water indicate that adequate barriers are in place. In 1996, in Brazil, inadequately treated surface water was linked to the deaths of 52 dialysis patients after microcystins present in finished drinking water also passed through on-site pretreatment consisting of sand filtration, carbon adsorption, deionization, and micropore filtration (Carmichael, Health Effects of Toxin-Producing Cyanobacteria: "The CyanoHABs" 2001, Jochimsen, et al. 1998). Another study of a conventional drinking water treatment plant on the Nile river in Egypt reported microcystin reaching concentrations as high as 3.6 µg/L in the treated water (Mohamed, et al. 2015). The cyanobacterial biovolume was dense in the source water (1.1–6.6 × 107 cells/L). It is important to remember that much of the developing world does not have as strong of management practices and regulations as the U.S.

Historical Occurrence Data in the US

The USGS, in conjunction with the USEPA National Lake Assessment, determined microcystins, cylindrospermopsin, and saxitoxin concentration in samples from 1,028 lakes, reservoirs and ponds in 2007 (Graham, Loftin and Meyer, et al. 2010, Graham, Loftin and Kamman 2009, Loftin 2008). There were 5 microcystin congeners analyzed: LA, LR, LY, RR and YR (Loftin, Graham, et al. 2016). Figure 1 shows a map of the continental US with the microcystin concentrations over 0.3 µg/L that were found during the 2007 National Lake Assessment survey.

Figure 1. 2007 National Lake Assessment microcystin data

Microcystin was present in 33 percent of the samples at average concentrations of 3 µg/L and a high of 230 µg/L. The reporting limit was 0.1 µg/L. Cylindrospermopsins and saxitoxin were detected in 5 and 8 percent of the samples respectively. The detections revealed geographical trends. Microcystin detections were common in the Midwest, while saxitoxins occurred most in the upper Midwest and south. Texas, Florida and the Ohio, Indiana and Kentucky region had the most cylindrospermopsin detections (Graham and Loftin 2014). No treated drinking water samples were collected in this study.

Approximately 20 percent of the lakes surveyed were considered to have high levels of nitrogen or phosphorus. High nutrient pollution makes a lake 2.5 times more likely to be categorized as having poor biological health (USEPA 2009). The change in eutrophication status was also examined by comparing the 2007 data to data collected as part of the National Eutrophication Survey from 1972 to 1976. Using chlorophyll-a as an indicator there were 26 percent of the water bodies showing improvement while 51 percent remained unchanged. This results in 23 percent of the lakes having a worse condition in 2007 than in the 1970’s.

In 2012 the USEPA conducted another round of National Lake Assessment sampling; however, those data are not yet publicly available (USEPA 2015g). A recommended lake nitrogen level was published based on the 2012 National Lake Assessment (Yuan, et al. 2014). This study found that

7 nitrogen more strongly correlated with microcystin occurrence than any other factor or combination of factors.

One recent study looked at cyanotoxin removal throughout five drinking water treatment plants (Szlag, et al. 2015). Four of the 5 plants had source water cyanotoxin detections, and those 4 plants were able to remove the cyanotoxins to below detection limits. A 2000 Water Research Foundation study (AWWRF at the time of the study) compared source and treated drinking water cyanotoxin concentrations (Carmichael 2000). These data were collected from June 1996 to January 1998 by 20 US and 3 Canadian utilities. Out of the 677 samples collected there were 29 samples with microcystin levels above the WHO guideline of 1 µg/L in the source water. Two finished water samples were also above the WHO guideline.

There have been other cyanotoxin occurrence studies with a non-drinking water focus as well (Al-Sammak, et al. 2014, Fetscher, et al. 2015). The Al-Sammak study showed occurrence of two additional cyanotoxins, BMAA and DABA, in Nebraska waters. Both of these compounds occurred more frequently than anatoxin-a. DABA and BMAA are considered neurotoxins. BMAA has been linked to a neurodegenerative disease in humans (Cox, et al. 2016). Fetscher, et al. found microcystin in sediment from rivers and streams in about one third of the samples collected in California. RECENT OCCURRENCE DATA IN THE US Currently available cyanotoxin occurrence data do not capture the full extent of cyanotoxin occurrence in the United States for several reasons. First, the majority of states do not require cyanotoxin monitoring in drinking water. In states with testing programs, the monitoring data are not in a consistent format from state to state. Since there is no USEPA requirement for testing, various methods are used and often not indicated when data is available. In spite of these limitations, there is value in examining the available data to determine the current state of knowledge and the most beneficial next research steps.

Data presented in this section are aggregated from state data that were available on the web or were obtained from states in a spreadsheet format. No states provided surrogate data, such as cell counts. When states were contacted to determine the approach that they are taking to the USEPA guidance, any available cyanotoxin data were requested. Table 4 provides details on the source of the data collected for this study and used in this report. Knowing that some recreational water bodies are also drinking water sources, recreational cyanotoxin data were included. Each state classified the data as recreational, source water, or treated drinking water. In some cases, the recreational data are from the same water body as the source water data, however the source water samples were collected at an intake to a water treatment plant, whereas the recreational samples were collected at non-source water locations.

8 Table 4. Summary of state data Source Treated Recreational Total Years State Water Drinking Water Website samples samples included samples samples 2006-2007, MN 671 0 0 671 Data not online 2012 OH 2,741 4,869 2,678 10,301 2010-2015 http://epa.ohio.gov/ddagw/HAB.aspx OR 0 129 27 156 2011, 2015 Data not online 532 http://www.drinkingwater.vt.gov/pcws VT 3 532 1,067 2015 wqbga.htm http://www.wvdhhr.org/oehs/public_h WV 0 48 24 72 2015 ealth/BGA_Sample_Results.asp 2000, 2007- WA 6,593 0 0 6,593 https://www.nwtoxicalgae.org/ 2015

The vast majority of drinking water data are from Ohio (7,547 out of 8,839 samples). Additional drinking water data are from Oregon, Vermont, and West Virginia. The fresh water recreational cyanotoxin data are from Minnesota, Ohio, Vermont, and Washington. Although the focus of this study was the 2015 bloom season, older data were included when available in the state databases. The data presented in this section were downloaded in December of 2015.

For clarity when graphing the data, anything reported as below the detection limit has been graphed as zero. Data points reported as greater than a given value (122 data points) were graphed as that given value. For example, data reported as greater than 5 µg/L without a more specific value were graphed as 5 µg/L. Some of the data sets did not indicate a detection limit. For the data where a detection limit was documented, Table 5 details the minimum, maximum and average detection limit reported for each cyanotoxin.

Table 5. Detection limit range of each cyanotoxin Cyanotoxin Minimum (μg/L) Maximum (μg/L) Average (μg/L) Anatoxin-a 0.006 1 0.02 Cylindrospermopsin 0.05 5 0.21 Microcystin 0.01 0.6 0.23 Saxitoxin 0.02 0.05 0.02

Saxitoxin has a narrow range of detection limits, and overall has a low average detection limit (0.02 µg/L). The detection limit for anatoxin-a varies by three orders of magnitude. This is significant because data that is reported as non-detect by one method may have been detected if a lower detection limit was used. The inconsistent detection limits are a constraint of this combined dataset.

As shown in Table 6, every state in the spreadsheet tested for microcystin. Ohio and Washington also tested for saxitoxin, anatoxin and cylindrospermopsin. Oregon did not test for saxitoxin, but did test for the other three cyanotoxins. Vermont also tested for cylindrospermopsin.

9 Table 6. List of cyanotoxins tested for in each state State Microcystin Cylindrospermopsin Anatoxin-a Saxitoxin Minnesota Yes Ohio Yes Yes Yes Yes Oregon Yes Yes Yes Vermont Yes Yes West Virginia Yes Washington Yes Yes Yes Yes

In Figure 2, the total number of samples in the spreadsheet is shown in blue, and include all of the cyanotoxins tested. These data are further divided into recreational water data (orange) and drinking water data (green). Each small cube represents 37 samples.

Figure 2. Cyanotoxin occurrence data in drinking and recreational water

Recreational data are included because, in most states, those are the only data available. Recreational water is also often the source water. Although 45 percent of recreational samples had cyanotoxin detections, it is possible that these data are not a complete representation because many states only sample when blooms have been visually detected in a water body. Thus, average annual occurrence rates for all water bodies can be expected to be below 45

10 percent. Out of the 3,261 treated water samples collected, 2.7 percent of those were detections. All of the treated water detections were from Ohio.

Figure 3 shows the seasonal pattern of microcystin occurrence from 2006 through 2015 (because of the limited data available, this may be partially a reflection of sampling practices rather than full occurrence). Sixty-one data points (1%) of recreational data are not shown because they are so high they obscure the rest of the data. The highest reported level was 80,000 µg/L. Recreational data are shown as light orange squares, and the source water concentrations are shown as light green diamonds.

Figure 3. Recreational and source water microcystin data from 2006 to 2016

11 Although detections of microcystin are possible year-round, there is a seasonal trend to the data with the highest concentrations occurring in the late summer and early fall. This trend is even more pronounced when comparing drinking water microcystin levels to recreational water microcystin levels. Figure 4 presents the concentration distribution of microcystins in both source water and recreational water. Those samples of source water with the highest concentrations of microcystins are still substantially lower than the concentration of microcystins in the recreational water samples with the highest concentrations.

Figure 4. Microcystin concentration histogram

The majority of source water samples have non-detect results, with 57.5 percent of samples below detection limits. Many of the recreational water samples also had non-detect results, with 44.3 percent of samples below detection limits. Looking at only at source water samples above the detection limit, 51.4 percent are between 0.3 and 1.6 µg/L. Recreational water detections have higher concentrations overall with 30.1 percent of those samples in the 1.6 to 20 µg/L range.

Because different analytical methods are used by the different agencies submitting data to these datasets, detection limits vary between samples. For non-detect samples, the detection limit of microcystin varied between 0.01 to 0.6 μg/L. Figure 5 presents a histogram of microcystin detection limits for both drinking water and recreational samples. The minimum detection level varied for these samples: In drinking water, 73 percent of samples that were non-detect had a

12 detection limit of 0.3 μg/L, which is the USEPA HA for microcystin. In comparison, the average detection limit for recreational microcystin samples was 0.17 μg/L. Therefore, it is possible that samples with microcystins concentrations above 0.17 μg/L but below 0.3 μg/L would have shown as detections in recreational water and non-detects in drinking water in some instances.

Figure 5. Microcystin detection limit histogram

Ohio Cyanotoxin Data

Since the majority of cyanotoxin occurrence data was gleaned from the Ohio database, it is worth looking at Ohio data separately from the other datasets. Analyses of both the recreational water dataset and drinking water dataset collected from Ohio are presented in this section.

Ohio Recreational Water Data

The Ohio microcystin data in recreational waters are shown in light orange in Figure 6. Samples exceeding the microcystin recreational water guidelines are shown in yellow. Since there are a variety of different recreational limits in the different states, the data are examined through two lenses. The box on the left compares the data to the lowest guideline (0.8 µg/L), while the box on the right compares the detections to the highest guideline (20 µg/L).

13 The comparison of the data to these two guideline values ranges from 23.4 percent of samples exceeding the highest guidance value to 51.8 percent exceeding the lowest guidance value.

Figure 6. Microcystin occurrence data in Ohio recreational water

Ohio Drinking Water Data

Most of the drinking water data come from Ohio so it is informative to look at those data in more detail. Figure 7 shows drinking water samples in light green. The detection data are inclusive of all cyanotoxins that were tested (microcystin, cylindrospermopsin, anatoxin-a and saxitoxin). Samples exceeding the microcystin HA level of 0.3 µg/L are shown in yellow.

Figure 7. Microcystin occurrence data in Ohio drinking water 2010 to 2015

Although 43.90 percent of source water samples exceeded the microcystin HA of 0.3 µg/L, only 1.16 percent of treated drinking water samples exceeded that same threshold. This provides evidence that the majority of PWSs in Ohio were generally able to successfully reduce microcystin levels in drinking water either through operation of existing treatment systems or implementation of additional treatment, although more study would be necessary to directly match source water to finished water samples for direct comparison.

No significant correlation (R2 of 0.55) between source water concentrations and treated water concentrations were observed.

Anatoxin-a, cylindrospermopsin and saxitoxin were not detected above the HA or Ohio limits in the source or treated drinking water. Table 7 summarizes the number of source water samples collected in Ohio and the range of results for each cyanotoxin. Table 8 summarizes the number and range of results for treated drinking water cyanotoxin detections.

15 Table 7. Cyanotoxin detections in Ohio source water Average/ Minimum Maximum Result Number of Samples Cyanotoxin (μg/L) (μg/L) (μg/L) detections collected Anatoxin-a 2 1 4 Cylindrospermopsin 0.11 1 270 Microcystin 0.054 20,000 25 1,877 4,162 Saxitoxin 0.022 0.88 0.22 164 433

Table 8. Cyanotoxin detections in Ohio treated drinking water Average/ Minimum Maximum Result Number of Samples Cyanotoxin (μg/L) (μg/L) (μg/L) detections collected Anatoxin-a 0 2 Cylindrospermopsin 0 179 Microcystin 0.054 11 1.33 32 2,243 Saxitoxin 0.022 0.064 0.037 56 254

There were only 254 treated drinking water saxitoxin samples collected, and there were 56 detections. The average detection limit for saxitoxin was 0.022 µg/L, which is about an order of magnitude lower than the average microcystin detection limit (0.23 µg/L). This fact may contribute to the higher number of detections. The highest saxitoxin detection was 0.064 µg/L, which is only slightly higher than the minimum microcystin detection of 0.054 µg/L.

Saxitoxin samples were collected from 32 locations with 65 percent of the detections in the source water at a single plant. In treated drinking water, 82 percent of saxitoxin detections were from samples collected at a single location, where there were 44 detections from July 31st through September 14th, 2015. That plant had two more detections, one on September 21st, and the other in December. The remaining treated water detections were from three additional locations, two locations with single detections, and one location with eight detections over a nine-day period. Saxitoxin does not currently have an EPA health advisory value associated with it for drinking water.

Regulatory Implications in Ohio

A more detailed study of the Ohio finished water detections is helpful in understanding the occurrence and impact of cyanotoxins in drinking water production, and to understand the implications of the current HA to Ohio utilities. All of the microcystin detections over 0.3 µg/L at Ohio treatment plants occurred during nine incidents. An incident is defined as a treated water detection over 0.3 µg/L.

16 In September 2013 at the Carroll Township treatment plant there was an initial detection of microcystin in treated water, followed by two days of confirmation samples ranging in levels from 1.43 to 3.56 µg/L. No additional samples were collected until 10 days after the final confirmation sample. This incident resulted in the first Do Not Drink order in Ohio due to cyanotoxins (Ohio Environmental Protection Agency 2014).

The 2014 Toledo event included 15 treated water detections that occurred between August 1st and August 19th. Under the current regulatory framework Toledo would have likely had to issue a second Do Not Drink/Do Not Boil (DND/DNB) in mid-August 2014, in addition to the notice that was in effect August 2nd through the 4th. The 2014 Toledo event included 15 treated water detections from samples taken between August 1st and August 19th. This accounts for 57 percent of the detections above 0.3 µg/L in treated drinking water among all Ohio samples.

The other seven incidents of treated water detections had initial detections, but the follow-up sampling did not confirm any detections. Three of the detections were on the same day, July 24, 2015, at three different locations. The samples were analyzed at the same laboratory. Source water concentrations ranged from non-detect to 37.2 µg/L.

UTILITY RESPONSES TO CYANOTOXIN-PRODUCING ALGAL BLOOMS

The August 2014 Do Not Drink/Do Not Boil event in Toledo, Ohio placed a spotlight on the potential for cyanotoxin-producing algal blooms to impact water utilities. Although the industry has been aware of cyanotoxins as contaminants of potential concern for many years (WRF 1995), the high profile and system-wide impact experienced in Toledo has resulted in renewed emphasis on preparing for and responding to cyanotoxin-producing algal bloom events at many utilities in the United States.

There is a particular emphasis on cyanotoxin-producing algal bloom events for public water systems located in Ohio, driven by several factors. In addition to the 2014 Toledo event, Ohio experienced widespread algal blooms in August and September of 2015, with a large bloom in Lake Erie and an extended bloom in the Ohio River. OEPA has also drafted a proposed regulation to, among other things, establish action levels for microcystins based on the USEPA HA, establish cyanobacteria screening and microcystins monitoring requirements for PWS using surface water, and to require submittal and approval of a cyanotoxin general plan for PWSs that detect microcystins in excess of 1.6 µg/L in more than one raw water sample within a consecutive 12- month period. Because of widespread bloom occurrence and OPEA’s focus on cyanotoxins, Ohio PWSs were generally aware of and prepared for the potential of cyanotoxin-producing algal blooms in their source waters.

However, this is not to say that PWSs in other regions of the country are not concerned about the potential for cyanotoxins in their source water. Many utilities had either experienced blooms previously or recognized the potential for future blooms. Although there were not any blooms

17 in 2015 as large as the Lake Erie or Ohio River blooms, detections were noted in many other areas.

In an effort to better understand how cyanotoxin-producing algal blooms affect PWSs, select utilities who had detected algal blooms and cyanotoxins in their surface water sources were contacted and interviewed to better understand how the utilities responded to and dealt with cyanotoxin events. Effort was made to understand the scope of what the PWSs experienced and how they responded to the event. In particular, this study focused on: 1) how the PWS detected the presence of cyanotoxins and what toxins were detected, 2) how did the PWS modify operations and treatment to limit the impact from the cyanotoxins, and 3) what were the impacts to the utility (financial, public relations, etc.) from the cyanotoxin-producing algal bloom event?

Of the 44 utilities contacted, 16 agreed to be interviewed and provide information for this study. Twelve of those 16 were located in Ohio. Two of the remaining four interviewed were located in Oregon, in addition to one PWS in Kentucky and one in Texas. The following section summarizes the information gathered from these interviews.

Detection of Cyanotoxins

All of the utilities contacted detected cyanotoxins in their source water in 2015. However, there was variation between the respondents regarding monitoring strategies, types of cyanotoxins that were monitored and detected, and analytical methods.

The date on which cyanotoxin-producing algal blooms first started to appear in 2015 varied by water source. The first reported bloom occurred in Oregon in mid-May. Many of the northwestern Ohio respondents reported bloom events in late July, while eastern Lake Erie and the Ohio River blooms were not reported until early September. The average duration of a bloom event was ~80 days, with the shortest duration bloom lasting ~30 days and the longest extending ~180 days.

Out of the 16 PWSs interviewed, 13 respondents indicated that they had standard operating procedures (SOPs) in place to detect and respond to cyanotoxin-producing algal bloom events. Of those, nine PWSs had written SOPs that were for internal use only (as opposed to formal documents submitted to an outside agency for review) while the remaining four PWSs relied on informal SOPs that consisted of verbal discussions during utility planning meetings.

The specifics of each SOP varied considerably. While the majority of the respondents reported a source water monitoring component to their SOPs, the specificity of monitoring varied between when samples are collected and what parameters are monitored. Most sampling plans were seasonal, and even those utilities that monitor year-round tend to move to an increased sampling program during the warmer months when blooms are expected (generally starting in June or July or after visual identification of a bloom). During the summer months, samples are generally collected weekly or three times a week, with reduced sampling (if any) in the winter months. One respondent reported using a monitoring sonde in Lake Erie to collect color and pH data to

18 help with bloom identification, and two respondents regularly collect algae counts and identify algae species present to help identify conditions when cyanotoxins might be present. Trigger levels for increased monitoring and/or treatment modifications also varied considerably between systems.

Although 15 of the respondents routinely monitor for cyanobacteria and/or cyanotoxins, only eight of the respondents reported that they first detected cyanotoxins in 2015 via routine monitoring. Eight reported that they were notified by upstream or adjacent water users, while three detected the cyanotoxin-producing algal bloom via visual inspection and two were notified by their state primacy agency (some respondents reported multiple means of first detection). One respondent noted that the cyanotoxin-producing algal bloom was detected not only by visual identification, but also by decreased filter run times and algae identification.

All of the 16 respondents monitored for microcystin. Some of those 16 only monitored for microcystin, while other systems also monitored for cylindrospermopsin, saxitoxin, and/or anatoxin-a. The number of systems monitoring for and detecting each of the cyanotoxins is presented in Table 9.

Table 9. Cyanotoxins monitored for and detected by respondent PWSs Monitored Detected No. of % of No. of % of Systems Systems Systems Systems Microcystin 16 100% 14 88% Cylindrospermopsin 8 50% 2 13% Anatoxin-a 3 19% 1 6% Saxitoxin 6 38% 0 0%

The two respondents that did not detect microcystin during the 2015 bloom season were located outside the state of Ohio. One of the Oregon respondents only detected anatoxin-a, while the Texas respondent only detected cylindrospermopsin. Both of the cylindrospermopsin detections also occurred outside of Ohio; in addition to the Texas respondent, the other Oregon respondent detected cylindrospermopsin in addition to microcystin. None of the Ohio respondents that monitored for additional cyanotoxins detected any toxin other than microcystin. Data regarding the specific congeners of cyanobacteria that were detected were not available.

Although all of the respondents detected cyanotoxins during extended bloom events, only one of the respondents detected cyanotoxins (microcystin) in their finished water during the 2015 season. Increased sampling after the one positive detection (at 0.34 µg/L) did not identify any samples above detection limits.

The most common analytical method use for cyanotoxin analysis was the ELISA lab method, which all of the Ohio respondents used. The Kentucky respondent and one of the Oregon respondents also utilized the ELISA lab method supplemented with LC/MS/MS with solid phase extraction. The other Oregon respondent utilized a high-performance LC-PDA method, while the

19 Texas respondent utilized an LC/MS/MS method both with and without solid phase extraction. Detection levels generally followed the method used; all respondents using ELISA methods reported 0.3 µg/L detection levels, while the high-performance LC-PDA method achieved a detection level of 0.2 µg/L. The Texas respondent utilizing LC/MS/MS achieved the lowest overall detection levels, reporting detection levels of 0.02 µg/L for anatoxin-a, 0.05 µg/L for cylindrospermopsin, and 0.1 µg/L for microcystin. All respondents reported lysing samples prior to analysis, so reported cyanotoxin levels generally represent total (intracellular and extracellular) levels. Analytical method usage by the responding utilities is summarized in Table 10.

Table 10. Analytical methods used for cyanotoxin analysis Detection Level No. of PWSs Method Microcystins Cylindrospermopsin Anatoxin-a Utilizing (µg/L) (µg/L) (µg/L) ELISA 12 0.3 0.3 0.3 ELISA + LC/MS/MS 2 0.3 0.3 0.3 LC/MS/MS 1 0.1 0.05 0.02 HPLC-PDA 1 0.2 0.2 0.2

Modifications to Operations and Treatment

Operational Strategies during a Cyanotoxin Event

Cyanotoxins can be challenging contaminants for conventional water treatment plants to remove because they may exist in a water treatment plant in two forms: extracellular (i.e., in the bulk liquid) or intracellular (i.e., cell bound and still within an intact cyanobacterial or blue-green algal cell). Both forms are significant, and must be considered when evaluating changes to plant operations and treatment.

The form of cyanotoxin reaching the plant will influence how a utility should respond to a cyanotoxin-producing algal bloom event. Extracellular toxins are generally poorly-removed by conventional flocculation-filtration-chlorination procedures (Himberg et al, 1989); however, conventional flocculation-filtration can effectively remove cyanobacterial cells containing intracellular cyanotoxins without causing the release of additional cell metabolites (Chow et al, 1999). Therefore, if utilities are seeing cyanotoxins at their intakes which are primarily intracellular, the conventional treatment processes would be one effective barrier to removing cyanotoxins. Additional process modifications may be necessary to avoid in-plant release of extra-cellular cells. For example, sludge withdrawal from sedimentation basins may need to be increased to reduce the amount of algal cells that decay and release extracellular toxins within the plant (OEPA, 2015). It may also be necessary to avoid recycle of liquid residuals streams (e.g. thickener supernatant, clarified spent filter backwash water, etc.) to prevent cyanotoxins from returning to the head of the plant. The OEPA recommends discontinuing the use of pre-oxidation (i.e. feeding oxidants at any point prior to filtration) during a cyanotoxin-producing algal bloom

20 event because the pre-oxidant may cause cells to lyse, converting intracellular cyanotoxins to extracellular (OEPA 2016). Exceptions would be made if testing established that a significant majority of toxins present were in extracellular form. If pre-oxidants are required, low doses of permanganate could be used as doses of 1 and 3 mg/L have been demonstrated to oxidize extracellular toxins without impacting the integrity of cyanobacterial membranes (Fan, et al. 2014).

Alternatively, if the influent cyanotoxins are primarily extracellular in nature, other treatment methods will be needed for cyanotoxin removal. The most common treatment methods for removal of extracellular cyanotoxins are adsorption and oxidation.

Adsorption via powdered or granular activated carbon (PAC or GAC) has proven effective for removal of extracellular toxins (Falconer et al, 1989). The efficacy of GAC-capped filters or GAC contactors will depend on operating conditions (e.g. empty bed contact time, carbon age, presence of other compounds being adsorbed, etc.), and may require carbon and water matrix specific testing to verify the allowable operating ranges to achieve acceptable removal within a given system. Systems that currently use PAC for other treatment purposes (e.g. taste and odor control, etc.) may need to feed higher doses of PAC than normal and/or feed PAC in different locations to achieve desired cyanotoxin removal rates.

Oxidation can also be effective for cyanotoxin removal, although the effectiveness of this treatment method is dependent on both the oxidant being used (e.g. chlorine, chlorine dioxide, potassium permanganate, ozone, etc.), the type of cyanotoxin present, and other water quality parameters (e.g. temperature, pH, TOC, etc.). AWWA has developed a calculator for estimating the oxidant dose required for removal of specific cyanotoxins, which is available here: http://www.awwa.org/resources-tools/water-knowledge/cyanotoxins.aspx. Additional information regarding the effectiveness of specific oxidants for cyanotoxin removal can be found in publications by AWWA/WRF (2015) and OEPA (2015).

As an alternative to treatment, some PWSs may be able to avoid the introduction of cyanotoxins entirely by either modifying their raw water intake level (if their intake structure is configured with multiple intake elevations) or by avoiding the use of the contaminated source altogether and relying on in-system storage or an alternate source.

Utilities’ Experiences during the 2015 bloom season

The 16 utilities that were interviewed for this report were asked about their strategies for responding to the detection of cyanotoxins in their source water. The respondents provided information regarding modifications to plant operations and treatment changes.

Out of the 16 systems that were contacted, three did not make any modifications to treatment or operations but were able to demonstrate removal of the cyanotoxins present in the raw water. Of those three, two PWSs had biological treatment aspects in their treatment train: one utilizes slow sand filtration while the other has GAC filter caps that are biologically active during the

21 summer months. The slow sand filtration plant was able to demonstrate removal of microcystin- LR peaks of 1.2 µg/L and cylindrospermopsin peaks of 38.9 µg/L in the raw water reservoir without detectable levels of either toxin in the combined filter effluent. The plant with GAC filter caps was challenged with lower cyanotoxin concentrations, with peak concentrations of 0.77 µg/L of microcystins in its raw water. However, that plant also was able to demonstrate removal of microcystins below detection limits without any modifications to plant operations.

The third PWS that did not modify operations or treatment is an outlier, as it consistently detects microcystins in its source water throughout the year. Because microcystins are essentially always present in the PWS’s source, the plant is required to operate in a manner that will remove cyanotoxins year round instead of limiting enhanced treatment to an algal bloom season. This plant utilizes pre-filtration ozonation and post-filtration GAC adsorbers, which have effectively removed microcystins since data collection began in 2010. There have been only two instances of microcystin detections in the finished water at this plant: the first appears to be a false positive with a reported value of 11 µg/L that was not confirmed by repeat sampling (which remained below detection limits), while the second includes a four-week period in 2014 when finished water levels of 0.2 µg/L were reported (the detection limit of the analytical method used at that time was reported as 0.15 µg/L). Since 0.2 µg/L remains below the HA for microcystins, the PWS appears to be able to utilize ozone oxidation and GAC adsorption to effectively treat microcystins over a range of water quality conditions. During the 2015 bloom season, this plant was able to treat influent microcystin concentrations as high as 185 µg/L without finished water detections.

The other thirteen PWSs that were interviewed decided to implement changes to plant operations and treatment processes to enhance removal of cyanotoxins. Most of the respondents reported that multiple treatment technologies were utilized to provide layers of protection against cyanotoxin breakthrough. Table 11 summarizes the treatment technologies utilized by these PWSs for cyanotoxin removal.

22 Table 11. Summary of cyanotoxin treatment practices at PWSs that were interviewed Modified Treatment/Practice for Cyanotoxin Removal Operations Eliminate Shut Modify Utility for Recycle of Adsorption Oxidation Down Pre-filter Cyanotoxin Liquid Intake† Oxidation Removal Residuals A Yes Yes Yes No Yes No B Yes No Yes No Yes No C No Yes Yes No No No D Yes Yes Yes No Yes No E Yes Yes Yes No Yes No F Yes Yes Yes No Yes Yes G Yes Yes Yes No Yes Yes H Yes No Yes No Yes Yes I Yes Yes Yes No Yes No J Yes No Yes No Yes No K Yes Yes No Yes No Yes L No No No No No No M Yes Yes Yes No Yes No N Yes Yes No No No No O Yes Yes No Yes Yes No P No Yes No No No No † Shut down intake refers to temporarily suspending intake of raw water, either by relying on off-line storage or by using an alternate source

The most common treatment technology utilized by the respondents was activated carbon adsorption, with 12 out of 16 PWSs reporting use of PAC and/or GAC as shown in Figure 8. Of the respondents using activated carbon, three systems utilized both PAC feed systems and GAC contactors or filter caps (including the plant discussed previously that operates biologically active GAC filter caps during warm water conditions). Two other respondents relied solely on GAC contactors, while seven additional PWSs utilized PAC. Four of the systems using PAC reported that PAC was not typically fed at the plant on regular basis for taste and odor events, while six of the systems using PAC reported that new PAC feed points were added in response to the cyanotoxin-producing algal bloom event. PAC dosages varied considerably, from a low of 1 mg/L (at a plant that did not regularly feed PAC) to a high of 60 mg/L (at a plant that normally fed 8 to 10 mg/L for taste and odor considerations). None of the plants utilizing GAC systems reported modifying operations of those systems specifically for cyanotoxin treatment.

23 Did Not Utilize Adsorption PAC Only GAC Only 4 PWS PAC + GAC

7 PWS 3 PWS 2 PWS

Figure 8. Breakdown of adsorption technologies used by the interviewed PWSs

The next most common change to plant operations was to modify oxidation conditions for disinfection, which was reported by eight of the respondents. This generally was accomplished by increasing chlorine dosages above normal operating conditions, although two plants were able to increase the contact time of the oxidation processes by either decreasing plant flow (by operating longer each day) or by changing clearwell depth levels. One utility increased the effectiveness of chlorine for inactivating cyanotoxins by changing its pH control strategy to avoid raising treated water pH until after the clearwells, which prolonged the amount of time the treated water remained below pH 8.0 (where chlorine is most effective for oxidation of cyanotoxins). The treated pH was adjusted to normal levels prior to the final point of entry.

While modifying oxidation conditions provided an extra layer of protection against cyanotoxins reaching the finished water for many PWSs, there were several PWSs constrained in how much they could enhance oxidation due to concerns about forming excessive DBPs. One utility experienced a DBP exceedance in the middle of the bloom season, measuring HAA5 at 80 µg/L. However, this occurred when the raw water source was measured at 25 µg/L of microcystins, so the utility decided it was better to risk a DBP violation than a potential do not drink/do not boil (DND/DNB) order. Another utility reported a DBP exceedance during the 2014 bloom season, but was able to prevent a repeat during the 2015 bloom season.

The third most common treatment modification that many of the respondents reported was modifying pre-filter oxidant feeds. Here there was a clear divergence in strategy between utilities. One strategy, used by five of the PWS, relied on increasing pre-filter oxidant dosages (potassium permanganate or ozone) to preemptively “attack” the cyanotoxins. Although this could potentially lyse the cyanobacterial cells, increase the amount of extracellular toxins, and

24 reduce the effectiveness of coagulation and clarification to remove intracellular toxins, these utilities decided that this downside was offset by the increased oxidation of the cyanotoxins prior to filtration.

Three of the respondents took the opposite strategy, and eliminated pre-filter oxidation (these plants normally fed permanganate for taste and odor or zebra mussel control). These utilities were concerned with lysing algal cells releasing further extracellular toxins, while the utilities that increased pre-filter oxidation reported that it enhanced total microcystin removal.

Finally, one respondent did not alter pre-filter oxidant dosages, but instead changed the feed location from the raw water intake to after the clarifiers. This change was accompanied by a new PAC feed at the raw water intake, which necessitated changing the potassium permanganate feed location.

Other treatment modifications were not widely implemented. Most of the PWSs that were interviewed were not able to shut down their intake or utilize an alternate source during the algal bloom events. The two utilities that did report using this strategy were located along the Ohio River and were able to shut down their intakes for one to three days (relying on in-system storage during that time) to allow the peak of the cyanotoxin bloom to pass downstream of the plants. Likewise, only two utilities reported modifying their recycle practices to avoid reintroducing algal cells to the head of the plant (although many utilities did not recycle liquid residuals in the first place). In each instance, the PWS was able to utilize a surface water outfall with an existing NDPES permit to discharge spent filter backwash water and other recycle streams during the cyanotoxin-producing algal bloom.

Impacts to Utilities

Each of the PWSs contacted for this study have been impacted by the detection of cyanotoxins in their source water; however, the nature and extent of these impacts were highly specific to each PWS. For those PWSs that did not need to modify treatment, the impact may not have extended beyond increased monitoring and vigilance during the cyanotoxin-producing algal bloom. Other utilities significantly modified plant operations to enhance treatment and removal of cyanotoxins.

This study did not identify any DND/DNB orders in the 2015 bloom season issued for cyanotoxin contamination in the United States. Extrapolating from the experiences of the PWSs interviewed, even though a number of PWSs may have experienced cyanotoxin contamination in their source waters, those systems were able to prevent contamination of the finished water through existing or enhanced treatment. By avoiding having to issue DND/DNB orders, these PWSs were able to avoid the widespread impacts experienced by the City of Toledo in 2014. Assessing the extent of the impacts that did occur, however, has proven to be difficult.

None of the PWSs interviewed have compiled comprehensive assessments of the financial impacts from the 2015 bloom season. A few systems have provided preliminary estimates of

25 certain aspects, such as increased PAC or permanganate costs. These costs were highly variable, ranging from $173 at a small 0.4 mgd plant to increase PAC usage for three days, to $280,000+ for a large system (335 mgd rated capacity) to increase PAC usage over three months. However, these estimates are often incomplete; for example, none of the systems had estimated increased labor costs due to overtime nor were they able to provide the cost of increased monitoring during the bloom event. Without such information it is difficult to understand the full financial impact to PWSs that experience cyanotoxin contamination in their source water.

It is also difficult to assess capital costs associated with preparing for cyanotoxin events. One of the utilities interviewed had recently installed a UV advanced oxidation process (AOP); while one of the advantages of this system is protection against cyanotoxins, the system was planned and constructed primarily for control of taste- and odor-causing compounds. Another of the utilities that participated in this study is currently planning an $800,000+ construction project to improve the PAC storage and feed systems at their two water treatment plants. While the project is necessary to increase the capacity of the PAC systems to meet projected usage during a cyanotoxin-producing algal bloom event, over half of the projected project cost is to replace existing PAC mixing and transfer equipment that is at the end of its useful life. The project was accelerated due to concerns regarding response to cyanotoxins, but much of the project would have been required even if cyanotoxin removal was not one of the project goals.

Given the myriad ways in which PWSs can approach protecting against cyanotoxins, it is currently difficult to assess the economic impact of cyanotoxin-producing algal events. Even those utilities who recently reacted to cyanotoxins in their source water were not able to fully capture the full financial cost of that response. Additional work is needed to provide a framework for capturing these impacts during future events.

2016 DND/DNB Order

Following the primary data collection effort for 2015 bloom season, a DND/DNB order for cyanotoxin contamination was issued by the City of Ingleside, Texas on January 29, 2016. The order was fully lifted on February 11, 2016. The cause of the contamination event appears to have been cross-contamination within the distribution system, although it was not possible to definitely point to a specific contamination event. This event is unique compared to those described in the literature because cyanotoxins were never detected in the system’s source water, with the only detections occurring in the distribution system.

The City of Ingleside purchases wholesale water from the San Patricio Municipal Water District (SPMWD) and distributes that water to customers within its service boundary. Texas Commission on Environmental Quality (TCEQ) does not require monitoring for cyanotoxins, so neither SPMWD nor City of Ingleside were actively monitoring for these compounds. In this case, contamination was discovered because of a citizen who collected water samples from their in- house plumbing due to discolored water. That citizen submitted the sample to Texas A&M for analysis, which detected microcystins. Initial sample results from samples collected on January 26, 2016 identified MC-LF and MC-RR in samples taken in the affected residence and upstream

26 and downstream of the residence. The highest levels were upstream of the residence, with peaks of 3.6 µg/L MC-LF and 1.5 µg/L MC-RR. All detections indicated the toxins were present intracellularly, with no detections in filtered samples.

These initial detections were followed with additional sampling on January 28, 2016. Microcystins concentrations in these samples were considerably higher. Unlike the January 26 sampling event, the microcystins in the January 28 sample were primarily extracellular, with peak levels of 12.3 µg/L of MC-YR and 64.6 µg/L MC-LF detected.

Following the detection of microcystins, the City issued a DND/DNB order for all customers within a localized portion of the City’s distribution system where the microcystins had been identified. After the City issued the DND/DNB order, sampling was extended throughout the entire distribution system. The City also initiated inspections in the affected area, which identified three customers without reduced pressure zone (RPZ) backflow preventers between irrigation wells and their domestic system. Further review by Texas Commission on Environmental Quality identified at least 99 customers who maintained private wells while connected to the City’s distribution system without air gaps or reduced-pressure backflow prevention assemblies to protect against contamination of the City’s distribution system. This, together with the fact that the City of Ingleside’s system is completely enclosed and not exposed to solar radiation and the fact that testing by SPMWD failed to identify cyanotoxins in either their source or at the point- of-entry to the City of Ingleside’s system, suggests that cross-contamination was the likeliest vector for the microcystins.

Samples on February 2, 2016 indicated that microcystins levels had dropped substantially, but did detect microcystins distributed further throughout the distribution system. Peak concentrations of 0.1 µg/L MC-YR, 0.1 µg/L MC-LA, and 0.66 µg/L MC-RR were detected. The results from the February 2 sampling event led the City to lift the DND/DNB from the initial area on February 3, 2016. However, at that time the City issued system-wide “Do Not Drink the Water” notice for children under the age of 6 and for individuals with compromised immune systems, in line with the USEPA HA for microcystins.

During the initial DND/DNB order, the City provided 2 gallons of water per person per day to households in the impacted area. Following the move to a City-wide DND order for children under 6 years of age and immunocompromised individuals, the City maintained the 2 gallons per day provision for the population meeting the criteria. On February 5, 2016 the City collected the first round of samples without any detection of microcystins in the water. Two additional rounds of sampling without detections led the City to lift the DND order on February 11, 2016.

City outreach efforts throughout this contamination event have included postings to the City website, the police department’s Facebook page, radio and TV ads, reverse 911 calls, fliers in the impacted area, and postings in public areas such as City Hall and the post office. Outreach has been largely successful, although the City noted that reverse 911 calls only extended to citizens who had opted in to the service. It was also noted by City officials that the original postings issued

27 by the City did not contain a graphical map indicating the impacted area, and a street-level description of the impacted area was difficult for citizens to interpret.

RECOMMENDED NEXT STEPS

No DND/DNB orders are known to have been issued in 2015, despite favorable conditions towards cyanotoxin formation in much of the country and two extremely large blooms in Lake Erie and the Ohio River that impacted utilities in multiple states.

This project was initiated to collect information to support analysis of PWS and community impacts from cyanotoxins in drinking water. After reviewing the data that was compiled and speaking to utilities, a few trends are apparent that should be investigated further:

REFERENCES

Al-Sammak, M., K. Hoagland., D. Cassada, and D. Snow. 2014. "Co-occurrence of the cyanotoxins BMAA, DABA, and anatoxin-a in Nebraska reservoirs, fish, and aquatic plants." Toxins 6 (2): 488-508. Austrailian Government. 2011. "Australian Drinking Water Guidelines 6." Guidance Document. Backer, L., and S. Moore. 2010. Harmful Algal Blooms: Future Threats in a Warmer World. New York, NY: Nova Science Publishers, Inc. Bogialli, S., F. di Gregorio, L. Lucentini, E. Ferretti, M. Ottaviani, N. Ungaro, P. Abis, and M. di Grazia. 2012. "Management of a toxic cyanobacterium bloom (Planktothrix Rubescens) affecting an italian drinking water basin: A case study." Environmental Science & Technology 47 (1): 574-584. Carmichael, W. 2000. Assessment of blue-green algal toxins in raw and finished drinking water. WRF Report, Denver, CO: Water Research Foundation. Carmichael, W. 2001. "Health Effects of Toxin-Producing Cyanobacteria: "The CyanoHABs"." Human and Ecological Risk Assessment 7 (5): 1393 - 1407. Chorus, I., ed. 2013. Current Approaches to Cyanotoxin Risk Assessment, Risk Management, and Regulations in Differnt Countries. Dessau-Roßlau: Federal Environment Agency (Umweltbundesamt). Cox, P., D. Davis, D. Mash, J. Metcalf, and S. Banack. 2016. "Dietary exposure to an environmental toxin triggers neurofibrillary tangles and amyloid deposits in the brain." 283 (1823). doi:10.1098/rspb.2015.2397. de Figueiredo, D., U. Azeiteiro, S. Esteves, Fernando J. Goncalves, and M. Pereia. 2004. "Microcystin-producing blooms - a serious global public health issue." Exotoxicology and Environmental Safety 59: 151-163. Delpla, I., A. Jung, E. Baures, M. Clement, and O. Thomas. 2009. "Impacts of climate change on surface water quality in relation to drinking water production." Environment International 35 (8): 1225-1233. Dillenberg, H., and M. Dehnel. 1960. "Toxic waterbloom in Saskatchewan, 1959." Canadian Medical Association Journal 83: 1151-1154. Dolman, A., J. Rücker, F. Pick, J. Fastner, T. Rohrlack, U. Mischke, and C. Wiedner. 2012. "Cyanobacteria and cyanotoxins: The influence of nitrogen versus phosphorus." PloS One 7 (6): e38757. Fan, J., P. Hobson, L. Ho, R. Daly, and J. Brookes. 2014. "The effects of various control and water treatment processes on the membrane integrity and toxin fate of cyanobacteria." Journal of Hazardous Materials 264: 313-322. Fawell, J., C. James, and H. James. 1994. Toxins from blue-green algae: Toxicological assessment of microcystin-LR and a method for its determination in water. Report No. FR0359/2/DoE 3, Swindon, Wiltshire, England: Water Research Centre.

29 Fetscher, A., M. Howard, R. Stancheva, R. Kudela, D. Stein, M. Sutula, L. Busse, and R. Sheath. 2015. "Wadeable streams as widespread sources of benthic cyanotoxins in California, USA." Harmful Algae 49 (November): 105-116. doi:10.1016/j.hal.2015.09.002. Government of Canada, Health Canada and the Public Health Agency of Canada. 2002. "Guidelines for Candadian Drinking Water Quality: Guideline Technical Document - Cyanobacterial Toxins - Microcystin-LR." http://healthycanadians.gc.ca/publications/healthy-living-vie-saine/water- cyanobacteria-cyanobacterie-eau/index-eng.php. Graham, J., and K. Loftin. 2014. "Spatiotemporal Variability of Harmful Algal Blooms with Respect to Cyanobacterial Changing Environmental Conditions." 2014 Water Mission Area Research Lecture Series. http://ks.water.usgs.gov/static_pages/studies/water_quality/cyanobacteria/jlgraham_2 014LectureSeries.pdf. Graham, J., K. Loftin, and N. Kamman. 2009. "Monitoring recreational freshwaters." Lakeline. http://ks.water.usgs.gov/static_pages/studies/water_quality/cyanobacteria/LLsummer- graham2.pdf. Graham, J., K. Loftin, M. Meyer, and A. Ziegler. 2010. "Cyanotoxin mixtures and taste-and-odor compounds in cyanobacterial blooms from the midwestern United States." Environmental Science & Technology 44 (19): 7361-7368. doi:10.1021/es1008938. Hoeger, S., B. Hitzfeld, and D. Dietrich. 2005. "Occurrence and elimination of cyanobacterial toxins in drinking water treatment plants." Toxicology and Applied Pharmacology 203 (3): 231-242. Hoeger, S., G. Shaw, B. Hitzfeld, and D. Dietrich. 2004. "Occurrence and elimination of cyanobacterial toxins in two Australian drinking water treatment plants." Toxicon 43 (6): 639-649. Hoffman, J. 1976. "Removal of Microcystis Toxins in Water Purification Processes." Water SA 2 (2): 58-60. Jochimsen, E., W. Carmichael, D. Cardo, S. Cookson, C. Holmes, M. Atunes, D. de Melo Filho, et al. 1998. "Liver faliure and death after exposure to microsytins at a hemodialysis center in Brazil." New England Journal of Medicine 338: 873-878. doi:10.1056/NEJM199803263381304. Loftin, K. 2008. "Preliminary assessment of cyanotoxin occurrence in lakes and reservoirs in the United States." NWQMC Sith National Monitoring Conference. Atlantic City, NJ. Loftin, K., J. Graham, E. Hilborn, and S. Lehmann. 2016. "Cyanotoxins in inland lakes of the United States: Occurrence and potential recreational health risks in the EPA National Lakes Assessment 2007." Harmful Algae 56: 77-90. Minnesota Department of Health. 2015. "Toxicological Summary for: Microcystin-LR." http://www.health.state.mn.us/divs/eh/risk/guidance/gw/microcystin.pdf. Mohamed, Z., M. Deyab, M. Abou-Dobara, A. El-Sayed, and W. El-Raghi. 2015. "Occurrence of cyanobacteria and microcystin toxins in raw and treated waters of the Nile River, Egypt: Implication for water treatment and human health." Environmental Science and Pollution Research 1-12.

30 OEPA. 2016. Developing a Harmful Algal Bloom (HAB) Treatment Optimization Protocol: Guidance for Public Water Systems. Guidance Document, Ohio Environmental Proection Agency, Division of Drinking and Ground Waters. OEPA. 2014. Draft Public Water System Harmful Algal Bloom. Ohio Environmental Protection Agency. http://www.epa.ohio.gov/Portals/28/documents/HABs/PWS_HAB_Response_Strategy_ 2014.pdf. OEPA. 2016. Public Water System Harmful Algal Bloom Response Strategy. Ohio Environmental Protection Agency. http://www.epa.ohio.gov/Portals/28/documents/HABs/PWS_HAB_Response_Strategy. pdf. Oregon Health Authority. 2012. "Cyanotoxins in Drinking Water - Frequently Asked Questions." https://public.health.oregon.gov/HealthyEnvironments/DrinkingWater/Monitoring/Heal thEffects/Pages/cyanotoxins.aspx. O'Reilly, C., S. Sharma, D. Gray, S. Hampton, J. Read, R. Rowley, and P. Schneider. 2015. "Rapid and highly variable warming of lake surface waters around the globe." Geophysical Research Letters. doi:10.1002/2015GL066235. Paerl, H., and V. Paul. 2012. "Climate change: Links to global expansion of harmful cyanobacteria." Water Research 46 (5): 1349-1363. Rapala, J., M. Nimela, K. Berg, L. Lepisto, and K. Lahti. 2006. "Removal of cyanobacteria, cyanotoxins, heterotrophic bacteria and endotoxins at an operating surface water treatment plant." Water Science and Technology: A Journal of the International Association on Water Pollution Research 54 (3): 23-28. Szlag, D., J. Sinclair, B. Southwell, and J. Westrick. 2015. "Cyanobacteria and cyanotoxins occurrence and removal from five hihg-risk conventional treatment drinking water plants." Toxins 7 (6): 2198-2220. USEPA. 2015d. Algal Toxin Risk Assessment and Management Strategic Plan for Drinking Water. 810R04003, U.S. Environmental Protection Agency. USEPA. 2015b. Drinking Water Health Advisory for the Cyanobacterial Microcystin Toxins. 820R15100, U.S. Environmental Protection Agency. USEPA. 2015a. Health Effects Support Document for the Cyanobacterial Toxin Anatoxin-A. 820R15104, U.S. Environmental Protection Agency. USEPA. 2015c. Health Effects Support Document for the Cynaobacterial Toxin Cylindrospermopsin. 820R15103, U.S. Environmental Protection Agency. USEPA. 2015e. "Method 544. Determination of Microcystins and Nodularin in Drinking Water by Solids Phase Extraction and LIquid Chromatography/Tandem Mass Spectrometry (LC/MS/MS)." EPA/600/R-14/474, Cincinnati, OH. USEPA. 2015f. Method 545. Determination of Cylindrospermopsin and Anatoxin-a in Drinking Water by Liquid Chromatography Electrospray Tandem Mass Spectrometry (LC/ESI- MS/MS). EPA-815-R-15-009, Cincinnati, OH: U.S. Environmental Protection Agency. USEPA. 2015g. National Lakes Assessment 2012 Results: Overviews and Factsheets. Accessed 31 2015, December. http://www.epa.gov/national-aquatic-resource-surveys/national- lakes-assessment-2012-results.

31 USEPA. 2009. National Lakes Assessment: A Collaborative Survey of the Nation's Lakes. U.S. Environmental Protection Agency. WHO. 1998. Guidelines for Drinking Water Quality - Health Criteria and Other Supporting Information. WHO/EOS/98.1, World Health Organization. http://www.who.int/water_sanitation_health/dwq/2edaddvol2a.pdf. Yoo, R., W. Carmichael, R. Hoehn, and S. Hrudey. 1995. Cyanobacterial (Blue-Green Algal) Toxins: A Resource Guide. Denver: AWWA Research Foundation and American Water Works Association. Yuan, L., A. Pollard, S. Pather, J. Oliver, and L. D'Anglada. 2014. "Managing microcystin: Identifying national-scale thresholds for total nitrogen and chlorophyll a." Freshwater Biology 59 (9): 1970-1981.

32 Appendix A‐ State Contacts and Approach to EPA Guidance

Contact information

Contact State Drinking water regulatory agency Contact name Contact email phone Website number

Alabama Dept. of Env. Management, Water Supply Branch Dennis Harrison [email protected] (334) 271‐7774 none Dept. of Env. Conservation, Drinking Water and Cindy Christian, Acting Alaska Wastewater Program Program Manager [email protected] (907) 451‐2138 none

Arizona Dept. of Env. Quality, drinking Water Section Jon Fiegen [email protected] (602) 771‐4648 none Jeff Stone, Director, Arkansas Dept. of Health, Divison of Engineering Engingeering Section [email protected] (501) 661‐2693 none http://www.mywaterquality.ca.gov/ State Water Resources Control Board, Division of [email protected]. monitoring_council/cyanohab_netw California Drinking Water Karen Larsen gov (916) 341‐5125 ork/index.html

Dept. of Health & Environment, Water Quality Control Colorado Division Tyson Ingels [email protected] (303) 692‐3002 none http://www.ct.gov/deep/cwp/view.a sp?a=2719&q=510024&deepNav_GI Connecticut Dept. of Public Health, drinking Water Division Kimberly Wholean [email protected] (860) 888‐6269 D=1654 Delaware Health and Social Services, Division of Public Delaware Health, Drinking Water Program Edward Hallock [email protected] (302) 256‐5394 none Dept. of Env. Protection, Ground Water Regulatory Florida Section David Wales [email protected] none Contact information

Contact State Drinking water regulatory agency Contact name Contact email phone Website number

Dept. of Natural Resources, Env. Protection Division, http://www.gachd.org/environment Georgia Water Resources Branch al‐health/harmful_algal_bloom_hab/ [email protected]. Hawaii Dept. of Health, Env. Management Division Jennifer Nikado gov (808) 586‐4328 http://healthandwelfare.idaho.gov/ Health/EnvironmentalHealth/Harmf ulAlgalBlooms/tabid/2174/Default.as Idaho Dept. of Env. Quality, Drinking Water Program px

http://www.epa.illinois.gov/topics/w Illinois Env. Protection Agency, Division of Public Water ater‐quality/surface‐water/algal‐ Illinois Supplies Dave McMillan [email protected] bloom/2015‐program/index Dept. of Env. Management, Office of Water Indiana Management Matthew Prater [email protected] http://www.in.gov/isdh/25974.htm

https://idph.iowa.gov/ehs/algal‐ Iowa Dept. of Natural Resources, Water Supply Section Diane Moles [email protected] (515) 725‐0281 blooms

Dept. of Health & Environment, Bureau of Water, http://www.kdheks.gov/algae‐ Kansas Public Water Supply Section Tom Stiles [email protected] (785) 296‐6170 illness/ http://water.ky.gov/waterquality/pa Kentucky Dept. for Env. Protection, Division of Water ges/HABS.aspx

Louisiana Dept. of Health & Hospitals John Williams [email protected] (504) 599‐0112 none Contact information

Contact State Drinking water regulatory agency Contact name Contact email phone Website number

Dept. of Human Services, Division of Health http://www.maine.gov/dep/water/l Maine Engineering Michael Abbott [email protected] (207) 287‐6196 akes/cynobacteria.htm [email protected] http://www.dnr.state.md.us/bay/ha Maryland Dept. of the Environment, Water Supply Program Nancy Reilman v b/ http://www.mass.gov/eohhs/gov/de partments/dph/programs/environm ental‐health/exposure‐ Deapartment of Env. Protection, Drinking Water topics/beaches‐algae/algae‐ Massachusetts Program Kristin L. Divris [email protected] (508) 849‐4028 information.html http://www.michigan.gov/deq/0,456 Dept. of Env. Quality, Drinking Water & Radiological 1,7‐135‐3313_3675_3691‐336800‐‐ Michigan Protection Division ,00.html

http://www.health.state.mn.us/divs/ Minnesota Dept. of Health, Drinking Water Protection Section Julia Dady [email protected] (651) 201‐4956 idepc/diseases/hab/ Mississippi Dept. of Health, Bureau of Public Water Supply none Dept. of Natural Resources, Water Protection Division, Missouri Public Drinking Water Branch Todd Eichholz [email protected] (573) 751‐3110 none

Montana Dept. of Env. Quality, Public Water Supply Section Jon Dilliard [email protected] (406) 444‐2409 none Deapartment of Health & Human Services, Public Nebraska Water Supply Program Mike Archer [email protected] none Division of Env. Protection, Bureau of Safe Drinking Nevada Water none

http://des.nh.gov/organization/divisi New Dept. of Env. Services, Water Supply Engineering ons/water/wmb/beaches/cyano_bac Hampshire Bureau Paul Susca [email protected] (603) 271‐7061 teria.htm Contact information

Contact State Drinking water regulatory agency Contact name Contact email phone Website number

Dept. of Env. Protection, Bureau of Safe Drinking http://www.state.nj.us/dep/wms/bf New Jersey Water bm/lakes.html

New Mexico Environment Dept., Drinking Water Bureau Martin Torrez [email protected] (505) 383‐2054 none Dept. of Health, Bureau of Public Water Supply New York Protection

Dept. of Environment and Natural Resources, Public North Carolina Water Supply Section Mina Shehee [email protected] (919) 707‐5920 none Dept. of Health, Division of Municipal Facilities, North Dakota Drinking Water Program none

Env. Protection Agency, Division fo Drinking & Ground [email protected]. http://epa.ohio.gov/ddagw/HAB.asp Ohio Water Heather Raymond gov (614) 644‐2752 x http://www.travelok.com/checkmyo Oklahoma Dept. of Env. Quality, Water Quality Division Kay Coffey [email protected] (405)‐702‐8100 klake https://data.oregon.gov/Recreation/ (541) 726‐2587 Algae‐Bloom‐Advisories‐2015/ui7v‐ Oregon Dept. of Human Resources, Drinking Water Program Casey Lyon [email protected] ex. 31 cgpt

Dept. of Env. Protection, Division of Drinking Water Pennsylvania Management Bob Titler (DEP) (717) 772‐4467 none

http://www.health.ri.gov/healthrisks Rhode Island Dept. of Health, Office of Drinking Water Quality June Swallow [email protected] (401) 222‐7790 /harmfulalgaeblooms/ Contact information

Contact State Drinking water regulatory agency Contact name Contact email phone Website number

South Carolina Dept. of Health & Env. Control, Bureau of Water Doug Kinard [email protected] none Mark Mayer, Drinking Dept. of Environment & Natural Resources, Drinking Water Program South Dakota Water Program Administrator [email protected] (605) 773‐6039 none

Dept. of Environment & Conservation, Division of Tennessee Water Resources David Money [email protected] (931) 840‐4172 none http://tpwd.texas.gov/landwater/wa Texas Commission on Env. Quality, Water Supply Division Gary Chauvin [email protected] (512) 239‐1687 ter/environconcerns/hab/ http://www.deq.utah.gov/Pollutants /H/harmfulalgalblooms/drinkingwat Utah Dept. of Env. Quality, Division of Drinking Water Benjamin Holcomb [email protected] (801) 536‐4373 er.htm

heather.campbell@vermont. http://healthvermont.gov/enviro/bg Vermont Dept. of Env. Conservation, Water Supply Division Heather Campbell gov (802) 585‐4693 _algae/bgalgae.aspx

[email protected] http://www.vdh.virginia.gov/epidem Virginia Dept. of Health, Division of Water Supply Engineering Susan Douglas ov (804) 864‐7490 iology/DEE/HABS/HABmap.htm Dept. of Health, Division of Env. Health, Office of https://www.nwtoxicalgae.org/Defa Washington Drinking Water Joan Hardy [email protected] (360) 236‐3173 ult.aspx Bureau for Public Health, Office of Env. Health http://www.dhhr.wv.gov/bph/Pages West Virginia Services, Env. Engineering Division /default.aspx Dept. of Natural Resources, Bureau of Drinking Water https://www.dhs.wisconsin.gov/wat Wisconsin and Groundwater Steven Elmore [email protected] (608) 264‐9246 er/bg‐algae/index.htm

Wyoming Wyoming Drinking Water Program, EPA Region 8Robert Clement [email protected] none Drinking water

Intention Acceptable Testing State guidance Data collection State Notes on testing program to collect test Lysing program for PWS method data methods (in‐house sampling and testing, utilities (Required, both (Required, (yes, no, sample and ship to (All, ELISA, lysed and unlysed (yes, no) optional) development) state, data LC/MS/MS) required, not reported by allowed) utilities)

Surface water testing program; only testing finished drinking water if Alabama optional cyanotoxins detected development yes required

Alaska optional no no

Arizona optional Waiting on EPA for further guidance no no

Arkansas optional Program in development no yes

data reported by California optional development no utilities

State facilitating discussion between utilities on creation of unofficial guidance utilities sample and Colorado optional document yes yes ship to state ELISA required Annonymous samples submitted from utilities, no water sources have had utilities sample and Connecticut optional detections above EPA guidance yes yes ship to state ELISA required

Delaware optional no no No intention for state action prior to further EPA guidance, few surface water Florida optional sites no no ELISA Drinking water

Georgia No cyanotoxin expert reached.

Hawaii optional Very frew surface water sites no no

Idaho No cyanotoxin expert reached.

samples shipped to EPA‐based guidance and voluntary state lab Illinois optional monitoring program development yes ELISA required

Indiana optional No cyanotoxin expert reached. Ohio guidance distributed to all systems, hosting webinars to train surface water data reported by Iowa optional utilities no yes utilities ELISA required Starting in 2016, raw and finished drinking water sampling for surface water samples shipped to sources with concentrations greater than state lab Kansas optional EPA guidance development yes ELISA required

Kentucky optional No cyanotoxin expert reached. *EPA guidance for cyanotoxins, had one samples sent to sampling test run at a utility and no Eurofins Eaton Louisiana optional detections development no Analytical Drinking water

Maine optional development yes data reported by Maryland optional yes yes utilities ELISA required

Massachusetts optional development yes required

Michigan No cyanotoxin expert reached. State guidance for microcystin, anatoxin‐a has been recommended for guidance Minnesota optional development no no Mississippi No cyanotoxin expert reached.

Missouri optional *in development

Montana optional Voluntary program no no

Nebraska data reported by Nevada optional no no utilities Adhoc committee: in process of deeloping utlilities monitoring explicit program, state fact sheet, NE HAB pigment data, New monitoring network. Monitoring reported to EPA Hampshire optional pigments not toxin levels development yes Region 1 Drinking water

New Jersey optional *in development In process of reconfiguring overall state monitoring program, want to include cyanotoxins in future plans, only 40 New Mexico optional surface water systems no no

New York *in development Only tests drinking water (intake and in‐house sampling and finished) if HAB detected near surface testing only for large North Carolina optional water intake no no blooms

North Dakota No cyanotoxin expert reached.

Ohio required yes yes All required

Oklahoma optional no no

Oregon optional yes yes ELISA required

NW region: utilities Extensive testing in NW Region near Lake sample and ship to Pennsylvania optional Eerie no no Universities for testing ELISA

in‐house sampling and Rhode Island required yes yes testing LC/MS/MS required Drinking water

South Carolina optional Waiting on EPA for further guidance no yes ELISA required

South Dakota No cyanotoxin expert reached.

Ohio guidance distributed to all Tennessee optional vulnerable systems no no

Texas *in development

Utah optional State approach in development no yes

in‐house sampling and Vermont optional yes yes testing All required

Virginia optional No cyanotoxin expert reached. no

Washington optional No cyanotoxin expert reached.

West Virginia No cyanotoxin expert reached. yes

Wisconsin optional development

Wyoming optional *in development Drinking Water, continued

If above EPA guidance, will release information unofficial Alabama not enforced to public and issue health advisory 0.3 0.7 action level

Alaska not enforced unofficial Arizona not enforced 0.3 1.6 0.7 3 guidance

Arkansas not enforced

unofficial California not enforced 0.3 1.6 0.7 3 guidance

If utility finds finished water dectections exceeding EPA guidance, the state recommends unofficial Colorado not enforced that the utility seek state guidance 0.3 1.6 0.7 3 guidance

unofficial Connecticut not enforced 0.3 1.6 0.7 3 guidance

Delaware not enforced

Florida not enforced Utilities decide own policy Drinking Water, continued

Georgia Very few surface water systems ; no signs of Hawaii not enforced blooms

Idaho

Beginning monitoring drinking water intake unofficial Illinois not enforced location. 12‐13 source water mointoring 0.3 1.6 0.7 3 guidance

Indiana

unofficial Iowa not enforced Would reqiure public notice if above guidance 0.3 1.6 0.7 3 20 20 0.2 0.2 guidance

Mostly like will issue HA but has not had to enforce yet; Microcystin measurement limited unofficial Kansas not enforced by 0.5 DL 0.5 1.6 0.7 3 guidance

Kentucky

unofficial Louisiana not enforced 0.5 1.6 0.7 3 guidance Drinking Water, continued

Action on Health Cylindrospermops Anatoxin‐a ( Type of State Notes on HA enforcement Microcystin (g/L) Saxitoxins (g/L) Advisories in (g/L) (g/L) limit (Official guidance, Under 6 Under 6 Under 6 Under 6 (Enforced like unofficial and and and and MCL, not Over 6 Over 6 Over 6 Over 6 guidance sensitive sensitive sensitive sensitive enforced, other) action pop. pop. pop. pop. level, MCL) Any detections above guidance levels reported unofficial Maine not enforced to state 0.3 1.6 0.7 3 guidance Utilities must contact state for guidance if unofficial Maryland enforced detected 1 guidance

Massachusetts not enforced

Michigan

official Minnesota not enforced No reports of cyanotxin in drinking water 0.1 guidance Mississippi

Missouri unofficial Montana not enforced 0.3 1.6 0.7 3 guidance

Nebraska

Nevada not enforced

Early in program ‐ have not correlated pigment New to toxin levels; lake program developing for Hampshire not enforced ELISA Drinking Water, continued

New Jersey

New Mexico not enforced

New York Have not adopted EPA guidance, monitoring and HA policy will be determined at the local North Carolina not enforced level

North Dakota

official Ohio enforced 0.3 1.6 0.7 3 20 20 0.2 0.2 action level unofficial Oklahoma not enforced 0.3 1.6 0.7 3 guidance

official Oregon not enforced 0.3 1.6 0.7 3 0.7 3 0.3 1.6 guidance

Regional, not state enforced, only 3 DW unofficial Pennsylvania not enforced detections far below the EPA guidance 0.3 1.6 0.7 3 guidance

Not required by PWS, but failure to cooperate unofficial Rhode Island enforced will most likely result in rule making 0.3 1.6 0.7 3 action level Drinking Water, continued

State offers water system opportunity to issue unofficial South Carolina enforced health advisory; if no action, state will enforce 0.3 1.6 0.7 3 action level

South Dakota

Developing program to assist systems that identify any cyanotoxin occurrences; process of unofficial Tennessee enforced securing funding; most probably release HA 0.3 1.6 0.7 3 guidance

Texas

Utah not enforced

unofficial Vermont not enforced 0.3 1.6 0.7 3 action level

Virginia

Washington

West Virginia

Wisconsin unofficial Wyoming not enforced 0.3 1.6 0.7 3 guidance Recreational Water

Microcystin Cylindrospermop State Testing program Anatoxin‐a (g/L) Saxitoxins (g/L) Type of limit (g/L) sin (g/L)

(Regular, only if (No contact, bloom detected, advisory) no program)

Alabama

Alaska only if bloom Arizona detected

Arkansas

California 0.8 4 90 advisory

Colorado regular

only if bloom Connecticut detected

Delaware

Florida regular Recreational Water

Microcystin Cylindrospermop State Testing program Anatoxin‐a (g/L) Saxitoxins (g/L) Type of limit (g/L) sin (g/L)

(Regular, only if (No contact, bloom detected, advisory) no program)

Georgia

Hawaii

Idaho

Illinois regular

Indiana regular

Iowa regular

only if bloom Kansas detected

Kentucky

Louisiana Recreational Water

Microcystin Cylindrospermop State Testing program Anatoxin‐a (g/L) Saxitoxins (g/L) Type of limit (g/L) sin (g/L)

(Regular, only if (No contact, bloom detected, advisory) no program)

Maine

Maryland regular 10 advisory

Massachusetts 14 advisory

Michigan

Minnesota Mississippi

Missouri

Montana only if bloom Nebraska detected

Nevada

New Hampshire Recreational Water

Microcystin Cylindrospermop State Testing program Anatoxin‐a (g/L) Saxitoxins (g/L) Type of limit (g/L) sin (g/L)

(Regular, only if (No contact, bloom detected, advisory) no program)

New Jersey regular

New Mexico

New York

only if bloom is North Carolina detected

North Dakota

Ohio regular 20 20 300 3 no contact

Oklahoma

only if bloom Oregon detected 10 20 20 10 advisory

regular in NW Pennsylvania region

Rhode Island Recreational Water

Microcystin Cylindrospermop State Testing program Anatoxin‐a (g/L) Saxitoxins (g/L) Type of limit (g/L) sin (g/L)

(Regular, only if (No contact, bloom detected, advisory) no program)

only if bloom South Carolina detected

South Dakota

only if bloom Tennessee detected

Texas

Utah

Vermont under development 6 10 10 no contact

only if bloom Virginia detected 6 no contact

Washington 64.51 75advisory

West Virginia only if bloom is Wisconsin detected

Wyoming