PB84-220326
Use of Probabilistic Information in the
Water Quality Based Approach
(U.S.) Environmental Research Lab.-Duluth, HN
1984
                                                                          J
        of Commerce
         Information Service

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                                                      PB84-220326
                                                   EPA-600/D-84-192
                                                   1984
USE OF PROBABILISTIC  INFORMATION  IN  THE WATER QUALITY BASED APPROACH
               Norbert A. Jaworskl and Donald I. Mount
                 Environmental Research Laboratory-Duluth
                   U.S. Environmental Protection Agency
                          6201 Congdon Boulevard
                         Duluth, Minnesota  55804

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                                  TECHNICAL REPORT DATA
                            (Pliae naa Jrumtcnoni on the rtvtnt btfon committing)
1. REPORT NO.
  EPA=£00/D-8d-192
             3. RECIPIENT'S ACCESSION NO.
                   Ppg L   220326
K TITLE ANDSUBTITLE
   USE OF PROBABILISTIC  INFORMATION IN THE WATER
   QUALITY BASED APPROACH
             5. REPORT DATE
                1984
             6. PERFORMING ORGANIZATION CODE
7. AUTHORIS)

 N. A.  Jaworski, and D. I. Mount
             . P&RFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
 U.S.  Environmental Protection Agency
 Environmental Research Laboratory-Duluth
 6201  Congdon Boulevard
 Duluth,  MN   55804
                                                           10. PROGRAM ELEMENT NO.
             II. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
 Environmental Research Laboratory
 Office  of Research and Development
 U.S.  Environmental Protection Agency
 Duluth,  MN   55804
             13. TYPE OF REPORT AND PERIOC COVERED
             14. SPONSORING A5ENCY CODE


               EPA-600/03
15. SUPPLEMENTARY NOTES
 Aquatic Toxicology:  Seventh Symposium, ASTM,  1984
           ^During the past two decades, implementation procedures in vastevater manage-
 ment  often resulted in a large margin of safety  being incorporated into the use of
 water quality criteria for the protection of aquatic  life and its uses.  Wasteload
 allocation design conditions, such as the use of seven-day, ten-year low flow, gave
 assurances of instrearn concentrations well below the  water quality criteria for a
 large percentage of time.  Present-day economic  conditions and the Increasing cost of
 advanced wastewater treatment are necessitating  a re-examination of how water quality
 criteria are being used in the water quality based approach for establishing effluent
 limitations.
            The relationships between water quality criteria and other components of
 the water quality based approach are identified.  The need for a better defined and
 more  consistent use of statistical information is suggested not only in the develop-
 ment  of  water quality criteria but also for the  entire water quality based approach.
 Intensity, duration, and frequency of occurrence (return period) appear to be three
 common statistical parameters of the six-step water quality based approach.' Research
 is identified, which if successful, would allow  wat=r quality managers better insight
 in determining pollutant exposures that more adequately simulate receiving water   ""
 conditions resulting from variable stream flows, wastewater discharge rates, and
 pollutant concentrations.
17.
                               KEY WOROb AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                             b.lDENTIFIERS/OPEN ENDED TERMS
                             COSATI Field/Croup
IB. DISTRIBUTION STATEMENT
  Release to public
                                              IB. SECURITY CLASS ITnuHtporli
                                               Unclassified
                                                                         21. NO. Of PAGES
                                20
20. SECURITY CLASS IThu pojtj
 Unclassified
                                                                         22. PRICE
EPA FMIW 2220-1 (R«». 4-771   »M(viOU» KOITION it OMOLCTC
                                             1

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                                          Or
*»«
 : ABSTRACT:   During the past two decades, Implementation procedures  in
   wastewater management often resulted in a large margin of safety being
   incorporated in the use of water quality criteria for the protection  of
*"' aquatic life and its uses.    Wasteload allocation design conditions,
   such as the use of seven-day ten-year low flows, gave assurances of
   instream concentrations well below the water quality criteria for a
  . large percentage of  the time.  Present-day economic conditions and
   increasing cost of advanced wastewater treatment are necessitating a
  i
  i re-examination of how water quality  criteria are being used In the
  i
  ! water quality based  approach  in wastewater management implementation
  j procedures.
  ;       The  interrelationships of water quality criteria and other steps of
  I the water quality  based approach  are identified.   The need for a better
  i
  ' defined and  more consistent use of probabilistic  Information  1s suggested
  : not only  In  the  development of water quality criteria but for the
    entire water quality based approach.  Intensity,  duration, and  frequency
    of occurrence (return period) appear to be three  common  statistical
    parameters of the  six steps of the water quality based approach.
         Research is Identified which, if successful, would  allow water  quality
    managers more insight Into the better selection of pollutant exposure
    histories that more adequately simulate receiving water  conditions.
    resulting from.variable stream flows and wastewater discharge rates.  It
    Is  also suggested that more aquatic toxiclty research resources be focused
    on  those areas where greatest variability and lack of knowledge currently
  I
     exist, such as  in species selection,  incorporating fluctuating exposures,   i
  • -  considering multi-pollutant  effects,  field applicability, etc.
                  	'	
      t          t               .  ___111.....
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  I I1 A i ..in ..Ti'ffi 1 'i i.i
                                                      TYPING GUIDE SHEET

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                _JI

  Introduction
       During the 1950's and 1960's, water quality criteria for the
•  protection of aquatic life prescribed a maximum pollutant concentration
  for the receiving water.  The criterion was usually presented as a "no-
I  effect level" which would protect aquatic life and its uses under most
  ambient conditions.  This was readily interpreted as applying to all
  stream flow and wastewater discharge conditions.
       This  "no-effect level" ambient concentration concept 1s analogous
  to a speed limit for our highways.  That 1s, a posted highway speed
  limit is  in essence a maximum "safe" speed for traffic under optimum
i
|  road conditions.   For both the water quality criteria and the speed
  limit applications, the "safe" limits have no time period restrictions.
  That 1s,  the  no-effect concentration can be maintained 1n the receiving
  water "forever"; likewise, one can drive forever at the maximum speed
!  limit.  The only safety factors  Incorporated are those asserted 1n
j  developing the  no-effect concentration or the maximum speed limit.
       The  early  intended use of water quality criteria was, in general, to
i
|  allow the determination of whether the concentration of a pollutant 1n the
!  receiving water was above, and/or below a level deleterious to aquatic life;
  simply  stated,  "safe" or  "unsafe".
       The  purpose of  this  paper is to demonstrate how the use of water
j  quality criteria/standards has gone beyond the  "speed limit" stage and
j  Us  use expanded in  the water quality based approach.  The Interrelationships
j  of water  quality criteria and other steps of the water quality based
;  approach  are  identified.  The need for a better defined and more  consistent   or7or.-.u
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l
   use  of probabilistic  Information 1s  suggested for  the entire water quality
   based approach.   Research areas  that require further study are  Identified.
 i                '                       i                                       I
 •Expanded Use of Water Quality Criteria  In  the Water Quality Based Approach
 i       A major departure from  the  early Intent (safe or unsafe) occurred when
 i
 .•water quality  standards were used to establish wastewater treatment  requirements
   as part of  the water  quality based approach.  The  water quality based
 i
 :  approach, as envisioned today, encompasses many  technical, socioecor.omic,
 land  judgmental Issues which  previously  were not  rigorously addressed.   It
   consists  of the  following components:
        1.   Establishment of water quality standards,  Including:
            a.   Use attainability analysis;
             b.   Development of water quality criteria,  Including site-
                 specific modification of the national  criteria;
             c.    Impact analysis.
        2.   Wasteload allocation process.
        3.   Development of wastewater discharge permit limits.
        4.   Design of wastewater treatment facilities.
        5.   Operation and maintenance of wastewater treatment facilities.
        6.   Compliance monitoring  of  both effluent and ambient receiving waters.
   Water  quality standards today take  on more meaning, and therefore th« use
 i
 i  of  standards  needs to be better  defined and be more consistent with the water
 i
 !  quality based approach.   In the  establishment of water quality standards.
 i
 j  both water quality criteria and  use attainability analysis are Integral
   aspects.   In  this  Interpretation, criteria and use attainability are
    linked  through exposure and water-body use attainability analysis.  Water
                                                                                  
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                                    CLNTLR OF
                                      I'AC'.f
  quality  standards, once established, are Incorporated In  the wasteload
  allocation process.
       To  illustrate this point,  let us  examine  how receiving stream flow
» characteristics  are  utilized along with water  quality criteria 1n the
  wasteload allocation process.  One part of the wasteload  allocation process
  Includes a statistical  analysis of hydrologic  stream-flow discharge rates.
  This  analysis was  usually accomplished Independently of the water quality
  criteria setting process.  For example, for a  wastewater discharge
  containing a toxic pollutant, the analysis can result in design  conditions
  In which the "criterion"  concentration 1s applied to a relatively  severe
  hydrologic condition which may occur less than five per cent of  the  time.   At
  all other times, the concentration 1n  the receiving water will be  much  less
  than the prescribed  "criterion" level.  This  use of water quality  criteria
  in conjunction with  the hydrologic analysis has  led to the establishment
  of wastewater permits and the design and operation of waste treatment
  plants  that are based on the "worst case" analysis.
       The degree of rigor involved  in  hydrologic  analysis  in the  late 1950's
  has greatly expanded through the  use  of operations research techniques.
  The use of advanced statistical  techniques  Including synthetic hydrology
  has given  the water quality planner greater insight into the  sensitivity
  of stream-flow  conditions and wastewater  treatment requirements.  Nevertheless,
  the two processes of development of water quality standards for  the protection
  of aquatic  life and analysis of  hydrologic  factors were  done  independently,
  and this  has  lead to the Incorporation of unnecessarily  large safety factors
  under some stream-flow conditions.
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                                    I'AGE NUMBER
                         DIMENSION
                         FOFI TAtiLES
                        1 ANO I II US-
                         T:IATICHJG
I III.'I
                                                      TYPING GUIDE SHEET

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1  Stream Flow and  Exposure Considerations
       Let us further examine the selection of stream-flow design conditions.
  Historically,  the water quality based approach has been based on the
  selection of stream-flow design conditions such as 7Q10, which 1s the
  lowest seven-day stream flow that occurs, on the average, once every
  ten years.    The specification of a stream flow (Intensity) for a seven-
  day period (duration) that occurs, on the average, once 1n ten years
  (frequency of occurrence or return period) was the basis for calculating
  the permit limitations.  These three statistical parameters:  Intensity,
  duration,  and return period, are major input  variables  in  the  six  steps
  of the  water quality based approach.  However,  many  times  the  three
  parameters are  either  not well defined or not used in  a  consistent
  manner.
        In many wasteload allocation  processes [1] especially for BOO-DO
  analysis, there often  Is a  coupling using relationships between stream
  flow characteristics and DO targets.  Nevertheless,  the basic design
  parameters are usually developed mainly from hydrologlc considerations,
  not from toxlcologlcal, proposed use, or water quality criteria consider-
  ations.
        Statistical analysis  of the exposure of aquatic systems to toxic
   pollutants can bridge the  gap between the development of standards and their
   use In wasteload allocation.  Pollutant exposure analysis has three basic
   properties which are very analogous to precipitation analysis  [2]. In
   precipitation analyses, one requires probabilistic  Information concerning
  ;the  intensity of rain  storms of various  frequencies and for specific
  !
   durations.  From  these analyses one can  determine the average Intensity           «.•».< or
                               	         I           _____  ____________ __.  —. -  i  • '•.;••"
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                                     PAGE NUMUEFl                                    '"" '°'**
   EPA form 23«M (4-001
                                                              r ,„
   (PREVIOUSLY CIN EH A TOMM 2*7)
                                                        TYPING GUIDE SHEET

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                                     CLtit I n UF


"'of a given frequency of rainfall for any desired duration.  The same


  probabilistic techniques can be used to develop the three pollutant exposure


  statistical parameters for a stream reach or lake segment.  The three


^parameters are:   Intensity, as measured by the concentration of a pollutant;


  duration, as measured by the exposure period; and return period, as measured


  by frequency of occurrence.  These parameters can facilitate the selection


  of design conditions for an ambient receiving stream's "pollutant exposure"


  which  can be expressed.         ly  to the stream flow design condition,


  as  "7C10" where 7  1s jurdi'on  of exposure  1n days, C is the water quality


  [criterion, and lp    retir    iriod in  years.  This simple analysis provides


  ja mechanism  fr              ae probability of events or exposure periods
  i

  j during which t.          .19 water concentration may be above or below the


  .no-effect level.   This  ability to  analyze  these  exposure periods  or events


  .during which the  toxicit.y  of  a pollutant may be  deleterious — depending, of
  i

  course, on the Intensity,  duration and frequency or return periods of


  •the events — adds greatly to our  understanding of how toxidty can occur


  and thereby helps  to ensure appropriate protection.


  Water Quality Criteria Interrelationships
  , «_«^H^HH_^^_^_^.^».^.^H^_^^_H_^.^M^^_^HBi^.^^^HH__^_aiM_B_MM^«^

  j      As our understanding of aquatic toxicological science became more


   sophisticated in the 1970's 1n the development of water quality criteria


   for the protection of aquatic life, there evolved a two number criterion.
  i
  i The criterion Includes a maximum concentration, usually for protection against
  I

   n.ost acute toxic effects, and an average  concentration for protection against


   ir.ost chronic  toxic effects.   The  National Guidelines [3] for  deriving water


   quality criteria, which were  developed  in 1978 and updated In 1930, reflected


  [  this  refinement In establishing national  water quality criteria.

  ::
V                     •-•

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                                    PACE NUMBER
   E?A Form 23SO-4 (4-80)                                                  ..
                                                     •i us novtiiNuf >.: pMiMt.r.Miinv
   IPILVIOUSLV CIN LPA FORM ZITJ
                                                                                ' AM.M
                                                                                 THATIO
                                                       TYPING GUIDE SHEET

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     To Investigate tne Interrelationships of water quality criteria,
wasteload allocation limits, return period, stream flow,  statistics,
time averaging  periods, and pollutant toxidty Information (acute/chronic
ratio), a Joint study was undertaken between the Environmental Research
Laboratory-Oulutn  and Manhattan College [4].  Preliminary study results
suggest the Following:
      1.    For toxic chemicals with an acute/chronic ratio less than  100
           and being discharged  Into a stream with  high flow variability, the
           wasteload allocation  limits are  mainly controlled by the maximum
           water quality criterion with  return periods having  a major
           Impact.  For chemicals  with an  acute/chronic ratio  above  100,
           the wasteload allocation  is controlled by the  average water
           quality criterion.
:      ?..    For  toxic chemicals with an acute/chronic ratio less than 15
'.            and  being discharged into a stream with  low flow variability,
:            the  wasteload allocation limits are mainly controlled by  the
            maximum water quality  criterion, with return  and ti-ne averaging
            period being of  lesser importance.  For chemicals  wiuh an
i
|            acute/chronic ratio  greater than  15, the average water quality
!            criterion is restrictive.
I
i       3.    When the third condition 1s added  to prevent  significant
•            excursions  between the maximum and average concentrations,  it
i
:            becomes the most restrictive in the wasteload allocation
i
I            process for toxic chemicals  which have  an acute/chronic  ratio
!            of about 8 or more,  and  stream flow variability and  return
j
!            period considerations  have small  Impact on  restricting
V •
~           wasteload allocations.
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              . .                   PA'ii MUM-iiH
                                                     TYPING GUIDE SHEET

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                                           CCIMTEH Of                                    .  .!rtnf
                                             PAGE                                    X* '.'.. -;
             The preliminary analysis  clearly demonstrates the Interrelationships
        and the need to integrate fully the various  processes of the water quality
        bi.sed approach.
        Use Attainability Considerations
             It is important to review how the water quality criteria are established.
        The basic building  blocks for the criteria are laboratory tests—acute,
        chronic, and bioconcentration--at steady-state exposures, and generally  in
        clean  test waters.   The algorithm that has been developed for the National
        Guidelines  brings  together  the  information required  to  derive criteria,
        Including a  maximum concentration and an  average  concentration,  that must
        be maintained  to protect aquatic life and Its  uses.   Th<*  intent  of  the
        two-number  criteria was  to  give the  planner  more  information and degrees of
         freedom in  the water quality  based approach.  A major question  to be asked
         1s: are use attainability considerations and analyses congruent with  the
         entire water quality based approach?
        I      If the analogy of the  speed limit for  traffic control  1s further
        .examined, additional  considerations arise.   If the maximum concentration
        1s analogous to the maximum speed  limit that cannot be exceeded, the
        i
        {average concentration has no  direct analogy 1n traffic control, unless
        iwe begin to distinguish  between "maximum" or "safe" speeds.  This dis-
        tinction adds significantly to the process and Involves other technical,
        jsodoeconomic, and judgmental Issues.  For example, how many accidents
        jwithln a given time period and of what type are  we willing  to accept?
        jLikewise, 1n the protection of aquatic life,  how many  exposure  events
        iand for what duration within a given time period and at what Intensity             .
        j                                                                                    ''CM O"
l!/.~r".-. •.»are we willing to  accept?                                                          '-f.v*'
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LAST .. ILL
             The current water quality based approach suggests  that the amount of
        wastewater treatment provided should consider not only  the establishment of a
        numerical water quality criterion for a given pollutant for the protection of
        aquatic life, but also "use attainability" considerations.  Use attainability.
        Including level of protection for a given site, can have a significant Impact
        on the other component steps of the water quality based approach.  For example,
        the selection of wasteload design conditions for duration and return period
        should be  based more  on the  use attainability analysis than on hydro!ogle and
        exposure considerations alone.  The  selection of design conditions for
         return period,  above  a given design  exposure concentration  (Intensity) and
         duration, should consider the assemblage  of  the aquatic organisms to be
         protected; that 1s, their biological value to  the  aquatic comnnnlty and
         their ability to repooulate.  One  further point  Is worth  mentioning here.
         If two deleterious events occur back-to-back,  t!;e  Impact  of the  No events
         may be additive.  Therefore, we may need  also to Include  an additional
         parameter for this effect, especially when  small  periods  of return are
         considered.
                        i                       I
                        i                       I
        ToxicoToqlcal Considerations
              In  reviewing  the National Water Quality Criteria Documents, one can
        readily  see  that  for  certain  pollutants the  slope  of the  ranked acute
        toxlcity plot for the species  tested 1s very steep, suggesting that all
        of the species  tested with that chemical  have  similar  toxidty responses.
        For other pollutants  the  species rank curve  Is relatively flat,  suggesting
        that some species are greatly more sensitive than others.  A key question
         here 1s how can we best take advantage of the information already known
iabout the differences 1n species  sensitivity to given  pollutants?   Can we
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                                               CENTER OF
                                                  PAGE
                                                                                 !,%•',r
    n[
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•take advantage of this Information by treatment of these relationships 1n
 a more probabilistic nature?
      Receiving stream data clearly demonstrate that the ambient concentration
 of pollutants can vary significantly. Influenced nalnly by effluent and
 stream flow variability.  The  preponderance of available  toxlclty data has
 been developed using clean water and constant toxicant concentrations.   We
 are just beginning  to  study  fluctuating exposures  In  the  laboratory.
 •Models [51  have  been  suggested for certain pollutants which  can  Incorporate
  the  tox1f1cat1on/detox1f1cat1on process, mainly on an acute  basis.  Laborator>
  data for certain compounds,  such as ammonia [6], suggest that even short
  exposure periods (hours) can have severe biological Impact.   With the high
  cost of data generation using existing laboratory test methods, the need
  exists to make better use of existing data bases by extrapolating from
  steady-state to fluctuating exposures.   It 1s paramount 1n this extrapolation
  process  to keep 1n perspective  the  receiving water pollutant exposure
  statistical parareters—Intensity,  duration, and return period.
        All of the above Items suggest more extensive and expensive  testing
  and analysis requirements 1n  the water quality based  approach.   Is this
  really  true?  Some preliminary studies [7]  suggest that ecosystems may  be
  more  similar than dissimilar  with  respect to toxlcologlcal endpolnts.
    LAST LIlNE JSf-
     - TLXT
              when comparative toxlclty analyses are made that couple the derivation of
              site-specific water quality criteria and analysis of use attainability
              requ1rc«nents.  If co, the process should collapse, not expand, into
              multl-toxlcologlcal endpolnts.  More extensive comparative toxlcological
              analysis Including probabilistic considerations in use attainability analysis
              should aid In answering this fundamental question.
                            I                       -                                     	1 DOTTOM O-
                  3-'8"
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EPA Form 2350-4 (4-80)
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                                               PAGE NUMOER
                                                                                FOR TABLf
                                                                            -- 1 AND ILLUS-
                                                                                TRATIONS
                                                               >' US G3VI MNWl N • PltlN I IN'.i Ol H» I •
                                                                 TYPING GUIDE SHEET

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       *     Studies [8] have Indicated that most wastewater discharges contain
        multiple pollutants near or above the  concentrations required to protect
        against chronic effects of aquatic life.  Many of the pollutants are not
       3readily removed by wastewater treatment,  and  are persistent in surface
        receiving waters.  The ability to Incorporate multiple pollutant effects
        in wasteload allocation, even at steady-state conditions, is not well
        developed at the present time.  The inclusion of multiple pollutants under
         fluctuating conditions is even more poorly understood.  Although the use of
         laboratory  toxicity  tests on complex effluents  1s  promising [9l, much more
         research is needed in use of the complex effluent  toxicity testing  approach
         as an alternative  to single pollutant testing 1n the water quality  based
        i
        iapproach, Including  Incorporating  appropriate Intensity,  duration,  and
        i
        I return period considerations.
              The selection of  wasteload design conditions  for intensity and duration
         of pollutant exposure  should  be based more on toxicological  considerations
          (I.e., water quality criteria/standards) than on hydrologic  conditions
         alone.  The pollutant  exposure design conditions should reflect both the
         characteristics of community  assemblage  to be protected and  of the toxicological
         characteristics of the toxicant.

          Need For An Integrated Approach
               Inherent  in all six steps of the water  quality based approach are design
          conditions which contain time variables  like intensity, duration of exposures,
          recruitment time, return period, permit  limits, wastewater treatment design
                        I                      i                                      i
         conditions and monitoring  frequency.  Although different terminoloyy Is
         often  used in  each  of the  steps,  one can grossly aggregate time considerations
          Into  three parameters:  intensity, duration, and return period.
                                                                                        1.1
        1    1 3/8"
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         EPA Form Z350-4 (4-80)
         |I*IIL VIOUSUV CIN. CPA FORM ZB7|
                                                '
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                                                                                           vl-.l.
                                          PACE NUMBER
                                                                                      FOR TAOLC:
                                                                                     I AND ILLUS
                                                                                      TRATIONS:
                                                            TYPING GUIDE SHEET

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                                       '.'.NTtHQF                                     1.Yr'J|l
Af
     I
     I
     Studies  [10] have shown that the concentrations of pollutants 1n effluents
and from non-point sources vary considerably but can be represented by a
probability function.  Likewise, studies  [11]  have  shown  the ambient stream
concentrations of most pollutants vary  considerably but a",so can be
expressed  by  a probability function.  Although the  robustness of the functions
1s debatable, probability functions,  for the most part, can be developed.
      Such  analyses  suggest that most  pollutants are "event" oriented
with  a  determinable Intensity, duration, and  return period.  In the development
of this argument further,  the need  for aggregating  common time units becomes
jmore  obvious  as  Indicated  below:
      1.   Water Quality Standards*
           .  What properties  of the aquatic systems are to be protected
             or not protected, and to what extent?
           .  What frequency and duration of Impairment should be used  for
              use attainability analysis?
      2.   Waste!oad Allocation
           .  What are the major factors that Influence exposure  and Impact  In
              receiving water:  wastewater effluent  variability,  stream flow
              variability, or  physical,  chemical, and biological  transport
              processes?
      3.   Wastewater Discharge Permit  Limits
           .  What are options for expression of loading,  1n terms of Intensity
              (concentration), duration, and return  period time units?
      4.   Wastewater  Treatment Design
            .  Are the design  parameters such as hydrologlc loadings and
              treatment removal  effectively based on time parameters similar to     ur..l0F
                                                                                    C AHEA
              those used 1n setting water uses?                                     l^utl
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                                                          TYPING GUIDE SHEET

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                          CE^Tf-ft OF
                            I'ACE
Wastewater Treatment Operation and Maintenance
ME:
             .  Are the operational  procedures  resulting  1n  effluents with
               the prescribed pollutant concentration  expressed in Intensity,
               duration, and return periods?
        6.   Monitoring
             .  Is the monitoring program of both effluent and ambient receiving
               water properly addressing time-event conditions?
        What does this mean In terms of the state of the establishment of water
   quality criteria 1n the water quality based approach for tha protection of
   aquatic life?  The message 1s very clear.  No longer can we consider water
   quality criteria for  the  protection of aquatic resources as a  simple  speed
   limit.  We  must better understand how It Is used 1n  the entire process of the
   water quality based approach.   We have taken a major first  step, In the authors'
   opinion,  by developing a two number criteria; that 1s, maximum and average
   concentration numbers.   However, these  terms  need  to be better defined  1n
   relation to the entire water quality based approach.  For example, what 1s
   maximum?  What 1s average?  What return periods  do these  two number criteria
    suggest 1n wasteload allocation, 1f any?  Should the duration and return
    periods be the same or different for the maximum and the  average concentration?
    Better defined and more consistent use of the probabilistic parameters are
    needed for all steps of the water quality based approach.
    Safety Factor Considerations
         The need for safety factors 1n the water quality based approach can be
    debated, but  it 1s of paramount Importance to determine when  safety  factors
    are being  employed,  either  Intentionally or unintentionally.   If  a better
   .defined  and more  consistent use of probabilistic  Information  were Incorporated  TQM OP
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*1nto the water quality based approach. It would be much easier to determine
  what safety factors are being employed and when the factors are or are not
  additive.
,      In the development of water quality criteria and standards, the
i
  speed limit concept does not Incorporate any safety factors.  The
  Incorporation of safety factors for protection of aquatic life results
  1n the selection of design conditions such as in wasteload allocation
  for calculating permit limitations from water quality standards.
       In the authors' opinion, much of the margin of safety provided by
  these Intentional or unintentional safety factors has provided a "cushion"
  for scientific uncertainty 1n developing water quality criteria for the
  protection of aquatic life.  We should be well aware of  the consequences
  to the environment when we begin  to  reduce these margins of safety In  the
  water quality based approach.
  Conclusions
        In  summary,  intensity,  duration,  and  return  period  of a  pollutant
  .exposure event  appear to  be  the cannon statistical  parameters also used
  in  the other component steps of the  water quality based  approach.   We
  need to  understand better how these  common statistical  parameters  can be
  utilized 1n the entire water quality based approach, so that consistency
  can be obtained and maintained; that Is, consistency in criteria development,
  use attainabllty determination, wasteload allocation, Impact analysis,
  wastewater treatment  permitting, treatment design and operation, and
                                                                                        .f/A'jL*
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              Specifically:
              1.   An approach for statistical defining receiving water pollutant
                   exposure 1s suggested consisting of the parameters of Intensity,
                   duration, and return period.
              2.   More emphasis should be placed on the consistent .~e of intensity,
                   duration, and return period, not only in defining acute and
                   chronic toxldty and bioaccumulation required In developing
                   the watv. • quality standards, but 1n the entire water quality
                   based approach.
              3.    It is well  established  that ambient concentrations  fluctuate
                    due to many reasons, as indicated  earlier.   We  must be able to
                    incorporate into  our current  aquatic  toxicology research, either
                    directly or indirectly, the ability to handle fluctuating
                    exposures.
               4.    Most systems have more than one pollutant.   We must begin to
                    give more attention to chemical Interactions of pollutants
                    and to multl-pollutant toxic  effects.  Currently we have a
                    very limited capability for handling multl-pollutant effects under
                    both laboratory and ambient conditions.  This could be Improved
                    in a number of ways:   use of simple models, multl-pollutant
                    models, or toxldty tests on complex effluents or  instream toxldty
                    determinations.
                5.   The species sensitivity comparative analysis must  be  coupled  to
                    use attainability—that 1s,  what  use  are we trying to protect-
                    not only the  specific  communities, but for what Intensity, duration,
                    and return period.
             A
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         6.    More rigorous comparative  toxlcologlcal studies to determine
              species sensitivity differences for a range of organisms  and
              compounds.   These relationships should be examined probabilistically
              and 1f possible be Incorporated Into the water quality standards
              process.
         The above Indicates that although we have come a long way  In aquatic
    toxicology research 1n support of the water quality based approach.
    there are many areas in which we can become more effective, efficient, and
    consistent 1n developing a scientific basis for the water quality based
    approach.  We need to focus our research efforts on these areas. We need to
    determine what are the key parameters that  have the greatest  Impact on the
    entire process and focus our research effort on answering the  key unknowns
    for  these parameters, so that the effectiveness of the  water  quality based
    approach can be maintained.

    References
          [1]   Krenkel. P.A.. Journal  of the Water Pollution  Control Federation,
               Vol.  51, No.  8.  Aug.  1979, pp 2168-2183.
          [2]   Wisler, C.O.  and Brater,  E.F., Hydrology,  2nd  ed.,
               Wiley. New York. 1963.  Chapter  4.  pp.  57-101.
          [3]   Environmental Protection  Agency, "Guidelines for Deriving
               Numerical  National Water  Quality Criteria for the Protection
               of Aquatic Life and Its Uses," Washington, D.C., Sept.  1982.
          [4]   DIToro, D.M., "Preliminary Probabilistic Interpretation of
               Proposed Two Number Criteria," Progress Report Manhattan College,
               Bronx, New York, April 1982.
if.e »C
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    |HMI.VIUUS_V CIN CPA FOI4M 287)
US GOVCRNMLNT PRIIJTINC O. 'ICE
                                                        TYPING GUIDE SHEET

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                                            PAGE
                                                                             . I .'/••% i,L
              [51 Manclnl, J.L., "A Method for Calculating Effects, on Aquatic
                  Organisms, of Varying Concentrations," (Journal Artele,
                  In press,  1983).
              [61 Environmental Protection Agency, "Ammonia Water Quality Criteria
                  for the Protection of Aquatic Life and Its Uses," Washington,  D.C.,
                  Final  Draft, Jari. 1983.
              [7]  Slouff, W.,  "Biological Effects of Chemical Pollutants In the
                  Aquatic Environment and Their Indication Value," Utrecht!ar.nt
                   Vol. 43, Ck  Lage Zucluwe, Nether!and, Apr. 1983, p. 4926
              [8]  Environmental  Protection Agency. "International Memorandum on
                   Predicted Performance of Less-Than-Secondary Treatment Processes."
                   Washington,  D.C., July  1582.
              [9]  DIToro, D.M.,  "Exposure Assessment for Complex Effluents -
                   Principles and Possibilities,"  presented at the  Hazard Assessment
                   for Complex Effluent Workshop,  Cody,  Wyoming, Aug.  1982
              [10 1  Yake, W.E. and James, R.K.,  Journal of the Water Pollution
                   Control Federation.  Vol. 55, No. 3, Mar. 1983, pp.  303-309.
             CHI
.fi.N
AST Llf.t !
           DIToro, D.M.,  "Probability Model of Stream Response to Runoff,"
           presented at  the  American Geophysical University Spring Meeting
           Symposium on  Impacts of Urban Runoff on Receiving Waters,
           Philadelphia,  Pennsylvania, June 1982.
        _bti_i	
EPA Form 2350-4 (4.&0)
(PREVIOUSLY CIN. CPA FORM 287)
                                         PAGE NUMBEH
                                                                             BOTTOM OF
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