vvEPA
United States
Environmental Protection
Agency
Algal Toxin Risk Assessment
and Management Strategic Plan
for Drinking Water
Strategy Submitted to Congress to Meet the
Requirements of P.L. 114-45
Product of the
United States Environmental Protection Agency
810R04003
November 2015
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Table of Contents
Table of Contents i
List of Sections Responsive to P.L. 114-45 ii
List of Abbreviations and Acronyms iii
I. Executive Summary 1
II. Introduction 3
III. Strategic Plan 5
a. Algal Toxins and Their Human Health Effects 5
b. Health Advisories 7
c. Factors Likely to Cause Harmful Algal Blooms 8
d. Analytical Methods 12
e. Frequency of Monitoring 13
f. Treatment Options 14
g. Source Water Protection Practices 16
h. Cooperative Agreements and Technical Assistance 22
IV. Information Coordination 27
a. Information Gaps 27
b. Information from Other Federal Agencies 30
c. Stakeholder Involvement 30
V. References 32
VI. Appendix 1. Text of Public Law No: 114-45 37
VII. Appendix 2. EPA's Current Activities Directly Related to Freshwater HABs 40
VIII. Appendix 3. EPA's Intended Future Activities Directly Related to Freshwater HABs 49
IX. Appendix 4. Federal Agencies' Current and Proposed Activities Directly Related to HABs 53
X. Appendix 5. Summary of Stakeholder Input 66
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List of Sections Responsive to P.L 114-45
Drinking Water Protection Act -
Elements Necessary for the Strategic Plan
Section of EPA's Strategic Plan
§1459(a)(l)(A)- "evaluate the risk to human health from drinking
water provided by public water systems contaminated with algal
toxins;"
§1459(a)(l)(B)- "establish, publish, and update a comprehensive list
of algal toxins which the Administrator determines may have an
adverse effect on human health when present in drinking water
provided by public water systems, taking into account likely
exposure levels;" and
§1459(a)(l)(C)(i)- "summarize - the known adverse human health
effects of algal toxins included on the list published [by EPA] when
present in drinking water provided by public water systems."
Algal Toxins and Their Human Health
Effects (Section II, A)
§1459(a)(l)(D)(i)- "publish health advisories pursuant to section
1412(b)(1)(F) for such algal toxins in drinking water provided by
public water systems."
Health Advisories (Section II, B)
§1459(a)(l)(C)(ii)- "factors that cause toxin-producing
cyanobacteria and algae to proliferate and express toxins."
Factors Likely to Cause Harmful Algal
Blooms (Section II, C)
§1459(a)(l)(D)(ii)- "establish guidance regarding feasible analytical
methods to quantify the presence of algal toxins."
Analytical Methods (Section II, D)
§1459 (a)(l)(D)(iii)- "establish guidance regarding the frequency of
monitoring necessary to determine if such algal toxins are present in
drinking water provided by public water systems."
Frequency of Monitoring (Section II, E)
§1459(a)(l)(E)- "recommend feasible treatment options, including
procedures, equipment, and source water protection practices, to
mitigate any adverse public health effects of algal toxins included
on the list published [by EPA]."
Treatment Options (Section II, F)
Source Water Protection Practices
(Section II, G)
§1459(a)(l)(F)- "enter into cooperative agreements with, and
provide technical assistance to, affected States and public water
systems, as identified by the Administrator, for the purpose of
managing risks associated with algal toxins included on the list
published [by EPA]."
Cooperative Agreements and Technical
Assistance (Section II, H)
§1459(b)(l)- "identify gaps in the Agency's understanding of algal
toxins, including—(A) the human health effects of algal toxins
included on the list published [by the EPA]; and (B) methods and
means of testing and monitoring for the presence of harmful algal
toxins in source water of, or drinking water provided by, public
water systems".
Information Gaps (Section III, A)
§1459(b)(2)- "consult, as appropriate, (A) other Federal agencies
that-(i) examine or analyze cyanobacteria or algal toxins; or (ii)
address public health concerns related to harmful algal blooms; (B)
States; (C) operators of public water systems; (D) multinational
agencies; (E) foreign governments; (F) research and academic
institutions; and (G) companies that provide relevant drinking water
treatment options."
Stakeholder Involvement (Section III, C)
§1459(b)(3)-"assemble and publish information from each Federal
agency that has—(A) examined or analyzed cyanobacteria or algal
toxins; or (B) addressed public health concerns related to harmful
algal blooms."
Information from Other Federal Agencies
(Section III, B)
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List of Abbreviations and Acronyms
ARS
Agricultural Research Service
ART
Analytical Response Team (NOAA's)
ASDWA
Association of State Drinking Water Administrators
AWWA
American Water Works Association
BMAA
Beta-methylamino-L-alanine
BMP
Best Management Practices
CCL
Contaminant Candidate List
CDC
Centers for Disease Control and Prevention
CEAP
Conservation Effects Assessment Project
CHRP
Coastal Hypoxia Research Program
CRMs
Certified Reference Materials
CWA
Clean Water Act
CyAN
Cyanobacteria Assessment Network
CYN
Cylindrospermopsin
DBP
Disinfection byproducts
DHHS
Department of Health and Human Services
DNA
Deoxyribonucleic acid
DOC
Department of Commerce
DOD
Department of Defense
DOE
Department of Education
DOI
Department of Interior
DWMAPs
Drinking Water Mapping System for Protecting Source Water
DWPA
Drinking Water Protection Act
DWSRF
Drinking Water State Revolving Fund
DWTP
Drinking water treatment plant
ELISA
Enzyme-linked immunosorbent assay
EPA
United States Environmental Protection Agency
ESA
European Space Agency
FDA
Food and Drug Administration
GAC
Granulated Activated Carbon
GAO
Government Accountability Office
GAP
General Environmental Assistance Program
GIS
Geographic Information Systems
GLRI
Great Lakes Restoration Initiative
HA
Health Advisory
HABHRCA
Harmful Algal Bloom and Hypoxia Research and Control Act
HAB
Harmful algal bloom
HESD
Health Effects Support Document
HHWQC
Human Health Water Quality Criteria
IWG
Interagency Working Group
LC/MS/MS
Liquid chromatography tandem mass spectrometry
LPS
Lipopolysaccharides
MMPB
2-methyl-3-methoxy-4-phenylbutyric acid
NARS
National Aquatic Resource Surveys
NASA
National Aeronautics and Space Administration
NCCOS
National Centers for Coastal Ocean Science
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NCER
National Center for Environmental Research
NDWAC
National Drinking Water Advisory Council
NERL
National Exposure Research Laboratory
NGO
Non-Governmental Organization
NHC
National HABs Committee
NIEHS
National Institute of Environmental Health Science
NIFA
National Institute of Food and Agriculture
NLA
National Lakes Assessment
NOAA
National Oceanic and Atmospheric Administration
NORS
National Outbreak Reporting System
NPDES
National Pollutant Discharge Elimination System
NPS
National Park Service
NRC
National Research Council
NRCS
Natural Resources Conservation Service
NRWQC
Nationally Recommended Water Quality Criteria
NSF
National Science Foundation
NWFSC
Northwest Fisheries Science Center
NWIS
National Water Information System
NWP
National Water Program
OCE
Division of Ocean Sciences (NSF)
Ohio EPA
Ohio Environmental Protection Agency
OKDEQ
Oklahoma Department of Environmental Quality
ORD
Office of Research and Development (EPA)
OST
Office of Science and Technology (EPA)
OW
Office of Water (EPA)
PAC
Powdered Activated Carbon
PMN
Phytoplankton Monitoring Network
PSP
Paralytic Shellfish Poisonings
PWS
Public Water System
qPCR
Quantitative Polymerase Chain Reaction
RARE
Regional Applied Research Effort
RPS
Recovery Potential Screening
SDWA
Safe Drinking Water Act
SEATT
South East Alaska Tribal Toxins network
SWP
Source Water Protection
TMDLs
Total Maximum Daily Loads
UC
University of Cincinnati
UCMR
Unregulated Contaminant Monitoring Rule
USACE
United States Army Corp of Engineers
USDA
United States Department of Agriculture
USGS
United States Geological Survey
WBPs
Watershed-Based Plans
WHO
World Health Organization
WQT
Water Quality Trading
WRF
Water Research Foundation
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I. Executive Summary
The prevalence and duration of harmful algal blooms (HABs) in freshwater is rapidly expanding in the
United States and worldwide. The water quality, human health and socioeconomic impacts of HABs can
be significant. Some HABs can produce toxins that are toxic to liver, kidney and nervous system
functions in humans and animals. These toxins, when found in source waters, can contaminate drinking
water supplies if that water is not adequately treated. The challenges that HABs pose to public drinking
water systems include an incomplete understanding of how to prevent, predict, analyze, monitor and
treat toxins in drinking water; determining how to effectively communicate risk to stakeholders; and
developing and implementing resource-efficient methods to reduce the risks posed by HABs in source
waters.
The United States Environmental Protection Agency (EPA) developed this document in accordance with
Section 1459 of the Safe Drinking Water Act, as amended by the Drinking Water Protection Act, which
requires that the Administrator of the EPA develop a strategic plan for assessing and managing risks
associated with algal toxins in drinking water provided by public water systems. This plan presents
examples of recently completed and ongoing HAB-related activities and provides steps and timelines for
intended future EPA activities. These ongoing and future activities outline EPA's plan for the next few
months through the next five years and beyond. This plan addresses:
Algal Toxins and Their Human Health Effects
Evaluating the risk to human health from drinking water contaminated with algal toxins provided by
public water systems; establishing, publishing and updating a comprehensive list of algal toxins that may
have an adverse effect on human health when found in drinking water provided by public water systems;
and summarizing those health effects.
Steps include: 1) Building on the existing work of compiling information on mechanisms of toxicity in
human and animals for the toxins microcystins, cylindrospermopsin and anatoxin-o; 2) evaluating
information gaps and analyzing the human health risk posed by other toxins of human health concern;
and 3) determining whether sufficient information is available to develop health advisories for
additional toxins.
Health Advisories
Determining whether to publish additional health advisories for the algal toxins represented on the
comprehensive list of algal toxins that may have an adverse effect on human health when found in
drinking water provided by public water systems.
Steps include: 1) Determining if adequate occurrence, toxicology and epidemiology data are available to
develop health advisories for the listed toxins other than those established in June 2015 for the
cyanotoxins microcystins and cylindrospermopsin; 2) evaluating the toxicity of these listed toxins
including the toxico-dynamics and toxicokinetics of microcystin congeners; and 3) analyzing the adverse
effects to the reproductive system from exposure to microcystins.
Factors Likely To Cause Harmful Algal Blooms
Summarizing the factors that cause toxin-producing cyanobacteria and algae to proliferate and express
toxins.
Steps include: 1) Building on research to better understand HAB ecology; 2) developing tools to quantify
HABs in U.S. freshwater lakes and reservoirs using satellite color data; 3) evaluating, interpreting and
linking existing data on algal toxins and the factors that impact their occurrence, including nutrient
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loading and climate change; and 4) identifying areas where more monitoring is necessary to support
scientific understanding.
Analytical Methods
Establishing additional guidance regarding feasible analytical methods to quantify the presence of algal
toxins.
Steps include: 1) Building on efforts to evaluate the comparability of rapid screening methods and more
specific analytical methods; 2) evaluating methods to fill knowledge gaps and provide improved
analytical methods for algal toxins in drinking water; and 3) providing standardized and validated
detection and analysis methods, as needed, for emerging algal toxins of concern.
Frequency of Monitoring
Evaluating the frequency of monitoring necessary to determine if such algal toxins are present in drinking
water provided by public water systems.
Steps include: 1) Engaging with states and public water systems to update and refine the existing
guidance on monitoring frequency as more information becomes available; and 2) using emerging
science on factors affecting HABs and algal toxins to inform monitoring frequencies.
Treatment Options
Evaluating feasible treatment options, including procedures and equipment to mitigate any adverse
public health effects of algal toxins included on the published algal toxin list.
Steps include: 1) Summarizing the state of knowledge regarding water treatment optimization and
identifying approaches to assist with treatment challenges related to HAB events; 2) researching the
removal effectiveness of unit operations for various toxins and developing better predictive
tools/models; and 3) investigating how to implement treatment process and operational changes for
maximum protection and cost-effectiveness under a variety of site-specific constraints.
Source Water Protection Practices
Evaluating and recommending feasible source water protection practices to mitigate any adverse public
health effects of algal toxins included on the published list.
Steps include: 1) Expanding computerized mapping and water quality modeling for HAB detection and
prediction at the watershed scale; 2) monitoring nutrients across watersheds to both target and assess
protection activities; 3) working with states to prioritize nutrient-impacted waterbodies for water quality
improvements and developing targets for clean-up; and 4) collaboratively working across the EPA's
regional offices to promote awareness amongst the public drinking water systems on the monitoring,
screening techniques and source water protection practices.
Additionally, this plan outlines a strategy for continuing to utilize cooperative agreements and provide
technical assistance to states and public water systems to address HABs.
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II. Introduction
On August 7, 2015, Public Law 114-45, titled the Drinking Water Protection Act, amended the Safe
Drinking Water Act (SDWA) by adding Section 1459, Algal Toxin Risk Assessment and Management (see
Appendix 1 for the text of P.L. 114-45). Section 1459 directs the Administrator of the United States
Environmental Protection Agency (EPA) to submit to Congress, no later than 90 days after the date of
enactment, a strategic plan for assessing and managing risks associated with algal toxins in drinking
water provided by public water systems (PWSs). The plan must include steps and timelines to:
• Evaluate the risk to human health from drinking water contaminated with algal toxins provided
by PWSs;
• Establish, publish and update a comprehensive list of algal toxins that may have an adverse
effect on human health when found in drinking water provided by PWSs, accounting for the
levels of likely exposure;
• Summarize known adverse human health effects of the listed algal toxins when present in
drinking water provided by PWSs and summarize factors that cause toxin-producing
cyanobacteria and algae to proliferate and cause cells to express toxins (i.e., produce and
release toxins);
• For the listed algal toxins, determine whether to publish health advisories, establish guidance on
feasible analytical methods to quantify the presence of algal toxins, recommend the frequency
of monitoring necessary to determine if algal toxins are present and recommend feasible
treatment options including source water protection practices; enter into cooperative
agreements with, and provide technical assistance to, affected states and PWSs, as identified by
the Administrator, for the purpose of managing risks associated with algal toxins included on the
algal toxin list developed by the EPA; and update the strategic plan as appropriate.
Section 1459 also directs the EPA to identify information gaps in the understanding of algal toxins,
including the human health effects and the methods and monitoring for algal toxins in source water or
in drinking water provided by PWSs. The new amendment directs the EPA, as appropriate, to consult
with other federal agencies (that evaluate cyanobacteria or algal toxins or that address public health
concerns related to cyanobacteria and algal toxins), states, PWS operators, multinational agencies,
foreign governments, research and academic institutions and companies providing treatment options. In
addition, Section 1459 also directs the EPA to assemble and publish information from each federal
agency that has evaluated cyanobacteria or algal toxins or addressed public health concerns related to
HABs.
This document presents to Congress a strategic plan for the assessment and management of the risk
associated with algal toxins in drinking water provided by PWSs. This strategic plan outlines steps and
timelines for currently planned EPA activities and the activities that could occur in the future, contingent
upon available resources and funding, to address specific items in Section 1459. Nothing in this
document, in and of itself, obligates EPA to expend appropriations or incur other financial obligations
that would be inconsistent with the Agency's statutory authority, its budget priorities, or the availability
of appropriated funds. This document also does not create any right or benefit, substantive or
procedural, enforceable by law or equity against EPA, its officers or employees, or any other person.
The strategic plan also includes ongoing activities of the Interagency Working Group (IWG) that was
established as part of the Harmful Algal Bloom and Hypoxia Research and Control Act (HABHRCA)
Amendments of 2014 (HABHRCA 2014; P.L. 113-124). The IWG on HABHRCA is chaired by the EPA and
National Oceanic and Atmospheric Administration (NOAA), and includes representatives of the U.S.
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Centers for Disease Control and Prevention (CDC), Food and Drug Administration (FDA), U.S.
Department of Agriculture (USDA), U.S. Army Corps of Engineers (USACE), United States Geological
Survey (USGS), National Aeronautics and Space Administration (NASA), National Institutes of Health
(NIH) and the National Science Foundation (NSF). The IWG develops action plans, reports and
assessments in coordination with federal agencies to advance the scientific understanding of and ability
to predict, detect, mitigate, control and respond to HABs and hypoxia events. This strategic plan
specifically focuses on toxins associated with cyanobacteria (cyanotoxins).1
1 There are toxins associated with some other algae as well. While cyanotoxins are technically not produced by
algae, this document describes cyanotoxins as algal toxins to be consistent with the common, synonymous usage
of these terms. Similarly, the document at times uses the terms cyanobacterial blooms and harmful algal blooms
synonymously.
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III. Strategic Plan
a. Algal Toxins and Their Human Health Effects
This section is responsive to §1459(a)(l)(A), §1459(a)(l)(B) and §1459(a)(l)(C)(i) of the SDWA directing
the EPA to develop a strategic plan to "evaluate the risk to human health from drinking water provided
by public water systems contaminated with algal toxins"establish, publish, and update a
comprehensive list of algal toxins which the Administrator determines may have an adverse effect on
human health when present in drinking water provided by public water systems, taking into account
likely exposure levelsand "summarize - the known adverse human health effects of algal toxins
included on the list published [by the EPA] when present in drinking water provided by public water
systems."
Cyanobacteria can produce a wide range of bioactive compounds, some of which may have beneficial or
therapeutic effects (Jensen et al., 2001). Other cyanobacteria can produce bioactive compounds that
may be harmful, called cyanotoxins. The most commonly recognized bioactive compounds produced by
cyanobacteria fall into four broad groupings: cyclic peptides, alkaloids, amino acids and
lipopolysaccharides (LPSs).
Cyanotoxins present a unique challenge. The same cyanotoxins can be produced by more than one
species of cyanobacteria and some cyanobacteria can produce more than one toxin at a time, resulting
in blooms with multiple cyanotoxins (Funari and Testai, 2008). The toxicity of a particular bloom is
complex, determined by the mixture of cyanobacteria species present and the variation in strains with
toxic and nontoxic genotypes involved (WHO, 1999). Toxin production can vary between blooms and
within an individual bloom over time (Duy et al., 2000).
Drinking water is a source of potential exposure to cyanotoxins. The occurrence of cyanotoxins in
drinking water depends on their levels in the raw source water and the effectiveness of treatment
methods for removing cyanobacteria and cyanotoxins during the production of drinking water. The
SDWA, as amended in 1996, requires the EPA to publish a list of contaminants every five years that are
known or anticipated to occur in PWSs and which may require regulation under the SDWA. This list is
called the Contaminant Candidate List (CCL). Cyanobacteria and their toxins were included in the CCL 1
and the CCL 2. The CCL 3 and the draft CCL 4 also identify cyanotoxins as a priority, highlighting three
particular toxins of interest: microcystin-LR, cylindrospermopsin and anatoxin-o (U.S. EPA, 2015a). As
part of the CCL processes, health and occurrence information were evaluated in establishing the lists.
Under the SDWA, the EPA uses the Regulatory Determination process to evaluate available data to
determine whether contaminants require regulation or if additional information is needed. The EPA has
not addressed cyanobacteria or cyanotoxins in any of the previous Regulatory Determination cycles due
to the limited occurrence and health effects information. The contaminants listed on the CCL generally
represent priorities for the Unregulated Contaminant Monitoring Rule (UCMR) program. Under UCMR,
occurrence data are collected to allow the Agency to evaluate contaminants that currently do not have
drinking water standards and to support subsequent Regulatory Determinations (U.S. EPA, 2012b).
Cyanotoxins have not been included on previous UCMRs due to a need for improvements in cyanotoxin
analytical methods.
Cyanobacteria are the primary harmful algal group in freshwater environments and have been
documented throughout the country. Many species of cyanobacteria are able to produce toxins.
Microcystins, cylindrospermopsin and nodularins are known to impact the liver (hepatotoxins);
anatoxin-o, anatoxin-ofsj and homoanatoxin-o are known to impact the nervous system (neurotoxins).
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These toxins pose potential risk to human health via exposure to contaminated water. Other common
toxins produced by cyanobacterial species are LPS endotoxins, saxitoxin and beta-methylamino-L-
alanine (BMAA). Saxitoxins, a large toxin family also known as paralytic shellfish poisoning (PSP) toxins,
are common in marine waters but have also been reported in freshwater systems in the United States.
The data on freshwater saxitoxins occurrence are limited, and toxicity data from exposure in drinking
water is not available. BMAA, a recently discovered neurotoxin, also has limited data on toxicity and
environmental fate and transport.
In 2012, the EPA developed an online resource, the EPA Cyanobacterial HABs Website
(http://www.epa.gov/cvanohabs) to provide information to stakeholders on cyanotoxins. The website
also includes available health effects information on these toxins.
Completed Activities
The EPA has compiled information on mechanisms of toxicity including acute, short-term, subchronic,
chronic and cancer in humans and animals, as well as toxicokinetic information for microcystins,
cylindrospermopsin and anatoxin-o. To view the Health Effects Support Documents (HESDs) for these
cyanotoxins in drinking water, visit the EPA's Health Advisory Web page:
http://water.epa.gov/drink/standards/hascience.cfm (U.S. EPA, 2015b, c, d). The toxicity of cyanotoxins
can vary, even within a specific type of toxin (for example, the microcystins). Symptoms reported after
acute recreational exposure to cyanobacterial blooms (including microcystin-producing genera) include
skin irritations, allergic reactions or gastrointestinal illnesses. Effects reported in humans following acute
or short-term exposure to cyanotoxins in drinking water include gastroenteritis, and liver and kidney
damage. Animal studies have shown that long-term adverse effects from cyanotoxins include liver and
kidney effects. A few available epidemiological studies suggest an association between liver and
colorectal cancers and some cyanotoxins. However, the epidemiology studies are limited by their study
design, including poor measures of exposure, potential co-exposure to microbial and/or chemical
contaminants and, in most cases, failure to control for known liver and colorectal risk factors. More
information is needed to determine the carcinogenicity of these toxins.
Ongoing Activities
The EPA anticipates gathering additional information going forward to determine whether additional
HABs or toxins should be included on the list required by §1459(a)(l)(B). The EPA also expects to
determine what human health effects information is available for these HABs and toxins, particularly
with regard to drinking water exposures. This information, coupled with available information on
occurrence in freshwater, would be used to refine the list of HABs and toxins to consider for future
development of Health Advisories (HAs). This list of HABs and toxins would be included on the EPA
Cyanobacterial HABs website (http://www.epa.gov/cyanohabs).
The EPA will determine if adequate occurrence, toxicology and epidemiology data are available to
develop HAs for additional listed cyanotoxins. The EPA also will continue assessing toxicity data on
microcystins, cylindrospermopsin and anatoxin-o as appropriate. Research activities to assess the
human health effects of cyanotoxins in drinking water include monitoring of cyanotoxins in U.S. waters
and conducting toxicological and epidemiology studies to further understand the effects of cyanotoxins.
Additional ongoing activities can be found in Appendix 2.
Intended Future Activities
The EPA plans to assess new information as it becomes available on current and emerging cyanotoxins
to determine if future HAs are needed. Additional information on EPA's proposed activities can be found
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in Appendix 3. Furthermore, as it evaluates human health effects of HAB exposures, EPA intends to
continue collaborating with public health partners.
Timelines for Ongoing and Future Activities
EPA has recently completed activities to evaluate the risk to human health from drinking water
contaminated with algal toxins (§1459(a)(l)(A)) for three algal toxins: anatoxin-a, microcystins and
cylindrospermopsin. Going forward, EPA will continue to evaluate additional toxicity data that may
become available for these three algal toxins, as appropriate. During FY 2016, EPA plans to evaluate the
available information on human health risk associated with other cyanotoxins to determine whether
sufficient information is available to develop HAs for additional cyanotoxins. These efforts will also
continue in the years ahead.
b. Health Advisories
This section is responsive to §1459(a)(l)(D)(i) of the SDWA directing the EPA to develop a strategic plan
to "publish health advisories pursuant to section 1412(b)(1)(F) for such algal toxins in drinking water
provided by public water systems."
SDWA provides the authority for the EPA to publish HAs for contaminants not subject to any national
primary drinking water regulation. HAs describe non-regulatory concentrations of drinking water
contaminants at which adverse health effects are not anticipated to occur over specific exposure
durations (e.g., one day, ten days, several years and a lifetime). They serve as informal technical
guidance to assist federal, state and local officials, as well as managers of public or community water
systems in protecting public health when emergency spills or contamination situations occur. They are
not legally enforceable federal standards.
There are currently no U.S. federal guidelines, water quality criteria, standards or regulations for
cyanobacteria or cyanotoxins in drinking water under SDWA, or in surface waters under the Clean Water
Act. However, the EPA identifies cyanobacteria and cyanotoxins as a priority, highlighting three
particular toxins of interest—microcystin-LR, cylindrospermopsin, and anatoxin-a—on previous CCLs and
the current draft CCL, which identify contaminants that may need regulation under SDWA. The EPA
found there are adequate health effects data to develop HAs for microcystins and cylindrospermopsin
but found the data inadequate to develop an HA for the cyanobacterial toxin anatoxin-a.
Completed Activities
On June 17, 2015, the EPA published two HAs in drinking water for the cyanotoxins, microcystins and
cylindrospermopsin (U.S. EPA, 2015e, f). The HAs for microcystins and cylindrospermopsin provide
states, drinking water utilities and the public with information on health effects of microcystins and
cylindrospermopsin, analytical methods to test for cyanotoxins in water samples, and treatment
technologies to remove cyanobacterial toxins in drinking water. These documents are available at:
http://water.epa.gov/drink/standards/hascience.cfm.
Ongoing Activities
The EPA intends to determine whether adequate occurrence, toxicology and epidemiology data are
available to develop HAs for the cyanotoxins to be included in the list developed under §1459(a)(l)(B).
The EPA also plans to continue assessing toxicity data on microcystins, cylindrospermopsin and
anatoxin-a to determine whether the existing health advisories should be updated. Additional ongoing
activities can be found in Appendix 2.
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Intended Future Activities
EPA is evaluating whether additional studies to evaluate the toxicity, including the toxico-dynamics and
toxicokinetics, of microcystin congeners are feasible within existing resource constraints. In addition, the
NIH National Toxicology Program intends to conduct toxicity studies to address the adverse effects to
the reproductive system from exposure to microcystins. The EPA also plans to continue evaluating the
health effects of cyanobacteria, including determining the toxicity and allergenic roles of purified
cyanobacteria lipopolysaccharide. Additional information on EPA's proposed activities can be found in
Appendix 3.
Timeline for Ongoing and Future Activities
The EPA published HAs for microcystins and cylindrospermopsin in June of 2015. If the EPA finds that
additional information is sufficient to develop HAs for cyanotoxins other than microcystins or
cylindrospermopsin, completion of HAs for additional cyanotoxins is expected to take approximately one
to two years per assessment.
c. Factors Likely to Cause Harmful Algal Blooms
This section of the strategic plan is responsive to §1459(a)(l)(C)(ii) of the SDWA, which directs the EPA
to develop a strategic plan to summarize the "factors that cause toxin-producing cyanobacteria and
algae to proliferate and express toxins".
Cyanobacteria, also known as blue-green algae, naturally occur in marine and fresh waters. Under
certain conditions cyanobacteria can grow rapidly, producing cyanobacterial blooms (AWWAand WRF,
2015). Some cyanobacteria are capable of producing toxins, called algal toxins or cyanotoxins, which can
pose health risks to humans and animals (U.S. EPA, 2014). Blooms producing toxins are often referred to
as HABs. The conditions that cause cyanobacteria to produce cyanotoxins are not well understood. For
example, even when cyanobacteria capable of producing toxins are present, they may not actually
produce toxins under all environmental conditions (U.S. EPA, 2012b). Also cyanotoxins can occur in the
absence of a visual bloom as not all blooms are visual. It is also not possible to determine solely upon
visual observation if a bloom is producing toxins. When blooms occur, the risk of cyanotoxin
contamination of the surface water increases, thus increasing potential risk to drinking water sources
(U.S. EPA, 2014).
Excess nutrient (nitrogen and phosphorus) loadings and concentrations are a leading cause of increased
occurrence of cyanobacterial bloom formation in water bodies (Yuan and Pollard, 2015). These excess
nutrients can originate from agricultural, industrial and urban sources as well as from atmospheric
deposition (Paerl and Otten, 2013; Conley et al., 2009; Glibert et al., 2014). Factors influencing the
occurrence of cyanobacterial blooms can include:
• excess nutrient (nitrogen and phosphorus) loadings and concentrations,
• slow-moving surface water,
• high water temperature,
• high intensity and duration of sunlight,
• water column stratification,
• changes in water pH, and
• occurrence of trace metals.
Many of these factors play a greater role during shifts in wind and/or precipitation patterns (Izydorczyk
et al., 2005; Ohio EPA, 2010). Rapid swings between drought and flooding can increase levels of
nutrients in adjacent and downstream water bodies that have accumulated on the land during the
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drought. Increased temperatures and changes in frequency and intensity of rainfall associated with
climate change can also favor bloom formation (Paerl and Huisman, 2009). In addition, Doblin et al.
(2007) demonstrated that cyanobacteria can be transported in ballast water from ships at a port where
active blooms occur to other locations when ballast water is discharged.
Completed Activities
The EPA has taken several steps to better understand cyanobacterial HAB ecology. In particular, the EPA
is conducting research to evaluate and summarize contributors to cyanobacterial HAB development and
toxin production. This research program also includes the use of molecular methods to characterize risk
in reservoirs due to algal blooms and toxin production.
The EPA provides nationally consistent and scientifically robust assessments of aquatic resources
through the National Aquatic Resource Surveys (NARS), with a variety of indicators including cyanotoxins
and cyanobacteria abundance (U.S. EPA, 2010). Other physical, chemical and biological indicators such
as chlorophyll-o, pathogens, nutrients and sediments are also surveyed. Information from these surveys
is available at: http://water.epa.gov/tvpe/watersheds/monitoring/aquaticsyrvev index.cfm. The NARS
dataset provides information useful for vulnerability assessments for risks of cyanotoxin exposure for
drinking water sources. The EPA evaluated data from the 2007 National Lakes Assessment (NLA) on
cyanotoxin co-occurrence with other environmental variables. A model was developed associating
concentrations of microcystins with concentrations of chlorophyll-o and total nitrogen. This model can
be used for predicting the occurrence of high concentrations of microcystins, and to identify watershed
management thresholds for total nitrogen and chlorophyll-o to reduce the risks of increased cyanotoxin
concentrations in source water (Yuan et al., 2014). The 2012 NLA data were used to describe a statistical
approach for deriving numeric targets for concentrations of total phosphorus and total nitrogen in lakes
and reservoirs that reduce the probability of excess growth of cyanobacteria in source water (Yuan and
Pollard, 2015). This analysis classified different lakes into groups in which the relationships between
cyanobacterial biovolume and nutrient concentrations were similar, improving the strength of
association between nutrient concentrations and cyanobacterial biovolume over the entire dataset.
Then relationships between total nitrogen, total phosphorus and cyanobacterial abundance were
estimated within different lake classes using hierarchical Bayesian statistical models.
In June 2015, the EPA released a step-by-step assessment guidance to help drinking water systems
conduct a system-specific evaluation to determine if and when their source water is vulnerable to
cyanotoxin occurrence (part of a recommendations document released to assist PWSs in managing risks
from cyanotoxins (U.S. EPA, 2015g)). The EPA also released HESDs for the cyanobacterial toxins
microcystins, anatoxin-o, and cylindrospermopsin
(http://water.epa.gov/drink/standards/hascience.cfm) that contain information on the factors likely to
cause cyanobacterial blooms and toxin production, in addition to health effects information.
Ongoing Activities
The EPA is working collaboratively with NASA, NOAA and the USGS on the Cyanobacteria Assessment
Network (CyAN) to detect and quantify cyanobacterial blooms in U.S. freshwater lakes and reservoirs
using satellite color data. These efforts will allow for more frequent observations over broader areas
than can be achieved by taking traditional water samples. Researchers are developing a mobile
application (app) to inform water quality managers of changes in water quality using satellite data on
cyanobacteria algal blooms (Schaeffer et al., Accepted). This network can assist freshwater systems in
incorporating satellite ocean color technologies into U.S. fresh and brackish water quality management
decisions. The overarching project goal is to support the environmental management and public use of
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U.S. lakes, reservoirs and estuaries by providing the capability to detect and quantify cyanobacterial
blooms using satellite data (Lunetta et al., 2015; U.S. EPA, 2015h). This tool can help states, PWSs and
others obtain efficient and timely information about source water conditions.
The EPA is working on monitoring projects to improve identification and removal of cyanotoxins in
drinking water and is also evaluating the impact of increasing water temperatures and nutrient loads on
bloom development and toxin production. The EPA is currently conducting research on HABs ecology
and the development of watershed and source water management techniques, including the
development of models for nutrient loadings, increasing efficiency of watershed placement of
phosphorus and sediment best management practices (BMPs) to reduce nutrient loadings, and the use
of water quality trading (WQT) to cost-effectively reduce nutrient loadings delivered to a watershed. The
EPA is also assessing the impact of land use and infrastructure on watershed changes and evaluating
ecological contributors to HAB development and toxin production. EPA-led monitoring projects are also
underway to improve identification and removal of cyanobacterial toxins in drinking water and to
identify and characterize the development of blooms in Lake Erie.
The EPA continues to analyze NARS datasets to determine if national recommendations can be made on
the concentrations of total nitrogen and total phosphorus in source waters that would most likely not
lead to formation of HABs. For additional ongoing activities see Appendix 2: EPA's Current Activities
Directly Related to Freshwater HABs.
Intended Future Activities
The ongoing efforts detailed above are expected to continue to completion. In addition, EPA released its
Strategic Research Action Plans for the 2016-2019 timeframe in October 2015. The EPA's Office of
Research and Development's Safe and Sustainable Water Resources Research Program has included a
project focused on HABs, with multiple tasks that are described in EPA's Intended Future Activities
Directly Related to Freshwater HABs (Appendix 3), including further development of satellite remote
sensing capabilities for freshwater HABs that can be utilized in monitoring and management programs.
The EPA plans to work with its federal, state and local partners to make full use of existing cyanobacteria
and cyanotoxin information from a variety of sources. State and regional investigators have conducted a
number of surveys of cyanotoxins that could be explored for inclusion into a central database. This
information could come from both field monitoring stations and supporting laboratory experiments.
Information on factors affecting bloom occurrence should also be compiled.
The EPA plans to work with state and federal partners to incorporate cyanotoxin monitoring into routine
source water and ambient monitoring programs to better understand the conditions that trigger bloom
occurrence and toxin production. The EPA also intends to develop HAB indicators, sampling designs and
protocols for use in national scale assessments. The EPA intends to also work with state and federal
partners to develop a domestic action plan for meeting the updated nutrient load targets for Lake Erie
established under Annex 4 of the Great Lakes Water Quality Agreement. The Great Lakes Water Quality
Agreement provides a case study of a framework the EPA could use to develop and implement nutrient
load targets on a large scale.
The EPA intends to evaluate existing data from case studies and modeling efforts to identify the factors
relating bloom occurrence and toxin production. EPA also intends to develop improved approaches to
understanding the interactive effects of increasing water temperatures and nutrient loads on HAB
development and toxin production as well as improved models to predict risks of HABs under climate
change scenarios. A summary of findings is anticipated to be shared broadly and incorporated into
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predictive tools. Also of interest is an improved understanding of the temporal dynamics of the
relationship between increased nutrients and HABs. Intensive sampling, over time, of a sub-set of the
sites included in the NARS will provide the data that could be analyzed in combination with existing
national datasets. This would allow the EPA to more accurately characterize the contributions of
temporal changes to observed relationships between nutrients and ecological effects in order to make
scientifically sound numeric nutrient criteria recommendations that are protective of the nation's
drinking water sources.
Additionally, the EPA intends to evaluate the links between changing temperatures and changing risk of
blooms on a national scale. Potential studies include relating air temperature to photic-zone
temperature with the intention of modelling this at a broader scale, evaluating how cyanobacteria or
indicators respond to changes in photic-zone temperature, including how this can be predicted over
large spatial extents, and studying how forecasted changes in air temperature impact the likelihood and
extent of bloom events. Additional information on EPA's proposed activities can be found in Appendix 3.
The contaminants listed on the CCL (including cyanotoxins) generally represent priorities for the UCMR
program. Under UCMR, occurrence data are collected to allow the EPA to evaluate contaminants that
currently do not have drinking water standards and to support subsequent regulatory determinations
(U.S. EPA, 2012b). EPA is currently evaluating whether to include certain cyanotoxins in UCMR 4, which
is scheduled for proposal by early 2016.
The EPA's goal is an improved understanding of the factors that are responsible for cyanobacterial
growth and bloom formation as well as an improved ability to predict when cyanobacteria are likely to
produce toxins. Additionally, the EPA hopes to develop an improved understanding of the relationship
between nutrient loading and cyanotoxin concentrations across a range of temporal and spatial scales.
This information is expected to be summarized and incorporated into tools that would help predict and
prevent algal toxin occurrence in drinking water sources.
An important approach to reducing potentially toxic cyanobacterial blooms is to develop and implement
cost-effective and scientifically sound nutrient reduction strategies to achieve healthy water quality in
drinking water sources. The EPA's research will inform tools that can predict downstream water quality
impacts, including cyanotoxin concentration, associated with various nutrient management decisions in
watersheds. This information will be useful for drinking water managers and others in comparing cost-
effective source water control practices to treatment activities at the utility. These tools are anticipated
to help predict source water responses to nutrients in the context of other drivers (e.g., climate change,
coastal acidification and hydrologic changes).
Timeline for Ongoing and Future Activities
Efforts to better understand the factors that cause toxin-producing cyanobacteria and other algae to
proliferate and express toxins are ongoing, and planned research activities are expected to require one
to five years to complete, dependent upon the project and contingent upon available resources. For
example, the capability of satellite detection of algal blooms is estimated to require up to three years to
complete. As another example, the evaluation of NARS data is an ongoing process, with the most recent
NARS lake assessment data with an anticipated publication date of spring 2016.
The EPA plans to publish the final UCMR 4 by late 2016 or early 2017. If cyanotoxins are monitored as
part of that effort, cyanotoxin national occurrence information in raw and finished drinking water will be
collected from 2018 to 2020.
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d. Analytical Methods
This section of the strategic plan is responsive to §1459(a)(l)(D)(ii) of the SDWA directing the EPA to
develop a strategic plan to "establish guidance regarding feasible analytical methods to quantify the
presence of algal toxins."
Accurate and scientifically validated methods to detect algal toxins are critical to assessing and
managing risks associated with algal toxins in drinking water. The EPA is actively collaborating with
states, utilities, and commercial laboratories to develop and validate analytical methods for algal toxins
in drinking water.
Completed Activities
With the CCL and UCMR in mind, EPA scientists developed and recently published two liquid
chromatography tandem mass spectrometry (LC/MS/MS) methods for cyanotoxin analysis in drinking
water: EPA Method 544 for determination of select microcystins and nodularin-R (U.S. EPA, 2015i) and
EPA Method 545 for determination of anatoxin-o and cylindrospermopsin (U.S. EPA, 2015j). In
developing the HAs for total microcystins and cylindrospermopsin, the EPA reviewed a variety of
additional analytical methods available for measuring these toxins in drinking water (U.S. EPA, 2015e, r).
Based on the Agency's understanding as of June 2015, the EPA provided recommendations for water
utilities on the use of enzyme-linked immunosorbent assays (ELISA) as a rapid, cost-effective screening
and monitoring tool and the LC/MS/MS methods to determine the concentration of a number of specific
toxins (U.S. EPA, 2015g).
Ongoing Activities
The EPA is continuing to develop and validate improved analytical methods for algal toxins in drinking
water, and evaluating other methods to fill knowledge gaps. Current efforts include further evaluating
the comparability of results from rapid screening methods and more specific analytical methods. The
EPA is also investigating a new LC/MS/MS method for microcystins based on analysis of an oxidative
product (2-methyl-3-methoxy-4-phenylbutyric acid or "MMPB") which may serve as a surrogate for the
total concentration of microcystins present in a sample. This method is an alternative to the ELISA
method, providing confirmatory data utilizing a more sophisticated, albeit more time-consuming,
complex and expensive method. Another concurrent effort involves adapting drinking water analytical
methods EPA Methods 544 and 545 for use in ambient water. Analysis of ambient water tends to be
more complex due to additional constituents in the water (e.g., organic matter, particulates) that can
potentially interfere with the analysis. The EPA plans to standardize and validate the ambient water
methods for use by states, utilities and commercial laboratories to measure cyanotoxins in source
waters. Additionally, the EPA is evaluating analytical tools such as real-time sensors, qPCR, and
fluorescence-based technologies of microspectrophotometry and flow cytometry to detect
cyanobacteria in source water. EPA is also planning to develop methods for analyzing toxins in
fish/animal tissues. The EPA is also increasing its laboratory capacity for analyzing cyanotoxins; for
example, EPA Region 7 enhanced its EPA lab capabilities and conducted microcystin analysis in
September 2015 for the Kickapoo Nation of Kansas for the Delaware River (source of water) and finished
water at the treatment plant. Additional ongoing activities can be found in Appendix 2.
Intended Future Activities
In addition to the ongoing efforts discussed above, as the EPA continues to evaluate the human health
risk from cyanotoxins in drinking water and establishes a list of algal toxins under §1459(a)(l)(B), there
will be continued interest in standardized and validated detection and analysis methods for additional
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algal toxins. Since it may prove impractical to develop methods to quantify each and every algal toxin in
water (as there are multiple classes of algal toxins and potentially more than one hundred variants
within one class, e.g., microcystins), it is important to develop effective and targeted methods for algal
toxins of concern. A significant challenge to analyzing algal toxins is the limited availability of certified
reference materials (CRMs) for many of the toxins that may impact U.S. waters. There is a need for
affordable methods for toxin analysis that can be implemented by a variety of user groups, quality-
assured with CRMs, and validated through inter-laboratory trials. The EPA plans to continue to
collaborate with other federal agencies and stakeholders to develop intra- and interagency methods and
approaches. The EPA intends to further investigate alternative ways to assess the impact of the many
toxins should quantitation of each and every toxin of interest prove impractical (e.g., due to lack of
available CRMs). Additional information on EPA's proposed activities can be found in Appendix 3.
Timelines for Ongoing and Future Activities
The EPA completed the development of EPA Methods 544 and 545 in 2015, as discussed above.
Evaluating, and as appropriate developing, an MMPB method is expected to take approximately two
years. Developing methods for ambient water is also anticipated to take around two years. As additional
algal toxins are identified or prioritized, the EPA plans to continue developing methods as needed, with
development of a method typically requiring two to four years.
e. Frequency of Monitoring
This section is responsive to §1459 (a)(l)(D)(iii) of the SDWA directing the EPA to develop a strategy to
"establish guidance regarding the frequency of monitoring necessary to determine if such algal toxins
are present in drinking water provided by public water systems."
Monitoring of algal bloom indicators and toxins in raw water and drinking water can provide early
warnings of HAB events and allow water managers to take actions when the HAB events threaten their
source water. Toxin concentrations are highly variable with season and time of the day and are
impacted by many factors (e.g., bloom dynamics, characteristics of water body, weather, etc.).
Currently, no national database on the occurrence of freshwater cyanotoxins is available, and no federal
program is in place to monitor for cyanotoxins at U.S. drinking water treatment plants. Therefore, data
on the presence or absence of cyanotoxins in finished drinking water are limited. Understanding the
factors and conditions that cause bloom formation could lead to better informed and cost-effective
monitoring activities, as discussed in Section III, c above. Cyanotoxins can be held within the cell
(intracellular) or outside the cell (extracellular). Toxins are released from the cell due to multiple factors
and during the normal bloom cycle die off. The relationship between the environmental conditions that
trigger the cyanobacteria to produce toxins is poorly understood. This variability and unpredictability of
the presence of toxins can make monitoring challenging.
Completed Activities
After consulting with states and other stakeholders, the EPA developed its recommendations on
monitoring frequency for microcystins and cylindrospermopsin in raw and finished drinking water
based, in part, on conditions in source water and at the treatment plant (U.S. EPA, 2015g). The EPA
advised that it is important for PWSs to establish their own monitoring frequency based on their site-
specific conditions, available resources, treatment capabilities and other factors (U.S. EPA, 2015g).
Additional information regarding monitoring procedures is available on the EPA Cyanobacterial HABs
website (http://www2.epa.gov/nutrient-policv-data/cvanohabs). where there are recommended
procedures for sampling, preservation, handling and transportation of samples collected to identify the
presence of algal toxins in drinking water.
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Ongoing Activities
Many of the inter- and intra-agency monitoring programs described in Section III, c , such as the CyAN
Project, will provide a better understanding of the appropriate monitoring frequencies of drinking water
in addition to helping understand the factors likely to cause HABs. For recreational waters and drinking
source waters, continuous, real-time monitoring offers some advantages over traditional water
sampling. These efforts can help inform PWS operators and states as to when they should sample their
raw and finished waters. The EPA is working with an interagency task force led by NOAA to develop
sensitive, quantitative, field deployable assays and sensors for HAB cells, toxins and relevant toxin
metabolites; develop remote sensing capabilities for HABs; and integrate HAB and toxin sensors into
emerging U.S. and global ocean observation systems.
Other examples of ongoing EPA efforts include a pilot-scale study that EPA Region 8 is conducting with
PWSs in Wyoming to monitor and collect samples for cyanotoxin analysis. As another example, with EPA
Region 10 support, through the Indian General Environmental Assistance Program, the Sitka Tribe of
Alaska formed the Southeast Alaska Tribal Toxins network (SEATT) with seven other tribes to gather HAB
baseline information. Additional ongoing activities can be found in Appendix 2.
Intended Future Activities
The EPA plans to continue the ongoing efforts detailed above, engaging with states and PWSs to update
and refine the existing guidance on monitoring frequency as more information becomes available. The
EPA anticipates that the development of HAB forecasts under the CyAN program will continue during
fiscal year 2016 and EPA intends to continue research on determining temporal and spatial variability of
blooms (see Section III, c for further discussion). Furthermore, the EPA plans to continue working with
NOAA on a systematic approach to provide warnings to states on water quality and occurrence of
cyanobacterial blooms, which will allow the states to evaluate patterns and trends in lakes and estuaries
that are at risk based on region-specific information. Additional information on EPA's proposed activities
is described in Appendix 3.
Additionally, as the EPA continues to evaluate monitoring frequency for UCMR 4, the EPA may suggest
possible cyanotoxin monitoring schedules and approaches as part of that effort. The toxins identified as
priority in CCL 4 that could be considered in UCMR 4 are: microcystin-LR, cylindrospermopsin, and
anatoxin-o.
Timeline for Ongoing gnd Future Activities
The EPA anticipates it will take four to six months to seek public input and analyze available information
from the 2015 HAB season (including PWS experience with the current recommendations in the 2015
HAB season). An additional three months is anticipated to update the current monitoring
recommendations as appropriate, based on this evaluation. Building of the Cyanobacteria Assessment
Network is currently underway and is expected to take an estimated three to five years to complete.
The EPA plans to publish the final UCMR 4 by late 2016 or early 2017. If cyanotoxin monitoring is
finalized as part of that rulemaking, any amended or new cyanotoxin-related monitoring schedules or
approaches to consider will be included as appropriate.
f. Treatment Options
This section is responsive to §1459(a)(l)(E) of the SDWA directing the EPA to develop a strategic plan to
"recommend fegsible tregtment options, including procedures, equipment, gnd source wgter protection
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practices, to mitigate any adverse public health effects of algal toxins included on the list published [by
the EPA]."
Controlling and managing cyanobacteria in source water and treating cyanobacteria and cyanotoxins in
drinking water are critical to protecting public health. If operated properly, conventional water
treatment designed to reduce turbidity can generally remove intact algal cells and low levels of toxins
(AWWARF, 2001; Haddix et al., 2007). More recently, a study conducted in the United States from 2008
to 2010 in five conventional drinking water treatment plants found microcystins and cylindrospermopsin
at low concentrations in raw water, but found toxins were removed to levels below detection in any of
the finished drinking water samples (Szlag et al., 2015). However, PWSs may face challenges in providing
safe drinking water during a severe bloom event, which can increase the cyanobacteria and cyanotoxin
levels in source waters. There are various prevention and treatment strategies and approaches at the
source, throughout the treatment train, and in the finished water storage and distribution system for a
PWS. As with other contaminants, a multiple-barrier approach is useful.
Completed Activities
The EPA has been working collaboratively with regional offices, states and PWSs to characterize the
effectiveness of drinking water treatment technologies in reducing algal toxins. In developing the HAs
for microcystins and cylindrospermopsin, the EPA reviewed available treatment technologies for
treating these toxins in drinking water. These available treatment technologies were published in the
HAs for microcystins and cylindrospermopsin (U.S. EPA, 2015 e, f). During the 2013 and 2014 blooms
seasons in Lake Erie, EPA researchers conducted sampling at seven drinking water treatment plants. In
addition, bench-scale studies on the impact of oxidation and powdered activated carbon (PAC) addition
early in the treatment process on toxin removal has been evaluated. Based on this and other
experiences, the EPA developed four basic treatment strategies that PWSs can implement to provide
immediate response to any cyanotoxins detected in drinking water intakes and included these strategies
within the recommendations support document released concurrently with the HAs (U.S. EPA, 2015g).
Ongoing Activities
In order to provide further assistance to utilities, the EPA is developing a document to summarize the
state of knowledge regarding water treatment optimization and identify approaches to assist with
treatment challenges related to HAB events. The EPA is also undertaking research to better understand
the removal effectiveness of unit operations for various toxins and develop better predictive
tools/models. For example, it is not known to what capacity a granulated activated carbon (GAC)
contactor unit is able to mitigate such compounds in the event of a severe bloom event. Additional
ongoing activities are described in Appendix 2.
Intended Future Activities
The EPA plans to continue the ongoing efforts detailed above as well as to undertake a systematic study
to evaluate the capacity of GAC to remove cyanotoxins from source water. In addition, the EPA plans to
investigate how to implement process and operational changes for maximum protection and cost-
effectiveness under a variety of site-specific constraints. Ideally, these changes would minimize capital,
maintenance and operational expenses and be scalable across treatment facility size and resource level.
In order to address these questions, EPA intends to perform pilot-scale studies at field locations and at
in-house facilities. The EPA also plans to continue to engage with water managers and other private and
public sector stakeholders to help ensure treatment goals are met, to streamline transfer and adoption
of viable management strategies and technologies and to utilize the available treatment research
information that is currently available and directly applicable to cyanobacteria and cyanotoxin removal.
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Additional intended future activities are listed in Appendix 3, EPA's Intended Future Activities Directly
Related to Freshwater HABs.
Timeline for Ongoing and Future Activities
The EPA anticipates the field studies will take approximately four years and the in-house pilot studies
will take about two years to complete. The optimization guidance document is estimated to take one
year to complete with additional research to be completed in four years. The evaluation of cyanotoxin
removal by GAC is estimated to take three years to complete.
g. Source Water Protection Practices
This section is responsive to §1459(a)(l)(E) of the SDWA directing the EPA to develop a strategic plan to
"recommend feasible treatment options, including procedures, equipment, and source water protection
practices, to mitigate any adverse public health effects of algal toxins included on the list published [by
the EPA]."
Source water protection (SWP) refers to watershed protection measures intended to prevent
contaminants such as cyanotoxins from entering or forming in a source of drinking water. SWP serves as
an early-stage barrier against drinking water contamination and is a proactive, often cost-effective
option to reduce contamination that would otherwise need to be addressed by drinking water
treatment technologies. PWSs can effectively reduce cyanobacteria and related contamination by
addressing factors likely to cause toxic blooms (hereafter "risk factors"). Numerous risk factors for toxic
blooms are discussed in Section III, c. Notably, high loadings of nutrients, like phosphorus and nitrogen,
under certain ambient water and climate conditions are drivers of HABs. While other factors like vertical
stratification and water temperature may impact HABs, recommended SWP practices address nutrient
loading as the most immediate, controllable risk factor.
Nitrogen and phosphorus in source waters can come from point sources of pollution like wastewater
treatment plants and/or nonpoint sources of pollution like agricultural or stormwater runoff. Air
deposition of nitrogen and legacy from in-stream sediments are also contributors. Effective SWP options
to reduce pollution from point vs. nonpoint sources differ; for example, point sources may be addressed
through facility-specific actions like Clean Water Act (CWA) permitted effluent limits, while pollution
from nonpoint sources may be reduced through broader measures like landscape-scale fertilizer
management (by agricultural producers and homeowners) and BMPs such as buffer strips and cover
crops on agricultural lands. SWP methods must also be attuned to drainage conditions, soil
characteristics and other hydrologic and geologic factors impacting nutrient discharge (Ohio EPA, 2015).
Steps toward recommending the most effective SWP practices to reduce incidents of HABs include:
• Identify source waters vulnerable to cyanotoxins, accounting for present, future and seasonal
conditions, in order to target early monitoring for cyanotoxins and SWP activities.
• Develop new and apply existing tools to inventory point and nonpoint discharges of nutrients
in each vulnerable source water to develop the most appropriate matrix of SWP options.
• Evaluate nutrient contributions
o Compare the relative contribution of potential sources of nutrients to in-stream nutrient
levels (what are the "root causes" of nutrients in the source water?),
o Estimate magnitude of HAB risk factors, considering time lags between nutrient load and
bloom response.
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o Establish the baseline ambient data to measure the impact of SWP activities, once
implemented.
• Assess any institutional factors (e.g., financing options, policy frameworks and partnership
opportunities) that will help stakeholders implement SWP.
Implementing nutrient input control requires the cooperation of many programs and stakeholders.
Examples of EPA collaborations to advance the strategies above include:
• A partnership of the EPA, the Association of Clean Water Administrators (ACWA), the
Association of State Drinking Water Administrators (ASDWA), the Ground Water Protection
Council (GWPC) and their networks worked together to produce Opportunities to Protect
Drinking Water Sources and Advance Watershed Goals through the Clean Water Act, a toolkit
that describes ways PWSs can use the strengths of SDWA and CWA programs to protect drinking
water. In the Toolkit, partners describe how programs like point source permitting, water quality
standards, listings, Total Maximum Daily Loads (TMDLs) and Section 319 watershed project
funding can protect source water, thus alleviating public health risks and treatment costs for
downstream PWSs (ASDWA et al., 2014; GWPC, 2012). Several elements of this Toolkit are
described below.
• The EPA is working alongside state and utility associations, non-governmental organizations
(NGOs), federal agencies like the USDA and other partners in the national Source Water
Collaborative (SWC), a group of 26 organizations dedicated to protecting sources of drinking
water. The SWC provides planning resources and technical support for local, state and regional
source water partnerships with a focus on reducing nutrient pollution. For example, the SWC
offers online guides to networking across sectors, accessing funding for SWP and designing
specific projects like manure storage systems and GIS scenario analysis for conservation
practices (SWC, 2015a). SWC members including USDA and the National Association of
Conservation Districts (NACD) also created a Conservation Partners toolkit, which offers a step-
by-step guide for understanding conservation programs through Soil and Water Conservation
Districts and USDA State Conservationists (SWC, 2015b).
• The EPA is working with states to develop and implement nutrient reduction frameworks to
identify their specific sources of nutrient pollution and prioritize watersheds and actions they
will take to reduce these sources, as well as measures to track progress in meeting their Clean
Water Act goals. These goals include meeting water quality standards for nutrients and
preventing HABs. The EPA builds state capacity to reduce nutrient pollution by providing grants
for state water pollution control programs and programs for controlling nonpoint sources of
pollution. The EPA also makes capitalization grants for state loan programs for municipal
wastewater infrastructure and stormwater best management practices. The EPA also provides
technical assistance and oversees regulatory programs that states use to reduce nutrient
pollution (e.g., National Pollutant Discharge Elimination System (NPDES) permits for point
source dischargers, TMDLs that set "pollution budgets" that are the basis for permit limits for
point sources and inform financial and technical assistance to nonpoint sources).
• The EPA works with states and other partners in geographically targeted programs to reduce
nutrient pollution contributing to harmful algal blooms in the Great Lakes, Chesapeake Bay and
its tributaries, and other places. The EPA co-leads the Gulf of Mexico Hypoxia Task Force, a
voluntary partnership of five federal agencies and 12 states, that seeks to reduce one of the
largest hypoxic zones in the world. Actions by Task Force members to reduce nutrient pollution
in the Gulf also have benefits in more local waters, including reduced HABs. The EPA's recently
released Report to Congress on the Hypoxia Task Force (U.S. EPA, 2015k) includes numerous
examples of collaborative work to control nutrients.
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• The EPA and USDA continue to collaborate in multiple geographic programs and in a National
Water Quality Initiative to demonstrate the benefits of using systems of conservation practices
on vulnerable lands to avoid, control and trap nutrients and maximize the effectiveness of
conservation investments.
Completed Activities
SWP and nutrient management planning: The 1996 amendments to the SDWA Section 1453 required
state drinking water agencies to complete Source Water Assessments no later than 3.5 years following
the Agency's approval of the state's program. Source Water Assessments can help stakeholders identify
whether a source water is vulnerable to cyanotoxins. The assessment delineates the Source Water
Protection Area of every public water supply, inventories significant potential sources of contamination
within the Protection Area, and evaluates the susceptibility of each system to contamination (U.S. EPA,
1997). All states completed Source Water Assessments by 2003. States and local stakeholders often use
the assessment as a baseline for proactive source water protection plans and activities. However, since
most of these assessments are more than 15 years old and the data used to develop them have
improved dramatically, the information may not be accurate today. In addition, many were not made
available to the public due to concerns about security. In some cases, because the assessment data were
not available to the public, it prevented the data from being used to make planning decisions at the
watershed scale. The advent of new sources of contamination (e.g., new urban development) and new,
open data sources provide strong incentives to update past assessments to reflect more current
information and HABs-specific vulnerabilities.
Additionally, the EPA has worked with states to create and update Nonpoint Source Management Plans
and Watershed-Based Plans (WBPs). The CWA requires states to develop Nonpoint Source Management
Plans which outline objectives to restore impaired waters and protect healthy waters against nonpoint
source pollution. Nonpoint Source Management Plans often form the basis for state regulatory and
voluntary initiatives (e.g., conservation programs) to curb nutrient pollution. WBPs, which target specific
waterbodies within a state, provide a roadmap to guide cost-effective, well-informed restoration and
protection efforts. WBPs serve as the planning framework for CWA §319 watershed projects (ASDWA et
al., 2014; GWPC, 2012). At the state level, watershed-specific source water assessments can be
compared to Nonpoint Source Management Plans and WBPs to inform SWP planning and activities.
Nutrient monitoring: State water quality agencies monitor and assess waters for nutrients as well as, in
some cases, cyanobacteria or microcystins, and share these data through the EPA's Water Quality Data
Portal. Another source of monitoring data for HAB information is satellite imaging, such as that used in
the Lake Erie HABs Bulletins by NOAA (NOAA, 2015). The United States Geological Survey (USGS) also
collects data on nutrients and cyanotoxins through the National Water Information System (NWIS). In
addition, cyanobacteria and microcystins are a part of the National Lakes Assessment included in NARS
(U.S. EPA, 2013b). However, monitoring for nutrients and cyanotoxins varies in frequency and quality
across watersheds and states. Current methods for measuring nutrient loading are expensive and do not
fully capture nutrient flux within ecosystems, limiting data availability (see "Ongoing Activities" for
additional information).
EPA Region 1 developed a GIS-based approach to identify potential risks from nutrient-related
impairments, including cyanobacteria blooms in New Hampshire's drinking water sources. The same
analysis and mapping is expected to be conducted for the other five New England states. This effort is
helping the region and states to gain a better understanding of the connection between drinking water
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source waters, CWA 303(d) impaired waters and algal blooms. This is a fundamental step to aligning
CWA and SDWA priorities.
Source water standards: The EPA'S Office of Water/Office of Science and Technology (OST) has
developed Nationally Recommended Water Quality Criteria (NRWQC) for Total Nitrogen and Total
Phosphorus (aquatic life ecoregional criteria) and nitrates (human health criteria) to help states and
tribes to develop Water Quality Standards under Section 304(a) of the CWA (U.S. EPA, 1986) (U.S. EPA,
20151). Additionally, the EPA continues to collaborate with states and tribes to develop and implement
region-specific Water Quality Standards that account for site-specific information, current science and
implementation flexibilities under the CWA. These standards form the first step toward controlling
nutrient discharge from point sources in drinking water. Water Quality Criteria inform Total Maximum
Daily Loads (TMDLs), which states can use to define nutrient permit limits for point sources.
To help restore waters that do not meet Water Quality Standards, the EPA has developed the Recovery
Potential Screening (RPS) tool, which outlines ecological, geographic and social factors that lead to
effective watershed protection. RPS helps watershed programs make decisions on where to invest in
protections for the highest chances of success (U.S. EPA, 2012c).
Ongoing Activities
New tools for HAB detection and tracking: The EPA is developing new HAB tracking tools and approaches
to help states and drinking water utilities identify vulnerable source waters and plan SWP activities that
are most suitable to those watersheds. The EPA is in the initial stages of developing mobile apps to help
citizen scientists report and analyze new blooms. As discussed in Section III, c, the EPA's ORD, NASA,
NOAA and USGS are also developing an early warning indicator system using historical and current
satellite data to detect algal blooms. Given additional support for these initial efforts, these tools can
help the EPA, states and utilities track and swiftly respond to HAB events nationwide. The EPA is also
coordinating with states and water systems to share information about protecting source waters,
monitoring for cyanotoxins, and managing cyanotoxins in drinking water.
Nutrient monitoring: Additional monitoring information across watersheds is necessary to both target
and assess SWP activities by measuring the most significant sources of contamination. For nonpoint
source discharges, real time water quality monitoring sensors for nitrogen and phosphorus could be
expanded in strategic locations such as downstream of point sources (see "Intended Future Activities"
below).
A coalition of federal agencies, including the EPA, NOAA, National Institute of Standards and Technology
(NIST), and USGS, has launched the Nutrient Sensor Challenge—an open-innovation competition to
accelerate the development and deployment of affordable sensors that can measure nutrients in
aquatic environments. The Challenge aims to spur development of inexpensive sensors that can be
commercially available by 2017. Sensors can be used by federal and state agencies, researchers, utilities
and watershed managers across the United States to gain a better understanding of nutrient levels and
how nutrients move through the environment—improving watershed management decisions (ACT,
2015).
The EPA is partnering with the dairy and swine industries to develop a Nutrient Recycling Challenge to
accelerate development and use of technologies that can recover nitrogen and phosphorus from animal
manure and generate value-added products. Environmental and economic benefits can become
substantial as more efficient ways to manage and transport nutrients are developed. The call for
concepts will launch November 16, 2015.
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Source water standards: For waters experiencing high nutrient and cyanotoxin levels, states, often with
assistance from the EPA, work to prioritize waterbodies for TMDL development and establish waste load
allocations and permitted effluent limitations under Section 402 of the Clean Water Act. By lowering
nutrient loads from upstream sources, states can reduce the burden on PWSs to remove nutrients and
cyanotoxins from raw water. The EPA's mapping tools like the Drinking Water Mapping System for
Protecting Source Water (DWMAPS) can identify watersheds critical to drinking water and the
impairment status of those waters so that states can easily locate impaired source waters and take
protective action (e.g., TMDL development). In addition, the Source Water Collaborative is currently
creating an online shared library for states to exchange technical information and Water Quality Criteria
for contaminants like nutrients and cyanotoxins, which can help states efficiently establish nutrient
criteria. The EPA is also providing NPDES permit writer training for state permit writers to help them
translate narrative nutrient criteria into permit limits to control nutrient inputs from point sources.
The EPA is co-leading a binational workgroup to develop and implement the Nutrients Annex ("Annex
4") of the 2012 Great Lakes Water Quality Agreement. Under Annex 4, the United States and Canada are
charged with establishing binational phosphorus targets for the nearshore and offshore waters of Lake
Erie, needed to meet several ecosystem objectives, including minimizing the extent of hypoxic zones
associated with excessive phosphorus loading and maintaining cyanobacteria biomass at levels that do
not produce concentrations of toxins that pose a threat to human or ecosystem health.
The EPA is also working closely with states and encouraging them to develop numeric nutrient criteria
for causal (nitrogen and phosphorus) and response (chlorophyll-o; water clarity) variables for multiple
water body categories (streams/rivers, lakes/reservoirs and estuaries/coastal waters). The increasing
frequency of HABs and cyanotoxins in drinking water supplies further underscores the need for the EPA
regions and states to strengthen their efforts. This could include developing these criteria or translators
of narrative nutrient criteria in a timely fashion and at levels protective of all uses, including the drinking
water use.
Regional HABs workshops and information-sharing: Where data on sources of drinking water exist,
partnerships between watershed stakeholders can allow pooling and sharing of information to ensure
that all stakeholders benefit. The EPA and the national Source Water Collaborative work to promote
information-sharing partnerships at the watershed scale through online guides like the Source Water
Collaborative's "How to Collaborate" toolkit and site-specific pilot programs. The EPA also encourages or
sponsors regional workshops designed to bring together state environmental agencies, health
departments, drinking water utility managers, public water supply operators, State Conservationists
(USDA-Natural Resources Conservation Service) and other agriculture partners to discuss HAB issues. For
example, the EPA hosted a HAB workshop on September 30, 2015 - October 1, 2015 in Rapid City, South
Dakota. The EPA plans to support at least two additional workshops of this kind in 2016. Additional
ongoing activities are described in Appendix 2.
Intended Future Activities
The EPA, along with other federal partners, plans to continue the ongoing efforts detailed above as well
as to expand computerized mapping and water quality modeling in order to estimate cyanotoxin risk at
the watershed scale. Current tools used by the EPA could benefit from data enhancements, user support
and flow-specific modeling capability to help estimate nutrient loading in watersheds. Further resources
would also allow the federal government to deploy early warning systems based on satellite imagery
and/or citizen scientist reporting to forecast blooms around the country (these technologies are
currently under development in discrete pilot sites/regions).
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Future work could include working collaboratively with the EPA's regional offices to promote awareness
amongst the public drinking water systems on the monitoring, screening techniques and source water
protection practices that can identify and reduce cyanotoxins that may impact public drinking water
supplies.
Nutrient monitoring is critical to SWP planning to address cyanotoxins. Future work could include EPA
and partners increasing the coverage and frequency of monitoring both up and downstream of key
sources of point and nonpoint source phosphorus and nitrogen pollution. Monitoring data could also
contribute to modeling efforts such as USGS SPARROW or evaluation of ORD's Mississippi River Basin's
multimedia system, which estimates the discharge, fate and transport of nutrients (USGS, 2011; U.S.
EPA, 2015m).
Contingent upon available resources, the EPA may continue to provide logistical and technical support
to the formation and maintenance of state, local and hydrologically based collaboratives of PWSs,
scientists, elected officials and citizens such as the Salmon Falls Source Water Collaborative. As noted
above, the EPA encourages place-based and issue-specific stakeholder workshops to address source
water contaminants of concern to local communities, and hopes to continue this effort. Workshops may
leverage planning tools such as Source Water Assessments and Watershed-Based Plans, as well as
frameworks like Water Safety Plans from the World Health Organization, to identify nutrient sources
and apply cost-effective discharge controls.
Future work could include the EPA conducting an analysis of the economic value of SWP. Analyzing and
articulating the economic value of SWP is necessary for PWSs to justify their investment in these
measures. While early case studies indicate that SWP is less expensive compared to plant-level
treatment methods, more comprehensive research is required (WRI, 2013; Winiecki, 2012).
Objectives for holistic watershed planning, involving a variety of stakeholders at the federal, state, and
local level, include:
• Decision-support and GIS mapping tools allow states and PWSs to assess source water
vulnerability to HABs.
• Ubiquitous source water monitoring in vulnerable watersheds provides states and PWSs with
data necessary to identify the most significant risk factors for HABs and design SWP treatment
options accordingly.
• Point sources help monitor for and reduce nutrient loading in source waters, where appropriate.
• Nonpoint sources of nutrients are mitigated through conservation and other SWP practices.
• CWA programs help protect sources of drinking water.
Timelines for Ongoing and Future Activities
Activities related to source water protection are ongoing. EPA hosted one regional HAB-related source
water protection workshop in fall of 2015, and plans to host at least two more in 2016. The preliminary
deployment for the citizen science tracking mobile app is estimated to take one year to complete and
two to three years to complete the nationwide deployment. A preliminary version of DWMAPS is
currently available (DWMAPS, 2015); more advanced versions are expected to be available for user
testing by a focus group of states and utilities within three to six months. The satellite detection of algal
blooms is estimated to take approximately one to three years to complete. The nutrient sensor
development and pilots are estimated to take approximately two years and the HABs community
workshops are estimated to take one year to complete.
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h. Cooperative Agreements and Technical Assistance
This section of the strategy is responsive to §1459(a)(l)(F) of the SDWA directing the EPA to develop a
strategic plan to "enter into cooperative agreements with, and provide technical assistance to, affected
States and public water systems, as identified by the Administrator, for the purpose of managing risks
associated with algal toxins included on the list published [by the EPA]."
This section of the strategy identifies past efforts undertaken by the EPA on cooperative agreements
and technical assistance, as well as ongoing, planned and potential future activities related to
cooperative agreements and technical assistance. This section also describes the goals of this strategy
with regard to meeting these provisions.
A key tool that the EPA utilizes to provide states the opportunity for technical assistance is the Drinking
Water State Revolving Fund (DWSRF), created under the 1996 Amendments to the SDWA. The program
provides financing to water systems for infrastructure improvements needed to achieve the health
protection objectives of the SDWA. Through annual appropriations to the EPA, states receive
capitalization grants for their state's DWSRF program, which then revolve at the state level. States have
the flexibility to take up to 31% of their capitalization grants in the form of set-asides to provide non-
infrastructure assistance. There are broad eligibilities under the four set-asides including capacity
development, source water protection and technical assistance and training. The four set-asides include
small system technical assistance, administrative and technical assistance, state program management,
and local assistance and other state programs. Each year, states develop work plans outlining how much
in set-asides they plan to take from their capitalization grants and what activities they plan to conduct
with those funds. States could also elect to use some of their funds for source water protection and
technologies related to the control of HABs.
Other cooperative agreements and technical assistance include utilizing the tools and authorities of both
the SDWA and the CWA. For instance, the Clean Water State Revolving Fund program allows a state to
provide, in addition to critical wastewater infrastructure financing, funding options for source water
protection projects. Performance partnership agreements also occur between the EPA and states. These
are two-year agreements that document mutual strategic goals, joint priorities, objectives and
commitments. These partnership agreements can provide flexibility in determining how federal grant
money can be used at the state level to fund source water protection measures and source water
monitoring efforts to help prevent and detect HABs.
The EPA also has tools for cooperative agreements and technical assistance for states that are more
informal in nature. These include the EPA's working relationships with state agencies and their
associations, drinking water research organizations and the EPA regional efforts in assisting states in
efforts to protect the quality of drinking water.
Completed Activities
The EPA has had formal and informal cooperative agreements with states and various organizations in
the drinking water industry, as well as provided technical assistance states and PWSs. For instance, with
regard to formal agreements, states have used DWSRF set-asides to fund the following activities:
* Obtain test kits/laboratory equipment for systems to test for newly recognized contaminants of
concern and training to use that equipment;
* Review and approve laboratory protocols to ensure these laboratories meet new/existing drinking
water analytical method requirements;
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* Provide technical assistance to laboratories related to data management and timely delivery of
drinking water quality results;
* Obtain laboratory equipment for conducting drinking water sample tests;
* Plan and implement surface water source assessment and protection activities, including source
water management plans, buffer establishment and upkeep, road and storm water management
and reconstruction activities, developing public outreach and educational programs and materials;
* Provide a source water protection ordinance template for city and county governments; and
* Support source water protection education and workshops.
Another example is the relationships the EPA has with the state drinking water regulatory agencies and
their associations. For instance, the EPA has a long-standing cooperative relationship with the
Association of State Drinking Water Administrators (ASDWA), a national professional association of state
drinking water programs. Examples of successful cooperation with ASDWA include the sharing of
information between the EPA and ASDWA, the participation of ASDWA on the EPA Federal Advisory
Committees and input on potential implementation concerns that may arise as a result of regulations
developed by the EPA. The EPA benefited greatly from the input of state representatives and ASDWA
during a May 11, 2015, public meeting on cyanotoxins, and on the EPA document "Recommendations
for Public Water Systems to Manage Cyanotoxins in Drinking Water." The technical assistance provided
within the document has assisted states and utilities in better preparing for and responding to
cyanotoxins in drinking water.
In addition, the EPA has utilized informal relationships with states and provided emergency technical
assistance to states in times of crisis. For example, the EPA provided analytical support and technical
assistance to the State of Ohio during the Toledo cyanotoxin bloom of 2014.
The EPA has also been an active participant in water industry research planning activities carried out by
the Water Research Foundation (WRF) and others. For instance, the EPA has participated on WRF
research advisory committees, which lead to an enhanced state of knowledge on a range of drinking
water issues, including cyanotoxins. WRF has funded several projects on cyanotoxins, such as
"Optimizing Conventional Treatment for Removal of Cyanobacteria and Toxins" (2010).
The EPA co-chairs the Interagency Workgroup on the Harmful Algal Blooms and Hypoxia Research and
Control Act, which was tasked by Congress with developing a Report to Congress on Harmful Algal
Blooms and Hypoxia Comprehensive Research Plan and Action Strategy. In addition, the IWG continues
to coordinate activities within the federal agencies on harmful bloom activities. The EPA is also involved
in the collaborative efforts of the National HABs Committee whose mission is to facilitate coordination
and communication of activities on a national level between the U.S. HAB community including
researchers and government agencies.
Ongoing Activities
The EPA has several activities in which the Agency is participating in cooperative agreements and
providing technical assistance in areas that may enhance drinking water protection from cyanotoxin
risks. These activities include assistance related to water monitoring, sample analysis, treatment and
capacity development. For instance, a state could use its DWSRF funds to help tackle cyanotoxin
challenges. DWSRF set-asides may be used as part of a state's strategy to build technical, financial and
managerial capacity of public water systems. For example, a state may use set-asides for demonstration
purposes to build the capacity of the system for activities such as monitoring and training for analysis of
toxins associated with HABs. One example of the use of DWSRF set-asides is from the Ohio
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Environmental Protection Agency (Ohio EPA), which established a fund in 2015 of $1 million to award
grants to surface water treatment plants to reimburse the purchase of cyanotoxin investigative
monitoring equipment (up to $10,000). Having the capacity to analyze samples at the water supply
instead of sending samples to an outside laboratory allows flexibility in monitoring and timely response
to any potential finished water detections.
Ohio EPA also plans in 2016 to spend another $1 million from its 15% Local Assistance and Other State
Programs set-aside to provide technical assistance to PWSs using surface water to help prevent impacts
from cyanobacteria. In addition, Ohio EPA is encouraging PWSs to acquire training from the provider on
the specific test kit purchased. Ohio EPA staff will also be available to provide guidance and technical
assistance on sample collection and analysis.
There are many areas in which the EPA has provided technical assistance and engaged in cooperative
agreements that fall outside of the scope of the DWSRF. For instance, the EPA provides technical
assistance to states and PWSs on a variety of challenges to drinking water quality, including preventing
algal toxin formation and in addressing algal toxins when they occur to mitigate adverse human health
risks from PWSs. The EPA has played a key role in the development of analytic and decision support
tools for drinking water quality protection. The EPA anticipates continuing to include the development
of analytic and decision support tools in future efforts to assist in collecting and analyzing algal toxin
data.
As described earlier, the EPA has a sustained and cooperative relationship with the states and state
representative associations (e.g., ASDWA). The EPA will continue to participate in the established data
and information sharing activities with ASDWA and other state partners as appropriate. These
relationships and activities are particularly important with regard to cyanotoxin concerns, as they can
facilitate the understanding of the potential risks posed if cyanotoxin blooms occur, as well as provide a
quicker and more accurate response to cyanotoxin detections. The EPA also provides logistical and
technical support for the formation and maintenance of state, local and hydrologically-based
collaboratives of PWSs, scientists, elected officials and citizens such as the Source Water Collaborative as
discussed in Source Water Protection Practices (Section III, g).
As an example of the EPA partnering with states to provide technical assistance, the EPA hosted a
workshop in South Dakota for Region 8 state SDWA and Clean Water Act program managers and staff to
address the formation of algal toxins. This workshop facilitated collaboration between states and federal
agencies, including the EPA, by exploring topics including how to prevent HAB occurrence through
source water protection and pollution reduction measures, and how to manage HAB occurrence
through enhanced ambient water quality monitoring and drinking water treatment. The EPA Region 2
and Environment Canada formed a Lake Ontario nutrients task team under the Great Lakes Water
Quality Agreement Annex 4. This task team is preparing a white paper that will, among other things,
characterize algal conditions in Lake Ontario and recommend data and information needs. The EPA
Region 5 Great Lakes Restoration Initiative (GLRI) provides funding to federal and state agencies to
identify collaboration project opportunities to minimize HABs in the Western Basin of Lake Erie. The EPA
Region 9 is working to assist tribes in HAB response, including targeted technical assistance, analytical
support and resources for infrastructure improvements to tribes. The EPA Region 9 worked with the
Hoopa Tribe in response to detection of anatoxin and microcystin in the Trinity River (source water for
Hoopa drinking water) to coordinate analyses, and later provided source water protection grant and
drinking water Tribal set-aside funds to support ozone treatment for the Tribe's drinking water system.
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An area of collaboration with other federal partners includes the EPA's ongoing work with the Natural
Resources Conservation Service (NRCS), the Agricultural Research Service, the United States Forest
Service, and USGS, among others, to help states leverage federal technical and financial resources in
applying the most cost-effective techniques to reduce the pollution of drinking water sources by HAB
precursors such as through natural treatment of cropland runoff. Additional ongoing activities are
described in Appendix 2.
Intended Future Activities
The EPA plans to continue the ongoing efforts detailed above as well having an active role in filling the
information gaps and research needs. In particular, the EPA has specific capabilities for assisting in
identifying HAB causes, development of analytical methods, enhancing monitoring and modeling
programs and sharing information with the public.
The EPA anticipates that the DWSRF will continue to be a source of funds available for mitigating and
preventing cyanotoxins in drinking water. While operation and maintenance are ineligible costs for both
the project loan fund and the set-asides, a state may finance one-time monitoring associated with
newly-installed equipment to ensure that the equipment is operating properly and meets equipment
specifications as part of the equipment delivery and installation process.
The EPA may also be able to provide technical assistance in the following areas:
- Development of watershed models to better predict nutrient loadings.
- Continued collaboration with ASDWA on providing technical assistance to states.
- Technical assistance to systems experiencing HABs.
- Continued input into the development of research recommendations to the WRF and other research
organizations.
- Workshops on opportunities to engage systems on the EPA recommendations to prepare for and
respond to cyanotoxins in drinking water.
- Pilot studies to provide technical assistance to a limited number of individual systems in preparing
for and responding to cyanotoxins in drinking water.
- Revisions to a document the EPA published in June 2015 on recommendations to prepare for and
respond to cyanotoxins in drinking water.
- Partnerships between the EPA regional laboratories with the goal of developing HAB analytical
capacity and analytical technical points of contact for state or PWS laboratory assistance.
- Coordination of state level information among states and stakeholders.
Additional assistance in these areas is anticipated to greatly enhance the ability of systems and states to
prepare for and respond to cyanotoxins in drinking water, as well as strengthen the activities of the
EPA's federal partners.
The goal of the EPA's activities on cooperative agreements and technical assistance is to provide
mechanisms for assistance to states and utilities to prepare for and, if necessary, respond to cyanotoxins
in drinking water. Establishing these agreements and relationships facilitates the responses needed if
and when a system is at risk to cyanotoxins in their water. In addition, the research-related activities
better positions the EPA to identify the most appropriate means to provide technical assistance.
Furthermore, financial assistance mechanisms described in this section enables systems to secure
resources to respond to cyanotoxins in cases where systems may lack the necessary expertise or other
resources. Utilizing cooperative agreements and providing technical assistance helps reduce the
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potential health, environmental and economic impacts of cyanotoxins in finished drinking water and
drinking water sources. Additional intended future activities are described in Appendix 3, EPA's Intended
Future Activities Directly Related to Freshwater HABs.
Timelines for Ongoing and Future Activities
The EPA will continue outreach efforts with states to communicate about possible DWSRF opportunities,
including communicating with partners over the next several months about these opportunities prior to
the next HAB season. The EPA plans to continue to exploring other partnership options with federal
government agencies, states, tribes, PWSs and utility member organizations such as the American Water
Works Association, the Association of Metropolitan Water Agencies and the National Rural Water
Association.
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IV. Information Coordination
a. Information Gaps
This section of the strategy is responsive to §1459(b)(l) of the SDWA directing the EPA, as part of their
strategic plan, to "identify gaps in the Agency's understanding of algal toxins, including—(A) the human
health effects of algal toxins included on the list published [by the EPA]; and (B) methods and means of
testing and monitoring for the presence of harmful algal toxins in source water of or drinking water
provided by, public water systems."
The EPA has previously worked to identify research gaps in the development of current and future
research plans such as the ORD's Safe and Sustainable Water Resources Strategic Research Plans. The
EPA finalized its 2016-2019 project plans in October 2015, which proposed several key research
questions the Agency intends to address in the coming years. EPA has also previously collaborated in
identifying research needs as part of the proceedings of the Interagency International Symposium on
Cyanobacterial Harmful Algal Blooms (ISOC-HAB, 2008). Research needs were identified in Harmful Algal
Research and Response: A National Environmental Science Strategy for 2005-2015 developed by the
Ecological Society of America, supported by NOAA (HARRNESS, 2005).
The EPA has also worked to develop research needs and challenges as part of the IWG, on the HABHRCA
Amendments of 2014. Public Law 113-124, §603A(e)(6) directs the IWG to identify additional needs and
priorities relating to HABs. The IWG developed a report on a comprehensive research plan and action
strategy that includes information gaps. The IWG, co-chaired by the EPA and NOAA, developed a
Comprehensive Research Plan and Action Strategy to address marine and freshwater HABs and hypoxia.
This plan will be submitted to Congress in 2015 and includes research gaps as described below. For more
information on information gaps discussed in the IWG, please see
http://coastalscience.noaa.gov/research/habs/habhrca.
Information gaps exist regarding the impact of drinking water contaminated with algal toxins on human
health. Additional research is needed on human health effects of existing and emerging cyanotoxins for
which no health data currently exist. Further research is also needed on the human health impacts for
which limited health effects data are available, and to better understand the various exposure pathways
of cyanotoxins, including ingestion, inhalation and dermal exposures, that occur through household use
of tap water provided by PWSs. For example, in June 2015, a Health Advisory document and Health
Effects Support Document (U.S. EPA, 2015f, 2015d) were released for microcystins. Microcystin-LR was
used as a surrogate for all the other microcystin congeners. More than 100 microcystin congeners exist,
which vary based on amino acid composition. Microcystin-LR may be one of the most potent congeners
and the majority of toxicological data on the effects of microcystins are available for this congener;
however the potential health risks from exposure to mixtures of microcystin congeners is unknown.
Thus, additional research is needed to understand the human health impacts of the other congeners,
both existing and emerging, as new congeners continue to be isolated and identified.
At present, limited health effects information is available to derive guideline values for the broader
range of cyanotoxins that may be present in drinking water. Other research gaps include information
from both short- and longer-term studies and carcinogenicity bioassays in experimental animals. One of
the challenges in conducting toxicological studies on cyanotoxins is the difficulty and cost of obtaining
the individual purified toxins that are needed to conduct the toxicological studies. Human health effects
information from cyanotoxin exposures in sensitive populations is needed, for example individuals with
preexisting liver conditions, individuals on dialysis, the elderly, pregnant women, and nursing mothers.
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There is an information gap regarding toxin transfer through the placental wall as well as through breast
milk. There is also a need to establish a rapid sample collection and response protocol for detecting HAB
toxins in humans and animals, specialized so that preparation procedures are compatible with analytical
methods for detecting HAB toxins in humans and animals.
Where and when HABs will occur remains an information gap that prevents us from fully understanding
the human exposure risks from cyanotoxins in drinking water provided by PWSs. There is a knowledge
gap regarding the occurrence and formation of blooms in surface waters, including rivers. Occurrence
information in all surface waters could be collected using planned and event response monitoring for
HABs, cyanotoxins and HAB predictors, such as nutrients. Understanding the factors leading to HAB and
cyanotoxin formation can help provide insight into occurrences of HABs and cyanotoxins, provide
information for recommendations for monitoring frequency, and better inform HAB prevention
strategies. For example, although research has shown nutrients, specifically phosphorous and nitrogen,
play key roles leading to HAB formation (WHO, 1999; Jacoby et al., 2000) additional information is
needed to fill information gaps on understanding the relationships among nutrient levels, bloom
formation, toxin release and other factors such as temperature and precipitation. This information could
be used to determine threshold values for various indicators.
Information gaps regarding analytical methods include the need for comparing the results obtained
using various cyanotoxin methods and developing cost-effective screening and monitoring methods. As
identified by stakeholders, better understanding of current methods and development of new methods
is a near-term need. At present, the standardized analytical methods that can be used in a national
monitoring program are limited to analyses of a few specific cyanotoxins or cannot speciate groups of
related cyanotoxins, such as the microcystins. Analytic standard production is limited, which, in turn,
limits capacity for monitoring and research, even when there are measurement methods available. The
methods also differ fundamentally in their detection capabilities, and additional research is warranted
to better understand the quantitative ability of immunological assays (that measure the interactions of
cyanotoxins with antibodies) versus that of LC/MS/MS techniques (that measure the mass-to-charge
abundances of ionized cyanotoxin fragments). Each technique has a unique set of advantages and
limitations. Additional methods will be needed in the future to measure new and emerging toxins for
which there are currently no methods. Methods that are more cost-effective and less lab-intensive
would allow for more widespread use in event response and screening. Developing methods for all
analyses, screening and monitoring needed to hoiistically confront the HAB challenge exceeds the scope
of any one agency, and may be best served by continued interagency partnerships and establishment of
a network of several reference laboratories for standardized and validated methods.
Additional research is needed to better understand congener-specific cyanotoxin removal capabilities of
currently available water treatment processes. It is also necessary to evaluate the potential
consequences that cyanobacteria and cyanotoxin treatment techniques have on the ability of a
treatment facility to comply with existing drinking water quality regulations. For example, the
application of high oxidant concentrations to high concentrations of bloom material may negatively
impact the ability of a facility to comply with the disinfection byproduct rules. Other information gaps
exist regarding cyanobacteria and cyanotoxin treatment such as absorption capacity of powdered
activated carbon, contact time (CT) tables for cyanotoxins removal and the effects of permanganate.
Application of source water treatments, such as algicides, is also an area where information gaps exist
with respect to the impacts of these treatments on treatment efficacy, source water quality,
environmental impacts and the efficiency of downstream treatment infrastructure. Prevention and
treatment activities can involve a multi-barrier approach as well as adaptive management to fully
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address the HABs issue. Information is needed to provide support to states and PWSs on developing and
incorporating these activities at the PWS level to ensure the best course of action is tailored specifically
to the PWSs specific circumstances.
Source water protection information gaps involve better understanding of the causes of blooms as well
as better understanding of how source water protection activities can prevent or reduce them.
Understanding the impacts of current source water protection practices (both short-term and long-term
practices) can help with the development of future protection practices and best management practices
within a source water's watershed.
The relationship among factors that promote algal bloom and subsequent toxin production are not well
understood. Those factors include both environmental conditions such as water clarity, meteorological
conditions, alteration of water flow, vertical mixing, temperature and water quality conditions such as
pH changes, nutrient loading (principally in various forms of nitrogen and phosphorus) and trace metals.
Developing approaches for open communication and engagement between specific stakeholders is also
needed for cooperation and support for SWP practices.
More information is also needed to better understand how climate change will affect the geospatial and
temporal distribution of HABs. For example, studies have shown that increases in temperature, altered
rainfall patterns, and anthropogenic nutrient loading may lead to an increase in bloom frequency,
intensity, duration and geographic distribution (O'Neil et al., 2012; Paerl and Huisman, 2009; Paerl et al.,
2011). Another information gap is understanding how the interactions of multiple future climatic
changes will impact HAB and cyanotoxins in fresh water systems. Given the potential increase in
cyanobacterial blooms due to both the direct and indirect effects of climate change, understanding the
effects at a regional scale can help water systems prepare for potential blooms that could occur due to
changes in regional climate.
A better understanding of risk communication in the context of risk management is also needed for
cyanotoxins and HABs. The HAs for microcystin and cylindrospermopsin established two advisory levels,
one for bottle-fed infants and young children of pre-school age and one for all other ages. This can
create confusion for the public, and additional tools would support water systems in communicating this
risk. The advisory levels are based on 10 days of exposure, which may also create difficulty in risk
communication. Additional support would help PWSs handle various scenarios such as short duration
exposures or low levels of exposures. The EPA has released recommendations regarding communication
language that can be found in the recommendations document (http://www2.epa.gov/nutrient-policy-
data/guidelines-and-recommendations) based on varying levels cyanotoxins found in the finished water.
The EPA will update this language and develop other tools as appropriate. Currently the EPA is also
working with the CDC and other stakeholders on updating the Drinking Water Advisory Communication
Toolkit to include cyanotoxins specific information
(http://www.cdc.gov/healthvwater/emergencv/toolkit/drinking-water-outbreak-toolkit.html).
Developing training tools to assist in answering the key questions specific to PWSs are warranted.
Although systems have been dealing with algal blooms for some time, additional training is needed
regarding the cyanotoxin-producing blooms, on preventing the toxins from reaching finished water as
well as training on how to handle communication situations as described above once cyanotoxins occur
in finished water. PWS training can also help systems understand the impacts of the management cost
consequences to the PWS for preparation and response measures to cyanotoxin occurrence.
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Additional development is also needed on how HABs data and information are managed and shared.
Many systems are collecting HABs and cyanotoxin information and it would be beneficial to have
commonalities among the data being generated such as all relevant metadata would need to be
included. Using available tools such as the EPA's Water Quality Exchange or the Water Quality Portal, a
cooperative service that is jointly sponsored by USGS and the EPA, can be used to assist the data
management of cyanotoxin information. Stakeholders identified needs to develop and use other
resource friendly information sources such as creating monitoring networks for sharing data.
b. Information from Other Federal Agencies
This section of the strategy is responsive to §1459(b)(3) of the SDWA directing the EPA, as part of its
strategic plan, to "assemble and publish information from each Federal agency that has—(A) examined
or analyzed cyanobacteria or algal toxins; or (B) addressed public health concerns related to harmful
algal blooms."
The HABHRCA IWG coordinates and convenes with relevant federal agencies to discuss HABs and
hypoxia events in the United States, and to develop a number of reports and assessments of these
situations. For more information on HABHRCA and the Interagency Workgroup please visit
http://coastalscience.noaa.gov/research/habs/habhrca.
Since 2013, the EPA is an ex-officio member of the National HABs Committee (NHC). The NHC is an
elected body with members representing the HAB research and state and local management community
with non-voting ex-officio members from the EPA, NOAA, USGS and CDC.
In addition to the ongoing EPA efforts described in Appendix 2 and on the EPA's website that details EPA
activities on cyanotoxins (http://www2.epa.eov/nutrient-policv-data/cvanohabs). several federal
agencies are conducting activities and projects to advance the research on toxin-producing
cyanobacteria and algal toxins in drinking water. Federal agencies, such as USDA, are collaborating to
address nonpoint sources of nutrients that can contribute to the rise of HABs. Other agencies support
research to better understand HABs, including ways to prevent, control and mitigate them. Health and
food safety agencies at the federal and state levels are studying and monitoring the health effects on
people and pets. In some cases, government agencies at all levels are engaging the public to conduct
citizen science to monitor water quality and the occurrence of HABs in local waters. These activities are
listed in the HABHRCA Comprehensive Research Plan and Action Strategy and in Appendix 4 of this
strategic plan. Appendix 4 was compiled from interagency efforts based on input and feedback from
other federal agencies. This information will be further explored with the release of the HABHRCA
Report to Congress anticipated to be released by the end of 2015.
Timeline
EPA intends to publish information on federal agency efforts on HABs in late 2015 through its
collaboration on the HABHRCA Congressional Report.
c. Stakeholder Involvement
This section of the strategy is responsive to §1459(b)(2) of the SDWA directing the EPA, as part of its
strategic plan, to "consult, as appropriate, (A) other Federal agencies that-(i) examine or analyze
cyanobacteria or algal toxins; or (ii) address public health concerns related to harmful algal blooms; (B)
States; (C) operators of public water systems; (D) multinational agencies; (E) foreign governments; (F)
30
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research and academic institutions; and (G) companies that provide relevant drinking water treatment
options."
Completed Activities
The EPA held a public listening session on September 16, 2015, to provide an opportunity for
stakeholders to present their views on the key issues that may inform the strategic plan on assessing
and managing risks from cyanotoxins to drinking water. Over 300 people participated and 13 individuals
provided written or oral input. Registrants of that session included members and stakeholders of the
drinking water community, such as PWS operators, state and local governments, academic institutions,
federal agencies, industry representative groups, environmental groups, technology manufacturers and
developers (see Appendix 5 for Summary of Stakeholder Input). Comments submitted during the
listening session were considered in the development of this strategic plan. On September 17, 2015, the
EPA heard clarification of input provided by states and water utilities in a meeting with ASDWA and
AWWA and several of their members. Participants provided additional input regarding key information
gaps related to our understanding of managing algal toxins in drinking water. The consultation focused
on discussions of activities to include in the strategic plan.
In April 2015, the EPA sought input on the most recent draft Contaminant Candidate List (CCL) 4. The list
contained cyanotoxins including anatoxin-o, cylindrospermopsin and microcystins. In May 2015, the EPA
held a public meeting to provide an opportunity for public input on potential actions states and PWSs
could take to prepare for and respond to cyanotoxin health risks in drinking water. The EPA engaged
with stakeholders on what information the Agency could provide to best support states and PWSs in
addressing their risks to cyanotoxins.
The IWG also conducted a series of webinars in all major regions of the United States and a public
meeting in Ohio to initiate a conversation with stakeholders on topics related to HABs and hypoxia.
Input received was used by the IWG to inform the development of the comprehensive research plan and
action strategy for dealing with and responding to HABs and hypoxia that will be published in fall 2015.
Intended Future Activities
As part of future efforts to evaluate risks to drinking water from cyanotoxins, the EPA will continue to
engage stakeholders, including states, ASDWA, AWWA, PWSs, the environmental community and others
as appropriate to ensure timely, useful and valid products. The EPA also intends to participate in
additional public meeting(s) after the current algal bloom season ends to obtain feedback on the EPA's
recommendation document for PWSs.
31
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V. References
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Conley, D.J., Paerl, H.W., Howarth, R.W., Boesch, D.F., Seitzinger, S.P., Havens, K.E., Lancelot, C., Likens,
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Doblin, M. A., Coyne, K. J., Rinta-Kanto, J. M., Wilhelm, S. W., Dobbs, F. C. 2007. Dynamics and short-
term survival of toxic cyanobacteria species in ballast water from NOBOB vessels transiting the Great
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Fawell, J. K., Mitchell, R. E., Everett, D. J., and Hill, R. E. 1999. The toxicity of cyanobacterial toxins in the
mouse. 1. Microcystin-LR. Human and Experimental Toxicology, 18(3): 162-167.
Fitzgeorge, N. L. M., Clark, S. A. and Kelvin, C. W. 1994. Routes of intoxication. In: G. A. Codd, T. M.
Jeffreies, C. W. Kelvin and E. Potter, (Eds.). Detection Methods for Cyanobacterial (Blue-Green Algal)
Toxins and First International Symposium on Detection Methods for Cyanobacterial (Blue-Green Algal)
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and WHO 1999)
Funari, E. and Testai, E. 2008. Human health risk assessment related to cyanotoxins exposure. Critical
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(HB-HAB) link. Environmental Research Letters 9(10): 105001.
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http://www.gwpc.org/cwa-sdwa-coordination-toolkit.
Haddix, P. L., Hughley, C. J., and LeChevallier, M. W. 2007. Occurrence of microcystins in 33 US water
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HARRNESS, 2005. Harmful Algal Research and Response: A National Environmental Science Strategy
2005-2015. Ramsdell, J.S., D.M. Anderson and P.M. Glibert (Eds.), Ecological Society of America,
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Washington DC, 96 pp. Available online at:
http://www.esa.org/HARRNESS/harrnessReportlQ032005.pdf.
Heinze, R. 1999. Toxicity of the cyanobacterial toxin microcystin-LR to rats after 28 days intake with the
drinking water. Environmental Toxicology, 14(1): 57-60.
Humpage, A. R. and Falconer, I. R. (2002). Oral Toxicity of Cylindrospermopsin: No Observed Adverse
Effect Level Determination in Male Swiss Albino Mice. The Cooperative Research Centre for Water
Quality and Treatment, Salisbury, South Australia. Research Report No. 13. (93 pages).
Humpage, A. R. and Falconer, I. R. (2003). Oral toxicity of the cyanobacterial toxin cylindrospermopsin in
male Swiss albino mice: Determination of no observed adverse effect level for deriving a drinking water
guideline value. Environmental Toxicology, 18(2): 94-103.
Interagency, International Symposium on Cyanobacterial Harmful Algal Blooms (ISOC-HAB) Proceedings.
2008. Cyanobacterial harmful algal blooms: state of the science and research needs. Available online at:
https://www.cdph.ca.gov/Healthlnfo/environhealth/water/Documents/BGA/ISOCHABdocument.pdf.
Ito, E., Kondo, F., Terao, K., and Harada, K-l. 1997. Neoplastic nodular formation in mouse liver induced
by repeated i.p. injections of microcystin-LR. Toxicon, 35(9): 1453-1457.
Izydorczyk, K. Tarczynska, M., Jurczak, T., Mrowczynski, J., Zalewski, M. 2005. Measurement of
Phycocyanin Fluorescence as an Online Early Warning System for Cyanobacteria in Reservoir Intake
Water. Environmental Toxicology 20(4): 425-430.
Jacoby, J. M., Collier, D. C., Welch, E. B., Hardy, F. J., and Crayton, M. 2000. Environmental factors
associated with a toxic bloom of Microcystis aeruginosa. Canadian Journal of Fisheries and Aquatic
Sciences 57: 231-240.
Jensen, G. S., Ginsberg, D. I., and Drapeau, C. 2001. Blue-green algae as an immuno-enhancer and
biomodulator. Journal of the American Medical Association, 3: 24-30.
Lunetta, R. Schaeffer, B.A., Keith, D., Jacobs, S., Stumpf, R., & Murphy, M. 2015. Evaluation of
cyanobacteria cell count detection derived from MERIS imagery across the eastern USA. Remote Sensing
of Environment. 157: 24-34.
National Oceanic and Atmospheric Association (NOAA), 2015. National Centers for Coastal Ocean
Science, "HAB Forecasting". Available online at:
http://coastalscience.noaa.gov/research/habs/forecasting. Accessed September 22, 2015.
O'Neil, J.M., Davis, T.W., Burford, M.A., Gobler, C.J. 2012. The rise of harmful cyanobacteria blooms: The
potential roles of eutrophication and climate change. Harmful Algae. 14: 313-334.
Ohio EPA. 2010. Harmful Algal Blooms in Ohio Waters. Available online at:
http://epa.ohio.gov/portals/35/inland lakes/HABBrochure.pdf.
Ohio EPA. 2015. Ohio Nonpoint Source Pollution Control Program. Available online at:
http://epa.ohio.gov/dsw/nps/index.aspx.
Paerl, H.W. and Huisman, J. 2009. Climate change: a catalyst for global expansion of harmful
cyanobacterial blooms. Environmental Microbiology Reports 1(1): 27-37.
Paerl, H.W., Hall, N.S, Calandrino, E.S. 2011. Controlling harmful cyanobacteria blooms in a world
experiencing anthropogenic and climatic-induced change. Science of Total Environment 4: 1739-1745.
Paerl, H.W. and Otten, T.G. 2013. Harmful Cyanobacterial Blooms: Causes, Consequences, and Controls.
Microbial Ecology 65(4): 995-1010.
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Reisner, M., Carmeli, S., Werman, M., and Sukenik, A. (2004). The cyanobacterial toxin
cylindrospermopsin inhibits pyrimidine nucleotide synthesis and alters cholesterol distribution in mice.
Toxicological Sciences, 82(2): 620-627.
Schaeffer, B.A., Loftin, K., Stumpf, R., and Werdell, J. Accepted. EPA, NASA, NOAA, and USGS collaborate
to develop a Cyanobacteria Assessment Network (CyAN). Eos, Transactions, American Geophysical
Union.
Source Water Collaborative (SWC). 2015a. How to Collaborate Toolkit. Available online at:
http://www.sourcewatercollaborative.org/how-to-collaborate-toolkit/.
SWC. 2015b. Source Water Protection and Conservation Partners Toolkit. Available online at:
http://www.sourcewatercollaborative.org/swp-conservation-partners-toolkit/.
Stevens, D. K. and Krieger, R. I. 1991a. Stability studies on the cyanobacterial nicotinic alkaloid anatoxin-
a. Toxicon, 29: 167-179.
Sukenik, A., Reisner, M., Carmeli, S., and Werman, M. (2006). Oral Toxicity of the Cyanobacterial Toxin
Cylindrospermopsin in Mice: Long-Term Exposure to Low Doses. Environmental Toxicology, 21(6): 575-
582.
Szlag, D., Sinclair, J., Southwell, B. and Westrick, J. (2015) Cyanobacteria and Cyanotoxins Occurrence
and Removal from Five High-risk Conventional Treatment Drinking Water Plants. Toxins 7(6), 2198-2220
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86-001.
U.S. EPA. 1997. State Source Water Assessment and Protection Programs, EPA 816-R-97-009.
U.S. EPA. 2010. National Lakes Assessment: A Collaborative Survey of the Nation's Lakes. Office of Water
and Office of Research and Development, Washington, D.C.
U.S. EPA. 2012a. Unregulated Contaminant Monitoring Program. Available Online at:
http://water.epa.gov/lawsregs/rulesregs/sdwa/ucmr/.
U.S. EPA. 2012b. Cyanobacteria and Cyanotoxins: Information for Drinking Water Systems. Fact Sheet
Office of Water. EPA-810F11001.
U.S. EPA. 2012c. Recovery Potential Screening: Tools for Comparing Impaired Waters' Restorability.
Available online at: http://water.epa.gov/lawsregs/lawsguidance/cwa/tmdl/recoverv/index.cfm.
U.S. EPA. 2013. National Lakes Assessment. Available online at:
http://water.epa.gov/type/lakes/lakessurvev index.cfm.
U.S. EPA. 2014. Cyanobacteria and Cyanotoxins: Information for Drinking Water Systems. Fact Sheet.
Office of Water. EPA-810F11001.
U.S. EPA. 2015a. Contaminant Candidate List (CCL) and Regulatory Determination- Draft CCL4 Chemical
Contaminants. Available online at: http://www2.epa.gov/ccl/chemical-contaminants-ccl-4.
U.S. EPA. 2015b. Health Effects Support Document for the Cyanobacterial Toxin Anatoxin-a. EPA
820R15104, Washington, DC; June, 2015. Available from:
http://water.epa.gov/drink/standards/hascience.cfm
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EPA 820R15103, Washington, DC; June, 2015. Available from:
http://water.epa.gov/drink/standards/hascience.cfm
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820R15102, Washington, DC; June, 2015. Available from:
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Cyanobacterial Toxins. July 2015, Version 1. U.S. EPA, Region 9.
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10/documents/htf report to congress final - 10-1.15.pdf
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Yuan, L. L. and Pollard, A. I. 2015. Deriving nutrient targets to prevent excessive cyanobacterial densities
in U.S. lakes and reservoirs. Freshwater Biology. (60)(9): 1901-1916.
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VI. Appendix 1. Text of Public Law No: 114-45
[114th Congress Public Law 45]
[From the U.S. Government Publishing Office]
Public Law 114-45
114th Congress
An Act
To amend the Safe Drinking Water Act to provide for the assessment and
management of the risk of algal toxins in drinking water, and for other
purposes. «NOTE: Aug. 7, 2015 - [H.R. 212] »
Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled, <>
SECTION 1. SHORT TITLE.
This Act may be cited as the "Drinking Water Protection Act".
SEC. 2. AMENDMENT TO THE SAFE DRINKING WATER ACT.
(a) Amendment.--Part E of the Safe Drinking Water Act (42 U.S.C.
300j et seq.) is amended by adding at the end the following new section:
"SEC. 1459. «NOTE: 42 USC 300j-19.» ALGAL TOXIN RISK
ASSESSMENT AND MANAGEMENT.
" (a) Strategic Plan.--
"(1) «NOTE: Deadline. Health and health care.>>
Development.--Not later than 90 days after the date of enactment
of this section, the Administrator shall develop and submit to
Congress a strategic plan for assessing and managing risks
associated with algal toxins in drinking water provided by
public water systems. The strategic plan shall include steps and
timelines to--
"(A) evaluate the risk to human health from
drinking water provided by public water systems
contaminated with algal toxins;
" (B) establish, publish, and update a comprehensive
list of algal toxins which the Administrator determines
may have an adverse effect on human health when present
in drinking water provided by public water systems,
taking into account likely exposure levels;
"(C) summarize--
"(i) the known adverse human health effects
of algal toxins included on the list published
under subparagraph (B) when present in drinking
water provided by public water systems; and
"(ii) factors that cause toxin-producing
cyanobacteria and algae to proliferate and express
37
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toxins;
" (D) with respect to algal toxins included on the
list published under subparagraph (B), determine whether
to--
" (i) publish health advisories pursuant to
section 1412(b)(1)(F) for such algal toxins in
drinking water provided by public water systems;
"(ii) establish guidance regarding feasible
analytical methods to quantify the presence of
algal toxins; and
" (iii) establish guidance regarding the
frequency of monitoring necessary to determine if
such algal toxins are present in drinking water
provided by public water systems;
"(E) recommend feasible treatment options,
including procedures, equipment, and source water
protection practices, to mitigate any adverse public
health effects of algal toxins included on the list
published under subparagraph (B); and
"(F) enter into cooperative agreements with, and
provide technical assistance to, affected States and
public water systems, as identified by the
Administrator, for the purpose of managing risks
associated with algal toxins included on the list
published under subparagraph (B).
"(2) Updates.--The Administrator shall, as appropriate,
update and submit to Congress the strategic plan developed under
paragraph (1).
"(b) «NOTE: Health and health care.>> Information Coordination.--
carrying out this section the Administrator shall--
"(1) identify gaps in the Agency's understanding of algal
toxins, including--
"(A) the human health effects of algal toxins
included on the list published under subsection
(a) (1) (B) ; and
"(B) methods and means of testing and monitoring
the presence of harmful algal toxins in source water
or drinking water provided by, public water systems;
appropriate, consult with--
"(A) other Federal agencies that--
"(i) examine or analyze cyanobacteria or
algal toxins; or
"(ii) address public health concerns related
to harmful algal blooms;
"(B) States;
"(C) operators of public water systems;
"(D) multinational agencies;
"(E) foreign governments;
"(F) research and academic institutions; and
"(G) companies that provide relevant drinking water
treatment options; and
"(3) assemble and publish information from each Federal
agency that has--
f or
of,
" (2) as
-------
"(A) examined or analyzed cyanobacteria or algal
toxins; or
"(B) addressed public health concerns related to
harmful algal blooms.
"(c) Use of Science.--The Administrator shall carry out this
section in accordance with the requirements described in section
1412(b) (3) (A) , as applicable.
"(d) Feasible.--For purposes of this section, the term 'feasible'
has the meaning given such term in section 1412(b)(4)(D).''.
(b) Report to Congress.--Not later than 90 days after the date of
enactment of this Act, the Comptroller General of the United States
shall prepare and submit to Congress a report that includes--
(1) an inventory of funds--
(A) expended by the United States, for each of
fiscal years 2010 through 2 014, to examine or analyze
toxin-producing cyanobacteria and algae or address
public health concerns related to harmful algal blooms;
and
(B) that includes the specific purpose for which the
funds were made available, the law under which the funds
were authorized, and the Federal agency that received or
spent the funds; and
(2) recommended steps to reduce any duplication, and improve
interagency coordination, of such expenditures.
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VII. Appendix 2. EPA's Current Activities Directly Related to Freshwater HABs
The efforts listed below include efforts by the EPA to manage and research harmful algal blooms in
freshwater systems. While extensive, this list is not exhaustive and additional efforts are ongoing at the
Agency. Better understanding of the science behind HABs is necessary to protect the public from
cyanotoxins in drinking water and their adverse health effects. Resources permitting, the EPA plans to
close informational gaps and provide helpful tools through research to better identify, monitor, and
manage HABs and toxins.
EPA/ORD Research Activities
o Ohio is the first state in the United States to implement a state-wide program of cyanobacteria
toxin monitoring in raw and finished drinking waters. The EPA collaborated with the Ohio EPA
and collected water samples at intermediate locations within drinking water treatment
facilities. The researchers employed enzyme linked immunosorbent (ELISA) assays for measuring
cyanobacteria toxin. The goals of the project were to: (1) provide a baseline estimate of the
efficacy of currently installed drinking water treatment infrastructure, (2) provide data to inform
cost-effective process upgrades, and (3) provide samples to support the development of a
chromatographic/mass-spectrometric method, which is robust enough to handle the matrix
variations commonly encountered in a water treatment facility. Preliminary results from the in-
plant sampling study indicated the release of intracellular cyanobacterial toxins into aqueous
solution during the addition of a powerful oxidizer (potassium permanganate). Potassium
permanganate is added early in the treatment process for zebra mussel and taste and odor
control. The release of intracellular toxins into a water treatment plant is potentially
problematic because the bulk of the existing treatment infrastructure is not designed to remove
dissolved chemical contaminants. This study also investigates the impacts of pH, suspended
particulate concentration, oxidant dose, oxidant contact time, powdered activated carbon (PAC)
type, PAC dose, temperature, and subsequent control of intracellular toxins.
o Four federal agencies (U.S. EPA, USGS, NOAA, and NASA) are participating in the Cyanobacterial
Assessment Network (CyAN) project to (1) develop a uniform and systematic approach for
identifying cyanobacteria blooms using ocean color satellites across the contiguous United
States; (2) create a strategy for evaluation and refinement of algorithms across satellite
platforms; (3) identify landscape linkage postulated causes of chlorophyll-o and cyanobacteria
blooms in freshwater systems; (4) characterize exposure and human health effects using ocean
color satellites in drinking water sources and recreational waters; (5) characterize behavioral
responses and economic value of the early warning system using ocean color satellites and
mobile dissemination platform; and (6) disseminate satellite data through an Android mobile
application and EnviroAtlas. The EPA anticipates that the use of uniform satellite data products
will improve the decision-making ability of managers. In addition, satellite data products may
augment federal, state, tribal, and municipal monitoring and research efforts. At the conclusion
of this project, there should be an increase in the applied use of remotely sensed water quality
data for water quality management. The use of this technology has tremendous potential owing
to the temporal and spatial coverage of the imagery and the current lack of data available for
many systems. Using satellite data to monitor and report blooms throughout a region or state
would provide a novel robust tool and assist in holistic management of events that may involve
significant risk to the public. Ultimately this project will reduce resource needs and potential
exposures of the public.
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o The EPA Office of Research and Development's National Risk Management Research Laboratory,
in partnership with Ohio EPA, USGS and local municipalities, sampled monthly during the 2013
and 2014 summers water throughout the treatment trains of 7 water treatment facilities that
use Lake Erie as a drinking water source. Sampling and testing was done for cyanotoxins,
chlorophyll-a, and other chemical and microbiological markers commonly associated with HABs.
The purpose of this project was to evaluate the effectiveness of toxin removal during water
treatment, detect cyanotoxins, and try to identify water quality indicators that predict the onset
of future HABs.
o The EPA currently conducts monitoring and modeling research in the East Fork of the Little
Miami River Watershed overlaid by five southwestern Ohio counties, including Clermont,
Brown, Highland, Clinton, and Warren. This collaborative research supports the Ohio EPA
surface water modeling division who is responsible for writing the TMDL for the system. Harsha
Lake is a 2000 acre flood control reservoir that bisects the watershed and receives significant
loads of nitrogen and phosphorus pollution from the predominant agricultural land use, failing
septic systems, and 10 small waste water treatment plants in the upper watershed. But the
loading is not static over seasonal or inter annual time periods. While the U.S. Army Corps of
Engineers (USACE) has historically funded monthly lake monitoring at six lentic sites within the
system, typically from May to August, the EPA's research objectives needed more temporal and
spatial coverage to completely understand the controls over the nutrient budgets. The entire
lake is now being sampled by EPA-ORD every three weeks throughout the entire year and a
continuous water quality sensing buoy is deployed from March through November. The buoy
sensing platform is paired with online monitors located within the intake structure to a 12
million gallons per day (mgd) drinking water treatment plant that include a fluoroprobe
configured to characterize divisional-level dynamics of the algal community. As a result of the
sampling intensity, the U.S. Geological Survey's Ohio Water Science Center has included Harsha
in its intensive molecular-based study to characterize HABs at beaches of inland lakes and Lake
Erie. The EPA visits the main beach site at Harsha weekly to establish a temporally dense time
series for this collaborative effort. Data resources now existing for Harsha Lake serve to help
verify remote sensing algorithms that the USACE is promoting for early HAB detection and
management in the Ohio River Basin. USACE funded an aerial imaging flyover and supported
permanent monitoring of lake inflows and outflows, as well as algal taxonomic analyses for the
project. The monitoring buoy is located near the drinking water treatment plant (DWTP) intake
but was specifically positioned to pair water quality data with satellite imaging. Synoptic
sampling methods are being used at 22 other USACE Louisville District reservoirs and at DWTP
intake locations on Lake Erie.
o The EPA's National Center for Environmental Research currently supports research that uses
molecular tools and satellite remote sensing to quantify water quality and human health risks of
harmful algal blooms and disinfection byproducts associated with extreme weather in Lake Erie
drinking water. This research is investigating the impacts of extreme precipitation on urban
runoff and urban water quality by integrating a set of models that down-scale climate
simulations to spatial scales relevant to urban hydrology and land cover products. Products from
this work include molecular tools for quantifying cyanotoxins; remote sensing indicators for
modeling water quality and human health; and visualization products that demonstrate future
changes in drinking water quality (in both long-term forecasting predictions, and short-term
forecasts immediately following an extreme event).
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o There are many barriers preventing the success of water quality trading (WQ.T) in the United
States. The EPA research focuses on two major barriers that hinder WQ.T: uncertainties in
modeling the watershed and thin markets (too few participants). The research will determine
whether any non-traditional participants would have an incentive to purchase nutrient
abatement credits from agricultural producers (traditional participants). Researchers have
examined a drinking water treatment plant's incentive, and will now assess the impact of HABs
on treatment costs. In addition, recreationalists and local property owners affected by problems
of HABs may also have incentive to purchase nutrient abatement credits from upstream
agricultural producers. A considerable lake modeling effort will be undertaken to better link HAB
dynamics to watershed management scenarios and socioeconomic factors along with the WQT
research.
o The EPA currently collaborates with USGS through an interagency agreement to characterize
cylindrospermopsin and saxitoxin occurrence in U.S. lakes included in the 2007 National Lakes
Assessment. Analyses will include assessing risk to human health via multiple exposure scenarios
to recreational and drinking waters.
o The EPA performs research on the detection of unique cyanobacteria organisms using
fluorescence-based technologies including micro spectrophotometer and flow cytometry.
Different types of algae and cyanobacteria occur in surface water. Occasionally these organisms
produce toxins with are harmful to organisms that live in the water or other organisms that are
exposed to the water. This research aims to correlate the specific spectra of the organism with
its unique morphology. It is anticipated that the specific spectra and changes in the spectra may
be an early predictor for toxin production. Initial preliminary research has identified unique
cyanobacteria that have distinct spectra in the 650 nm range that are different than the algae
that fluoresce in the 690 nm range. It is hoped that a specific signature of different
cyanobacteria can be developed to identify the cyanobacteria that may be producing toxins.
o The EPA-ORD works with the OW's National Coastal Condition Assessment (NCCA) program and
EPA Region 5. The researchers recently mapped cyanobacteria concentrations across the coastal
zone of the Great Lakes. States and the EPA collected whole water samples and analyzed the
samples for nutrients, chlorophyll-o and phytoplankton species composition, including
Microcystis. A set of about 400 sites across the coastal zone of the Great Lakes were sampled in
2010. Plans are to repeat the effort in 2015. The research included phytoplankton indicators and
mapping of cyanobacteria levels according to WHO thresholds. Phytoplankton will again be
included 2015 in the NCCA survey. Results will contribute to the development of empirical
models linking water quality and plankton levels in coastal waters to watershed disturbance
levels across the Great Lakes Basin, including 762 coastal watersheds.
o The EPA tested cylindrospermopsin (CYN) for mutagenicity in the Salmonella (Ames)
mutagenicity assay using the standard plate-incorporation method in strains TA98 and TA100
with rat-liver metabolic activation (S9). Because studies in the literature showed the CYN
induced chromosomal mutations in vitro only in the presence of S9, and because of the small
amount of sample available, the EPA evaluated the mutagenicity of CYN in Salmonella with S9
and did not do any experiments without S9. The researchers performed two experiments. The
first was exploratory, with a dose range of 1 - 20 ng of CYN per Petri plate; the second
experiment had a slightly higher range of 25 - 100 ng/plate. The results were all negative for
mutagenicity in both of the strains tested. There was not enough sample to repeat the assays at
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even higher doses, and EPA's source for the CYN (GreenWater Laboratories, Palatka, FL) could
not provide additional sample at the time. The EPA plans to test CYN one time more at higher
doses (perhaps 1000 ng/plate) if additional sample can be obtained. Otherwise, at this point,
the results show that CYN is not mutagenic in Salmonella, which means that it does not induce
gene mutations. However, the literature does show that in the presence of S9 or in vivo, CYN
can induce chromosomal mutations (i.e., micronuclei) and DNA damage (the comet assay). Thus,
it may have carcinogenic potential through these mechanisms of chromosomal DNA damage.
Thus, CYN clearly causes chromosomal mutation, but until it is tested at somewhat higher doses,
it is unclear if CYN can also cause gene mutation.
o The EPA continues to develop analytical methods for cyanobacterial toxins. The only liquid
chromatographic/mass spectrometric (LC/MS) cyanobacterial toxin analytical method currently
published by the EPA is intended as a finished water method to support the Unregulated
Contaminant Monitoring Rule (UCMR) as appropriate. The EPA is developing
chromatographic/mass spectrometric methods that can be applied with equal confidence
throughout the treatment process, from raw to finished water. If development proceeds with
sufficient speed, ELISA results from the treatment plant sampling study will be compared with
LC/MS results, with the ultimate goal of determining the optimum monitoring trade-off
between ELISA and chromatographic/mass spectrometric analysis.
o The EPA is exploring the impact of algal blooms, including HABs, on disinfection by-products
(DBPs) formation potential in drinking water treatment plants (DWTPs). The EPA began
collecting water quality information at a DWTP intake with the intent to examine what water
quality parameters are most applicable to predicting the water treatment impacts of HABs.
Included in this work are online toxicity monitor testing for HAB toxins and development of
treated water testing protocols for toxin detection.
o The overall health effects caused by cyanobacteria remain poorly elucidated. Our current
understanding of the individual toxicological, dermatological and allergenic effects of
cyanobacterial toxins (cyanotoxins) and their components (including metabolites and by-
products) as well as their possible synergistic interactions is lacking. Numerous species of
cyanobacteria are capable of producing a wide variety of structurally and biochemically diverse
metabolites (some of which have proven to be toxic to other organisms). Animal and cellular
studies have shown the presence of toxicity despite the lack of measurable known cyanotoxins.
The EPA will identify and characterize cyanobacteria peptide(s) responsible for allergic
sensitization in susceptible individuals and to investigate the functional interactions between
cyanobacterial toxins and their co-expressed immunogenic peptides. This effort is a
collaboration between the EPA, Northern Kentucky University and the University of Cincinnati
(UC, Department of Internal Medicine, Division of Immunology and Department of
Environmental Health Gene Environmental Interactions Training Program). Data collected from
EPA and UC will lead to a better assessment of the toxicological and allergic response potential
from cyanobacteria. The outcomes of this study will provide researchers with expertise in (1) the
identification of cyanobacteria and their toxins, (2) the isolation and culturing of cyanobacteria
from the environment, (3) the purification and characterization of lipopolysaccharides (LPS) and
(4) the performance of the in vitro beta-hexosaminidase release assay for allergens using sera
from atopic patients skin-prick positive for M. aeruginosa extract. The data provided by the
effort will be used by the researchers to determine if there is a potential allergenic component
to the health outcomes using animal models and possibly develop a generic screening method
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to determine exposure to cyanobacteria. This collaborative study provides the opportunity to
characterize cyanotoxins, cyanobacteria-derived allergenic components and their possible roles
in the presence or absence of synergistic interactions.
o Immunoassays are widely used biochemical techniques to detect microcystins in environmental
samples. The use of immunoassays for the detection of microcystins is vulnerable to matrix
components and other interfering substances. The EPA research evaluates the effects of
interfering substances commonly found in drinking and ambient water samples using
commercially available immunoassay kits for microcystin toxins. The microplate and strip test
immunoassay formats were tested in the study. Results of this study may assist in the further
refinement of existing assays and the development of practical antibody-based methods to
detect cyanotoxins in water.
EPA Regional Activities
o In Region 1, the EPA has convened a region-wide cyanobacteria monitoring and "bloom watch"
workgroup consisting of state agencies, tribes, public water suppliers, NGOs, citizen monitoring
groups, and academics. During the 2014 pilot, over 100 water bodies were sampled and in 2015
the program was expanded, including 10 public drinking water system sources and additional
recreational water bodies. Workgroup members participate in a variety of ways - all designed to
ensure sampling and data collection are performed in a uniform and consistent manner for
analyzing regional cyanobacteria occurrence. Participants use monitoring kits complete with
portable microscopes and smartphone adaptors so samplers can identify cyanobacteria in the
field and directly send images to taxonomy experts to confirm their initial identifications. The
smartphone app also allows sampling crews to electronically submit monitoring data to a central
database. A second app is currently in development for tracking the occurrence of blooms
across the region and the mid-west. Portable fluorometers are available on loan as a rapid
assessment tool to detect changes in cyanobacteria. 2016 project enhancements will include
refining data collection and analysis efforts, formatting designs for relaying information to the
general public, enhancing the citizen science program components and recruitment of drinking
water systems. Funding is, in part, through a recently awarded the EPA-ORD Ideation grant.
o EPA Region 1 staff developed a GIS-based method to identify potential risks from nutrient
related impairments, including cyanobacteria blooms in New Hampshire's drinking water
sources. Information was gathered on drinking water intakes that were in close proximity to
surface waters that have been listed as impaired on the state's 303(d) list for nutrient related
parameters such as total phosphorus, total nitrogen, chlorophyll-o, dissolved oxygen, excess
algal growth, algal toxins and turbidity. Nine drinking water intakes were identified using
geospatial analysis where at least one nutrient related impairment existed in a waterbody that
was within 200 feet of the intake. A map was produced that shows the identified water systems
along with nutrient impaired water bodies. The same analysis and mapping will be conducted
for the other five New England states. This effort is helping the region and states to gain a better
understanding of the connection between drinking water source waters, CWA 303(d) impaired
waters and algal blooms and is a fundamental step to aligning Clean Water Act and Safe Drinking
Water Act priorities.
o EPA Region l's Regional Laboratory established in 2010 monitoring buoys in the Charles and
Mystic Watersheds to track cyanobacterial blooms and water quality conditions. The buoys
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measure for chlorophyll and use fluorescence sensors to measure for phycocyanin. Field
samples are collected for chlorophyll-o and cyanobacterial cells to correct and evaluate data.
o Renegotiation of the Great Lakes Water Quality Agreement requires that the Parties (EPA and
Environment Canada) re-examine and establish phosphorus loading targets and associated in-
lake endpoints and metrics associated with hypoxia, hazardous algal blooms, and Cladophora for
each of the Great Lakes. In addition, phosphorus load allocations must be determined by
country, state and province, and for priority watersheds. Because of the severe symptoms being
experienced in Lake Erie, it has been designated as the first and lead lake for evaluation; it is
anticipated that Lakes Ontario and Michigan will follow. The EPA is managing phosphorus and
nutrient loading data to ensure consistent use and interpretation for the purposes of setting
loading and other associated targets in Lake Erie. Work is being conducted linking watersheds
with coastal receiving waters. The loading datasets are by source category including municipal
point sources, industrial point sources, atmospheric and nonpoint sources. Preliminary results
indicate that the phosphorus loads of the Maumee and Detroit Rivers are among the largest for
all of the Great Lakes and are high priority watersheds requiring attention to abate the various
symptoms being observed in western Lake Erie. Total phosphorus and dissolved phosphorus
both are greatest from these major sources. The phosphorus loading dataset will be used for
satisfying other requirements of the Agreement through various empirical and statistical
assessments and modeling applications. An ensemble modeling approach is being used by the
Parties consisting of federal and academic partners and is beginning a Science Advisory Peer
Review on December 2014. For the Interagency Task Force, responses from Region 5 and the
Great Lakes National Program Office are pending.
o EPA Region 5 co-leads a binational workgroup to develop and implement the Nutrients Annex
("Annex 4") of the 2012 Great Lakes Water Quality Agreement. Under Annex 4, the United
States and Canada are charged with establishing binational phosphorus targets for the
nearshore and offshore waters of the Great Lakes needed to meet several ecosystem objectives,
including minimizing the extent of hypoxic zones associated with excessive phosphorus loading
and maintaining cyanobacteria biomass at levels that do not produce concentrations of toxins
that pose a threat to human or ecosystem health. This effort is focused on Lake Erie in the near
term, with specific milestones in the next 3-5 years (see below). In addition, EPA Region 2 has
begun working with Annex 4 to develop strategies to address phosphorus targets for Lake
Ontario, which is the next Great Lake that will receive focused attention by Annex 4. Region 2 is
conducting a nutrient monitoring protocol that will provide baseline monitoring and modeling
data to help establish phosphorus loading targets for Lake Ontario.
o On September 3, 2014, the EPA Administrator Gina McCarthy announced that the Great Lakes
Restoration Initiative (GLRI) will provide nearly $12M to federal and state agencies for projects
identified as a result of an August 2014 meeting held by Region 5 to identify collaboration
opportunities to minimize HABs in the Western Basin of Lake Erie. These projects include:
¦ Farmer incentives
¦ Soil testing and fertilizer recommendations
¦ Planting of winter crops
¦ Upgrades to controlled drainage systems
¦ Funding of best management practices (BMP) at livestock facilities
¦ Expanding Environmental Quality Incentives Program (EQIP) funding
¦ Improve HAB monitoring and forecasting by NOAA
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¦ Tributary monitoring for phosphorus
Stakeholder consultation is an explicit requirement in the 2012 Great Lakes Water Quality
Agreement. The EPA will solicit input from stakeholders on the new phosphorus loading targets
for Lake Erie prior to ratification in 2016.
EPA Region 5 has been working on the Grand Lake St. Marys Project to identify present
conditions and model the Grand Lakes St. Marys watershed in order to identify problem areas
and assist watershed managers with useful information to assist in decision making. The project
started in July 2011 and is funded by the Regional Applied Research Effort (RARE), ORD's
Regional Science Program, which responds to high-priority, near-term research needs of the
EPA's regional offices. The EPA is assessing lake conditions and using USDA/Agricultural
Research Services (ARS) models to identify problem areas in the watershed. USDA provided
recommendations in land use management and BMP selection. Another RARE project between
the EPA Region 5 and the EPA involves methods for assessing the water quality degradation
through water treatment plants during algal blooms, which will evaluate cyanotoxin analytical
methods, identify relationships between water quality parameters and algal toxin
production/release, and evaluate treatment effectiveness of different processes on algal toxins.
The project started in September 2014 and will run through 2015. The EPA has been collecting
monthly samples from Lake Erie drinking water treatment plants including raw water, finished
water, and effluents of all intermediate unit processes. Samples are analyzed for cyanobacterial
toxins, mycotoxins, chlorophyll-o, phosphate, ammonia, nitrate, nitrite, dissolved organic
carbon, total nitrogen, and trace metals. Bench-scale studies will evaluate the impact of oxidant
dose, powdered activated carbon dose and pH on algal toxin control.
EPA Region 6 is working closely with states and encouraging them to develop numeric nutrient
criteria for causal (nitrogen and phosphorus) and response (chlorophyll-o; water clarity)
variables for multiple water body categories (streams/rivers, lakes/reservoirs, estuaries/coastal
waters). Increasing frequency of HABs and cyanotoxins in drinking water supplies further
underscores the importance of regions and states stepping up their efforts to develop these
criteria or translators of narrative nutrient criteria in a timely fashion and at levels protective of
all uses, including the drinking water use. This also points to the need for eventual criteria
development (once national criteria are available) and routine ambient monitoring for
cyanotoxins in waters with drinking water uses.
EPA Region 7 coordinates with the state drinking water programs who are working with their
respective state recreational monitoring programs. In 2015, the EPA Region 7 laboratory
increased its capabilities to analyze for cyanotoxins and will be collecting algal toxin samples at
the end of September in the source water and the finished water of targeted treatment plants in
tribal lands.
EPA Region 8 purchased several Abraxis test strip kits to distribute to drinking water operators
for raw water (intake) sampling because these strips were key to a successful HAB response in
the Boysen Reservoir (in Wyoming). Abraxis test strips can be used for drinking water systems as
a screening tool to determine if the ELISA method should be used. These types of field methods
are useful in this part of the country, as laboratory capacity for analyzing algal toxins is limited.
The Region is working with groups in each state to accelerate the development of lab capacity
for cyanotoxin analysis.
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o EPA Region 8 hosted a harmful algal blooms workshop September 30 - October 1, 2015, in
Rapid City, South Dakota. The workshop was designed to bring together state environmental
agencies, health departments, drinking water utility managers, and public water supply
operators to discuss HABs issues in Region 8. Agenda items included topics such as: impacts
associated with HABs; what causes HABs; HABs monitoring for drinking water and recreational
impacts; new technologies for tracking HABs; and opportunities for outreach and education. The
workshop also provided a forum for sharing updates on state and regional HABs-activities and
building partnerships with other agencies.
o EPA Region 9 is working to assist tribes in HAB response including targeted technical assistance,
analytical support, and resources for infrastructure improvements to tribes. EPA staff worked
with the Hoopa Tribe in response to anatoxin and microcystin in the Trinity River (source water
for Hoopa drinking water) to coordinate analyses, and later provided a source water protection
grant and drinking water Tribal set-aside funds to support ozone treatment for the Tribe's
drinking water system.
o EPA Region 9 and ORD-National Exposure Research Laboratory were awarded an internal,
competitive 2015 ORD Safe and Healthy Communities Regional Sustainability and Environmental
Sciences Research Program (RESES) program project for their proposal entitled, "Floating
Vegetation Islands: Using Traditional Ecological Knowledge (TEK) for Development of Leading
Indicators of Ecosystem Function for BMP Effectiveness, Water Quality Standards, Biological
Criteria, and Harmful Algal Blooms (HABs)." This pilot research project will develop leading
indicators of ecosystem function to determine the need for and effectiveness of best
management practices. Leading indicators help decision makers be proactive in developing
adaptive management plans. Leading indicators will be correlated to alterations in ecosystem
functions and water quality with changes in land-use practices and climate variability. TEK from
the Chemehuevi Indian Tribe and the Colorado Indian Tribes will be used to help determine
ecosystem potential condition for current restoration projects.
o EPA Region 9 supports its states to address HAB concerns including: updating state guidance and
thresholds for recreational exposures; providing training to agencies and waterbody managers
for recognizing and responding to HABs; developing statewide field monitoring protocols;
establishing lab networks (state and federal labs, identifying capabilities and sharing analytical
methods/ protocols); developing a database for tracking HAB occurrence, toxin data, etc.; and
coordinating with veterinary labs for tissue analysis of affected animals (e.g., dogs, cattle).
o The EPA Region 9 laboratory provides microcystin analysis by ELISAto support program
requests, including: (1) analysis for numerous state and local agencies for initial assessment of
HAB-impacted waters, (2) ongoing monitoring since 2006 in the Klamath River Watershed and
(3) analytical support for monitoring of the 2015 bloom season at Clear Lake for 2015, (the latter
two are two of the region's priority watersheds). The Region 9 Lab has analyzed 300 - 700
samples annually since approximately 2008. EPA Region 9 also has a Risk Management Program
Grant through an interagency agreement with USGS and ORD/NERLto analyze and optimize
cyanotoxin sample preparation methods for ELISA and LC/MS analysis.
o EPA Region 10 recently funded the Southeast Alaska Tribal Toxins (SEATT) project. The SEATT is
a partnership represented by eight Alaska tribes that was funded to conduct monitoring and
develop better predictive tools for HABs. With over $225K in Indian Environmental General
Assistance Program (IGAP) funding from EPA, together with training support from NOAA and
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financial support from the Administration for Native Americans' Environmental Regulatory
Enhancement Program, the partner tribes will monitor HAB events that pose a human health
risk to shellfish harvesters, such as paralytic shellfish poisoning (PSP). This monitoring effort will
provide weekly data on the timing and distribution of HABs, along with measurements of
environmental conditions, indicators, and potential mechanisms that trigger HAB events. The
data collected will be used to create a more rigorous framework for mitigating the impacts of
HAB events on fisheries, rather than traditional rules of thumb which are no longer effective due
to changes in the type, magnitude, frequency and duration of HABs in the region.
o In 2012-2013, EPA funding through the Puget Sound National Estuary Program supported the
Washington Department of Health and Washington Department of Ecology in conducting a
comprehensive sampling effort for diarrhetic HABs throughout Puget Sound and along the
Washington Coast (28 sites in 2012 and 72 sites in 2013). The main HAB sampling target was
Dinophysis spp. in shellfish tissue. Ancillary measurements collected during the project included
temperature, salinity, and nutrients. The goal of the project is to work toward developing a
HABs early warning system. One of the EPA's approaches has been to use Bayesian regression
models to estimate the effect of nutrient concentrations on chlorophyll-o concentrations above
/below a threshold given nutrient inputs. The estimated marginal densities include use of the
National Lakes Assessment (NLA) sample weights, and represent the estimated Ecoregion 8
marginal densities for loglO(Total Phosphorus) and loglO(Total Nitrogen). The idea is this type of
approach could serve as some of the basis for empirical modeling of the likelihoods of
cyanobacteria blooms, whether toxic or not, including in freshwater systems that serve as
drinking water sources. Additionally, the NLA (2007) data will be used for the contiguous U.S.
Some modeling aspects of this work can be applied in the Northeastern U.S. where ORD is
interacting with EPA Region 1 and two New England states (MA and Rl).
o EPA regions and states are working together to protect the public from exposure to HABs in
coastal and freshwater systems. EPA Region 1 has been working with the State of Vermont on
the Lake Champlain cyanobacteria monitoring, a qualitative and quantitative monitoring
program on Lake Champlain for cyanobacteria during the 2014 summer season. This project is
funded through a grant to the State of Vermont Department of Environmental Conservation
with the purpose of identifying areas of high concentrations of cyanobacteria, particularly toxin
levels, and provide warnings to the public.
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VIII. Appendix 3. EPA's Intended Future Activities Directly Related to Freshwater
HABs
Information in this Appendix is based on the EPA's proposed research project (i.e., research area),
Reducing Impacts of Harmful Algal Blooms, for its 2016-2019 research cycle. Work completed under this
project will provide stakeholders and decision makers with improved scientific information and tools to
assess, predict and manage the risk of HABs, associated toxicity events and the ensuing ecological,
economic and health impacts. The project directly addresses legislative mandates, Agency research
needs, Agency Program Office initiatives, National Water Program (NWP) needs and community and
other stakeholder needs as follows:
• Improve the science of HAB and toxin detection by developing HAB-specific analytical methods
and sampling strategies.
• Assist the NWP in developing new HAB indicators, sampling designs and protocols for use in
national-scale assessments.
• Develop improved approaches to understanding the interactive effects of increasing water
temperatures and nutrient loads on HAB development and toxin production.
• Develop improved models to project risk of HABs under warming climate scenarios.
• Improve understanding of the human health and ecosystem effects resulting from toxin
exposure.
• Provide drinking water treatment system operators with improved methods for detecting and
treating toxins in order to limit or prevent human exposures.
This project will be focused on four intertwined research areas:
Area 1: Management strategies.
Research needs exist to develop new, market-ready treatment technologies, and to optimize existing
technologies for the removal of toxins present in drinking water systems. Ideally, these methods would
minimize capital, maintenance, and operational expenses, and be scalable to such a degree that they
could be implemented in communities ranging from large and wealthy to small and economically
marginalized. Active collaborations with water managers and other private and public sector
stakeholders will help ensure these goals are met and streamline transfer and adoption of viable
management strategies and technologies. Work in this area would be predicated on the assumption that
there are no significant policy or institutional barriers to adoption.
In the area of drinking water treatment, removal effectiveness for various unit operations have been
documented for a subset of the small group of toxins for which commercial standards are available.
However, knowledge gaps exist for (1) the large set of toxins for which standards are currently
unavailable, and (2) how to implement process and operational changes for maximum protection and
cost-effectiveness under a variety of site-specific constraints.
In the area of reservoir management, existing research indicates that modifications of reservoir
hydrology may help to reduce the frequency, intensity, duration and toxicity of bloom events. However,
the efficacy of these efforts is site-specific, and gaps remain in the knowledge of the optimal method(s)
to apply for any given set of reservoir conditions. ORD scientists and engineers will develop a scientific
basis for the development and application of reservoir management strategies. In the domain of
recreational area management, the primary research needs are the development of body contact
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exposure standards for the entire suite of known toxins as well as the development of scientifically
based guidance for optimal sampling strategies.
Area 2: Health, ecosystem and economic effects.
One of the strongest drivers for changes that may be required to prevent future HABs, and/or mitigate
those that occur, is the threat of serious adverse health effects in exposed populations. Research gaps to
evaluate sources and routes of human exposures and their potential toxicity will need to be addressed.
When HABs and toxins occur in drinking water and recreational water sources, exposed human and
animal populations will need to be evaluated for health effects. The identification of exposure
biomarkers that are simple to obtain are necessary for timely evaluation of exposure levels. The types of
toxicity (critical organ system, chronic, developmental, and reproductive) are not known for most
identified toxins and these potential endpoints will be the focus of research efforts. Mammalian effects
from exposure to widespread fish toxins are also an area that needs focused research efforts, since
these widespread compounds have not been evaluated in mammals. The identification of ichthyotoxins
and their mechanisms of action are needed since these have had a serious effect on fish stocks, both
wild and in aquaculture. The potential of freshwater algal toxins to cause adverse health effects after
transport from lakes and streams into the coastal environment, and subsequent bioaccumulation in
marine organisms, is known to have occurred and requires further research.
HABs have the potential to affect aquatic ecosystems. Gaps in the following research areas need to be
addressed: food web disturbances resulting from toxin production and hypoxic areas, toxicity thresholds
for sentinel species, and the potential for toxin bioaccumulation in fish populations, both wild and aqua-
cultured.
Questions include: 1) "What are the ecological impacts of algal toxins on aquatic life through direct
exposure and through food chain bioaccumulation? 2) How sensitive are real-time biomonitoring
systems that use larval fish, daphnia and algae in comparison to traditional toxicity test organisms used
in whole effluent toxicity testing? And 3) What are the nutrient and other environmental conditions that
are conducive to establishment of toxin producing species?"
Assessment approaches will include determination of whether algal toxins inhibit zooplankton grazing
behavior and population dynamics, as well as the impact on benthic filters; whether simultaneous and
sequential exposure to multiple toxins, particularly the combination of multiple cyanotoxins, pose
cumulative or synergistic risks to aquatic life; the potential for bioaccumulation, bioconcentration, and
biomagnification of different cyanotoxins and other cyanobacterial bioactive compounds in food webs;
development of algal reference toxicant tests using the top 4 toxins found during algal blooms;
comparison of results of reference toxicant tests using standard species to the results obtained from
real-time monitoring systems; and the culturing of toxin-producing species under laboratory conditions
using various combinations of environmental conditions in order to observe the effect on toxin
production.
An accurate assessment of economic effects is a critical piece of the puzzle as the Agency works to craft
a response that is cost-effective and protective of public, economic, and societal health. To the best of
the authors' knowledge, such an assessment does not currently exist. The assessment would be broken
down into two parts:
1. A nationally representative random sample survey to estimate the direct costs generated by
HABs: these may include, but are not limited to extra monitoring expenses, water treatment
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plant upgrades and chemical costs and lost revenue from beach closures and drinking water
advisories. The planning and implementation of such a survey, using traditional tools of
economic research, represents an opportunity for cross-agency collaboration.
2. A nationally representative random sample survey to estimate the degree to which public
confidence in the safety of drinking water, natural and recreational assets is affected by
scientific data, general-audience news from traditional media outlets, and information across
the quality spectrum circulated on social media outlets. The motivation for such a survey is the
fact that information circulated through these channels has the potential to quickly shape public
perceptions, and these perceptions, in turn, drive behavior at the individual and family level
with potentially significant negative economic consequences. It is envisioned that such a census
would employ data from a variety of information and social media platforms to track the spread
of information within a strictly delineated subject area.
Area 3: Temperature impacts and bloom modeling
The scientific community generally agrees that HABs have been increasing in frequency, duration and
geographical range. The factors responsible for these postulated increases are thought to include ease
of global transport of species, rapid evolutionary response of algal/bacterial species to changing
environments, increased nutrient loads in aquatic environments, perturbations in rainfall, and increases
in the overall average temperatures of aquatic bodies. These factors all enhance the ability of algal and
cyanobacterial species to move, spread and form blooms with increased temporal, locational and spatial
dimensions, including different water depths. A contributing factor in bloom formation, or duration, is
thought to be increased average water temperatures, which provide a suitable environment for algal
growth. Both laboratory and environmental studies on harmful bloom dynamics are necessary to
understand the extent of effects of increased water temperatures on bloom formation, and tendency of
such blooms to generate toxins that may have adverse environmental and health effects.
Improved modeling capabilities are needed for an assessment of the risk associated with HABs under
the dynamic of different climate scenarios. An understanding of the species, temporal and spatial
dynamics of HABs will improve the capability to anticipate the course of HABs and their potential
adverse effects. The vast majority of HABs are not comprised of one species throughout the course of
the bloom, multiple species are the usual case, either at the same time or sequentially. Detailed
knowledge of the roles different environmental factors play on species identity, toxic vs non-toxic bloom
formation, persistence of blooms, and spatial/temporal extent of blooms is needed in order to increase
the accuracy of bloom forecasts. This is also true of the types of toxins that will be formed in specific
blooms. Together, an increased ability to predict the character of blooms will enable regulatory agencies
at the national, state, tribal and local level to better predict the course of blooms and, therefore,
respond appropriately.
Area 4: Analysis and monitoring in fresh and coastal/estuarine environments.
Effective response to HABs must be based on accurate and timely assessments of the species that
comprise the bloom, the toxins, if any, that are being produced, and the ecosystem impacts resulting
from the presence of HAB biomass.
Morphological, culture-based, molecular biology, and optical sensing (flow cytometry, satellite imaging)
approaches have been used to identify and quantify the primary algal, and related bacterial, species in
blooms. All of these strategies have strengths and weaknesses. Consequently, it is important to improve
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existing monitoring and analytical methods, and to develop and validate new cost- and time-effective
methods that can be used by Program Offices, Regions, states and other stakeholders.
For ecosystem impacts, existing methods need to be improved, and new methods need to be
developed, all with the goal of delivering the greatest possible amount of analytical power into the
hands of small, local, laboratories, operating on modest budgets.
For toxins, the accuracy and precision of existing methods needs to be improved for different aqueous
matrices (e.g., fresh, treated drinking water, brackish, marine, etc.) and animal tissues. Toxin analytical
methods need to be standardized and, where possible, simplified in order to promote their adoption
across the widest possible range of laboratories. New methods, capable of being employed from a
variety of physical platforms, such as lab benches, field kits, buoys and flow-through monitors, need to
be developed.
Finally, guidance needs to be developed that allows water managers to set up site-specific monitoring
programs that take advantage of the existing suite of analytical methods, and potential in situ
monitoring networks, in order to maximize protection while minimizing sampling and analytical effort.
In recent years, HAB-driven adverse environmental and health effects have been observed in the
estuarine and marine environments of all coastal areas. Adverse health effects have been recorded in
humans through direct exposures and consumption of toxin-containing seafood. Serious adverse health
effects have also been recorded in marine mammals, fish and birds, some of which are endangered.
These effects are largely caused by algal species with toxins that are different from those found in fresh
waters. The factors that act to favor the formation of HABs are largely unknown in marine and estuarine
(saline) environments. The development of estuarine- and marine-specific analytical methods and
indicators is essential for the protection of the environment as well as human populations.
Analytical and monitoring efforts in fresh, estuarine, and marine environments have the potential to
generate data sets across a range of temporal and spatial scales. These data sets would encompass
direct readings on riparian, lake and coastal bodies of water as well as remote sensing from satellites.
The monitoring of HABs is ongoing by the Agency, a number of other federal entities including the U.S.
Geological Survey (USGS) and the National Oceanic and Atmospheric Administration (NOAA), and by
State, Local and academic entities. Data from these monitoring efforts exist in both published and
unpublished form. The utility of these large data sets depends upon their consistency and availability.
Developing a data portal that integrates existing and future data into a programmatic data base would
result in a more cohesive HAB program. This portal would allow data sharing, promote collaborative
research and speed the development of a comprehensive view of HAB extent throughout the United
States. It is recognized that the technical challenges of developing and maintaining a data portal are
significant. However, the potential benefits are so significant that laying the groundwork for such a
portal is an aspirational goal of this project area.
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IX. Appendix 4. Federal Agencies' Current and Proposed Activities Directly Related
to HABs
The information in this appendix is compiled from interagency efforts based on input and feedback from
other federal agencies. It is intended to be representative rather than a comprehensive listing of
HABHRCA-related work. This information will be further explored with the release of the HABHRCA
Report to Congress, anticipated to be released by the end of 2015.
Federal Agencies' Current and Proposed Activities Directly Related to HABs
Office/
Dept.
Agency
HABs/
Hypoxia/
Both
Program Title
(brief description)
Program Activities
DHHS
CDC
HABs
HAB-related
Outbreak and Illness
Surveillance
CDC initiated waterborne and foodborne disease
outbreak surveillance systems in the 1970s. U.S. states
and territories voluntarily report to these systems via
the electronic National Outbreak Reporting System
(NORS), which receives aggregate data on human cases
and their exposures, including exposures to harmful
algal blooms (HABs) or HAB toxins. The One Health
Harmful Algal Bloom System (OHHABS) is being
developed for single case-level reporting of human and
animal illness, and relevant environmental data.
OHHABS is being programmed to inform restoration
activities in the Great Lakes but will accessible to all
states via NORS. The pilot version of the system is being
tested in preparation for a 2016 launch.
DHHS
CDC
HABs
Great Lakes State
Health Surveillance
Capacity
CDC has partnered with the Council of State and
Territorial Epidemiologists (CSTE) since 2013 to place
and provide technical support for epidemiology fellows
in Great Lakes states, including Indiana, Illinois,
Michigan, Minnesota, New York, Ohio, and Wisconsin.
The activity is supported by the Great Lakes Restoration
Initiative. Fellows focus on waterborne disease
detection, investigation, response and reporting. The
fellowship has expanded state waterborne disease
reporting and analytic capacity; improved state health
surveillance for harmful algal blooms; and ensured
dedicated staff time for waterborne disease
surveillance and coordination activities.
DHHS
CDC
HABs
Health
Communications
CDC's health communications activities related to HABs
include the preparation of a HAB website with
information for public health practitioners, clinicians,
and the general public, and the expansion of the
Drinking Water Advisory Communications Toolbox
(DWACT) to include information about HAB-related
drinking water advisories. The DWACT was created
through a collaborative effort among CDC, EPA, the
American Water Works Association, the Association of
State and Territorial Health Officials, the Association of
State Drinking Water Administrators (ASDWA), and the
National Environmental Health Association (NEHA).
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Office/
Dept.
Agency
HABs/
Hypoxia/
Both
Program Title
(brief description)
Program Activities
Multiple
CDC, EPA, NOAA
HABs
Interagency Analytic
Workgroup
Additional research is needed to fully characterize and
understand the health risks from drinking water
provided by public water systems when that water is
contaminated with cyanobacterial toxins. There is a
need to establish standardized biological sample
collection and analysis protocols to support assessment
of toxin-associated health effects. Multiple federal
agencies are working together to assess sampling and
analytical capabilities related to analysis of biological
specimens collected from human and animals exposed
to cyanobacteria toxins via contaminated water,
including drinking water. The goal is to combine
expertise to develop robust analytic methods to detect
biological evidence of exposure to cyanobacterial
toxins, to optimize laboratory and emergency response
capacity in the collection, analysis, and response to
harmful algal bloom-related illnesses.
DHHS
CDC
HABs
Method development, refinement, and validation for
detecting human exposures to HAB toxins through the
detection of toxins and specific biomarkers in clinical
samples. Current methods approved for use include the
detection of saxitoxin, neosaxitoxin, tetrodotoxin, and
gonyautoxins (1-4), which have been applied to
individual cases to confirm suspected HAB exposures.
DHHS
FDA
HABs
Method development, refinement, and validation for
detecting HAB toxins; improving understanding of HAB
toxin sources and vectors that impact seafood and
dietary supplement safety.
DHHS
FDA
HABs
Developed, evaluated, and validated rapid screening
for HAB toxins in seafood, thereby improving
regulatory monitoring, surveillance programs, and
outbreak response. For example, FDA developed an
onboard screening dockside testing program for PSP
toxins in shellfish, which led to reopening of a large
portion of Georges Bank in 2013 to safe commercial
harvest of clams.
DOC
NOAA
HABs
SoundToxins
The Northwest Fisheries Science Center (NWFSC) has
established a new monitoring partnership called
SoundToxins for the early warning of marine harmful
algal blooms in Puget Sound. The NOAA National
Centers for Coastal Ocean Science ECOHAB program
provided 3 years of funding to develop the Puget Sound
Harmful Algal Bloom (PS-AHAB) project to understand
environmental controls on the benthic (cyst) and
planktonic life stages of the toxic marine dinoflagellate
Alexandrium, and evaluate the effects of climate
change on the timing and location of blooms.
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Office/
Dept.
Agency
HABs/
Hypoxia/
Both
Program Title
(brief description)
Program Activities
DOC
NOAA
HABs
National
Phytoplankton
Monitoring Network
The Phytoplankton Monitoring Network (PMN) was
established to monitor phytoplankton and harmful
algal blooms and promote environmental stewardship
though the use of citizen volunteers. PMN volunteers
are trained by NOAA staff on sampling techniques and
identification methods for over 50 genera, including 10
potentially toxin-producing genera, of dinoflagellates
and diatoms on the volunteers watch list. Currently,
250 marine and Great Lakes sites in 22 states and U.S.
territories including 52 schools, 15 universities, 298
civic groups and 40 state and federal agencies collect
phytoplankton and environmental data. Since the
inception of the program in 2001, more than 275 algal
blooms and 15 toxic events have been reported by
PMN volunteers.
DOC
NOAA
HABs
National Analytical
Response Team
NOAA's Analytical Response Team (ART) provides rapid
and accurate identification and quantification of
marine algal toxins in suspected harmful algal blooms
(HABs), and related marine animal mortality events and
human poisonings. From 2009 to 2014, ART received
over 4000 samples from state and federal government
agencies, NGOs, and academic partners for
determination of toxins associated with harmful algae.
In addition to water samples, marine toxins were
analyzed in samples from marine and freshwater algae,
shellfish, fish, cetaceans, pinnipeds, birds and sea
turtles.
DOC
NOAA
HABs
Technology Transfer
Team
The Technology Transfer Team completed rigorous,
international inter-laboratory trials in partnership with
interagency organizations, federal agencies and private
businesses to bring the receptor binding assay for
paralytic shellfish poisoning (PSP) toxins to U.S. and
international regulatory approval; and guided its
commercialization to assure U.S. marine shellfish are
safe for U.S. citizens and export throughout the world.
The team also provided training on use of the method
to more than 30 countries through formal agreement
with the International Atomic Energy Agency to
promote safe food supply and increased economic
growth through the export of fisheries products and to
the Southeast Alaska Tribal partnership to enable
monitoring of subsistence resources.
DOC
NOAA
HABs
Ecological
Forecasting
The National Centers for Coastal Ocean Science
(NCCOS) develops and transitions HAB forecasts for
coastal and Great Lakes waters. NOAA is also working
with EPA on systematic approach to either warning
state health/water quality on cyanobacteria blooms
and allowing them to evaluate patterns and trends in
lakes and estuaries that are at risk.
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Office/
Dept.
Agency
HABs/
Hypoxia/
Both
Program Title
(brief description)
Program Activities
DOC
NOAA
HABs
Continue to make satellite coverage of ocean and
coastal zones more comprehensive and combine it with
existing data to enable quantifiable estimates of HABs
(much of this has been funded by NASA). Plan to
transfer promising new monitoring and prediction
technology and approaches from research to
operational HAB forecasts for Gulf of Mexico, Lake Erie,
Chesapeake Bay, Puget Sounds, Pacific Northwest, and
California.
DOC
NOAA
HABs
Ecology and
Oceanography of
Harmful Algal Blooms
(ECOHAB)
Developing a better understanding of marine HAB
causes and impacts that form the basis for better
management to reduce HABs and their impacts.
DOC
NOAA
HABs
Monitoring and
Event Response for
Harmful Algal Blooms
(MERHAB)
National, competitive extramural research program
that builds capacity for enhanced coastal and Great
Lakes HAB monitoring and response in state, local, and
tribal governments.
DOC
NOAA
HABs
Prevention, Control,
and Mitigation of
Harmful Algal Blooms
(PCMHAB)
National, competitive extramural research program
that develops new methods of coastal and Great Lakes
HAB prevention, control, and mitigation. It also
addresses the socioeconomic impact of HABs and
efforts to reduce HAB impacts.
DOC
NOAA
HABs
Event Response
Provides modest support to supplement monitoring of
coastal and Great Lakes HAB events, and advance the
understanding of HABs when they occur.
DOC
NOAA
Hypoxia
Coastal Hypoxia
Research (CHRP)
National, competitive extramural research program
that develops understanding of hypoxia causes and
impacts that form the basis for better management to
reduce hypoxia and its ecological and socioeconomic
impacts. Includes all coastal systems except the large
hypoxic zone along the northern Gulf of Mexico
continental shelf.
DOC
NOAA
Hypoxia
Northern Gulf of
Mexico Ecosystems
and Hypoxia
Assessment Program
(NGOMEX)
National, competitive extramural research program
that develops understanding of the causes and impacts
of the northern Gulf of Mexico hypoxic zone, that form
the basis for better management to reduce the hypoxic
zone and its ecological and socioeconomic impacts.
DOC
NOAA
Hypoxia
Continue to convene workshops to obtain stakeholder
needs that drive research prioritization, and
disseminate advanced knowledge and tools for hypoxia
mitigation to regional managers and interagency
management networks such as the Gulf Hypoxia Task
Force or the Landscape Conservation Cooperative.
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Office/
Dept.
Agency
HABs/
Hypoxia/
Both
Program Title
(brief description)
Program Activities
DOC
NOAA
HABs
Studies molecular ecology of HABs in the Great Lakes
and makes improvements to monitoring HABs and
toxicity in the Great lakes. Monitors six routine stations
in the western basin of Lake Erie weekly during blooms
season and supplies data that supports the predictive
models in Lake Erie. Developing a three dimensional
lagrangian particle transport model to effectively
predict HAB advection as part of the Lake Erie
Operational Forecasting System, which is set to go
operational through fiscal year 2015.
DOD
USACE
HABs
Responding to HABs in response to public
reports/complaints in close coordination with state
water quality/public health agencies. Response
programs developed by individual USACE
Divisions/Districts. The Engineer Research and
Development Center (ERDC) is available to support
Divisions/Districts in assessing HAB impacts to USACE
Civil Works Projects (e.g., WQ modeling, remote
sensing, and technical assistance). General WQ
monitoring and HAB response to meet authorized
project purposes and recreation mission requirements.
DOD
Oceanographer
of the Navy
HABs
Studies the variability of in situ and remotely sensed
spectral optical properties to identify dinoflagellates
through field sampling and improvement of remote
sensing techniques. Dinoflagellate information has
been incorporated into Naval Research Laboratory's
ecological-circulation models for better
understanding/prediction.
DOI
BOEM
Hypoxia
Gulf Oxygen
Deepwater
Experiment
Study plan pending approval: To address noted data
gaps that addresses deepwater oxygen dynamics such
as in the Oxygen Minimum Zone in the Gulf, whereas
the Louisiana-Texas (LATEX) shelf studies were on the
shallower hypoxic zone.
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Office/
Dept.
Agency
HABs/
Hypoxia/
Both
Program Title
(brief description)
Program Activities
DOI
NPS
HABs and
hypoxia
Outreach and
Education
Of the 407 NPS units, there are 86 units that are
considered ocean, coastal, or Great Lake parks, in
addition to other park units that have extensive surface
water bodies. HABs have the potential to influence all
of these park units at various levels, and it is therefore
important to prepare for these events in order to
preserve our resources. The National Park Service is
creating a website containing a public health and
ecological HAB events reporting system. It also
provides a point of contact for park managers to
partner with local and state health and environmental
agencies who will provide park personnel with
technical assistance for the management of HAB
events. Outreach materials (brochures, interpretive
displays and materials) on HABs, their causes, the
effects on the ecosystem, and the many ways to reduce
or stop nonpoint source pollution, many of which are
simple to implement.
DOI
USGS
HABs and
hypoxia
National Water
Quality Program
USGS conducts long-term monitoring of nutrients and
other water-quality characteristics in surface and
groundwater networks. The sources and quantities of
nutrients delivered by streams and groundwater to
coastal areas and the Great Lakes are monitored at 106
sites. Annual updates from the monitoring sites are
made available to the public, including nutrient
concentrations, loads, and yields. These data, along
with data aggregated from numerous other agencies,
are used to evaluate trends in critical water quality
parameters including nutrients and sediment. Real-
time measurements for dissolved oxygen and
temperature are collected at over 500 and 2000
locations, respectively. USGS is pioneering new field
sensor methods and systems for monitoring and
delivering real-time nutrient data, with over 100 nitrate
sensors deployed. The USGS SPARROW model
quantifies nutrient sources and sediment loads to
coastal areas, the Great Lakes, and inland lakes in the
Eastern U.S. SPARROW has also been linked to an
online Decision Support System, which allows direct
exploration of the potential benefits of nutrient
management for systems including the Chesapeake
and the Mississippi, other coastal rivers, and the Great
Lakes.
DOI
USGS
HABs and
hypoxia
National Water
Quality
Program/National
Water Quality
Assessment
USGS collects fish-, aquatic macroinvertebrate-, and
algae-community samples, and conducts stream
physical habitat surveys to assess the effects of multiple
stressors—including algal toxins—on aquatic
organisms in streams in several ecoregions.
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Office/
Dept.
Agency
HABs/
Hypoxia/
Both
Program Title
(brief description)
Program Activities
DOI
USGS
HABs
National Water
Quality Program/
Cooperative Water
Program
HAB research is conducted in at least 20 USGS Water
Science Centers. Studies include both short- and long-
term projects focused on quantifying blooms and
associated toxins and taste-and-odor compounds, and
understanding causal factors. Many studies employ
new and developing sensor technology to detect algal
pigments. For example, a study of the primary drinking
water supply for Wichita, Kansas combined long-term
discrete and continuous water-quality data to develop
models that estimate the probability of microcystin
occurrence in near real time.
DOI, USDA
USGS, USDA-
NRCS
HABs and
hypoxia
GLRI
Assesses the impacts of agricultural management
practices, climate change, and land use change on the
timing and magnitude of delivery of nutrients and
sediments to the Great Lakes at 30 sites. Works with
NOAA, EPA, states, universities, and NGOs to
understand how nutrient and sediment loading from
the Great Lakes watershed affect hypoxia, HABs and
biological communities in the near-shore environment.
Edge-of-field studies in GLRI priority watershed
quantify phosphorus, nitrogen, and sediment to
evaluate nutrient reduction projects on agricultural
land. Rapid sharing of edge-of-field monitoring results
with local stakeholders allows for adaptive
implementation.
DOI
USGS
HABs
Energy, Mineral, and
Environmental
Health/Toxic
Substances
Hydrology Program
Pioneer new field monitoring methods (sensors),
assessment techniques, and laboratory methods
needed to address harmful algal bloom issues in
freshwaters. New methods include a multi-toxin
method that can quantify cyanotoxin mixtures, and
DNA- and RNA-based molecular methods for detecting
microcystin and microcystin producers.
DOI
USGS
HABs
Ecosystems
USGS has ongoing research characterizing ecological
and food web impacts of cyanotoxins. For example, a
USGS study in Upper Klamath Lake demonstrated a link
between microcystin and reduced young-of the year
recruitment of federally endangered suckers.
HHS
NSF/NIEHS
HABs
Ocean and Human
Health (OHH)
Initiative and the
NSF's Division of
Ocean Sciences
The NIEHS supports multiple studies focused on the
effects of HAB toxins on human and mammalian
physiology, development of biomarkers for chronic
toxin exposure, and the design and testing of novel
technologies for in situ detection of algal toxins in fresh
and salt water environments. For example, a number of
ongoing studies are supported that analyze the effects
of domoic acid on neurotoxicity as well as cognitive
impacts in human cohorts, non-human primates and
rodent models. Also, NIEHS is accepting unsolicited
applications for support and use of time-sensitive
mechanisms to allow research support for
unanticipated bloom events.
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Office/
Dept.
Agency
HABs/
Hypoxia/
Both
Program Title
(brief description)
Program Activities
NSF
NSF
HABs and
hypoxia
Ocean Observing
Initiative and the
National Ecological
Observatory Network
Provides environmental data for studies of HABS (both
marine and freshwater) and hypoxia.
NSF
NSF
HABs
Division of Ocean
Sciences (OCE), NSF
Ocean Observing
Initiative (OOI)
Observational capabilities for research in marine
systems.
NSF
NSF
HABs
Directorate of
Geosciences,
Prediction and
Resilience Against
Extreme Events
(PREEVENTS)
Focused interdisciplinary research projects.
NSF
NSF
HABs
Division of Biological
Infrastructure,
National Ecological
Observatory Network
(NEON)
Observational capabilities for ecological research.
NSF
NSF
HABs
Division of Ocean
Sciences
Research Support, unsolicited proposal in marine
ecology.
NSF
NSF
HABs and
hypoxia
Collaboration
between NSF GEO,
SBE, and ENG
directorates, as well
as USDANIFA.
Program supporting interdisciplinary research to
understand and predict the interactions between the
water system and climate change, land use, the built
environment, and ecosystem function and services
though research and models. Several research projects
are focused on nutrient movement and hypoxia
mitigation strategies.
NSF
NSF
HABs
Ocean and Human
Health Initiative, a
collaboration
between NSF's
Division of Ocean
Sciences (OCE), and
the National Institute
for Environmental
Health Sciences
(NIEHS)
Studies of the effects of HAB toxins on human and
mammalian physiology, development of biomarkers for
chronic toxin exposure, and the design and testing of
novel technologies for in situ detection of algal toxins
in fresh- and salt-water environments. Also accepting
unsolicited applications for support and use of time
sensitive mechanism to allow research support for
unanticipated bloom events.
USDA
NIFAand ARS
HABs
Support of extramural and intramural research on the
effects of HABs and HAB toxins on food safety,
aquaculture, and livestock.
USDA
ARS
Hypoxia
Research on nutrient management, nutrient
contribution to hypoxia, and aquaculture. Long-Term
Agro-Ecosystem Research (LTAR) and Watershed
Research Centers.
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Office/
Dept.
Agency
HABs/
Hypoxia/
Both
Program Title
(brief description)
Program Activities
USDA
NIFA
Hypoxia
Research support for studies of the effects of nutrient
cycling, climate change, and nutrient management for
agriculture.
USDA
NRCS
HABs and
hypoxia
Conservation
Technical Assistance
(planning);
Environmental
Quality Incentives
Program;
Conservation
Stewardship
Program;
Agricultural
Conservation
Easement Program
Regional
Conservation
Partnership Program
NRCS provides conservation planning assistance to
agricultural producers on cropland, grazing land, and
for confined livestock operations. NRCS also has
financial assistance programs to help producers
implement and install practices. These programs are all
voluntary and are incentive-based. For confined
livestock systems, this includes, but is not limited to,
practices such as waste storage structures, and
associated practices like roofs and covers, roof runoff
management, diversions, and a nutrient management
plan for the utilization of manure.
On cropland, this may include agronomic practices such
as residue management, cover crops, conservation
cropping systems, and nutrient management; buffer
practices like filter strips and riparian forest buffers;
water management practices such as grassed
waterways, grade stabilization structures, drainage
water management, blind inlets (to replace surface
inlets), wetland restoration and creation; and
prescribed grazing systems and associated practices for
grazing land. The Natural Resources Conservation
Service (NRCS) also assists farmers financially with
edge-of-field water quality monitoring.
USDA
NRCS
Hypoxia
Great Lakes
Restoration Initiative,
Mississippi River
Basin Healthy
Watershed Initiative,
National Water
Quality Initiative, etc.
Under various water quality initiatives, NRCS and its
partners help producers in selected watersheds to
voluntarily implement conservation practices that
avoid, control, and trap nutrient runoff; improve
wildlife habitat; and maintain agricultural productivity.
These initiatives utilize NRCS programs such as the
Environmental Quality Incentives Program (EQIP) and
the Conservation Stewardship Program (CSP) within
targeted watersheds to provide technical and financial
assistance.
USDA
NIFA and ARS
HABs and
hypoxia
Supports research on best management practices for
nutrient management, aquaculture, and plant
breeding, among others. Specific concerns addressed
by this research include manure management from
animal feeding operations and water use and
conservation on irrigated cropland.
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Office/
Dept.
Agency
HABs/
Hypoxia/
Both
Program Title
(brief description)
Program Activities
EPA
EPA
HABs and
hypoxia
Water Quality
Management
Diversified approach to better understand
cyanobacterial HABs ecology and the development of
watershed and source water management techniques,
including the development of models for nutrients
loadings, the optimization of watershed placement of
phosphorus and sediment BMPs, and the use of water
quality trading (WQT) to cost-effectively reduce
nutrient loadings. It also includes an assessment of the
impact of land use and infrastructure on watershed
changes, and the evaluation of ecological contributors
to cyanobacterial HAB development and toxin
production. This research program also includes the
use of molecular methods to characterize the risk in a
reservoir for toxin and algal blooms, and the analysis of
the impact of HABs on creating disinfection byproducts
(DBPs) precursors.
EPA
EPA
HABs
Human and
Ecological Health
Research support to address data gaps associated with
health, ecosystem, and economic effects of HABs.
Research activities include the characterization of
cyanobacteria and their toxins and allergic
components, the evaluation of the toxicity of multiple
congeners of microcystins, and identification of
biomarkers of exposure for human health risk
assessments. Epidemiology studies to characterize
toxin occurrence in U.S. inland lakes, and studies to
determine that bioaccumulation, bioconcentration,
and biomagnification of cyanotoxins in mammalian
tissues and food web are also in place. EPA is also
assessing occurrence and health information for the
inclusion of cyanotoxins in the Contaminant Candidate
List (CCL) and the Unregulated Contaminant
Monitoring Rule (UCMR) program. In addition, EPA is
developing Human Health Water Quality Criteria
(HHWQC) for cyanotoxins in recreational waters.
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Office/
Dept.
Agency
HABs/
Hypoxia/
Both
Program Title
(brief description)
Program Activities
EPA
EPA
HABs
Monitoring and
Analytical Methods
Development
A collaborative effort of EPA, NASA, NOAA, and USGS to
provide an approach for mainstreaming satellite ocean
color capabilities into U.S. fresh and brackish water
quality management decisions. The Cyanobacteria
Assessment Network (CyAN) for freshwater systems
will develop approaches to relate nutrient loads and
land use to the frequency, location, and severity of
cyanobacterial blooms in lakes of the United States. It
will include assessing risk to human health from
satellite multispectral data to assess biological
conditions and risk to human health in lakes and
reservoirs in the United States.
EPA also provides nationally consistent and
scientifically defensible assessments of aquatic
resources through the National Aquatic Resource
Surveys (NARS), including indicators associated with
cyanotoxin exposure. EPA and its regions are also
working on monitoring efforts such as the Lake
Champlain Cyanobacteria Monitoring, Great Lakes
Restoration Initiative projects and Phosphorus
Reduction Strategy, Southeast Alaska Tribal Toxins
(SEATT) project, and the Puget Sound Toxins Project.
EPA is also working on monitoring projects to improve
identification and removal of HAB toxins in drinking
water, and evaluating the impact of temperature on
bloom development.
EPA is developing analytical tools including the use of
real-time sensors, qPCR and fluorescence based
technologies of micro spectrophotometer and flow
cytometry to detect cyanobacteria organisms in source
water.
EPA
EPA
HABs
Drinking Water
Treatment
EPA is working collaboratively with regional offices to
characterize the effectiveness of drinking water
treatment techniques in reducing toxins.
EPA
EPA
HABs
Outreach
EPA conducts webinars and provides online resources
to promote public awareness and information sharing.
NASA
NASA
HABs
The Ocean Biology
and Biogeochemistry
Program
Basic HABs research resulting in publications and new
retrieval algorithms.
NASA
NASA
HABs
Health and Air
Quality Applications
Program
Improve the forecast resolution and frequency of risk
of Karenia brevis toxins on every beach, every day,
rather than every county, twice a week. The methods
would be applicable across the Gulf of Mexico.
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Office/
Dept.
Agency
HABs/
Hypoxia/
Both
Program Title
(brief description)
Program Activities
NASA
NASA
HABs
Health and Air
Quality Applications
Program
Monitoring and surveillance of cyanobacterial harmful
algal blooms (CyanoHABs) in drinking and recreational
water supplies. Satellite derived products that were
developed for western Lake Erie are being analyzed for
their use in other regions (e.g., Chesapeake Bay and
inland lakes in Ohio and Florida). This project has
established methods to identify environmental
thresholds that indicate the potential for
cyanobacterial blooms to form or persist, and these
data sets are also being made available to CDC.
Multiple
agencies and
partners,
including but
not limited to
EPA, FWS,
NOAA, NPS,
USACE, USD A,
USGS
HABs and
hypoxia
Water Quality Portal
Co-sponsors of the Water Quality Portal, a cooperative
data service that makes data publically available. The
data are derived from the USGS National Water Quality
Information System (NWIS), the EPA Storage and
Retrieval data warehouse (STORET), and the USDA ARS
Sustaining the Earth's Watersheds - Agricultural
Research Database System (STEWARDS). With data
from over 400 federal, state, tribal, and local agencies,
this efforts will improve understanding of progress in
nutrient reduction efforts.
Multiple
agencies: CDC,
NASA, NOAA,
NSF, USDA, and
USGS
HABs
ES21 Federal
Working Group on
Exposure Science
Exposure assessment is instrumental in helping to
forecast, prevent, and mitigate exposure that leads to
adverse human health or ecological outcomes. This
vision expands exposures from source to dose, over
time and space, to multiple stressors, and from the
molecular to ecosystem level. HAB exposure
assessment is addressed by ES21 Working Groups on
Biomonitoring, Citizen Engagement/Citizen Science and
Sensors/Dosimeters.
Multiple
Agencies, EPA
and NOAA
HABs
Volunteer
Freshwater
Phytoplankton
Monitoring Program
Volunteer monitoring program that collects baseline
data on harmful algal species and builds capacity by
providing data to NOAA Phytoplankton Monitoring
Network and EPA. Volunteers are trained to identify
algae, collect water samples, conduct basic water
quality analyses, and preserve samples for further
analysis by the NOAA Analytical Response Team.
Network became operational in 2015 with stations in
the Western Basin of Lake Erie in seven lakes in EPA
Region 8, with plans to expand to Lakes Michigan,
Superior, Huron and Grand Lake St. Mary in 2016.
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Office/
Dept.
Agency
HABs/
Hypoxia/
Both
Program Title
(brief description)
Program Activities
The Conservation Effects Assessment Project (CEAP) is
a collaborative, multi-agency effort to quantify the
environmental effects of conservation practices and
programs and develop the science base for managing
the agricultural landscape for environmental quality.
Project findings are used to guide USDA conservation
policy and program development, and help
conservationists, farmers, and ranchers make more
informed conservation decisions. USGS will incorporate
conservation data collected by CEAP into its surface
water quality monitoring.
USDA/Multiple
agencies, led by
USDA NRCS,
ARS, NIFA, FSA,
and NASS. Also
includes USGS,
NOAA, FWS,
EPA, BLM,
NASA, USDA
Economic
Research
Service and US
Forest Service
Both
CEAP
CEAP-Croplands developed a National Resources
Inventory (NRI) statistical approach that combines
information voluntarily collected through NASS
producer surveys, and conservation practice data as
inputs into two process based models, the Agricultural
Policy Environmental extender (APEX) field-scale
model and the Soil and Water Assessment Tool (SWAT)
watershed scale model. In addition to determining
conservation practice adoption trends, the CEAP
modeling team is able to estimate the environmental
benefits of conservation practices and conservation
treatment needs within major drainage basins of the
United States. In the first CEAP-Croplands National
Assessment, current conservation conditions and
outstanding needs were assessed in twelve major
basins, including the Mississippi River Basin,
Chesapeake Bay and Great Lakes. Since the 2003-06
national survey CEAP-Croplands has revisited
watersheds through special studies, including
Chesapeake Bay (2011), Western Lake Erie Basin
(WLEB) (2012), California Bay Delta (2013), and the St.
Francis and Lower Mississippi River Basin (2014). A
second CEAP-Croplands National Assessment was
initiated in 2015. In addition, the Watershed
Assessment Component of CEAP continues to conduct
small watershed-scale studies across the United States
to quantify water and soil resource outcomes of
conservation practices and systems and enhance
understanding of processes. Interactions among
practices are investigated as well as modeling
enhancements, watershed targeting approaches, and
socioeconomic factors. Practice standards are
developed or updated to improve effectiveness and
address gaps.
USDA
Multiple
agencies, led by
USDA NRCS,
ARS, NASS and
FSA
CEAP
In 2012, NASS worked with NRCS to administer a CEAP
Cropland-survey focused on the Western Lake Erie
Basin (WLEB). Data from the survey and other sources
is being used to assess conservation effects in the WLEB
and compare trends and progress in conservation as
well as evaluate additional treatment needs in that
region. The assessment report is forthcoming.
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X. Appendix 5. Summary of Stakeholder Input
The information transcribed below is based upon oral and written comments received during the
Listening Session Webinar on September 16, 2015. This summary is the EPA's best effort to accurately
record input received by stakeholders. The EPA utilized the input received and incorporated elements
into this strategic plan.
Public Statements
Scott Biernat, Association of Metropolitan Water Agencies (AMWA)
AMWA represents large publically owned systems. AMWA appreciates the technical and
implementation challenges EPA faces in addressing the risks posed by HABs and toxin exposure via
drinking water sources. Plans for addressing must be carefully crafted and implemented to achieve
optimal public risk reduction and public health benefits.
HR 212 presents an important opportunity to set the path for a thoughtful collaborative approach for
addressing challenges posed by algal toxins in drinking water. The process that is established for further
evaluation and reevaluation of algal toxins risks is important to assure optimal risk reduction. This
process must include continuous in-depth consultation with stakeholders to ensure all necessary
expertise and practical experience is brought to the table. Based on the information gathered that lead
to the cyanotoxin Health Advisories, EPA has a good understanding of the nature of the additional
information needed to assess next steps to further reduce algal toxin risk. AMWA notes several points:
• First, the best and most cost effective long range strategy to protect the public from algal toxins
is to prevent bloom-causing nutrients from entering waterway in the first place. In that regard, a
meaningful reduction in algal blooms must begin with the agricultural sector. The development
of a bolder, more innovative strategy for managing nonpoint source water pollution, particularly
from the agricultural sector, must be a part of the strategic plan.
• Second, the strategic plan must place an emphasis on developing robust analytical methods in
time for including cyanotoxins on the Unregulated Contaminant Monitoring Rule (UCMR 4).
Collection of occurrence data under UCMR 4 can fill key information gaps related to algal toxin
occurrence and provide a vital foundation for additional risk assessment as mandated by SDWA.
These analyses will inform future stakeholder discussions and policy decisions from EPA and
other local, state and federal agencies intended to ensure algal toxins do not pose human health
risks if they reach drinking water supplies.
• Third, the assessment of existing guidance and support documents, including all existing health
criteria documents should be identified as an iterative process within the strategic plan, drawing
on lessons learned and new data as they become available to make appropriate and timely
updates. With the summer bloom season under the new cyanotoxin health advisories now
behind us, it is a particularly good time to reengage stakeholders to evaluate how to best
address algal toxin challenges.
• Additional consideration of communication challenges regarding algal toxin health risks should
be a focus of the plan. The setting of the health advisories based on a 10-day exposure and at
two different age-based levels poses a unique public communication challenge. Further
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guidance must offer robust interpretation of how to evaluate the health advisory levels within
this 10-day timeframe that corresponds to actual risk involved. Going forward it will be the
strength of the collaborative process put in place to augment existing programs and processes
that will determine how efficiently and effectively any data and information gaps are filled, and
will help in identifying the action that will most effectively manage algal toxin risks. Combined
with the already robust process for evaluating contaminant risk and evaluating the need for
further regulation required under SDWA, such evaluation will ensure sound policies are
developed.
In closing, AMWA thanks EPA for initial efforts in getting ahead of algal toxin issues and looks forward to
collaboration on its next steps.
Steve Via, American Water Works Association (AWWA)
AWWA appreciates the opportunity for stakeholder involvement and input. AWWA understands the
agency is working on a tight schedule and there is a lot of work to do to meet the deadline. Congress
provided good direction, and the health advisory documents and their recommendations are important
guides to taking on the task to assess and manage algal toxins. Some detailed suggestions:
• Health effects: look beyond microcystins LR, right now working on assumption that all
congeners have equal health effects, and that it is true of natural congeners and degradates.
That assumption might not prove valid in the long haul. Useful for agency to communicate next
steps for anatoxin-o, the health assessment only covered microcystins and cylindrospermopsin
while there were a number of identified data gaps with anatoxin-o.
• Important to realize goal for occurrence is both assessment and management of cyanotoxins.
One of the key gaps from utilities is the need for ongoing and reliable monitoring systems, for
toxins and the parameters that inform their management, both in water supplies and influent
waters.
• Look to other strategies under other vehicles like the Clean Water Act, Unites States Geological
Survey (USGS) and others to develop data systems to inform risk management at water supply
level. Technical tools and support for action at utility level - clear awareness what information is
actually useful for decision making. For example, lysing source water and using that observation
as assessment of risk. To make a treatment change, that lyse data may or may not be most
important especially for removal by coagulation and settling.
• Help make strong technical decisions and provide good support for a regulator rather than
utility itself. There has been a lot of discussion about what methods should be used, need robust
testing in relevant concentration range which is between 0.1-3 ug/L for microcystins rather than
data driven by higher level concentrations.
• EPA source water collaborative with the United States Department of Agriculture (USDA)
conservation division has identified a number of practices for achieving land use management,
and implementation of best management practices.
• We really need to think about risk communication in context of risk management. One doesn't
occur well without the other. A 10-day HA is challenging construct. Understanding impacts of
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management action, cost consequences for a community as they are thrown in preparation and
response measures.
Beth Messer, Ohio EPA
Ohio EPA Responses to U.S. EPA HAB Webinar Questions - verbal comments
In an effort to keep the comments brief, Ohio EPA will provide verbal comments based on our
experiences and what we consider the highest priority.
1) What do you consider to be the key information gaps in understanding the human health
effects of specific algal toxins?
Additional research is needed for all microcystin variants, as well as saxitoxin for acute, short-
term, and long-term exposures.
More information is needed on potential sensitive population exposures such as the elderly,
immuno-compromised or individuals with pre-existing liver disease or on dialysis, and data is
needed on whether cyanotoxins cross the placental wall and potential exposure via breastmilk
2) What do you consider to be the key information gaps in understanding the occurrence of
blooms and toxin formation?
More information is needed on:
• the triggers for cyanotoxin production, release and degradation;
• triggers for cyanobacteria to release cyanotoxins to the extracellular form;
• movement of blooms within the water column, which may assist public water systems
with avoidance strategies
• the role of resting cells/akinetes in the probability of future bloom formation; and
• factors that contribute to a shift in phytoplankton community dominance to HABs.
3) Please identify effective technical support or tools, including outreach and education efforts,
that could benefit states' and PWSs' ability to predict, prevent and mitigate the occurrence of
algal blooms and inform management decisions.
Guidance is needed on effective reservoir management strategies, in particular the impacts of
algaecide application. Many public water systems rely on algaecide as a source control strategy.
The effectiveness of this strategy could be improved through guidance on proper application
rates and timing for different types of blooms, the effect of algaecides on akinetes, and
information on the effect on community dynamics and possible long-term implications of use
(specifically copper resistance).
Finally, Ohio has found remote sensing data to be useful tool, and recommends continued
support for remote sensing projects including NOAA's Lake Erie HAB Bulletins and forecasts,
CyAN collaborative efforts, and NASA and other research efforts on use of multi-spectral sensors
(aircraft or drones).
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4) In your opinion, what are the most important steps that can be taken to improve strategies
for use of HAB-related analytical methods, monitoring, and treatment of harmful algal toxins
for drinking water?
More information is needed to optimize treatment strategies, including:
• CT tables or cyanotoxin reaction kinetics for microcystin (including variants other than
MC-LR) and saxitoxin for commonly used oxidants such as chlorine and permanganate
under variable pH, temperature, and concentration ranges;
• the effect of permanganate on cell lysis for genera other than microcystis;
• the effectiveness and operational guidance for granular activated carbon (GAC),
including different types of carbon on saxitoxin, MC-LR and other common microcystin
variants;
• saxitoxin adsorption capacity for different types of powdered activated carbon; and
• short-term plant optimization guidance for removal/destruction of cyanotoxins via
conventional surface water treatment processes.
Thank you for providing Ohio EPA the opportunity to comment.
Rob Blair, Kentucky Division of Water
The comments Kentucky put together have been addressed by other presenters.
Van McCienden and Ken Hudneii, North American Lakes Management Society
(Comments were read, and also submitted electronically. Comments appear here as they were
submitted electronically)
1. I commend EPA for heightened concern about protecting the public from the health risks posed by
cyanotoxins produced by cyanobacteria. The Agency has taken a number of steps in this direction,
including:
- April 2015 - Teaming with NASA, NOAA, EPA and USGS on developing a satellite surveillance
system
- June 2015 - Producing Drinking Water Health Advisories for Two Cyanobacterial Toxins
- June 2015 - Recommending that Public Water Systems Manage Cyanotoxins in Drinking Water
- By having two cyanotoxins on the UCMR4 candidate list and apparently moving toward
implementing testing at utilities to better understand the scope of cyanotoxins in source water
and finished drinking water
- And finally, hosting this webinar to get public input on developing a strategic plan for
addressing cyanotoxins in drinking water
2. I also commend EPA for realizing that the incidence of cyano HABs is increasing even as we've spent
decades and many millions of dollars on the watershed management point- and nonpoint-source
programs to reduce new nutrient inputs into freshwaters. I hope and think that the Agency is moving
toward re-implementing the CWA's Clean Lakes program that calls for treating impaired waterbodies.
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Even Ben Grumbles who made the decision to de-emphasize waterbody treatments in the early 1990s
has told me he regrets that decision and no longer believes that watershed management alone can
reverse the trend of increasing freshwater impairment. Movement toward fully implementing the CWA
by complementing watershed management with waterbody management is indicated by:
- December 2013 - EPA produced A Long-Term Vision for Assessment, Restoration, and
Protection under the Clean Water Act Section 303(d) Program (Webpage to PDF) - that allows
for Alternative Approaches - "By 2018, States use alternative approaches ...that incorporate
adaptive management and are tailored to specific circumstances where such approaches are
better suited to implement priority watershed or water actions that achieve the water quality
goals...."
- May 2014 - Webinar, A Systems Approach to Freshwater Management: Waterbody Treatments
- September 2014 - Putting up a webpage on Nutrient Policy, Controls & Waterbody Treatments
3. As the Agency develops a strategic plan for addressing Algal Toxins in Drinking Water, I urge the
Agency to seriously consider using an Adaptive Systems Approach to Freshwater Management as
described by the North American Lake Management Society or NALMS. I'll be glad to send you a
description of an ASA, but the core of an ASA is using rigorous science and cost-benefit analyses in
putting together a feasible plan that uses the best of watershed and waterbody management tools. An
ASA uses:
- rigorous science in consideration of the physical, chemical, and biological characteristics of
freshwaters to identify the direct and contributing causes of impairments, in this case
eutrophication and cyano HABs
- cost-benefit analyses of waterbodies' designated uses, in this case drinking source water, and
of all watershed and waterbody management tools
- an implementation strategy for drinking water protection should reduce the risks of adverse
health effects from cyanotoxins in the near term at an affordable cost. If a strategy is not being
effective enough, the ASA process is reiterated, and the strategy is adapted to produce a more
effective strategy
4. A drinking water protection strategy should focus on preventing cyanobacteria from proliferating in
source waters by using sustainable waterbody treatments to suppress cyanobacteria and remove or
deactivate nutrients in the waterbody where they are highly concentrated and easy to get to. If
cyanotoxins are not in the source water, they cannot be in the finished drinking water. It is much
cheaper to combine technologies to treat source waters than it is to annually spend millions of dollars
on removing cyanotoxins from drinking water using activated carbon, ultraviolet irradiation, or
microfiltration. And none of these ensures that all cyanotoxins will be removed from drinking water.
5. There is currently a movement towards combining waterbody treatments to suppress cyanobacteria
and remove or deactivate nutrients. Projects are being planned to assess the efficacy of combining
water circulation to suppress cyanobacteria and synergize nutrient removal or deactivation by other
technologies. For example, circulation and ultrasound guns can likely suppress cyanobacteria in even the
most difficult waterbodies where shallow, weeded areas continually seed cyanobacteria into open
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waters. And circulation increases nutrient uptake by plants on floating artificial wetlands, and growth of
periphyton on curtains that transfer nutrients from the water column to higher trophic levels.
Circulation can keep specialized micro-pellets suspended that stimulate blooms of diatoms that also
transfer nutrients from the water column to higher trophic levels. A treatment system could also meter
out flocculants and keep them suspended to capture and deactivate nutrients as they enter a waterbody
from a stream.
6. EPA should contribute funds to the 3 NOAA HAB research grant programs as directed by Congress in
last year's reauthorized and expanded HABHRCA law. These funds could support studies such as that
just mentioned, and enable utilities to make better informed decisions about approaches to source
water protection.
7. To assist states and utilities, EPA should revive the Section 314 grant program that provided money
for waterbody treatments. EPA can encourage states to include waterbody management treatments in
their watershed management plans that EPA approves. Currently, the Agency only encourages states to
use 5% of Section 319 funds for waterbody treatments.
8. Finally, EPA should request line-item funding for funds to support the 3 NOAA HAB research-grant
programs and the Section 319 waterbody treatment program.
I would also like to comment and commend the EPA for moving forward on addressing such an
important public health risk and to emphasize the need to move expeditiously on creating regulatory
requirements for testing and treating impaired water bodies. We feel the Adaptive Systems Approach
will bring a science based assessment to the problem and provide an effective cost-beneficial solution to
an issue that has been under addressed in the public arena.
Thank you for allowing me to provide input on this very important project. Both I and NALMS will gladly
supply any assistance that we can.
Rebecca Gorney, NY State Department of Environmental Conservation, Department of Lake
Management
NY requests assistance on question #3: What are the definitions of appropriate thresholds in variety of
contexts like algal biomass in terms of determining bloom concentrations and bloom existence as well as
nutrient concentration and how these can be used to prevent and mitigate blooms once occurring? Also
need help understanding secondary health factors related to toxin removal in drinking water. Useful to
better understand secondary health factors, such as disinfection by-products and what happens after
toxins are removed.
Clayton Creager, CA North Coast Regional Water Quality Control Board
Comments are not from the drinking water division, but CA is dealing with nuisance levels of blue green
algae and have a total maximum daily load (TMDL) for microcystins for rivers. We have compiled
endpoint numbers for public health warning across states and found quite a bit of variance. Is this an
artifact of risk calculation equations, or a difference in toxicity data available to the states doing the
calculations? Has anyone looked at consistency both for drinking water and health advisories and why
they vary? Drinking water systems draw from rivers that are seeing more frequent occurrence of
nuisance levels in flowing water. Lower flows and higher temps and more abundant growth of
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filamentous algae as a substrate are three things to cause issues. There is little information to evaluate
the implications of this apparently increasing trend. CA has found a high correlation of 10 ug/L
chlorophyll-o as inflection point to where species composition dramatically shifted to cyanobacteria.
That became our threshold as a biomass indicator.
Lynn Thorp, Clean Water Action
Clean Water Action recognizes the ongoing work by EPA and what Congress has asked them to do, but
still thinks there is value in addressing info gaps in the contribution of different kinds of pollution and
source water contamination to occurrence of cyanotoxins. Also information gaps on how reductions in
pollutants will help in short and long terms with the jobs that utilities and EPA now have to take on. We
think this is a really important and interesting example of the integration of CWA and SDWA which has
been a priority both inside and outside the agency for some time. Consider these connections as part of
way to respond to Congress. Agree about risk communication as a part of the response, and need to
include non-drinking water impacts of HABs, both other human health and ecological.
Jessica Giowczewski, City of Akron, Ohio
(Comments appear here as they were submitted electronically)
If source water protection is going to be a focus on preventing algal blooms, someone needs to have
authority to enforce and follow up on potential pollution situations which bridge gaps between
townships, villages, cities, municipalities, counties and states. It doesn't have to be a utility managing
the watershed they use, but there needs to be more cooperation and more enforcement and support
from other jurisdictions and stakeholders, as well as enforceable penalties for pollution events.
Kim Ward, California State Water Resources Control Board
(Comments appear here as they were submitted electronically)
Helpful overview of the changes in agricultural production methods which seem to play an important
role in changes observed in toxigenic blooms observed in the Great Lakes in recent decades:
https://dl.sciencesocieties.ore/files/publications/crops-and-soils/keeping-farm-based-p-out-of-lake-
erie.pdf
"Source water protection" should include consideration of sediment/soil conditions in surface
waterbodies, e.g., the possible occurrence of microcystins/other cyanotoxins in biological soil crusts
(often found in arid environments) and as cyanotoxin-producing symbionts/endosymbionts in aquatic
plants (e.g. cyanolichens). http://apsiournals.apsnet.org/doi/pdfplus/10.1094/MPMI-22-6-0695:
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3942747/;
https://www.ncbi.nlm.nih.gov/pubmed/25752.635:
http://www.sciencedirect.com/science/article/pii/S0048969712.001349
A key information gap concerns potential aerosol exposures in raw & finished water, e.g. research by
CDC on microcystin aerosols, etc.:
Lyda Hakes, Alameda County Water District
(Submitted electronically)
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1) More information is needed on the growth/death rates of harmful algal blooms and the half-life
of the cyanotoxins (both extracellular and intracellular). Also, more information about what
drives extracellular versus intracellular concentrations would be useful.
2) Consider regulating cyanotoxins (specifically microcystin) by grouping them as Total
Trihalomethanes (TTHMs) and haloacetic acids (HAA5) are. This would better allow for the use
of a quantitative instrument like Liquid Chromatography/Tandem Mass Spectrometry (LC/MS-
MS) so that PWSs and regulators know exactly what is in the water and at what quantities.
3) Investigate further the nexus between climate change and the increased presence and
persistence of HABs. Also, research on the relationship between drought conditions and HABs
and cyanotoxins.
Amy Little, California State Water Resources Control Board
(Submitted electronically)
1) In the event of a public notification event due to a health advisory exceedance, what, if any,
information should be communicated to hemodialysis centers.
2) There is literature to describe how toxins are distributed in cyanobacteria cells (intra- vs. extra-
cellular) but this is likely changing throughout a bloom. If a public water system was faced with
exceeding a health advisory, knowing how toxins are distributed during the exceedance would
likely provide valuable information to the utility in order to target treatment optimization.
3) We have utilized fluorometers (when keeping cells intact is a treatment strategy) to evaluate cell
lysis at different stages of treatment, UV254 instruments to evaluate jar tests, provided
systematic technical assistance during bloom onsets on a case-by-case basis (e.g. shift intake to
a lower position where the pH is lower, add acid to lower the pH, add a filter aid to improve
filter performance), and we would like to explore the value of bench top charge analyzer to
enhance coagulation/flocculation treatment performance.
4) We are very grateful for the steps the USEPA has taken thus far to provide comprehensive
guidance and recommendations; as compiling this information was likely a tremendous task. In
our opinion, expanding on satellite information to provide up-to-date information and/or
predict when the blooms are toxic to govern efficient monitoring strategies would be of
tremendous value.
5) Peter Moyle, a fisheries biologist in California, developed a ranking system to prioritize which
dams should modify operations to significantly improve fishery habitat. This was the
introduction of indexing ecological parameters as a means to rank where to target effort in
order to get the most effective results. Many have expanded on this approach in nutrient loaded
systems. In our opinion, developing a way to measure (and prioritize) the most effective efforts
would be valuable.
Don Jensen, City of Highland Park, Illinois
(Submitted electronically)
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As manager of a water utility blessed with Lake Michigan as a source, algal toxins are relatively low on
my list of worries.
I am, however, concerned when the news accounts of toxic algal blooms in the Great Lakes alarm our
residents.
Watershed risk assessment tools including indicators of risk (water temperature, sunlight hours, nutrient
loading, dissolved organic carbon, total organic carbon etc.) and associated mapping products would be
quite helpful in allaying those fears.
Of course, they would be most useful to water system managers in watersheds with higher risk of such
blooms.
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DarciL. Meese, WaterOne (Submitted electronically)
Wales
j
Setting the Standard for
Utility Excellence
J
Water District No, 1 of Johnson County
October 16, 2015
Sent Via e-mail to foreman.katherine@epa.gov
Ms. Katherine Foreman
EPA
RE: Federal Cyanobacteria Management Strategy (Drinking Water Protection Act) Comments
Dear Ms. Foreman:
WaterOne is an independent public water utility. We've been proudly serving the Johnson County,
Kansas area since 1957. Every day, over 400,000 customers rely on WaterOne to provide fresh, clean
water on demand. We can produce up to 200 million gallons per day using source water from both the
Kansas River and the Missouri River.
Treat the Source - Nutrients
WaterOne agrees with the Association of Metropolitan Water Agencies (AMWA) that the long range
strategy must include prevention of the nutrients from entering waterways including lakes, reservoirs,
rivers, and streams. Agriculture must be engaged and non-point sources must be included in a nutrient
control strategy to protect public health. WaterOne asks that EPA include nonpoint source nutrient
reductions in the Federal Cyanobacteria Management Strategy (Drinking Water Protection Act).
The Whole View - Watershed Management
The Kansas River is fed from three federal reservoirs, Milford, Tuttle, and Perry, all which are controlled
by the Corps of Engineers, in 2011, an algal bloom in Milford was released Into the Kansas River causing
taste and odor concerns along with health advisories on the river. WaterOne has the ability to switch
sources and utilize the Missouri River however, others utilities using the Kansas River as a source water
do not have this capability. This event caused WaterOne, the City of Olathe, the City of Topeka, the City
of Lawrence, the Kansas Department of Health Environment (KDHEJ, the Kansas Water Office (KWO) and
USGS to jointly study the both the Kansas River and removal treatment technologies through a WaterRF
study. EPA has focused its efforts on lake and reservoir activity. These studies have brought to light that
a flowing river can also be a source of cyanobacteria. Very little research has been conducted on rivers
as a source for cyanobacteria.
WaterOne asks EPA to include the management of the watershed as a whole system and include flowing
bodies of water as a potential source of cyanobacteria in its Federal Cyanobacteria Management
Strategy (Drinking Water Protection Act}.
Background
10747 Renneb Boulevard . Lenexa, Kansas 66219 . TEL: 913.895.8500 . www.waterone.org
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Katherine Foreman
EPA
October 16,2015
Confirming samples using LC/MS Testing
WaterOne has been using the ELISA method to conduct Myerocystin LR testing since the summer of
2012 along with many other area laboratories. EPA focuses on this test method in its health advisory
guidance. While we have proven that it is an effective method for determining the presence of the toxin,
we believe there may be some conditions that affect the methods ability to accurately quantify the
concentration, especially at levels near the specified detection limits of the test kits.
The manufacturer specified control for the ELISA method is acceptable within a 25% interval of the true
value. Meaning a measured of value 0.200 micrograms per liter could be anywhere from 0.150 to 0.250
and still fall within the acceptable testing limits.. We have noticed that extreme temperatures of
samples and variations in incubation can have significant effect on the consistency of results.
Additionally, we have seen a negative bias to testing when chemicals such as FeCI2, AIS04, or NaCIo3-
are present in the sample while the presence of CaO often results in a high positive bias.
Because all of these conditions and chemicals are common in drinking water treatment facilities and
because the acceptable control limits of the testing are already pretty wide, we believe that this testing
method may not be the best available technology for the accurate determination of Microcystin LR in
drinking water. This is especially true when trying to determine values at or near the specified detection
capability of the test which is also near the health advisory level of 0.3 micrograms per liter.
LC/MS methods are more precise, have a lower specified detection limit of O.lug/L, and the additional
capability of determining values for 7 seven different variations of Microcystin. For determining Total
Microcystin in samples there were also inconsistencies found with methods used for lysing the cells in
the sample.
We are planning to begin evaluating the ELISA kits for the determination of Cylindrospermopsin in the
near future but do not have any results at this time.
WaterOne asks that the LC/MS methods be used as confirming methods prior to the public notification
for values at or near the health advisory limit and that EPA account for the manufacturer specified
control of the ELISA LR test in its Federal Cyanobacteria Management Strategy (Drinking Water
Protection Act) and health advisory guidance.
Sincerely,
Darci L. Meese
Deputy General Counsel
DLM/grl
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