vvEPA
United States
Environmental Protection
Agency
Cyanotoxin Management Plan
Template and Example Plans
November 2.016
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Office of Water (4607M)
EPA 810-B-16-006
November 2016
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Disclaimer
This document was prepared by the U.S. Environmental Protection Agency (USEPA) as an informational
resource for public water systems and primacy agencies to prepare for and respond to the risk of
cyanotoxins in finished water.
This document is not a regulation; it is not legally enforceable; and it does not confer legal rights or
impose legal obligations on any party, including USEPA, States, or the regulated community. While the
USEPA has made every effort to ensure the accuracy of the discussion in this document, the obligations
of the regulated community are determined by statutes, regulations or other legally binding
requirements. The recommendations discussed are not a substitute for applicable legal requirements. In
the event of a conflict between the discussion in this document and any statute or regulation, this
document would not be controlling.
Although this document describes suggestions for managing cyanotoxin issues in raw and finished water
and provides examples of how five utilities are managing their risks, the recommendations described in
the template and activities included in the examples may not be appropriate for all situations and
alternative approaches may be applicable.
Mention of trade names, commercial products, specific methods and treatment for cyanotoxins does
not constitute an USEPA endorsement or recommendation for use.
Questions concerning this document should be addressed to:
Hannah Holsinger
USEPA OGWDW, SRMD, Standards and Risk Reduction Branch
1200 Pennsylvania Ave., NW
MC4607M
Washington, DC 20460
(202) 564-0403, holsinger.hannah@epa.gov
/'/'
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Acknowledgements
EPA's Office of Ground Water and Drinking Water would like to thank the Association of State Drinking
Water Administrators, the States of California, New York, Ohio and Oregon for their contributions to this
document.
This document was developed by the USEPA Office of Ground Water and Drinking Water in partnership
with the States of California, New York, Ohio and Oregon, Highlands Mutual Water Company, Village of
Perry Water System, Akron Water Supply Bureau, Ottawa County Regional Water System, City of Myrtle
Creek, The Cadmus Group, Inc. and USEPA: Office of Research and Development, Region 2, Region 5,
Region 9 and Region 10.
The following individuals helped to develop and review this document:
Hannah Holsinger, USEPA, OW
Katherine Foreman, USEPA, OW
Ryan Albert, USEPA, OW
Rachel Carlson, USEPA, OW
James (Bo) Williams, USEPA, OW
Karen Sklenar, The Cadmus Group, Inc.
Lesley D'Anglada, USEPA, OW
Nicholas Dugan, USEPA, ORD
Crystal Rodgers-Jenkins, USEPA, OW
Phil Oshida, USEPA, OW
Kenneth Rotert, USEPA, OW
Lili Wang, USEPA, OW
Deborah Vacs Renwick, USEPA, OW
Thomas Waters, USEPA, OW
Highlands Mutual Water Company-Example Plan
Norm Birdsey, Highlands Mutual Water Company
Jeff Davis, Highlands Mutual Water Company
Susan Keydel, USEPA, Region 9
Amy Little, California State Water Resources Control Board
Sheri Miller, California State Water Resources Control Board
Village of Perry Water System-Example Plan
Arlene Anderson, USEPA, Region 2
Jeff Drain, Village of Perry
Hyland Hartsough, NY Department of Health
James Hyde, NY Department of Health
Michael Lowy, USEPA, Region 2
Andrew Meyer, Wyoming County Health Department
Lloyd Wilson, NY Department of Health
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Akron Water Supply Bureau
Valerie Bosscher, USEPA, Region 5
Wendy Drake, USEPA, Region 5
Jessica Glowczewski, Akron Water Supply Bureau
Heather Raymond, Ohio EPA
Ottawa County Regional Water System
Valerie Bosscher, USEPA, Region 5
Wendy Drake, USEPA, Region 5
Kelly Frey, Ottawa County, Ohio
Mike Jividen, Ottawa County Regional Water System
Jeff Kukay, Ottawa County Regional Water System
Heather Raymond, Ohio EPA
Ron Wetzel, Ottawa County Regional Water System
City of Myrtle Creek
Rochelle Labiosa, USEPA, Region 10
Casey Lyon, Oregon Health Authority
Sean Negherbon, City of Myrtle Creek
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Cyanotoxin Management Plan Template Table of Contents
Abbreviations and Acronyms vi
Introduction viii
Sample Template for System Use T.l
Example Cyanotoxin Management Plans
Highlands Mutual Water Company Management Plan El.l
Village of Perry Water System Management Plan E2.1
Akron Water Supply Bureau Management Plan E3.1
Ottawa County Regional Water Supply Management Plan E4.1
City of Myrtle Creek Management Plan E5.1
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Abbreviations and Acronyms
Hg/L Micrograms per Liter
ACH Aluminum Chloro-Hydrate
Adda - (25,35,85,95,4ฃ,6ฃ)-3-amino-9-methoxy-2,6,8-trimethyl-10-phenyl-4,6-decadienoic acid
AWWA American Water Works Association
BMP Best Management Practice
Caltrans California Department of Transportation
CI02 Chlorine Dioxide
CMP Cyanotoxin Management Plan
CSLAP Citizens Statewide Lake Assessment Program
CWA Clean Water Act
DBP Disinfection Byproduct
DEQ Department of Environmental Quality
DOH Department of Health
DWMAPS Drinking Water Application to Protect Source Waters
ELISA Enzyme-Linked Immunosorbent Assay
EMA Emergency Management Agency
EPTDS Entry Point to the Distribution System
GAC Granular Activated Carbon
HAB Harmful Algal Bloom
MGD Million Gallons per Day
MIB 2-methylisoborneol
MRDL Maximum Residual Disinfectant Level
NHDPIus National Hydrography Dataset
NLCD National Land Cover Dataset
NOAA National Oceanic and Atmospheric Administration
NPDES National Pollutant Discharge Elimination System
NTU Nephelometric Turbidity Unit
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NYS DEC
New York State Department of Environmental Conservation
NYSFOLA
New York State Federation of Lake Associations
OCRWS
Ottawa County Regional Water System
OHA
Oregon Health Authority
PAC
Powdered Activated Carbon
PETG
Polyethylene terephthalate glycol
PUR
Partnership for Umpqua Rivers
qPCR
Quantitative Polymerase Chain Reaction
SCADA
Supervisor Control and Data Acquisition
SUNY ESF
SUNY College of Environmental Science and Forestry
SWRCB
State Water Resources Control Board
TMDL
Total Maximum Daily Load
TOC
Total Organic Carbon
USEPA
United States Environmental Protection Agency
USGS
US Geological Survey
WRF
Water Research Foundation
WTP
Water Treatment Plant
WWTP
Waste Water Treatment Plan
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Introduction
Cyanobacteria, formerly known as blue-green algae, naturally occur in surface waters. Under certain
conditions such as warmer water temperatures and increased nutrients (nitrogen and phosphorus)
cyanobacteria are able to grow rapidly, producing "blooms" referred to as harmful algal blooms or HABs.
HABs can produce toxins known as cyanotoxins, which can be harmful to humans and animals.
Conventional water treatment (consisting of coagulation, sedimentation, filtration and chlorination) can
generally remove intact cyanobacterial cells and low levels of cyanotoxins from source waters. However,
public water systems may face challenges in providing drinking water during a severe bloom event when
there are high levels of cyanobacteria and cyanotoxins in source waters. With planning and active
management, public water systems can reduce the risks of cyanotoxins occurring in finished drinking
water.
The United States Environmental Protection Agency (USEPA) developed this cyanotoxin management
plan (CMP) template and partnered with five utilities to develop example CMPs to support states, tribes
and public water systems in preparing for and managing the risks from cyanotoxins to drinking water.
The CMP template can be used by utilities to build system-specific cyanotoxin management plans as
they deem appropriate. The template contains potential steps for monitoring, treatment,
communication and long-term activities.
Ready-To-Use Template
The CMP template was developed to parallel the steps in the USEPA 2015 Recommendations for Public
Water Systems to Manage Cyanotoxins in Drinking Water. The template was further refined as a result
of the information gathered while collaborating with the five partner utilities to develop their system-
specific plans. The recommendations document can serve as a resource for public water systems
developing system-specific CMPs. Another available resource includes the utility action guide, Managing
Cyanotoxins in Drinking Water: A Technical Guidance Manual for Drinking Water Professionals,
developed by the American Water Works Association (AWWA) and the Water Research Foundation
(WRF) available through both http://www.awwa.org/ and http://www.waterrf.org. As a public water
system develops its plan, both documents can serve as useful sources of information to support a given
public water system's approach.
The template is provided in both an editable version (available on USEPA's website at:
https://www.epa.gov/ground-water-and-drinking-water/cyanotoxins-drinking-water) and within this
document (found on p. T.l). The editable version will allow systems to develop a plan by directly adding
text to the template and selecting resources as they deem appropriate, to create a system-specific CMP
responsive to their individual systems and situations. The template depicts the following steps that
public water systems could take to manage cyanotoxins in their drinking water systems:
Step 1: Assess Source Water. The template introduces considerations for assessing source water for
vulnerability to HABs, including a number of factors: watershed characteristics, historic water quality
information and pollution sources. Various sources could be used to gather this information, including
state and local source watershed assessments, as well as online resources.
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Step 2: Preparation, Monitoring for Early Warning Signs and Immediate Actions. The template
introduces considerations for possible actions to prepare for bloom and cyanotoxin occurrences including
conducting training, acquiring monitoring and treatment equipment and materials, identifying necessary
points of contact, monitoring early warning signs of a bloom and taking any immediate actions if a
bloom is suspected.
Step 3: Raw Water Cyanotoxin Monitoring and Treatment Adjustments. The template introduces
considerations for initial cyanotoxin monitoring in the raw water if a bloom is suspected near the intake
and any treatment adjustments that may be necessary to ensure cyanotoxins do not reach the finished
water.
Step 4: Finished Water Cyanotoxin Monitoring and Treatment Adjustments. The template introduces
considerations for addressing cyanotoxin detections in the raw water and finished water sampling,
including any additional treatment adjustments. Treatment adjustments and additions improve the
likelihood of cyanotoxins being removed from the raw water to prevent finished water cyanotoxin
contamination.
Step 5: Continued Finished Water Cyanotoxin Monitoring, Treatment Adjustments and Public
Communication. The template introduces considerations for finished water monitoring treatment
adjustments, which improve the likelihood that cyanotoxins are removed from the finished water. The
section also includes where the utility can outline their process for public communication based on
finished water monitoring results.
Opportunities to plan possible communication activities are included within each step. For example,
possible communication could include contacting public water systems using the same source water if a
bloom is suspected, or contacting local and state officials and the public if cyanotoxins are detected in
finished water. To support public water systems, states and local governments in developing, as they
deem appropriate, their own materials for communicating cyanotoxin risks to the public, USEPA
developed a risk communication toolbox.
Example Plans
Using the template described above as a general guide, the USEPA partnered with utilities to support
the development of five example CMPs. All five example CMPs generally follow the approach outlined in
the template previously discussed and present information from a variety of different systems with
varying sizes, source water types and treatment strategies. All five partner utilities had history of bloom
occurrences in their source waters. Systems developing system-specific plans can see these plans as
examples of how other systems are confronting their cyanotoxin challenges. Table 1 provides an
overview of characteristics of the five partner utilities' systems.
Please note, these five partner utilities' CMPs are provided as examples and were developed in
partnership with the utilities. Not all contents of the CMPs are appropriate to transfer to other systems.
By presenting these plans, EPA is not endorsing how the systems manage their cyanotoxin risks.
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Table 1. Characteristics of the five partner utilities' systems.
State
System
Source
Population
Served
(Approx.)
Treatment
California
Highlands
Mutual Water
Company
Clear Lake
6,200
Powdered activated carbon
(PAC), permanganate, ozone,
clarification, filtration, granular
activated carbon (GAC),
chlorination, corrosion control
New York
Village of Perry
Water System
Silver Lake
3,700
Coagulation, flocculation,
sedimentation, filtration, GAC,
permanganate, chlorination,
fluoridation, corrosion control
Ohio
Akron Water
Supply Bureau
Lake Rockwell
280,000
Permanganate, PAC,
coagulation, chlorine dioxide,
flocculation, sedimentation,
rapid sand filtration,
chlorination, corrosion control,
fluoridation
Ohio
Ottawa County
Regional Water
System
Lake Erie
25,000
Permanganate, PAC,
coagulation, clarification,
filtration, chlorination,
corrosion control, fluoridation
Oregon
City of
Myrtle Creek
South
Umpqua
River
3,400
Infiltration gallery, coagulation,
microfiltration, GAC, UV,
chlorination
Considerations for Plan Development
The template can assist public water systems in developing their own CMPs, recognizing the best
approach will vary on a case-by-case basis. As they deem appropriate, public water systems may want to
see the plans as examples of how other systems have planned to manage cyanotoxins. Described below
are five themes that emerged from the example plans that are potential approaches to addressing
cyanotoxins in drinking water.
Robust cyanotoxins monitoring approaches to managing blooms
Akron Water Supply Bureau and Ottawa County Regional Water System represent systems that have
robust monitoring programs for both cyanotoxins and their indicators as a way to manage the risks of
cyanotoxins in drinking water. To comply with Ohio state regulations, these systems, along with all other
public water systems using surface water in Ohio, must routinely monitor source and finished water for
total microcystins weekly or bi-weekly, depending on the season. Ohio's regulation requires the
frequency of monitoring at both raw and finished water sampling points to increase if microcystins are
detected in raw and/or finished water sampling points. Routine raw water genomic cyanobacteria
screening (through quantitative polymerase chain reaction (qPCR)) is also required bi-weekly.
Additionally, Akron Water Supply Bureau and Ottawa County Regional Water System use a sonde to
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measure the cyanobacterial indicators chlorophyll-o and phycocyanin in the source water. These two
systems' example plans use an approach to managing cyanotoxins through early detection as a way to
inform early treatment adjustments to decrease the risk of cyanotoxins breaking through to finished
water.
Source water assessment and protection approaches to managing blooms
Highlands Mutual Water Company's CMP provides an example with a more in-depth source water
evaluation including identifying source water protection areas, detailing source water characteristics,
evaluating land use characteristics within the watershed, reviewing historical cyanobacteria and
cyanotoxin occurrences and evaluating point and nonpoint sources of pollution in the source water.
Additionally, Highlands Mutual Water Company and Akron Water Supply Bureau's plans also include
enhanced source water protection strategies to prevent cyanotoxins in drinking water sources.
Source water management approaches to managing blooms
Akron Water Supply Bureau treats its source water with a commercial algaecide to decrease
cyanobacterial blooms when cyanobacterial populations are increasing in the source water. Treatment
occurs in a targeted fashion to avoid treating the entire lake. Akron Water Supply Bureau's plan can be
used as an example of a plan where the primary approach to ensuring algal toxins do not contaminate
the finished water is through source water mitigation strategies for algae and cyanobacteria.
Smaller system approaches to managing blooms
The City of Myrtle Creek and Village of Perry represent smaller systems with historical problems with
bloom occurrence. These small systems encounter challenges with managing cyanotoxins that may be
similar to other small systems. These systems rely on indicators of blooms, such as visual observations of
conditions in the source water and observations of changes in the treatment plant, rather than having
their own routine cyanotoxin monitoring and screening program. Monitoring for microcystins in these
systems is often only performed if a bloom is suspected in their source waters though source water and
plant indicators or through coordination with state and local monitoring programs that monitor their
source waters. Additionally, in the case of the City of Myrtle Creek, microcystins test strips are used for
much of the raw water quality monitoring.
Enhanced treatment approaches
In addition to the above characteristics, all example plans include the systems' plan to use
enhanced treatment barriers to protect finished water from cyanotoxin contamination. Most of the
systems either discontinue the use of pre-oxidation (e.g., pre-chlorination or pre-zonation) or use pre-
oxidation with caution (e.g., use a low dose permanganate). Additionally, most of the systems use
powdered activated carbon (PAC) and/or granular activated carbon (GAC) to treat cyanotoxins. For
example, Highlands Mutual Water Company, Akron Water Supply Bureau and Ottawa County Regional
Water System use PAC. The Village of Perry Water System, City of Myrtle Creek and Highlands Mutual
Water Company use GAC for mitigating cyanotoxins. In addition, most systems developed strategies to
optimize their existing coagulation and filtration processes for cell removal and enhance their post
chlorination capacity to oxidize toxins.
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Summary
For those systems vulnerable to HAB events in their source water, the CMP template can provide a
roadmap to support plan development, as the system deems appropriate. It provides an opportunity for
public water systems to use a template that can be tailored to address system-specific conditions,
recognizing the best approaches vary based on source water conditions and system characteristics. The
five partner utilities' plans following the template (found in sections E1-E5) are examples of how other
systems are managing cyanotoxin risks to their drinking water. Other sources of information, including
USEPA's 2015 Recommendations for Public Water Systems to Manage Cyanotoxins in Drinking Water,
USEPA's Water Treatment Optimization for Cyanotoxins and AWWA's and WRF's Managing Cyanotoxins
in Drinking Water: A Technical Guidance Manual for Drinking Water Professionals, can serve as
additional resources to support public water systems in their cyanotoxin management efforts.
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Cyanotoxins Management Plan
Insert cover photo.
[Your Water System]
Enter Public Water System Contact Information and Address.
Enter Publication Date.
T.l
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Instructions for Using Template
The template is intended to assist states, tribes and water utilities in developing their own cyanotoxin
management plans specific for their locations. The template includes potential steps for monitoring,
treatment and communication activities. However, systems should evaluate their system-specific
conditions as the most appropriate course of action will vary for each water system depending on the
type of system and conditions of the source water. To support systems as they develop their plans, five
system-specific cyanotoxin management plans were developed to provide examples for utilities to see
as they develop system-specific plans for their utility. Bolded language below provides instructions for
filling out the template; gray language provides prompts for systems to include their system-specific
language; and italicized language offers examples of types of information that may be useful.
T.2
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Table of Contents
Instructions for Using Template T.2
Table of Contents T.3
Appendices T.4
Template Overview T.5
Management Steps for Determining a Public Water System's Exposure to Cyanotoxins T.5
Cyanotoxin Management Plan Executive Summary T.7
[Your Water System] Overview T.8
Source Water T.8
Treatment Process T.8
Routine Water Quality Monitoring T.8
Step 1: Assess Source Water T.10
1.1 Identify Source Water Protection Areas T.10
1.2 Create Inventory of HABs Risk Factors T.ll
Source Water Characteristics T.ll
Water Quality Parameters T.12
Point Sources of Nutrients and Other Contaminants T.13
Nonpoint Sources of Nutrients and Other Contaminants T.13
Climate and Weather T.14
Other Source Water Management Activities T.14
1.3 Assess Vulnerability T.14
Step 2: Preparation, Monitoring for Early Warning Signs and Immediate Actions T.16
2.1 Preparation T.16
Prepare Staff and Equipment for Monitoring T.16
Prepare Treatment Adjustments T.16
Communications T.16
Establish Communication Plan with Other Source Water Users T.17
Communication with Stakeholders T.17
2.2 Monitoring for Early Warning Signs T.17
Early Indicators or a Cyanobacterial Bloom T.17
2.3 Immediate Actions if a Bloom is Suspected T.17
Monitoring Actions in Response to Early Warning Signs T.17
Treatment Adjustments in Response to Early Warning Signs T.18
Communication Actions in Response to Early Warning Signs T.18
Source Water Mitigation Actions in Response to Early Warning Signs T.18
Step 3: Raw Water Cyanotoxin Monitoring and Treatment Adjustments T.19
T.3
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Monitoring if Cyanobacteria are Identified or Suspected T.19
Operational Adjustments Based on Raw Water Cyanotoxin Measurements T.19
Communications Based on Raw Water Cyanotoxin Measurements T.19
Step 4: Finished Water Cyanotoxin Monitoring and Treatment Adjustments T.20
Finished Water Cyanotoxin Monitoring T.20
Treatment Adjustments T.20
Communications T.20
Step 5: Continued Finished Water Cyanotoxin Monitoring, Treatment Adjustments and Public
Communication T.21
Continued Finished Water Cyanotoxin Monitoring T.21
Treatment and Operations T.21
Communications T.21
Long-Term Activities T.23
Appendices
Appendix A Cyanotoxin Management Flowchart T.24
Appendix B Contacts and Stakeholder Information T.25
Appendix C Notifying the Public of Cyanotoxins in their Water T.26
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Template Overview
Cyanobacteria naturally occur in surface waters. Under certain conditions, such as warmer water
temperatures and increased nutrients (nitrogen and phosphorus), cyanobacteria can grow rapidly
producing "blooms" referred to as harmful algal blooms or HABs. HABs can pose a significant potential
threat to human and ecological health. Cyanobacteria have the potential to produce toxins (known as
cyanotoxins) that can cause adverse health effects in humans and animals through the contamination of
waterways used for recreational purposes and drinking water supplies.
The United States Environmental Protection Agency (USEPA) encourages public water systems to
consider how likely their systems may be to encounter HABs in their source waters. Systems with source
waters that are susceptible to HABs could benefit from developing a system-specific cyanotoxin
management plan (CMP) prior to a HAB event. Public water systems may want to periodically evaluate
and modify their CMPs as their understanding of the specific challenges related to HABs facing their
system evolves.
USEPA presents a possible approach to developing a CMP for drinking water systems in the 2015
document Recommendations for Public Water Systems to Manage Cyanotoxins in Drinking Water. The
approach includes components for determining if and when a public water system is vulnerable to
cyanotoxins, monitoring for cyanotoxins, treatment actions and communication strategies. The potential
management steps are intended to provide a stepwise approach that allows a public water system, as it
deems appropriate, to take actions to reduce the likelihood of cyanotoxin occurrence in its finished
water.
Management Steps for Determining a Public Water System's Exposure to
Cyanotoxins
Monitoring, treatment and communication are key elements of a CMP and play important roles during
each step. An overview of each element is provided below.
Monitoring. Source water and system observations can inform a water system's decisions about if and
when to start cyanotoxin monitoring in raw and finished water, when and how to adjust treatment plant
operations and when to communicate with external stakeholders and the public. USEPA does not
currently regulate cyanotoxins and public water systems are not required to monitor for cyanotoxins in
their drinking water (unless required by their state or primacy agency). Sampling locations and
frequencies are useful to include in a CMP. Water systems that monitor may want to consider
maintaining their records, as historical data can be valuable to a water system (and nearby systems) for
determining if and when the water system is vulnerable to cyanotoxins. Details on monitoring and
related resources are discussed in each of this CMP's steps.
Treatment. A water system is encouraged to identify its treatment strategies for controlling
cyanotoxins, and to do so in the context of its other drinking water treatment goals (e.g., turbidity
control, disinfection byproduct (DBP) control, disinfection, taste and odor control, corrosion control,
etc.). A water system can evaluate its existing treatment capabilities and make any needed short- and
long-term improvements before the bloom season in order to be prepared to respond when
cyanotoxins are detected. Treatment adjustments have been identified and included in the description
of how to proceed for each step of this CMP. USEPA's Water Treatment Optimization for Cyanotoxins is
an available resource describing cyanotoxin optimization techniques.
Template Cyanotoxin Management Plan - Template Overview
T.5
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Communication. Communication is an integral part of each step of a CMP. Important communications
to consider as part of a plan include sharing of information with the primacy agency, contract
laboratories, neighboring drinking water systems utilizing the same source waters, local officials,
drinking water stakeholders and the public. For public communications, communication strategies could
take into consideration the media and non-English speakers, as well as segments of the public that are
likely to take the greatest interest in messaging on cyanotoxins (such as parents of bottle-fed infants and
other young children under the age of six years old). Partnerships to help communicate with sensitive
populations, such as day care centers, pediatricians and dialysis centers, would also be helpful to
identify in the plan. The plan can include contact information and instructions on when and how to
communicate with stakeholders and the public. USEPA's Cyanotoxin Risk Communication Toolbox is an
available resource to assist with communicating the risks from cyanotoxins in drinking water.
For additional information about monitoring, treatment and communications see EPA's 2015
Recommendations for Public Water Systems to Manage Cyanotoxins in Drinking Water.
Template Cyanotoxin Management Plan - Template Overview
T.6
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Cyanotoxin Management Plan Executive Summary
[Your Water System] has developed this Cyanotoxins Management Plan (CMP) to provide an action plan
to prepare for and mitigate risks from harmful algal blooms (HABs) and cyanotoxins in order to protect
public drinking water from cyanotoxin contamination. This document provides steps and documents
activities to prepare for and identify a potential HAB occurrence and make treatment and operational
adjustments to remove cyanotoxins from the water. This document also includes steps to provide timely
information and (as appropriate) an advisory to the water system's customers, and to document
information about occurrences of HABs so that information can be used to minimize the effect of HABs
on the water system in the future. This plan also contains possible future activities the utility could
engage in to mitigate the risks from HABs and cyanotoxins, such as long-term source water protection
activities. A detailed flowchart of the CMP can be found in Appendix A.
The steps outlined in this CMP include:
Step 1: Assess Source Water
Step 2: Preparation, Monitoring for Early Warning Signs and Immediate Actions if a Bloom is Suspected
Step 3: Raw Water Cyanotoxin Monitoring and Treatment Adjustments
Step 4: Finished Water Cyanotoxin Monitoring and Treatment Adjustments
Step 5: Continued Finished Water Cyanotoxin Monitoring, Treatment Adjustments and Public
Communication
Template Cyanotoxin Management Plan - Executive Summary
T.7
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[Your Water System] Overview
Enter general information about your drinking water system, providing the level of detail and
information necessary for the users of the plan.
Source Water
Explain your source water options.
Identify each source that is available (e.g., lake, reservoir, river, wells, springs)
For each surface water source, how many intakes are available? How many depths are available
to draw water from?
Explain any interconnections you have with other systems and conditions and/or limitations when
using them.
Enter information about source water options.
Treatment Process
Describe your treatment process, in the order that the water
include a treatment schematic. Please discuss any competing
Enter information about treatment process. Include a schematic below.
Routine Water Quality Monitoring
For all of your available source waters, list (Table 1) any routine source water
quality monitoring that your water utility and/or others that you know of (e.g.,
environmental agencies, U.S. Geological Survey (USGS), academic institutions,
volunteer organizations) conducts or has recently conducted. Also consider
contacting your state, as you deem appropriate, to determine if additional
monitoring is occurring in your source waters.
If you think another group or agency may be monitoring but you do not know the details, write down what
you know or you think may be true. As much as possible, provide information about:
Which water quality parameters are/were monitored
Monitoring locations
Monitoring frequency
How readily available the data is on an ongoing basis
How reliable the results are (e.g., trained monitoring staff, QA plan, certified laboratory)
How quickly current monitoring results can be made available to you
Enter any water quality monitoring information.
Table 1. Source Water Quality Monitoring Information
Parameter
Location
Frequency
Who Collects
Sample?
Who Does
Analysis?
is treated and/or
priorities.
Template Cyanotoxin Management Plan - Overview
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Enter Treatment Plant Schematic Heading
Enter treatment plant schematic.
Template Cyanotoxin Management Plan - Overview T.9
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Step 1: Assess Source Water
Evaluating available data on source water supports making a weight of evidence determination about
the vulnerability to cyanotoxins. If a public water system determines that its source water is vulnerable,
the water system proceeds to Step 2. If a public water system determines its source water is not
vulnerable to cyanotoxins, the water system may want to consider periodically reassessing its source
water as watershed characteristics could change over time.
1.1 Identify Source Water Protection Areas
A source water assessment is an evaluation of a drinking water source to determine its susceptibility to
contamination. The first step of any source water assessment is to delineate (map) the areas of water
and land that drain into the water supply that are to be evaluated for contaminant sources. This is called
the Source Water Protection Area.
Delineate your Source Water Protection Area and describe the methods and
resources used to do so.
How to delineate your Source Water Protection Area:
State resources
States completed Source Water Assessments in the early 2000s, which delineate Source
Water Protection Areas for each system in the state. You can access your state's Assessment
and Service Planning Area maps by contacting your state's source water staff. Please note
information may have changed since their original development although some Source
Water Assessments may have been updated.
Many states have online mapping tools for Source Water Protection Areas.
Enter available state resources and source water protection area information.
Drinking Water Application to Protect Source Waters (DWMAPS)
DWMAPS is a tool to help you quickly delineate a source water protection area based on
mean water flow. Use the "Upstream" toolbar in DWMAPS to select your system's location
and trace catchments upstream. You can trace your Service Planning Area based on:
o Time of travel, e.g., 24 hours by mean flow from the stream reach. This method is useful
for timing bloom response.
o Fixed distance, e.g., 15 miles along streamline, or 15 miles of setback around an intake.
While not technically sophisticated, this method is easy to implement.
o Modeling uses surface runoff models to estimate the pathway of pollutants during
rainfall and from point source outfalls. DWMAPS does not model specific pollutants.
Zone of Concern
o Some states use a tiered zoning approach to map their source water protection areas.
For example, water systems in the Ohio River Valley Water Sanitation Commission
define multiple zones: the least critical zone is the entire Ohio River Basin and the most
critical is all catchments within / mile upstream of an intake. You can use DWMAPS or
other modeling tools to quickly delineate zones of concern.
Template Cyanotoxin Management Plan - Step 1
T.10
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Map 1: Delineation of source water protection area (yellow) based on 24 hours' time of
travel, DWMAPS
South
Beaver
Twp
SI Clair
Hooksto\
Bergholz
Frankfort
Springs 1
East
Springfield
LFFFRSON
Bloominqd3U
Waqi virnir
NPDES Other Facilities
Enter Source Water Protection Area delineation methods.
Enter description of map. A map can be created using DWMAPS
(https://www.epa.gov/sourcewaterprotection/dwmaps) or other available mapping programs. For use
of DWMAPS, navigate DWMAPS extent to the water systems intake location. Click Layers button in top
right selection panel. Click the check box next to Catchments layer under Hydrography and Watersheds
section. Click Legend button in top right selection panel. Use Snipping Tool application to extract map to
JPEG file. A DWMAPS user guide is also available to assist in creating maps.
Enter Map Heading
Insert map image.
NPDES Sewerage Facilities
an Twp
Combined Sewer Overflows
(CSO)
Burgettstcwn Joffre
West M;
Selected NHD Flowlines
m Brighjji T
Ohioville
matching query
Catchments
S b
NPDES Refuse Facilities
ฆ
Raccoon Twp
Wayne Twp
1.2 Create Inventory of IHABs Risk Factors
The next step is to create an inventory of possible HABs risk factors within your source water protection
area(s). An example of a table of risk factors created by a utility is provided following the discussion on
risk factors in Table 2. Information on the following factors can help you determine if and when blooms
may occur.
Source Water Characteristics
In general, fast flowing, nutrient-poor rivers are less vulnerable to HABs than nutrient-rich lakes and
reservoirs. You may also consider factors such as vertical stratification, light intensity, wind patterns and
Template Cyanotoxin Management Plan - Step 1
T.ll
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mixing (see Appendix A of Recommendations for Public Water Systems to Manage Cyanotoxins in
Drinking Water for more information).
Is your source water ground or surface water?
Is it fast-flowing, slow-moving or still water?
Is it nutrient (phosphorus and nitrogen) rich?
To investigate source water characteristics:
If needed, consult your state water quality office, local monitoring data from nearby utilities or federal
databases for source water information.
Useful resources include Source Water Assessments and Lake Management Plans, as well as
Clean Water Act 303(d) and 305(b) Integrated Reports, Nonpoint Source Management Plans and
319 grant proposals, and Total Maximum Daily Load (TMDL) analyses. For example see
DWMAPS or WATERS.
National Hydrography Dataset (NHDPIus) provides information on surface water and watershed
characteristics.
For each source, identify any limitations to using that source (e.g., water quantity,
water quality, operational limitations, permit restrictions, costs).
Enter general information about source water type and include any source water limitations.
Describe or map land use within the watershed.
Evaluate land use using DWMAPS or another tool to view the National Land Cover Dataset (NLCD) or
other land use classification tools. NLCD uses satellite data to classify land cover across the United
States by 16 land use types. Use NLCD to determine where agriculture (hay/pastureland, cultivated
crops) or urban development may affect your source water.
Enter a description of land use within the watershed.
Water Quality Parameters
Water quality parameters can help to determine if the source water has had a history of blooms.
Parameters to look for include:
Cyanobacterial cell counts (including dominant cyanobacterial species)
Nitrogen and phosphorus levels
Chlorophyll-o levels
Phycocyanin levels
Zebra mussel population
Fish kills due to hypoxia
Presence of blooms and scums on the water
To investigate water quality:
Search water quality databases, outlined here: http://sourcewatercollaborative.org/assess-
protect-drinking-water-sources/find-data-in-my-area/.
Useful resources include Source Water Assessments and Lake Management Plans, as well as
Clean Water Act 303(d) and 305(b) Integrated Reports.
Template Cyanotoxin Management Plan - Step 1
T.12
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If needed, consult your state water quality office for more information about local monitoring
data from nearby utilities, water quality volunteer or academic institutions and for additional
information about federal databases for water quality data.
Provide a brief explanation of historical algae, cyanobacteria and cyanotoxin events
in your source water. Describe any information used to conduct your evaluation.
Enter information on historical algae, cyanobacteria and cyanotoxin events in source water. Include
predominant species of algae and/or cyanobacteria when possible.
Point Sources of Nutrients and Other Contaminants
It is important to inventory all potential sources of contamination discharging into your source water.
This inventory can point to critical HABs contributors.
Point sources of phosphorus and nitrogen can include:
Permitted dischargers of nutrients under the National Pollutant Discharge Elimination System
(NPDES)
Publically owned treatment works
Combined sewer overflows
To create an inventory:
1. Use DWMAPS (Geographic Information System or GIS) layers or "Upstream" toolbar) to locate
NPDES dischargers and publically owned treatment works. DWMAPS is synchronized with EPA's
Enforcement and Compliance History Online, which tracks facilities that have violated permit limits
and may discharge excessive nutrients into your source water
2. Use EPA's Discharge Monitoring Report database for more detailed facility information on small and
large NPDES dischargers and treatment plants
Describe point sources of nutrients and other contaminants.
Enter any point sources of pollution, specifically sources of phosphorus and nitrogen.
Nonpoint Sources of Nutrients and Other Contaminants
Nonpoint sources can include:
Agricultural uses including animal and crop production (manure, pesticide and fertilizer) runoff
Urban stormwater or domestic runoff
Failing septic systems
Landfills/dumps
Atmospheric deposition
To create an inventory:
Useful state resources include Source Water Assessments and Lake Management Plans, as well
as Clean Water Act 303(d) and 305(b) Integrated Reports and Total Maximum Daily Load
information.
EPA's Nitrogen and Phosphorus Data Access Tool displays nutrient data by watershed across the
U.S., combining metrics from USE PA and USGS research programs.
Template Cyanotoxin Management Plan - Step 1
T.13
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Describe nonpoint sources of nutrients and other contaminants.
Enter any nonpoint sources of pollution, specifically sources of phosphorus and nitrogen.
Climate and Weather
Warm ambient and source water temperatures, heavy rainfall and runoff, drought and calmer wind
often favor bloom growth. The climate of your geographic location can also impact temperature,
stratification and turbulence in the water column, which affects bloom timing and occurrence. Research
your area's bloom history and consult with other water systems to track climatic and temporal patterns.
Describe the climate and typical weather conditions in your area.
Include descriptions of precipitation and temperature throughout the year.
Enter climate and weather conditions.
Other Source Water Management Activities
Describe any source water management activities such as an active watershed
management program or other protection and improvement activities underway in
your source waters. Include a description of how your water utility's interests are
represented by these efforts (if represented).
Briefly describe source water protection efforts being carried out in your watershed (e.g.,
agricultural best management practices, conservation easements, streambank restoration, storm
water runoff controls, wastewater treatment plant upgrades, environmental education and
outreach) and who is making those efforts.
Enter a description of watershed management program.
Describe any previously implemented (or current implementation) of source water
protection activities (perhaps derived from your last source water assessment).
Explain if you have any partners in these efforts, what the expected outcomes were, how the
activities were financed and if there are any additional activities planned.
Enter information about your source water protection activities.
1.3 Assess Vulnerability
A weight of evidence approach can be used to determine if the source water is vulnerable to HABs
based on source water characteristics and HABs risk factors. Possible methods to evaluate vulnerability
include:
Build off of your inventory from Step 1.1 and Step 1.2 and assign risk "rankings" compared
to risk-reducing "rankings" for the watershed. As an example, The California Drinking Water
Source Assessment and Protection Program outlines this method for quantifying your
Susceptibility here. Examples are shown in Table 2 below.
Enter a description of source water vulnerability including whether or not the source water has be
determined to be vulnerable to HABs. See Section 1 and Appendix A of USEPA's Recommendations for
Public Water Systems to Manage Cyanotoxins in Drinking Water.
If you have determined that your source water is vulnerable go to Step 2.
Template Cyanotoxin Management Plan - Step 1
T.14
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Table 2: Example of an Inventory ofHABs Risk Factors from a Utility Evaluation
HABs Risk Factor
Measure
Data Source
Risk
Ranking
Source Water Characteristics
Source Water Type
Mean Surface Water
Temperature (F)
Water Body Depth (ft.)
Vertical Stratification
Residence Time
Lake/Reservoir
Lower Arm ~752 (24^C) (July-
August)
Lower Arm Mean: 33.8 ft.; intake
depth 15-20 ft.
Well-mixed; few occurrences of
sustained stratification
4.5 years, relatively short
USGS NHDPIus
CA Department of Water
Resources
Clear Lake Report (2020)
Clear Lakes Report (2010)
Water Resources
Department of the Lake
County Department of
Public Works
High
High
Low
Low
Water Quality Parameters
Cyanobacteria
Occurrence
Cyanotoxin Levels (n/L)
CWA 303(d) Impairment
Status
Microcystis, Anabaena and
Aphanizomenon, Lyngbya
Lower Arm: .52 anatoxin-a (2010)
Impaired, Nutrients (1986);
Nutrient TMDL(2006)
Home, 1975; Richerson et
al., 1994; Mioini, 2011
Mioni, 2011
USGS SPARROW (2002
model for Lower
Mississippi)
High
High
Medium
Point Sources
Point Sources of
Nutrients
Lake County Stormwater
Permittees; California
Department of Transportation
(Caltrans): 2,100 kg phosphorus
TMDL discharge limit
Clear Lake Nutrient TMDL
(2006)
Low
Nonpoint Sources
Nonpoint Sources of
Nutrients
Bureau of Land Management, the
United States Department of
Agriculture's Forest Service,
irrigated agricultural dischargers,
and Lake County; 85,000 kg
TMDL discharge limit
Clear Lake Nutrient TMDL
(2006)
High
Climate and Weather Conditions
Ambient temperature F^,
May-September
Drought Risk
Range: high average 92^, low
average 45^
NOAA National Weather
Service
U.S. Drought Monitor
High
Medium
Template Cyanotoxin Management Plan - Step 1
T.15
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Step 2: Preparation, Monitoring for Early
Warning Signs and Immediate Actions
2.1 Preparation
You have determined that [Your Water System] is potentially vulnerable to cyanotoxins. Possible next
steps include preparing for possible cyanobacterial blooms and cyanotoxin occurrence. A water system
can prepare by: determining when blooms are most likely to occur, contingency planning in the event
alternative sources of water are needed, evaluating the current treatment process to determine
susceptibility and vulnerabilities, communication with other water utilities with the same source water,
monitoring source waters, preparing for treatment adjustments and ordering necessary laboratory
equipment, or establishing contracts with outside laboratories. Preparation can also involve establishing
communication plans in order to be prepared for any public communication as appropriate or required
by the state. Preparation can also include establishing and documenting sampling procedures, testing
procedures and quality assurance procedures.
Prepare Staff and Equipment for Monitoring
For tips on monitoring and sampling see Sections 2.2, 3.1, 4.1, 5.1 and Appendix A of USEPA's
Recommendations for Public Water Systems to Manage Cyanotoxins in Drinking Water, USEPA's Online
Source Water Quality Monitoring for Water Quality Surveillance and Response Systems, and American
Waterworks Association (AWWA) and Water Research Foundation (WRF)'s Managing Cyanotoxins in
Drinking Water: A Technical Guidance Manual for Drinking Water Professionals. Preparing for
monitoring can involve preparing your utility lab for monitoring, such as ordering necessary supplies. It
can also involve setting up contract labs, as appropriate, prior to bloom season in order to allow for
rapid monitoring response if a bloom has occurred.
[Your Water System] will carry out the following activities in order to be prepared
for the monitoring steps described in this plan:
Enter monitoring preparation steps.
Prepare Treatment Adjustments
For tips on treatment adjustments see Sections 2.4, 3.3, 4.3, 5.3 and Appendix E of USEPA's
Recommendations for Public Water Systems to Manage Cyanotoxins in Drinking Water, USEPA's Water
Treatment Optimization for Cyanotoxins and Section II of AWWA and WRF's Managing Cyanotoxins in
Drinking Water: A Technical Guidance Manual for Drinking Water Professionals.
[Your Water System] will carry out the following activities in order to be more
prepared to treat its source water during a HAB:
Enter treatment preparation steps.
Communications
For tips on communication see Sections 2.3, 3.2, 5.2 and Appendix D of USEPA's Recommendations for
Public Water Systems to Manage Cyanotoxins in Drinking Water, USEPA's Drinking Water Cyanotoxin
Risk Communication Toolbox. Section IV of AWWA and WRF's Managing Cyanotoxins in Drinking Water:
Template Cyanotoxin Management Plan - Step 2
T.16
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A Technical Guidance Manual for Drinking Water Professionals and Centers for Disease Control's
Drinking Water Advisory Communication Toolbox.
Establish Communication Plan with Other Source Water Users
Describe any utilities using the same source water as your utility.
Do you communicate with one another? Do you have an organized method for communicating?
Are there specific reasons or conditions when you contact one another? Explain briefly.
Enter a description of interactions with other neighboring utilities or other source water users.
Communication with Stakeholders
[Your Water System] will carry out the following activities in order to be more
prepared for the communications steps described in this plan:
Do you have any pre-prepared public communication materials? Do you have a method for communicating
with stakeholders?
Enter communication preparation steps.
2.2 Monitoring for Early Warning Signs
Based on historical blooms in [insert source water source], there may be a time of year and other
conditions that prompt you to watch closely for signs of blooms. Early indicators, like challenges to
normal treatment schedules or changes in other water quality parameters, can serve as early warning
signs of impending blooms. Early warning signs that operators can look for during the system's normal
operation are identified in this section, including routine water quality monitoring, as well as follow-up
activities if any of the early warning signs are observed.
Early Indicators of a Cyanobacterial Bloom
Describe specific conditions related to your source water or treatment system that
are early indicators of a cyanobacterial bloom.
(Some examples could include: reduced Secchi disk depth in source water, increased turbidity,
color change, taste and odor complaints, geosmin and/or MIB (2-methylisoborneol) occurrence,
shortened filter run times, increased disinfectant demand, weakening thermocline, cyanobacteria
detects, toxin-producing cyanobacterial gene detects (quantitative polymerase chain reaction
(qPCR)), increased cyanobacterial biomass and/or cell counts, changes in cyanobacteria/algae
community composition, cyanotoxin detects, phycocyanin and chlorophyll-a)
Enter any early indicators of a cyanobacterial bloom that you have noticed in the source water.
2.3 Immediate Actions if a Bloom is Suspected
Monitoring Actions in Response to Early Warning Signs
Describe monitoring actions to take in response to early warning signs.
Enter sampling actions, if any, that will be taken.
Template Cyanotoxin Management Plan - Step 2
T.17
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Describe additional immediate observation/monitoring steps to take if any of the
early warning signs identified above are detected.
Enter any additional sampling or monitoring actions including water type and methods. Include any
language about the transition to Step 3 and/or Step 4, if applicable as an immediate action.
Treatment Adjustments in Response to Early Warning Signs
Describe immediate treatment adjustments (if any) to make if a cyanobacterial
bloom is beginning to take place in your source water.
Enter treatment adjustments, if any, that will occur. Include any language about the transition to Step 3
and/or Step 4, if applicable as an immediate action.
Communication Actions in Response to Early Warning Signs
Describe immediate communication actions (if any) to take if cyanobacteria are
identified in source water sample(s) including those that are potential cyanotoxin
producers.
Enter communication actions, if any, that will be taken.
Source Water Mitigation Actions in Response to Early Warning Signs
Describe the use, either by you or anyone else, of algaecides, coagulants or other
chemicals to treat your source water before it enters your treatment plant. Include
details on what treatment is used, how often and under what conditions. (Note,
waterbody management strategies, such as algaecides or introduction of predator
species, may have downstream unintended consequences. State regulations may
also apply.)
Enter list of source water mitigation activities, if any.
Template Cyanotoxin Management Plan - Step 2
T.18
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Step 3: Raw Water Cyanotoxin Monitoring and
Treatment Adjustments
If a cyanobacterial bloom is observed or inferred during Step 2. [Your Water System] begins sampling.
In cases where raw water monitoring (Step 3) is determined necessary by visual confirmation of blooms
near the intake (for example microscopically confirmed cyanobacteria) or other indications of a bloom
near the intake, the public water system may want to consider continuing raw water sampling until the
bloom is no longer visually identifiable or indicators are no longer observed.
A water system may want to communicate with some of its stakeholders and adjust treatment or
system operations based on raw water monitoring cyanotoxin results.
Monitoring if Cyanobacteria are Identified or Suspected
Describe monitoring actions to take if cyanobacteria are identified or suspected in
source water located near the intake.
Enter raw water monitoring actions and methods used.
Operational Adjustments Based on Raw Water Cyanotoxin
Measurements
Describe operational adjustments to make to your treatment (if any) based on
source water cyanobacteria or raw water cyanotoxin measurements.
Enter a description of operational treatment adjustments, if any.
Communications Based on Raw Water Cyanotoxin Measurements
Describe communication actions to take if cyanotoxins are detected in the raw
water.
Enter communication actions, if any.
If monitoring results indicate the presence of cyanotoxins in the raw water, [Your Water System]
continues to Step 4.
Enter a description of how quickly the system will move to Step 4.
If no cyanotoxins are found in the raw water, [Your Water System] intends to continue to monitor or
watch closely for blooms (Step 2).
Template Cyanotoxin Management Plan - Step 3
T.19
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Step 4: Finished Water Cyanotoxin Monitoring
and Treatment Adjustments
Detecting and positively confirming cyanotoxins in the finished water indicates that cyanotoxins have
broken through the treatment barriers. It is important to evaluate the performance of individual unit
processes across the treatment train to help understand what is happening in the treatment train and
identify possible treatment breakdown. Public water systems likely will want to continue implementing
treatment strategies described in Steps 2 or 3 and consider further testing and adjustments to improve
treatment performance.
Finished Water Cyanotoxin Monitoring
Describe finished water monitoring including which methods will be used.
Enter monitoring steps and methods used.
Describe what additional monitoring will occur if cyanotoxins are not found in
finished water including any monitoring to occur in the source or raw water.
Enter additional monitoring your system will carry out, if any.
Treatment Adjustments
In addition to the treatment adjustments
treatment steps will occur.
Enter additional treatment steps, if any.
Communications
listed in Step 3. describe what additional
Describe what communications [Your Water System] will carry out if cyanotoxins
are present in finished water.
Enter communication activities, if any.
If cyanotoxins were detected in any of the entry point or distribution system samples, [Your Water
System] proceeds to Step 5.
Template Cyanotoxin Management Plan - Step 4
T.20
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Step 5: Continued Finished Water Cyanotoxin
Monitoring, Treatment Adjustments and
Public Communication
Step 5 can contain communication actions, treatment actions and additional monitoring based on the
concentrations of cyanotoxins found in the finished water. Having clearly described actions in this fifth
step enables a public water system to act quickly if cyanotoxins are confirmed in its finished water.
Continued Finished Water Cyanotoxin Monitoring
Describe what additional monitoring steps [Your Water System] will take if
cyanotoxins are detected in the finished water including which methods will be
used.
Enter monitoring steps and methods you intend to use.
Include any toxin levels that [Your Water System] will use to decide whether to
conduct additional cyanotoxin sampling.
Include analytical method that [Your Water System] will use when having
additional samples analyzed.
Analyses carried out by the laboratory are typically considered more reliable tests than those
carried out using test strips and therefore, are useful when confirmation samples need to be
taken to inform management decisions.
Enter a description of the toxin level that would indicate a need for additional sampling and describe the
additional sampling and which method will be used.
Describe what monitoring steps [Your Water System] will take if the additional
sampling does not detect cyanotoxins.
Enter monitoring steps.
Treatment and Operations
Describe any treatment steps [Your Water System] will take.
Enter treatment adjustments or additions, if any.
Communications
Describe any communication steps [Your Water System] will take if any of the
distribution system samples or the entry point sample(s) tested during additional
sampling are at or exceed any established toxin levels.
Enter communication steps, if any, and include with who and when communication will take place.
Include communication action items based on level of cyanotoxins detected, if any.
Template Cyanotoxin Management Plan - Step 5
T.21
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Describe any communication steps [Your Water System] will take if the additional
sample results for all the samples are below an established toxin level in the entry
point to the distribution system or in the distribution system.
Enter communication steps, if any, and include communication action items based on levels of
cyanotoxins detected, if any.
Describe any communication steps [Your Water System] will take if all of the
additional sample results for all samples show no cyanotoxin detects.
Enter communication steps, if any.
Template Cyanotoxin Management Plan - Step 5
T.22
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Long-Term Activities
Describe any long-term plans for prevention, mitigation and management of the
risks to drinking water from HABs such as treatment and monitoring activities,
source water protection and mitigation activities and enhanced coordination with
stakeholders.
Enter any long-term activities.
Template Cyanotoxin Management Plan - Long-Term Activities
T.23
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Appendix A
Cyanotoxin Management Flowchart
Is It vulnerable?
Yes
Were toxins detected?^
Were toxins detected?.
yS Are there signs \
of a bloom or cyanotoxin
occurrence?
Step 4: Finished Water
Cyanotoxin Monitoring
and Treatment
Adjustments
Step 5: Continued
Finished Water
Cyanotoxin Monitoring,
Treatment Adjustments,
and Public
Communication
Step 1: Assess Source
Water
Step 3: Raw Water
Cyanotoxin Monitoring
and Treatment
Adjustments
Step 2.1 : Preparation
Step 2.3: Immediate
Actions if a Bloom Is
Suspected
Step 2.2 : Monitoring
the Early Warning Signs
Continue evaluating
for possible bloom
(Step 2.2).
Begi n any
preparation, as
needed, for
monitoring,
treatment and
communication.
Begin monitoring,
communication, and
source water
mitigation actions.
Continue
monitoring,
treatment, and
communication
activities as needed.
Return to previous
steps as appropriate.
Cyanotoxins: Actions to Monitor
Occurrence and Minimize
Exposure
Template Cyanotoxin Management Plan - Appendix A
T.24
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Appendix B
Contacts and Stakeholder Information
Provide names and contact information (office and mobile phone numbers, email address, affiliation) for
the most appropriate contacts. Names may be repeated if the person will serve more than one role.
Laboratory Contact Information
Enter your laboratory's name, phone number and any other contact information that will be needed to
contact the lab in case of an occurrence of HABs.
Stakeholders
Not all cyanotoxin management plans are the same, but the basic concepts of designing a plan are
similar to those of other environmental or sustainability programs. For any plan to be successful it is
important to involve utility management, the utility employees and all interested stakeholders early and
often. A joint management/employee/stakeholder committee could be used to ensure the plan is
implemented correctly. Examples of stakeholders include: primacy agency, local officials, emergency
managers, other government agencies such as health departments, nearby public water systems and
hospitals.
Agency/Company
Position
Contact Name Contact Phone
Contact Email
Template Cyanotoxin Management Plan - Appendix B
T.25
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Appendix C
Notifying the Public of Cyanotoxins in their Water
At the time of publication of this document, public water systems are not currently required to notify
their customers of any bloom or cyanotoxin occurrence and are not required to include detections as
part of a system's Consumer Confidence Report under any National Primary Drinking Water Regulations.
Systems should consider consulting with their state or primacy agency to determine if they are subject
to any state or tribal notification requirements. Although not currently required by federal regulations,
water systems may want to consider communicating with their consumers if cyanotoxins in finished
water are confirmed in additional samples. This communication may be received more positively if the
water systems have engaged in prior communication with the public about HABs. A water system is
encouraged to tailor its communications based on the cyanotoxin levels detected.
In fall 2016, the USEPA released the drinking water cyanotoxin risk communication toolbox. This toolbox
is a ready-to-use, "one-stop-shop" to support public water systems, states and local governments in
developing, as they deem appropriate, their own risk communication materials. It includes editable
worksheets, press release templates, social media posts and other quick references. The materials focus
on communicating risk and providing background information to the public prior to and during a
drinking water cyanotoxin contamination event as well as general information on harmful algal blooms
and cyanotoxins. For the full toolbox please see USEPA's Cyanotoxin Risk Communication Toolbox.
Below are some sample templates from that toolbox that are ready-to-use for cyanotoxin Drinking
Water Advisories. Brackets ( [ ] ) are included as prompts to fill in system-specific information. There are
three template options available, one for each of the following scenarios, when toxin levels1 in finished
drinking water are:
Greater than the USEPA's Health Advisory level for everyone, meaning levels are greater than
both the Health Advisory levels for infants and young children under the age of six and those for
children six years and older through adults;
Greater than the USEPA's Health Advisory level for infants and young children under the age of
six, but less than or equal to the Health Advisory level for children six years and older through
adults;
Less than or equal to the USEPA's Health Advisory level for everyone, meaning levels are less
than or equal to Health Advisory levels for infants and young children under the age of six and
therefore they are also less than the Health Advisory levels for children six years and older
through adults.
As means of an example, the USEPA's Health Advisory levels for microcystins and cylindrospermopsin
are used as cyanotoxin levels that inform public communication decisions in these Drinking Water
Advisories. Materials can be edited to include any information determined appropriate by states and
public water systems such as different cyanotoxin levels that inform public communication decisions.
1 The U.S. Environmental Protection Agency's Health Advisory levels are the following: less than or equal to 0.3 micrograms per
liter for microcystins and less than or equal 0.7 micrograms per liter for cylindrospermopsin in drinking water for children under
the age of six years old. Children six years and older through adults, the recommended Health Advisory levels for drinking water
is less than or equal to 1.6 micrograms per liter for microcystins and less than or equal 3.0 micrograms per liter for
cylindrospermopsin.
Template Cyanotoxin Management Plan - Appendix C
T.26
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DRINKING WATER ADVISORY
[CYANOTOXIN NAME] is present in [WATER SYSTEM NAME]
DO NOT DRINK THE TAP WATER
[Date issued]
Why is there an advisory?
[Cyanotoxin name], a toxin produced by cyanobacteria (formerly known as blue-green algae)
was detected in the drinking water from [System name] on [date],
Elevated levels of toxins have been detected in [source name] that supplies water to
[geographic area, cities, counties, distribution system segments, etc.],
[System name] is taking the following actions to reduce [cyanotoxin name] levels: [list
actions such as: adjusting treatment, changing source, etc.],
Samples collected on [dates] show [cyanotoxin name] in the drinking water at [levels and/or
ranges], which are above the U.S. Environmental Protection Agency's [cyanotoxin name]
national drinking water Health Advisory of [level].
What should I do?
Do Not Drink the tap water.
[Alternative sources of water] should be used for drinking, making infant formula, making ice
and preparing food and beverages.
Do Not Boil the tap water. Boiling the water will not destroy cyanotoxins and may increase the
toxin levels.
Everyone may use tap water for showering, bathing, washing hands, washing dishes, flushing
toilets, cleaning and doing laundry. However, infants and young children under the age of six
should be supervised while bathing and during other tap water-related activities to prevent
accidental ingestion of water.
Drinking water containing [cyanotoxin name] at levels exceeding the national drinking water
Health Advisories can put you at risk of various adverse health effects including upset stomach,
vomiting and diarrhea as well as liver and kidney damage. Seek medical attention if you or
family members are experiencing illness.
Animals may be vulnerable to adverse health effects of [cyanotoxin name] at the detected levels
indicated above; consider providing animals alternative sources of water. Contact a veterinarian
if animals show signs of illness.
If you, your family members or your animals have experienced adverse cyanotoxin-related
health effects, please contact [State or local Health Department] to report the illness.
What is being done?
[System name] is working closely with local and state public health and emergency response
agencies to address the situation and to quickly to reduce [cyanotoxin name] levels in tap water.
[System name] will post an updated advisory when: the [cyanotoxin] levels are less than or
equal to the national drinking water Health Advisories, this Do Not Drink Advisory is lifted
and/or if there are any changes to the conditions of this Do Not Drink Advisory.
Template Cyanotoxin Management Plan - Appendix C
T.27
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For more information please contact [contact information] or visit [website].
Please share this information with all the other people who drink this water, especially those who may not have
received this notice directly (for example, people in apartments, nursing homes, schools and businesses). You can do
this by posting this notice in a public place or distributing copies by hand.
This notice is being sent to you by [system]. State Water System ID#: Date distributed:
Template Cyanotoxin Management Plan - Appendix C
T.28
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DRINKING WATER ADVISORY
[CYANOTOXIN NAME] is present in [WATER SYSTEM NAME]
INFANTS, YOUNG CHILDREN AND OTHER
VULNERABLE POPULATIONS: DO NOT DRINK THE TAP
WATER
[Date issued]
Why is there an advisory?
[Cyanotoxin name], a toxin produced by cyanobacteria (formerly known as blue-green algae),
was detected in the drinking water from [System name] on [date],
Elevated levels of toxins have been detected in [source name] that supplies water to
[geographic area: cities, counties, distribution system segments, etc.],
[System name] is taking the following actions to reduce [cyanotoxin name] levels: [list
actions such as adjusting treatment, changing source, etc.],
Samples collected on [dates] show [cyanotoxin name] in the drinking water at [levels and/or
ranges], which are above the U.S. Environmental Protection Agency's [cyanotoxin name]
national drinking water Health Advisory for vulnerable populations (listed below) of [level].
What should I do?
The following vulnerable populations should Not Drink the tap water because they may be
vulnerable to the effects of [cyanotoxin name]:
o Infants,
o Young children under the age of six,
o Pregnant women and nursing mothers,
o Those with pre-existing liver conditions,
o Those receiving dialysis treatment, and
o As a precautionary measure, the elderly and other sensitive populations should consider
following these advisory instructions.
Vulnerable populations, listed above, should use [alternative sources of water] for drinking,
making infant formula, making ice and preparing food and beverages.
Do Not Boil the tap water. Boiling the water will not destroy toxins and may increase the toxin
levels.
Individuals not considered to be in the vulnerable category, as listed above, may drink the
water.
Everyone may use tap water for showering, bathing, washing hands, washing dishes, flushing
toilets, cleaning and doing laundry. However, infants and young children under the age of six
should be supervised while bathing and during other tap water-related activities to prevent
accidental ingestion of water.
Vulnerable populations, as listed above, who drink water containing [cyanotoxin name] at levels
exceeding the national drinking water Health Advisories are at risk of various adverse health
Template Cyanotoxin Management Plan - Appendix C
T.29
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effects including upset stomach, vomiting and diarrhea as well as liver and kidney damage. Seek
medical attention if you or family members are experiencing illness.
Animals may be vulnerable to adverse health effects of [cyanotoxin name] at the detected levels
indicated above; consider providing animals alternative sources of water. Contact a veterinarian
if animals show signs of illness.
If you, your family members, or your animals have experienced adverse cyanotoxin-related
health effects, please contact [State or local Health Department] to report the illness.
What is being done?
[System name] is working closely with local and state public health and emergency response
agencies to address the situation and quickly reduce [cyanotoxin name] levels in tap water.
[System name] will post an updated advisory when: the [cyanotoxin] levels are less than or
equal to the national drinking water Health Advisories, this Do Not Drink Advisory is lifted
and/or if there are any changes to the conditions of this Do Not Drink Advisory.
For more information please contact [contact information] or visit [website].
Please share this information with all the other people who drink this water; especially those who may not have
received this notice directly (for example, people in apartments, nursing homes, schools and businesses). You can do
this by posting this notice in a public place or distributing copies by hand.
This notice is being sent to you by [system]. State Water System ID#: Date distributed:
Template Cyanotoxin Management Plan - Appendix C
T.30
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DRINKING WATER ADVISORY LIFTED
for [WATER SYSTEM NAME]
Everyone May Drink the Tap Water
[Date issued]
Why is the advisory lifted?
Drinking water advisory issued on [date] for [System name] that supplies water to [geographic
area: cities, counties, distribution system segments, etc.] has been lifted.
Samples collected on [dates] shows [cyanotoxin name] in the drinking water at [levels and/or
ranges], which are [less than or equal to] the U.S. Environmental Protection Agency's
[cyanotoxin name] national drinking water Health Advisory of [level],
[System name] took the following actions to reduce [cyanotoxin name] levels: [list actions such
as adjusting treatment, changing source, etc.].
What should I do?
Everyone may resume using the tap water for all uses.
[Insert any suggested activities for customers when resuming consumption of their tap water],
[Insert any actions taken by public water supply to reduce risks of cyanotoxins in drinking water
in the future].
Please share this information with all the other people who drink this water; especially those who may not have
received this notice directly (for example, people in apartments, nursing homes, schools and businesses). You can do
this by posting this notice in a public place or distributing copies by hand.
This notice is being sent to you by [system]. State Water System ID#: Date distributed:
Template Cyanotoxin Management Plan - Appendix C
T.31
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Cyanotoxins Management Plan
Highlands Mutual Water Company
Clearlake, California
November, 2016
Ell
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Table of Contents
Executive Summary E1.4
Highlands Mutual Water Company Overview El.5
Source Water El.5
Treatment Process El.5
Routine Water Quality Monitoring El.6
Cyanotoxin Management Plan El.6
Step 1: Assess Source Water El.9
1.1 Identify Source Water Protection Areas El.9
1.2 Create an Inventory of HABs Risk Factors El.11
1.2.1 Source Water Characteristics El.11
Land Use El.12
1.2.2 Water Quality Parameters El.13
Historical Cyanobacteria and Cyanotoxin Events in Source Water El.13
Presence of Toxic Cyanobacteria in Clear Lake El.13
Presence of Cyanotoxins in Clear Lake El.14
Nutrients El.15
1.2.3 Point Sources of Pollution El.15
1.2.4 Nonpoint Sources of Pollution El.16
1.2.5 Climate and Weather El.17
1.3 Assess Vulnerability El.18
Step 2: Preparation, Monitoring for Early Warning Signs and Immediate Actions El.19
2.1 Preparation El.19
Prepare Staff and Equipment for Monitoring El.19
Prepare for Treatment Adjustments El.19
Communications El.20
Establish Communication Plan with other Source Water Users El.20
Communication with Stakeholders El.20
2.2 Monitoring the Early Warning Signs El.21
Early Indicators of a Cyanobacterial Bloom El.21
2.3 Immediate Actions if a Bloom is Suspected El.22
Monitoring Actions in Response to Early Warning Signs El.22
Communication Actions in Response to Early Warning Signs El.22
Source Water Mitigation Actions in Response to Early Warning Signs El.22
Step 3: Raw Water Cyanotoxin Monitoring and Treatment Adjustments El.23
Monitoring if Cyanobacteria are Identified or Suspected El.23
Operational Adjustments Based on Raw Water Cyanotoxin Measurements El.23
Communications Based on Raw Water Cyanotoxin Measurements El.24
Step 4: Finished Water Cyanotoxin Monitoring and Treatment Adjustments El.25
E1.2
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Finished Water Microcystins Monitoring El.25
Treatment El.26
Communications El.26
Step 5: Continued Finished Water Cyanotoxin Monitoring, Treatment Adjustments and Public
Communication El.27
Continued Finished Water Microcystins Monitoring El.27
Treatment El.27
Communications El.28
Long-Term Activities El.29
Treatment Activities El.29
Monitoring Activities El.29
Source Water Protection Management Approaches El.29
References El.31
Appendices
Appendix A Cyanotoxin Management Flowchart El.32
Appendix B Contacts and Stakeholder Information El.33
Appendix C Notifying the Public of Cyanotoxins in their Water El.34
E1.3
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Executive Summary
Highlands Mutual Water Company, with the support of the State of California and the United States
Environmental Protection Agency (USEPA), has developed this Cyanotoxins Management Plan (CMP) to
prepare for and mitigate risks from harmful algal blooms (HABs) and cyanotoxins occurring in Clear Lake
in order to protect public drinking water from cyanotoxin contamination. This document provides steps
and documents activities to prepare for and identify a potential HAB occurrence, make treatment and
operational adjustments to remove cyanotoxins from drinking water, provide timely information and (as
appropriate) an advisory to the water system's customers and document information about occurrences
of HABs so that information can be used to minimize the effect of HABs on the water system in the
future. This plan also contains possible future activities the utility could engage in to mitigate the risks
from HABs and cyanotoxins, such as long-term source water protection activities.
The steps and activities outlined in this CMP include:
Step 1: Assess Source Water
Step 2: Preparation, Monitoring for Early Warning Signs and Immediate Actions
Step 3: Raw Water Cyanotoxin Monitoring and Treatment Adjustments
Step 4: Finished Water Cyanotoxin Monitoring and Treatment Adjustments
Step 5: Continued Finished Water Cyanotoxin Monitoring, Treatment Adjustments and Public
Communication
In addition to the five steps above, long-term activities are also discussed to enhance the utility's ability
to prevent, mitigate and manage the risks from cyanotoxin occurrence in source and finished waters.
Highlands Mutual Water Company Cyanotoxin Management Plan - Executive Summary
E1.4
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Highlands Mutual Water Company Overview
The Highlands Mutual Water Company is located on the shores of Clear Lake, California and serves 6,169
people through approximately 2,300 service connections. Water is pumped from Clear Lake and treated
using powdered activated carbon (PAC), permanganate, ozone, conventional filtration, granular
activated carbon (GAC) filtration and chlorine. A description of the water system's treatment process is
provided below, as well as a schematic of the treatment system. Besides concerns related to HABs, the
water system contends with taste and odor problems stemming from geosmin and MIB production by
some HABs. The water system is also challenged by Disinfection Byproducts (DBPs) formed when the
organically-rich water from the lake is chlorinated.
Source Water
The only source of water is Clear Lake. The water system draws water from the lake with two vertical
turbine pumps, one on line and one on standby. Each pump can produce 2,000 gallons per minute. The
pumps can be lowered with a limited adjustment of one to three feet. Limitations with the source are
primarily related to water quality, with silts up to 200 nephelometric turbidity units (NTU) in the winter
and large algal blooms in late spring and summer. Both of these problems can cause a large percentage
of in-service time loss on the dual media filters and GAC filters, as well as adversely affect water quality.
Treatment Process
Highlands Mutual Water Company provides the following treatment on the water from Clear Lake
(Figure 1 displays a diagram of the treatment train):
Lake Water Pumps: Raw water is drawn from Clear Lake and pumped by one of two large
vertical turbine pumps located on Beakbane Island to the Hillcrest Avenue Treatment Plant for
processing. The water system can produce 2.5 million gallons per day through the treatment
plant. During the summer months PAC is added just after the raw water pumps for both taste
and odor as well as cyanotoxin control.
Ozone Gas Treatment and Potassium Permanganate Addition: The primary use of ozone gas is to
help control taste and odor problems in the lake water that occur during the warm summer
months. Operators are concerned about cell lysis and typically restrict operations to minimize
floating material. There is discussion of making post-ozone available between the dual media
filters and the GAC filters to minimize cell lysis. Ozone is not used in storage or distribution
systems as it does not hold an adequate residual.
Clarification: Water flows through each ozone contact chamber into parallel upflow clarifiers for
the next stage of treatment, with aluminum chloro-hydrate (ACH) added as a coagulant before
the water enters the clarifiers. The two clarifiers settle out about 90 percent of the turbidity
from the water. Sludge accumulates on the weekends and is a potential source of cyanotoxins.
The operators are working on automating the screw press to run during the weekends to
process the sludge continually.
Dual Media Filters: Water is taken from the top of each clarifier and pumped through dual
media filters consisting of anthracite coal and filter sand. The two dual media filters are
operated in parallel, with one filter per clarifier.
GAC Filters: Water from the dual media filters flows into two sets of two GAC filters that are
operated in series. Their main function is further removal and control of taste and odor
compounds and total organic carbon (TOC). The first set of GAC filters contains GAC made from
Highlands Mutual Water Company Cyanotoxin Management Plan - Overview
E1.5
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coconut shells, the second set contains GAC made from lignite. The filter media is changed every
three to five years.
Chlorine Disinfection: The final stage of the water treatment process involves the injection of
chlorine for disinfection. Sodium hypochlorite is injected before water enters the clearwell, in
order for adequate disinfection CT to be achieved. The pH of water can vary from 7.7 to 9.7
depending on the size of the algal bloom and type of algae (or cyanobacteria) in the lake. The
water system does not have a disinfection profile or benchmark. The plant is considered
equivalent to conventional treatment and is credited with 2.5 log reduction of Giardia lamblia
cysts. Therefore, the plant is required to achieve 0.5 log inactivation of Giardia lamblia cysts
through disinfection. The plant typically operates to achieve a detectable residual in the
distribution system between 1.6 and 1.8 mg/L chlorine residual at the entrance to the
distribution system.
The water system recycles its backwash water within a month, not to exceed 10% of instantaneous
production with a target of 2 NTU and filters water to waste before putting its filters back on line after a
backwash. The water system pre-chlorinates only for operational reasons. Pre-chlorination is not
necessary in order for the water system to achieve its required disinfection CT. When filter problems
start occurring due to algae and cyanobacteria in the raw water, the water system begins to pre-
chlorinate because adding chlorine seems to help with filter performance. However, pre-chlorination
may cause cell lysing and needs to be used with caution. Most of the time, however, the water system
does not pre-chlorinate in order to prevent total trihalomethanes and haloacetic acid formation in the
clarifiers.
Routine Water Quality Monitoring
Raw water is monitored by the water system for alkalinity, TOC, pH and turbidity at the raw water pump
discharge. Some samples are sent to a certified lab and the results are returned within 7 to 10 working
days. Turbidity and pH results that are measured in the plant are available immediately. A scientist from
the Elem Colony Tribe tests the lake water for microcystins biweekly using ELISA (Enzyme-Linked
Immunosorbent Assay) method in the lab. Beginning in the summer of 2016, the water system will use
test strips during alternate weeks to ensure that source water microcystins analysis takes place on a
weekly basis throughout the bloom season (May through October).
Table 1. Raw Water Monitoring
Parameter
Location
Frequency
Who Collects
Sample?
Who Does
Analysis?
Alkalinity
Raw Water Pump
Discharge
Monthly
Highlands MWC
Lab
TOC
Monthly
Operator
Lab
PH
Pre-Ozone Tower
Daily
Operator
Plant
Turbidity
Pre-Ozone Tower
15-min
SCADA
Plant
Microcystins
Raw Water Pump
Discharge
Bi-Weekly
Operator
Test Strip
Microcystins
Clear Lake
Bi-Weekly
Elem Colony Tribe
Lab
Cyanotoxin Management Plan
Highlands Mutual Water Company and the State of California, with the support of the United States
Environmental Protection Agency has developed a Cyanotoxins Management Plan (CMP) detailed in the
Highlands Mutual Water Company Cyanotoxin Management Plan - Overview
E1.6
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steps below. This CMP provides an action plan to prepare for and mitigate risks from harmful algal
blooms (HABs) and cyanotoxins occurring in Clear Lake in order to protect public drinking water from
cyanotoxin contamination. The plan includes immediate steps discussing monitoring and treatment
should HABs and cyanotoxins occur as well as long-term steps the system can engage in to protect
source waters and to fully evaluate treatment capabilities. A detailed flowchart of the CMP can be found
in Appendix A.
Highlands Mutual Water Company Cyanotoxin Management Plan - Overview
E1.7
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Figure 1. Schematic Diagram of the Treatment System
Ozone Tower
Intake \
at Clear i-
, Lake J
Ozone
Acid Injection
(optional)
ProPAC 9890
(optional filter aid)
PAC
Potassium
Permanganate
Pre-chlorination ACH
(optional)
Dual Media
Filters
Dual Media
Filters
GAC Filter b
| GAC Filter |-
L J
(Coconut
shell)
GAC
\ J
1
GAC
NaOCI
I Infinw riarifipr
Mixer
-~ Clearwell
Distribution
System
- Zinc Ortho-P04
(Lignite)
Highlands Mutual Water Company Cyanotoxin Management Plan - Overview
E1.8
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Step 1: Assess Source Water
1.1 Identify Source Water Protection Areas
A source water assessment is an evaluation of a drinking water source to determine the susceptibility to
contamination. The first step of any source water assessment is to delineate (map) the areas of water
and land that drain into the water supply that are to be evaluated for contaminant sources. This is called
the Source Water Protection Area (State Water Resources Control Board, 1990).
Highlands Mutual Water Company delineated its Clear Lake Source Water Protection Area using the
following methods and resources:
1. 2012 Clear Lake Watershed Sanitary Survey: The water provider referenced the techniques and
survey areas described within the 2012 Clear Lake Watershed Sanitary Survey, a report
completed by Clear Lake drinking water utilities which summarizes the state of the Clear Lake
watershed and the effect of watershed activities on source water quality. The 2012 Sanitary
Survey area encompasses the Clear Lake watershed area that drains to Clear Lake and Cache
Creek upstream of the Cache Creek Dam. This coincides with the US Geological Survey (USGS)
National Hydrography Dataset HUC10 watershed (determined using the USGS National Map).
The Survey delineates "Protection Zones" within the survey area based on radial distance
around each water system intake. Higher priority Protection Zones represent area in 2,500-foot
proximity to a specific intake (Forsgren Associates, Inc., 2012).
2. Clear Lake Integrated Watershed Management Plan: Highlands also reviewed the Clear Lake
Integrated Watershed Management Plan, which was produced for the County of Clear Lake in
2013. The project boundary for this management plan encompasses the HUC10 watershed area,
which corresponds with the survey area of the 2012 Sanitary Survey (Lake County, 2010).
3. Drinking Water Mapping Application to Protect Source Waters (DWMAPS): DWMAPS is an
online mapping tool for assessing source waters and source water protection planning. The
"Find Potential Sources of Contamination" toolbar in DWMAPS maps catchment areas upstream
of an intake, and displays point sources of contamination located within the catchment areas.
DWMAPS was used to search a fixed distance of 10 miles upstream of its intake (distance coincides with
length of Lower Arm). However, given the size of the Clear Lake watershed, the water system used a
two-tiered system for delineating its source water protection area: the Clear Lake watershed (defined as
the HUC10 watershed area) is a source water protection area (Tier 1see Map 1 below), but the zone of
higher concern is the area immediately upstream (15 miles) of the intake (Tier IIdelineated by
DWMAPS, see Map 2 below). The purpose of these zones is to define portions of the watershed where
activities have a higher risk of contaminating the source water and where waterbody and watershed
conditions should be more closely evaluated. The water system can focus a thorough evaluation within
Tier II, the zone of higher concern. This tiered approach is consistent with the methods utilized in the
2012 Sanitary Survey and described in the Drinking Water Source Assessment and Protection Program
document from the California State Water Resources Control Board Division of Drinking Water (formerly
the California Department of Public Health Drinking Water Program).
Highlands Mutual Water Company Cyanotoxin Management Plan - Step 1
E1.9
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na ฅ
Rodman Slough V X
1 , >U U
Gilbert CซeW |
Upper Arm
Clear Lake
Mercury Mne
Lower.
iek Dam
Legend
~fc Stream Gages
Streams
Lakes
Map 1. Tier I Source Water Protection Area: USGS HUC10 watershed 1802011603. Map
extracted from Clear Lake Integrated Watershed Management Plan:
http://www.co.lake.ca.us/Assets/WaterResources/Clear+Lake+lntearated+Watershed+Mana
aement+Plan/ll+Plate+4+Clear+Lake+Watershed+Surface+Water+Resources.pdf)
Highlands Mutual Water Company Cyanotoxin Management Plan - Step 1
El. 10
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Ni cซ
Catchments
NPDES Refuse Facilities
NPDES Sewerage Facilities
Wj *ฃ&**
NPDES Other Facilities
RCRA Facilities
/- ^ " _j CI earl .ike
Jp.aks-
CERCLA (Superfund)
Facilities
TRI Facilities
ig Valley
TSCA Facilities
Combined Sewer Overflows
(CSO)
Map 2. Tier II Source Water Protection Area: Catchments 10 miles upstream of intake in Clear
Lake, CA (Source; DWMAPS)
1.2 Create an Inventory of HABs Risk Factors
Clear Lake experiences a variety of HABs risk factors described in detail below and summarized in a table
following the discussion (Table 4). Risk factors can include source water characteristics, water quality
parameters, point source pollution, nonpoint source pollution and climate and weather characteristics.
1.2.1 Source Water Characteristics
Clear Lake is the only source of water for Highlands Mutual Water Company. Clear Lake is located in the
Coast Range of California, 80 miles north of San Francisco (38.95ฐN, 122.63ฐW), and is the largest natural
lake entirely within California. The lake is 18 miles long, has 68 square miles (43,790 acres) of surface
area, 100 miles of shoreline, and an average depth of 26 feet. Clear Lake is a shallow, warm, nutrient-
rich system with three distinct arms: Upper Arm (28,000 acres), Oaks Arm (2,800 acres) and Lower Arm
(8,200 acres). The lake is comparatively shallow with an average depth of 23.3 feet in the Upper Arm,
36.4 feet in the Oaks Arm, and 33.8 feet in the Lower Arm. The westerly winds push surface water from
the Upper Arm into the Oaks Arm and Lower Arm, setting up a return flow of bottom water (Lake
County, 2010; Richerson et a!., 1994).
Clear Lake's water level has been manipulated by operation of the Cache Creek Dam since 1914. The
Yolo County Flood Control and Water Conservation District must regulate the depth of the lake
(determined by the Rumsey gauge) between 0-7.56 feet, under non-flood conditions and 0-9.00 feet
under flood conditions. Clear Lake can drop from 3 - 6.5 feet in any given summer and fluctuates 5.5 feet
each year on average (Lake County, 2010).
Highlands Mutual Water Company Cyanotoxin Management Plan - Step 1
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The lake is generally well-mixed with stable temperature stratification between surface and deeper
waters only occurring for short periods during the hot summer periods when wind patterns are calm
(Winder et al. 2010); maximum surface water temperatures in July and August are typically near 75ฐF
(24ฐC) and average 40 ฐF (4.5ฐC) in the winter months (Richerson et al., 1994; Lake County, 2010).
Prevailing winds and the lake's modest depth facilitate vertical mixing. Numerous gas vents and
subsurface springs help induce mixing in the lake as well (Lake County, 2010). Residence time of the lake
(the time it would take to empty at the average annual outflow) is about 4.5 years, which is relatively
short (Richerson et al., 1994).
Land Use
Some land uses, including urban and agricultural uses, have been associated with sources of nutrients
(nitrogen and phosphorus) that can contribute to higher occurrences of HABs and cyanotoxins. The
water provider referred to the 2012 Sanitary Survey, the Clear Lake Integrated Watershed Management
Plan, the Total Maximum Daily Load (TMDL) for Nutrients in Clear Lake, and DWMAPS to gather
information on land cover and land use for the Clear Lake watershed.
The Clear Lake watershed (HUC10) includes an area of approximately 450 square miles (282,138 acres)
(USGS National Map Viewer). Much of the watershed consists of undeveloped lands. This includes the
Bureau of Land Management Cow Management Recreation Area and the U.S. Forest Service Mendocino
National Forest. Together, public lands make up 24% of the Clear Lake watershed (Lake County, 2010).
Irrigated and non-irrigated agriculture account for the largest use of developed lands (Forsgren
Associates, Inc., 2012). Agricultural and urban land uses in the Clear Lake watershed are primarily
located in the lowland areas adjacent to the lake. The largest municipality is the town of Clearlake
(population 13,100), which is located at the end of the Lower Arm. Urban areas cover less than 2.5% of
the total watershed land area (Sanitary Survey, 2012). Table 2 below describes land use in Clear Lake's
watershed (Tetra Tech, 2004).
Highlands Mutual Water Company Cyanotoxin Management Plan - Step 1
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Table 2. Land Use in Clear Lake's Watershed
Land Use Category
Total Land Area
Percent Total
(Acres)
Bare rock/sand/clay
966
0.34
Deciduous forest
110,029
39.00
Deciduous shrub land
48, 390
17.15
Emergent herbaceous wetlands
90
0.03
Grassland/herbaceous
65,824
23.33
High intensity commercial/industrial/transportation
646
0.23
High intensity residential
2
<0.01
Low intensity residential
4,794
1.70
Mixed forest
23,053
8.17
Open Water (not including Clear Lake)
1,491
0.53
Other grasses (urban, recreational)
141
0.05
Pasture/hay
9, 683
3.43
Planted/cultivated (orchards, vineyards, groves)
16, 583
5.86
Quarries/strip mines/gravel pits
58
0.02
Row crops
6
<0.01
Small grains
1
<0.01
Transitional
429
0.15
Woody wetlands
1
<0.01
Source: Total Maximum Daily Load (TMDL) for Nutrients in Clear Lake, Tetra Tech, 2004
1.2.2 Water Quality Parameters
Historical Cyanobacteria and Cyanotoxin Events in Source Water
The next step in assessing source water vulnerability to HABs and cyanotoxins is to review source water
quality parameters, notably past occurrence of cyanobacteria and cyanotoxin events within the source
water protection area. Historical occurrence of HABs, cyanobacterial cell occurrence and cyanotoxins in
a source water protection area is a good indication that a surface water system is vulnerable to future
occurrences of HABs, and may provide evidence of the potential timing, location and intensity of these
blooms.
Presence of Toxic Cyanobacteria in Clear Lake
Clear Lake is a productive lake where the presence of suspended algae and aquatic vegetation occurs
naturally. Several major research efforts, the Clear Lake Algal Research Unit (1970-1990), the Clean
Lakes Report (1994), and the Central Valley Regional Water Quality Control Board reports (2011, 2012)
indicate recurrent seasonal blooms of toxic species of blue-green algae (cyanobacteria) in Clear Lake.
These blooms form noxious, scum-forming mats that can cause considerable degradation of the
lakeshore and surface environment of Clear Lake (Forsgren Associates, Inc., 2012). The magnitude and
composition of the blooms varies substantially from year to year (Richerson et al., 1994). Algae
problems are most serious at the eastern end of the Lake where prevailing winds can push floating algae
into huge rotting mats that produce strong odors. Blooms typically occur in Clear Lake from April to
November.
The research indicates that Clear Lake has been seriously impaired by seasonal blooms of scum-forming
cyanobacteria for much of the past century, but that blooms became more of a problem in the second
half of the 20th century (1970-1990) (Richerson et al., 1994) (Mioni and Kudela, 2011). During this
Highlands Mutual Water Company Cyanotoxin Management Plan - Step 1
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period, researchers found that several genera of cyanobacteria dominated the scum forming algae in
Clear Lake: Anabaena, Aphanizomenon and Microcystis. Microcystis blooms were documented in both
the Oaks Arm and Lower Arm, with the largest blooms occurring in the Lower Arm in 1991.
Aphanizomenon showed similar trends and was the dominant scum former up to 1985, when it
suddenly became much less abundant. Anabaena was never responsible for blooms on the scale of
Microcystis and Aphanizomenon in any arm but was a common component of the midsummer scums
throughout the record (Mioni and Kudela, 2011). Microcystis and Anabaena were noted to occur from
late summer to early fall. Aphanizomenon were noted to reach a peak in late spring and early summer,
and late fall, but have also been observed blooming in winter months (Lake County, 2010). Lyngbya was
not observed until 1984 and the first large bloom event dominated by this mat-forming filamentous
cyanobacteria was not observed until 2009 (Mioni and Kudela, 2011).
The Clear Lake Nutrient Total Maximum Daily Load Update (2012) notes that blooms occurred with less
frequency from the early 1990s until 2004, but that massive algal blooms and nuisance conditions were
present in several years since 2004, most notably in the summer and fall months of 2009, 2010 and 2011
(Central Valley Regional Water Quality Control Board, 2012).
Research in 2010 and 2011 by University of California - Santa Cruz researcher Dr. Cecile Mioni for the
Central Valley Regional Water Quality Control Board identified presence of Mycrocystis aeruginosa,
Aphanizomenon flos-aquae, Anabaena temmermanii, Synechococcus, all of which are capable of
producing cyanotoxins. Aphanizomenon was noted to have occurred primarily in early summer,
Mycrosystis in early and late summer, Anabaena throughout the summer and Lyngbya throughout the
summer. Within the Lower Arm, Lyngbya Cincinnati and Anabaena spiroides were the two dominant
cyanobacterial species (Mioni et al., 2012).
The Big Valley Rancheria Band of Pomo Indians and the Elem Indian Colony have collaborated since fall
2014 to monitor cyanobacteria and cyanotoxin occurrence in Clear Lake. The Elem Indian Colony is
monitoring drinking water sources in the Lower Arm for six of the seventeen surface water treatment
plants around the lake.
The State of California Water Quality Monitoring Council maintains a webmap which displays locations
of HAB incidents that have been voluntary reported including a bloom reported in June 2016.
Presence of Cyanotoxins in Clear Lake
Fish kills and neurological disorders in eight domestic cats were reported in the Clear Lake area in 1989
following an exceptionally dense cyanobacterial bloom (Microcystis, Anabaena and Aphanizomenon)
(Mioni and Kudela, 2011). These events prompted a special toxicological and epidemiological studies
program by the California Department of Health Services (called the California Department of Public
Health after 2007). Microcystin toxins were the only toxins examined and were detected over the course
of this special study (Mioni and Kudela, 2011). Although recurrent cyanobacterial blooms have plagued
Clear Lake for the past century, this is the only toxicology survey available prior to the 2010 and 2011
research by University of California - Santa Cruz under Cecile Mioni and Rapheal Kudela. This 2010 study
found low levels of microcystins, below the recreational advisory limit of 8 ng/L for the State of
California, however in several samples the microcystins concentrations exceeded the WHO advisory
limit for drinking water (1 ng/L) and USEPA's Health Advisory levels for total microcystins in drinking
water. Anatoxin-a was detected in two of the samples collected in the lower arm in August 2010. At
both collection sites, anatoxin-a was well below the suggested action levels for recreational use (50
Highlands Mutual Water Company Cyanotoxin Management Plan - Step 1
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Hg/L). Saxitoxins were below the detection limit or not present in the lake surface water (using Abraxis
ELISA kits only) (Mioni and Kudela, 2011).
Nutrients
Clear Lake has been assessed for attainment of surface water quality standards under Section 305(b) of
the Clean Water Act (CWA). Based on this assessment, Clear Lake was listed as an impaired waterbody
due to nutrients (phosphorus and nitrogen) under Section 303(d) of the CWA. A nutrient TMDL was
developed by the Central Valley Regional Water Quality Control Board in 2006 in response to the
impairment listing. The TMDL defines targets for nutrient loading to Clear Lake and outlines strategies
for reducing nutrient loading, specifically of phosphorous, derived from sediment erosion, which will
ultimately reduce algal growth (Central Valley Regional Water Quality Control Board, 2012).
The TMDL notes that there may be other factors, in addition to nutrients, affecting cyanobacterial
blooms, including concentrations of sulfate, iron availability and ecological dynamics.
For additional information on Clear Lake water quality (such as nutrient concentrations, temperature,
iron, turbidity, chlorophyll-o, phycocyanin) and other factors controlling algal blooms, see the Clear Lake
historical Data Analysis. Clear Lake Report; Central Valley Water Quality Control Board, Control of
Nutrients in Clear Lake report; Harmful cyanobacteria blooms and their toxins in Clear Lake and the
Sacramento-San Joaquin Delta (California) report; Causes and Control of Algal Blooms in Clear Lake; and
the Clear Lake Integrated Watershed Management Plan. For additional water quality information, see
the CA State Water Resources Control Board website.
1.2.3 Point Sources of Pollution
The water system created an inventory of possible precursors to HABs within its source water protection
area using the USEPA DWMAPS tool (Map 1). Phosphorus and nitrogen are drivers of algal and
cyanobacterial growth in lakes and reservoirs. Sources of phosphorus and nitrogen can include discharge
of domestic and industrial wastewater, septic systems and runoff from agricultural and urban lands.
A query of the USEPA DWMAPS tool as well as the USEPA Discharge Monitoring Report for nitrogen and
phosphorus loading indicates that there are no National Pollutant Discharge Elimination System (NPDES)
permitted wastewater dischargers or Combined Sewer Overflows within 10 miles upstream of Clear
Lake. However, the Clear Lake TMDL set specific phosphorous load limits for several point source
dischargers within the Clear Lake watershed. Point source dischargers, Lake County Storm Water
Permittees (Lake County, Cities of Clearlake and Lakeport), and the California Department of
Transportation (Caltrans), were given a waste load allocation of 2,000 kg and 100 kg per year,
respectively. This is a small portion of the combined total point and nonpoint source phosphorous load
allocation of 87,100 kg per year. Caltrans maintains a statewide Stormwater Program, which identifies
how Caltrans will comply with the provisions of its NPDES permit and its Municipal Separate Storm
Sewer System permit (MS4) (California State Water Resources Control Board, 2012). Table 3 below
describes Clear Lake annual phosphorus loading.
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Table 3. Clear Lake Annual Phosphorus Loading
Source
Source Type
Load Allocation
(kg/yr)
Lake County Stormwater Permittees
Waste Load (point
source)
2,000
California Department of Transportation (Caltrans)
Waste Load (point
source)
100
United States Forest Service, Bureau of Land Management,
Lake County, irrigated agricultural dischargers
Load (nonpoints
source)
85,000
Total
87,100
Source: Clear Lake Nutrient Total Maximum Daily Load Control Program update, Central Valley Regional
Water Quality Control Board, 2012.
1.2.4 Nonpoint Sources of Pollution
As mentioned previously, The Clean Lakes Report (1994), the Clear Lake Algal Research Unit (1970-
1990), and the State Water Resources Control Board report (2011, 2012) indicate that that excess
phosphorus is a primary driver of nuisance cyanobacterial blooms in Clear Lake. The 2006 amendment
to the TMDL for Nutrients in Clear Lake (2006) notes that most sources of phosphorus to Clear Lake are
sediment driven, and that the following activities are the most likely sources of excess phosphorus to
Clear Lake (Central Valley Regional Water Quality Control Board, 2006):
Erosion from paved and unpaved roads
Urban stormwater runoff
Instream channel erosion (accelerated by removal of riparian vegetation)
Construction
Gravel Mining
Wildfires and controlled burns
Timber harvesting
Livestock grazing
Dredging and filling
Failing septic systems
The Clear Lake TMDL allocates 85,000 kg per year (of a total 87,100 kg per year) of phosphorousa 40%
reduction in average annual phosphorous loading by 2017- to nonpoint source dischargers, which
include the Bureau of Land Management, the United States Department of Agriculture's Forest Service,
irrigated agricultural dischargers and Lake County. While agriculture is one of the major land use and
economic activities in the Clear Lake watershed, phosphorous fertilizer is applied at such low rates that
it is unlikely to be a significant phosphorous source to Clear Lake (Lake County, 2010). However, past
agricultural development and associated wetland reclamation projects (total loss of approximately 79%
of wetland area) removed much of the lake's natural filtration system for removing eroded sediments
from the upper watershed and contributed to streambank channelization and erosion above natural
levels. Road development and modifications (1,500 miles of unpaved road in Clear Lake watershed) is
also considered a significant source of fine sediments and phosphorous (Lake County, 2010).
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A summary of phosphorous reducing activities by TMDL regulated entities can be found at the California
Central Valley Regional Water Quality Control Board website.
1.2.5 Climate and Weather
Clear Lake is located within Lake County, CA, which is typified by warm, dry summers and moist, cool
winters. Clear Lake is prone to periodic drought, at times severe. Recent notable droughts occurred from
1976-1977 and 1986-1992 (Lake County, 2010). During winter months (December-February), average
high temperatures are in the 50s (Fahrenheit) and average lows are in the 30s (Fahrenheit) (Lake
County, 2010). Temperatures below freezing can occur throughout the watershed, although they are
less common adjacent to Clear Lake. Summer average high temperatures at lake level are in the low 90s
(Fahrenheit), but can reach over 100ฐF. On most nights during the summer, there is significant cooling
(by 30-40ฐF) (Lake County, 2010).
Most precipitation in the Clear Lake watershed occurs as rainfall with minor amounts of snow at the
highest elevations. Prevailing winds blow from the west and northwest during most of the year and
bring winter Pacific storms to the watershed during the rainy season (September-May). Average annual
precipitation at lake level is about 30 inches, with most precipitation occurring between December and
March (Lake County, 2010). In wet years, or during strong storm events, stream-flows tend to be
extremely "flashy"; that is, they are subject to very rapid rises and fluctuation in flow (Forsgren
Associates, Inc., 2012).
Table 4. Summary of Clear Lake HABs Risk Factors
HABS Risk Factor
Measure
Data Source
Source Water Characteristics
Source Water Type
Lake/Reservoir
USGS NHDPIus
High
Mean Surface Water
Lower Arm ~ 75ฐF (24ฐC) (July-August)
CA Department of Water
High
Temperature (F)
Resources
Water Body Depth (ft)
Lower Arm Mean: 33.8 ft
Clear Lake Report (2010)
High
Vertical Stratification
Well-mixed; few occurrences of
Lake County
Low
sustained stratification
Residence Time
4.5 years, relatively short
Richerson et al., 1994
Low
Water Quality Parameters
Cyanobacteria
Microcystis, Anabaena,
Home, 1975; Richerson et al.,
High
Occurrence
Aphanizomenon, Lyngbya
1994; Mioni and Kudela,
2011
Cyanotoxin Levels (n/L)
Lower Arm: .52 anatoxin-a (2010)
Mioni and Kudela, 2011
High
Nutrient Enrichment:
Impaired, Nutrients (1986); Nutrient
Clear Lake Nutrient TMDL
Medium
CWA 303(d) Impairment
TMDL (2006)
(2006)
Status
Point Sources
Point Sources of
Lake County Stormwater Permittees;
Clear Lake Nutrient TMDL
Low
Nutrients
California Department of
(2006)
Transportation (Caltrans): 2,100 kg
phosphorous TMDL discharge limit
Nonpoint Sources
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HABS Risk Factor
Measure
Data Source
Nonpoint sources of
nutrients
Bureau of Land Management, the
United States Department of
Agriculture's Forest Service, irrigated
agricultural dischargers, and Lake
County; 85,000 kg TMDL discharge
limit
Clear Lake Nutrient TMDL
(2006)
High
Climate and Weather Conditions
Ambient temp Fฐ, May-
September;
Drought Risk
Range: High Ave 92ฐ, Low Ave 45ฐ
National Oceanic and
Atmospheric Administration
(NOAA) National Weather
Service
U.S. Drought Monitor
High
Med
1.3 Assess Vulnerability
A weight of evidence approach was used to characterize the vulnerability of Clear Lake to occurrence of
cyanobacterial blooms and cyanotoxin occurrence. Evidence includes all of the discussion in this section
and results of the HAB risk factor inventory including: historical occurrence of cyanobacteria and
cyanotoxins, source water characteristics, external point and nonpoint sources of nutrients and other
known factors controlling algal productivity, Clear Lake water quality parameters and impairment status,
and climate and weather information. Clear Lake is vulnerable to occurrence of HABs, typically occurring
between April and November. Highlands Mutual Water Company intends to take additional steps
(moving to Step 2) to prepare for cyanobacterial blooms and cyanotoxin occurrence described in the
following steps.
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Step 2: Preparation, Monitoring for Early
Warning Signs and Immediate Actions
2.1 Preparation
Since Highlands Mutual Water Company determined that its source water is vulnerable to
cyanobacterial blooms, the next step is to consider how to prepare for blooms and cyanotoxin
occurrence. Preparation includes preparing to monitor raw and finished waters such as ordering
necessary laboratory equipment or establishing contracts with outside laboratories, preparing for
treatment adjustments and establishing communication plans including communication with other
water utilities with the same source water.
Prepare Staff and Equipment for Monitoring
The water system will carry out the following activities in order to be prepared for the monitoring steps
described in this plan:
1. Train operators on algae and cyanobacteria identification, counting and identification of gas
vacuoles.
2. Train operators on how to use microcystins test strips.
Establish sampling procedures
Establish testing procedures
Establish quality assurance procedures
Document all sampling, testing and quality assurance procedures
3. Enter into an agreement with a laboratory that can reliably and promptly analyze samples using
the Adda-specific ELISA test.
4. Establish a procedure for submitting Adda-specific ELISA samples to the identified laboratory.
Document all sampling, testing and quality assurance procedures for lab samples
Have coolers, chain of custody forms and shipping labels on site and ready for use
Ensure that the appropriate bottles (glass or polyethylene terephthalate glycol, minimum
100 mL volume) are on site for the Adda-specific ELISA sampling in the event that such
sampling is required
Also have sodium thiosulfate available for quenching disinfected samples as soon as they
are collected
Prepare for Treatment Adjustments
Highlands Mutual Water Company will carry out the following activities in order to be more prepared to
treat its source water during a HAB:
1. Ensure all required materials for cyanotoxin treatment are available.
2. Consider either:
Moving the ozone application point from before the upflow clarifier to after the mixed
media filters (but before the GAC) to reduce the risk of toxin release, or
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Introducing the option of two ozone injection points: the existing one before the clarifier
and a new one between the media filters and the GAC.
3. Begin tracking chlorine CT daily using a spreadsheet or computer program. This will allow the
water system to know how much chlorine CT is in place when different microcystins
concentrations are measured in the raw water (and how much microcystins protection is being
provided through chlorination).
4. Begin testing for ammonia in the raw water, upflow clarifier effluent (before 2nd chlorine
injection point), and before the clear well (before the 3rd chlorine injection point).
5. Measure free and total chlorine to see if the free chlorine is at least 80 percent of the total
chlorine; if not, the water system may be making chloramines. While this is not directly a
cyanotoxins concern, it may be related to the presence of cyanobacterial activity in the
treatment plant (e.g., the upflow clarifier).
6. Evaluate the toxin removal capacity of the current treatment process using jar tests spiked with
varying levels of toxins.
Communications
Establish Communication Plan with other Source Water Users
Several water utilities draw their water from the lake; a few also have wells. A large tributary enters the
lake at the northern end, and water systems located in this area often experience algal problems prior
to the water systems farther south. Highlands Mutual Water Company draws water from the
southeastern part of the lake. As a result, communication among the lake's various water system
operators provides an important warning of impending HABs. During the summer months, Highlands
Mutual Water Company operators are in constant communication with the other two water systems
with which they are interconnected. They share information related to chemical doses, physical
problems with the water, and how the water is reacting to sedimentation and filtration. The system's
operators are also in contact with water companies at the northern end of the lake to try to get early
warning of water quality problems they may soon face.
Communication with Stakeholders
The water system will carry out the following activities in order to be more prepared for the
communications steps described in this plan:
1. Develop a stakeholders list (Appendix B) and reevaluate on a recurring basis to maintain an up-
to-date list.
2. Add language to the water system's consumer confidence report asking home and clinic dialysis
customers to contact the water system so they can be added to the stakeholders list and
receive early warning about potential microcystins contamination of the finished water.
Explanations of when stakeholders will be contacted about a HAB are provided in Step 5 of this
plan.
3. Prepare a public health advisory template that is available and ready for use if necessary. Also
prepare another notice that would be issued to lift an existing public health advisory.
Explanations of when a public health advisory will be issued or lifted are provided in Step 5 of
this plan. (See Appendix C for draft template)
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4. Prepare and have available a "Frequently Asked Questions" outreach document for water
consumers and have copies available in the office where customers pay their bills and/or
include it with their bills. (See example in USEPA's Cyanotoxin Risk Communication Toolbox).
2.2 Monitoring the Early Warning Signs
Based on historical bloom occurrence in Clear Lake, Highlands Mutual Water Company begins looking
for signs of blooms in April. Signs of bloom occurrence include early indicators such as drinking water
treatment operational challenges. Identified in this section are early warning signs that operators can
look for during the system's normal operation, routine water quality monitoring, as well as follow-up
activities if any of the early warning signs are observed.
Early Indicators of a Cyanobacterial Bloom
The water system operators have identified several early warning signs that a cyanobacterial bloom is
likely to occur in the very near future (or has begun to occur). The following early warning signs are a
combination of observations of conditions in the lake itself and in the treatment plant:
Visual observations show cyanobacteria mats forming (depending on cyanobacteria or
algae type)
Algae rising to the surface or gathering on the tules (bulrushes) during daily visual
inspections of the lake at the intake from April through November
Algae buildup on equipment in the plant
Sludge coming off the screw press begins looking green
Raw water pH shows a strong, sharper daily swing, or raw water pH >9 (before PAC
addition)
Raw water pH swings from day to night
Raw water pH probe's sample cell has algal growth and an odor
Coagulant dose increases
Filter performance degrades
Backwashing of the carbon filters is needed twice as often
Strainers for the pump control plug with algae or cyanobacteria and cause operational
challenges
Individual filter effluent turbidity is slow to respond or stabilize at the beginning of a filter
run
Increased differential pressure across filter beds
Odor in the raw water and odor coming off the lake strengthens
Chlorine demand increases
Other water utilities call and report problems, especially the water utilities in the northern
part of the lake
Weekly routine raw water monitoring results show presence of cyanotoxins
In addition, the state will soon be providing the water system with an on-line fluorometer. While it has
not been installed yet, it is anticipated that fluorometric readings at the source will show increased
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chlorophyll-o or phycocyanin. Once the fluorometer has been installed and readings have been
observed, the water system will see if HAB levels of concern can be identified.
2.3 Immediate Actions if a Bloom is Suspected
Monitoring Actions in Response to Early Warning Signs
If there are any early indicators of a cyanobacterial bloom, the following actions will be immediately
taken:
1. Immediately collect a source water sample at the intake before PAC is added.
Ideally, collect samples that represent several depths or collect a composite sample that
represents the entire water column. The sample should be collected before PAC addition
because it will be inspected through the microscope and there should be no interference.
Identify the algae present in the sample using water company microscope:
Refer to the algae keys and any catalog of previous algae identified in Clear Lake.
Check with Elem Colony Tribe to confirm algae and/or cyanobacteria identifications and
utilize Greenwater Laboratories if still unable to identify.
2. If cyanobacteria are identified, also check whether gas vacuoles are present.
When gas vacuoles are present, the cyanobacteria are more difficult to remove in the upflow
clarifier.
3. Move to Step 3.
Communication Actions in Response to Early Warning Signs
Call neighboring water utilities to see if they are having problems and to let them know what Highlands
Mutual Water Company has found.
Source Water Mitigation Actions in Response to Early Warning Signs
Lake County treats Clear Lake with the aquatic herbicide Sonar for weed control two or three times per
year. No other in-lake mitigation measures are currently taken.
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Step 3: Raw Water Cyanotoxin Monitoring and
Treatment Adjustments
If a cyanobacterial bloom is identified during Step 2. the Highlands Mutual Water Company plans to
begin monitoring water quality in multiple locations, adjusting treatment and communicating with
utilities that are using the same source water.
Monitoring if Cyanobacteria are Identified or Suspected
Analyze samples for microcystins as soon as possible using test strips using the following steps:
1. Test a raw water sample as soon as possible for microcystins using a test strip. The sample
should be collected before PAC has been added. If the raw water sample collected has >0.3 ng/L
microcystins using the test strip go to #2(a) and 2(b).
2. (a) Use test strips to measure microcystins at both of the following locations:
Source water before PAC addition (again, 2nd sample)
Entry point to the distribution system (EPTDS)
AND
(b) Use test strips to sample at each of the following locations, following the flow of water until
microcystins are not detected:
After permanganate is added
After the clarifier
After the media filters
After the first set of GAC filters (the "new" GAC filters)
After the second set of GAC filters (the "old" GAC filters)
The mixture of sampling water and filter-to-waste water
3. Track weekly routine sampling results, discussed under routine water quality monitoring in the
overview, and follow # 2a-b if a weekly raw water sample has >0.3 ng/L microcystins
It is important to monitor the performance of individual unit processes across the treatment train to
help understand what is happening in the treatment train or identify possible treatment breakdown. If
either monitoring determined necessary by a suspected bloom or routine monitoring results indicate
the presence of cyanotoxins in the raw water, additional confirmation sampling (#2 above) will take
place before Highland Mutual Water Company continues to Step 4. Follow-up sampling will take place
within 24 hours after the first detection of cyanotoxins in the raw water collected. If the follow-up
sampling continues to show cyanotoxins in the raw water, Highlands Mutual Water Company continues
to Step 4.
Operational Adjustments Based on Raw Water Cyanotoxin
Measurements
Highlands Mutual Water Company does not wait for finished water cyanotoxin detections to adjust
treatment, but rather begins making treatment adjustments when cyanobacteria are detected in the
raw water. The following are treatment adjustments that will be made when cyanobacteria or
Highlands Mutual Water Company Cyanotoxin Management Plan - Step 3
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cyanotoxins are identified in the raw water. Please note that these proposed treatment adjustments are
empirical and have not been comprehensively evaluated or supported by engineering studies.
If potential toxin-producing cyanobacteria are identified in the source water sample(s) then:
Increase PAC dose. Conduct jar tests to help determine the optimal PAC dose
Lower ozone dose if:
o Algae appear to be in growth phase
o Lyngbya or Anabaena are found in the samples
Turn off ozone if:
o Gas vacuoles are seen on cyanobacteria in microscope samples
o Green foam comes out of the ozone vents or off-gas destruct unit
Begin pre-chlorinating before clarifier because the upflow clarifiers can have difficulty removing
cyanobacteria that can regulate their buoyancy with gas vacuoles
Dose Pro Pac 9890 filter aid at 0.1 mg/L to control trouble from cyanobacteria on the filters
Increase ACH (coagulant) dose (use jar tests to determine an optimal ACH dose)
Add small amount of ACH directly onto the clarifiers
Consider stopping the recycling backwash process or adding PAC to recycle water stream if:
o The test strip (or routine source water monitoring) detects >0.3 ng/L microcystin
Communications Based on Raw Water Cyanotoxin Measurements
1. Contact the two water utilities with interconnections to alert them of any cyanotoxin results
available from sampling the different treatment segments.
2. Contact all water utilities that draw water from the lake to alert them of the raw water
cyanotoxin results.
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Step 4: Finished Water Cyanotoxin Monitoring
and Treatment Adjustments
Detecting and positively confirming cyanotoxins in the finished water indicates that cyanotoxins have
broken through the treatment barriers. Again, it is important to monitor the performance of individual
unit processes across the treatment train to help understand what is happening in the treatment train
or identify possible treatment breakdown. If cyanotoxins have been detected in the finished water,
Highlands Mutual Water Company should continue implementing the treatment strategies described in
Step 3 and carry out the additional testing and treatment adjustments described in this section.
Finished Water Microcystins Monitoring
If finished water monitoring is determined necessary by Step 3. take a sample from the EPTDS. If this
sample is >0.3 ng/L microcystins using the test strip, sample at the following locations as soon as
possible:
1. Repeat the monitoring at the EPTDS as soon as possible with a test strip
2. Repeat the monitoring with test strips at the following locations:
Source water before PAC addition
After permanganate is added
After ozone is used
After the clarifier
After the media filters
After the first set of GAC filters (the "new" GAC filters)
After the second set of GAC filters (the "old" GAC filters)
3. If the repeat sample tests are negative, test water at the EPTDS a third time as soon as possible
with a test strip
4. If 2 out of the 3 entry point samples are >0.3 ng/L total microcystins using the test strips, lab-
based Adda-specific ELISA samples will be collected as soon as possible at the following
locations (samples should contain sufficient quenching agent to consume any residual oxidant):
Raw water before PAC addition
EPTDS
Four routine coliform monitoring sites
Dialysis center
5. Also collect Adda-specific ELISA samples after each of the following treatment steps (samples
should contain sufficient quenching agent to consume any residual oxidant):
After permanganate is added
After ozone is used
After the clarifier
After the media filters
After the first set of GAC filters (the "new" GAC filters)
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After the second set of GAC filters (the "old" GAC filters)
The mixture of instrument waste stream and filter-to-waste
6. If any of the Adda-specific ELISA samples in the distribution system conducted by the laboratory
are positive (>0.3 ng/L) go to Step 5
Treatment
In addition to the treatment adjustments listed in Step 3. Highlands Mutual Water Company will conduct
the following additional treatment optimization activities:
1. Increase chlorine dose before clearwell (i.e., second injection point) if test strip monitoring
indicates microcystins have made it through the GAC filters
2. Monitor raw water pH closely to ensure proper chemical dosages
3. Use turbidity and UV254 readings to track plant performance for particle and organics removal
Communications
Highlands Mutual Water Company will carry out the following communications as soon as possible if
Adda-specific ELISA results are equal to or exceed the 0.3 ng/L microcystins level:
1. Call the laboratory (Greenwater Laboratories) to let them know samples will be coming for
Adda-specific ELISA analysis or EPA Method 544
2. Notify stakeholders that preliminary results show microcystins levels >0.3 ng/L while waiting
for confirmation samples from the laboratory
3. Fill out the previously prepared public notice template to have it ready should the public
notification step be reached in Step 5 (Appendix C)
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Step 5: Continued Finished Water Cyanotoxin
Monitoring, Treatment Adjustments and
Public Communication
Step 5 contains communication actions, treatment actions and additional monitoring that should be
carried out based on the concentrations of cyanotoxins confirmed in the finished water. This fifth step
enables Highlands Mutual Water Company to act quickly if cyanotoxins are confirmed in the finished
water.
Continued Finished Water Microcystins Monitoring
If any Adda-specific ELISA or EPA Method 544 results exceed >0.3 ng/L microcystins, conduct the
following monitoring:
1. Continue monitoring the raw water tap before PAC addition and water from the EPTDS using
test strips
Flush around any distribution system sites that tested positive, measuring the effectiveness
of the flushing using test strips
When the test strip results are >0.3 ng/L, conduct the following monitoring:
1. Collect Adda-specific ELISA lab based samples as soon as possible at:
Raw water sample tap
EPTDS
Four routine total coliform monitoring sites
Dialysis center
2. Also collect Adda-specific ELISA samples at each of the following treatment steps:
After permanganate is added
After ozone is used
After the clarifier
After the media filters
After the first set of GAC filters (the "new" GAC filters)
After the second set of GAC filters (the "old" GAC filters)
The mixture of sampling water and filter-to-waste
Highlands Mutual Water Company will continue looking for early warning signs (Step 2) for cyanotoxins
when all Adda-specific ELISA results are below <0.3 ng/L.
Treatment
If any Adda-specific ELISA Result is at or above 0.3 ng/L Highlands Mutual Water Company will, in
addition to the treatment optimization steps identified in earlier steps of this plan, conduct jar testing to
optimize PAC and coagulation/flocculation processes and evaluate the condition of the GAC media.
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Communications
Highlands Mutual Water Company will provide the following notifications:
If the follow-up distribution system confirmation samples or the entry point samples tested
with the Adda-specific ELISA lab based method exceeds 0.3 ng/L:
o Notify stakeholders that microcystins levels >0.3 ng/L have been confirmed in the finished
water.
o Issue public health advisory system-wide (even if the toxin is only found in one distribution
system pressure zone).
If microcystins are detected in raw water samples with the Adda-specific ELISA lab-based
method but not detected at the EPTDS or in the distribution system, Highlands Mutual Water
Company will:
o Notify stakeholders that microcystins remain a concern in the raw water but microcystins
levels >0.3 ng/L were not confirmed in the finished water.
If Adda-specific ELISA results for all distribution samples are below 0.3 ng/L, Highlands Mutual
Water Company will:
o Lift the public health advisory if it has been issued.
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Long-Term Activities
Additional long-term activities can be undertaken by Highland Mutual Water Company to better
understand treatment effectiveness, develop a cohesive monitoring program, explore monitoring other
cyanotoxins of concern in addition to microcystins and engage in additional source water protection
activities.
Treatment Activities
Evaluation of treatment adjustments will require jar testing. The Highlands Mutual Water Company may
consider conducting jar tests to determine proper doses of chemicals (such as ozone, ACH and filter aid)
or media (PAC) for control of cyanotoxins while achieving other treatment goals (e.g., control of taste
and odor, removal of DBP precursors, etc.). In addition, the Highlands Mutual Water Company will need
to evaluate the effectiveness of these treatment adjustments based on sampling results and refine these
approaches as appropriate.
Monitoring Activities
Consider establishing a cohesive, routine raw water and in-plant process control sampling and
monitoring protocol for HABs. Consider monitoring the distribution of the toxin in the cells of the
clarifier sludge to determine percentage of intra- or extra-cellular during onset and/or peak of blooms to
assess clarifier rake speed/check if adequate. Also consider monitoring the pre-ozone dosage using
microscopy to assess cell condition to determine cell lysis or limit to 2.7 ng/L.
Additionally, consider learning more about cylindrospermopsin and anatoxin-a test strips. If appropriate
(based on lake monitoring results and information about the test strips, their cost, detection levels, and
accuracy), work them into the cyanotoxins management plan.
Source Water Protection Management Approaches
Identify all ongoing monitoring, committees, government programs and other organized
watershed management activities taking place related to Clear Lake. For each of these provide
activity descriptions, milestone dates, lists of key players and funding sources. Identify ways
Clear Lake's water utilities could become more involved and the benefits to the water utilities
of greater involvement. Prioritize which of these may be the most helpful for furthering the
specific interests of the water utilities in the watershed.
The Highlands Mutual Water Company could assist water quality efforts in the watershed by
identifying its role in Clear Lake's Watershed Management Plan, or by working with county and
state officials to identify an appropriate role, which may be in the form of an activity such as
providing additional water quality monitoring.
Development of a well-designed network of monitoring sites would help provide greater
understanding of the water quality and cyanobacteria/algae dynamics in Clear Lake partnering
with other utilities and/or state agencies. A monitoring strategy could be developed that uses
targeted sampling to gather as much relevant information as possible. In addition, it would be
beneficial to understand the differences among vegetative covers and land uses in terms of
nutrient and sediment export. The monitoring strategy should take into account watershed size
and consider other aspects of monitoring design in order to effectively determine
loadings/impacts to the lake, such as intake location.
Highlands Mutual Water Company Cyanotoxin Management Plan - Long-Term Activities
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Apply for State Revolving Funds (or other funding sources) to improve source water quality.
In April 2016, in partnership with the State of California, the utility and interested stakeholders
conducted an evaluation of activities the utility could engage in to enhance source water
protection. The evaluation determined what additional steps could be taken by the utility to
mitigate HAB occurrence. The result of the evaluation was that the utility could include
additional activities in the upcoming watershed sanitary survey related to nutrient pollution in
source waters. Based on a review of the last (2012) watershed sanitary survey, it was identified
that it would also be helpful to address nutrient loading and associated water quality problems
in Clear Lake in greater detail in the 2017 Watershed Sanitary Survey.
Highlands Mutual Water Company Cyanotoxin Management Plan - Long-Term Activities
E1.30
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References
CVRWQCB (Central Valley Regional Water Quality Control Board). 2006. Amendment to the Water
Quality Control Plan for the Sacramento River and San Joaquin Basins for the Control of Nutrients in
Clear Lake. Staff Report June 2006.
CVRWQCB (Central Valley Regional Water Quality Control Board). 2012. Clear Lake Nutrient Total
Maximum Daily Load Control Program 5-Year Update, Final Report. September, 2012.
CVRWQCB (Central Valley Regional Water Quality Control Board). 2013. The Clear Lake Nutrient TMDL
Implementation Handout. February 7, 2013.
Forsgren Associates, Inc. 2007. Clear Lake Watershed Sanitary Survey 2007 Update.
Forsgren Associates, Inc. 2012. Clear Lake Watershed Sanitary Survey 2012 Update.
Lake County Water Resources Department. 2010. Clear Lake Integrated Watershed Management Plan.
http://www.co.lake.ca.us/Government/Directory/Water_Resources/watershedplan/CLIWMP_Docs.htm
(accessed 08.30.16).
Mioni, C., Kudela, R. 2011. Algal toxins bioassessmentClear Lake, July/August 2010. April 2011.
Mioni, C., Kudela, R., Baxa, D. 2012. Harmful cyanobacteria blooms and their toxins in Clear Lake and the
Sacramento San Joaquin Delta (California). April 2012.
Richerson, P.J., T.H. Suchanek and S.J. Why. 1994. The Causes and Control of Algal Blooms in Clear Lake,
Clean Lakes Diagnostic/Feasibility Study for Clear Lake, California. Report prepared for Lake County
Flood Control and Water Conservation District, California Department of Water Resources, and United
States Environmental Protection Agency. Division of Environmental Studies, University of California,
Davis, CA.
State Water Resources Control Board (SWRCB), 1999. Drinking Water Source Assessment and Protection
(DWSAP) Program. State Water Resources Control Board, January, 1999.
Tetra Tech. 2004. Total Maximum Daily Load for Nutrients in Clear Lake, Lake County, California,
Technical Report. Prepared for the Central Valley Regional Water Quality Control Board. December 1,
2004.
Winder, M., Reuter, J., Schladow, G. 2010. "Clear Lake Report: Clear Lake Historical Data Analysis".
Report prepared Lake County Public Water District. University of California, Davis, CA.
Highlands Mutual Water Company Cyanotoxin Management Plan - References
E1.31
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Appendix A
Cyanotoxin Management Flowchart
Is it vulnerable?
No
Yes
Yes
Yes
Were toxins detected?
Were toxins detected?>
No
No
Are there signs
of a bloom or cyanotoxin
occurrence?
Step 4: Finished Water
Cyanotoxin Monitoring
and Treatment
Adjustments
Step 2.1 : Preparation
Step 1: Assess Source
Water
Step 2.3 : Immediate
Actions if a Bloom is
Suspected
Step 2.2 : Monitoring
the Early Warning Signs
Step 3: Raw Water
Cyanotoxin Monitoring
and Treatment
Adjustments
Step 5: Continued
Finished Water
Cyanotoxin Monitoring,
Treatment Adjustments,
and Public
Communication
Begin monitoring,
communication, and
source water
mitigation actions.
Continue
monitoring,
treatment, and
communication
activities as needed.
Return to previous
steps as appropriate.
Continue evaluating
for possible bloom
{Step 2.2).
Begin any
preparation, as
needed, for
monitoring,
treatment and
communication.
Cyanotoxins: Actions to Monitor
Occurrence and Minimize
Exposure
Highlands Mutual Water Company Cyanotoxin Management Plan - Appendix A
E1.32
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Appendix B
Contacts and Stakeholder Information
Agency/Company
Title
Contact Name
Contact Phone
Contact Email
Local/State Organizations
Lake County
Public
Health
Officer
Central Valley Water
Board
Mendocino District
Office, State Drinking
Water Field Office
Branch, SWRCB
District
Engineer
City of Clearlake
Foreman
City of Clearlake
Public
Works
Director
Medical Facilities
Dialysis Center
Medical Facilities
Medical Facilities
Hospitals
Hospitals
Veterinarians
Veterinarians
Tribal Communication
Elem Indian Colony
Environ-
mental
Director
Big Valley Rancheria
Band of Porno Indians
Neighboring Public Water Systems
Konocti County Water
District
Golden State Water
Company
Highlands Mutual Water Company Cyanotoxin Management Plan - Appendix B
E1.33
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Appendix C
Notifying the Public of Cyanotoxins in their Water
The State of California has provided the following draft template (in English and Spanish) for Highlands
Mutual Water Company to use, as appropriate, when issuing a do not drink advisory:
English version:
LETTERHEAD OR INSERT HIGHLANDS WATER COMPANY
LOGO
IMPORTANT INFORMATION REGARDING YOUR DRINKING WATER
Low Levels of Cyanotoxins Found in Treated Drinking Water
Low levels of [specific cyanotoxin] were found in your treated drinking water, [specific
cyanotoxin] is a cyanotoxin. Cyanotoxins are created by bacteria known as cyanobacteria
or blue-green algae. Under certain environmental conditions, the cyanobacteria can
create harmful algal blooms that can create a health risk if ingested. However, not all
'blooms' produce these cyanotoxins. Your treated drinking water was sampled to
determine if cyanotoxins were present when a suspected bloom was occurring. The
sampling was conducted on [date]. The test results confirmed on [date] showed
cyanotoxins are present in your treated drinking water and may present a health risk. As
a result, we are changing our treatment operations to lower concentrations of [specific
cyanotoxin] as quickly as possible.
What should I do?
Use bottled drinking water for the preparation of baby formula, cooking, and as
your source of drinking water for humans and pets until further notice. Boiling
water will not remove the cyanotoxins.
Seek medical treatment immediately if a person, pet, or livestock might have been
exposed to cyanotoxins. Common symptoms of exposure to cyanotoxins include:
eye irritation, skin rash, mouth ulcers, vomiting, diarrhea, and cold or flu-like
symptoms.
Use this water for showering (avoid swallowing the water), washing dishes,
cleaning, laundry, watering gardens, and flushing toilets.
What is being done?
We are working hard to correct this problem, and do not expect this problem to last more
than [number of days]. We will notify you when the water is acceptable for drinking. More
information can be found at: [link].
For questions, please contact: INSERT NAME at [(xxx) xxx-xxxx].
Highlands Mutual Water Company Cyanotoxin Management Plan - Appendix C
El. 34
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Date Distributed: Month Day, Year
Spanish version:
LETTERHEAD OR INSERT HIGHLANDS WATER COMPANY
LOGO
INFORMACION IMPORTANTE SOBRE SU AGUA POTABLE
Se Encontraron Nivel Bajos de Cianotoxinas en Agua Potable
Tratada
Se encontraron bajos niveles de [specific cyanotoxin] en su agua potable tratada. La/el
[specific cyanotoxin] es una cianotoxina. Las cianotoxinas son creadas por bacterias
conocidas como cianobacterias o algas verde-azules. Bajo ciertas condiciones
ambientales, las cianobacterias pueden crear floraciones de algas nocivas que pueden
crear un riesgo para la salud si son ingeridas. Sin embargo, no todas la 'floraciones'
producen estas cianotoxinas. Se tomaron muestras de su agua potable tratada para
determinar si habfa cianotoxinas presentes en su agua cuando habfa sospecha de
floracion. El muestreo se llevo a cabo el [date], Los resultados de las pruebas
confirmados en [date] muestran que hay cianotoxinas presentes en su agua potable
tratada y pueden presentar un riesgo para la salud. Como resultado, vamos a cambiar
nuestras operaciones de tratamiento para disminuir las concentraciones de [specific
cyanotoxin ] tan pronto como sea posible.
tQue debo de hacer?
Hasta nuevo aviso, use agua potable embotellada para preparar la formula
infantil, para cocinar y como fuente de agua potable para los seres humanos y
mascotas. Las cianotoxinas no se eliminan hirviendo el agua.
Busque tratamiento medico inmediatamente si una persona, mascota, o ganado
podrfan haber estado expuestos a cianotoxinas. Los sfntomas comunes de
haber estado expuesto a cianotoxinas incluyen: irritacion de los ojos, ronchas,
ulceras en la boca, vomito, diarrea y sfntomas de resfriado o gripe.
Evitando tragar agua, puede usar esta agua para banarse, para lavar los
trastes, limpiar, lavar la ropa, regar jardines y para el inodoro.
^Que se esta haciendo?
Estamos trabajando diligentemente para corregir este problema y no se espera que
este problema dure mas de [number of days], Nosotros le notificaremos cuando el agua
se pueda usar para beber. Puede encontrar mas informacion en: [link].
Para preguntas, puede contactar a: INSERT NAME al [(xxx) xxx-xxxx].
Highlands Mutual Water Company Cyanotoxin Management Plan - Appendix C
El. 35
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Cyanotoxins Management Plan
ฃ&ป
Village of Perry Water System
Perry, New York
November, 2016
E2.1
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Table of Contents
Executive Summary E2.4
Village of Perry Water System Overview E2.5
Source Water E2.5
Treatment Process E2.5
Routine Water Quality Monitoring E2.6
Cyanotoxin Management Plan E2.7
Step 1: Assess Source Water E2.9
1.1 Identify Source Water Protection Areas E2.9
1.2 Create an Inventory of HABs Risk Factors E2.9
1.2.1 Source Water Characteristics E2.9
Land Use E2.9
1.2.2 Water Quality Parameters E2.10
Historical Cyanobacteria and Cyanotoxin Events in the Source Water E2.ll
Nutrients E2.ll
Point and Nonpoint Sources of Pollution E2.ll
1.3 Assess Vulnerability E2.ll
Step 2: Preparation, Monitoring for Early Warning Signs and Immediate Actions E2.12
2.1 Preparation E2.12
Prepare Staff and Equipment for Monitoring E2.12
Prepare for Treatment Adjustments E2.12
Communications E2.12
Establish Communication Plan with other Source Water Users E2.13
Communication with Stakeholders E2.13
2.2 Monitoring the Early Warning Signs E2.13
Early Indicators of a Cyanobacterial Bloom E2.13
Communication: Early Indicators of a Cyanobacterial Bloom E2.14
2.3 Immediate Actions if a Bloom is Suspected E2.14
Monitoring Actions in Response to Early Warning Signs E2.14
Communication Actions in Response to Early Warning Signs E2.14
Source Water Mitigation Actions in Response to Early Warning Signs E2.14
Step 3: Raw Water Cyanotoxin Monitoring and Treatment Adjustments E2.15
Monitoring if Cyanobacteria are Identified or Suspected E2.15
Operational Adjustments Based on Raw Water Cyanotoxin Measurements E2.15
Communications Based on Raw Water Cyanotoxin Measurements E2.15
Step 4: Finished Water Cyanotoxin Monitoring and Treatment Adjustments E2.16
Monitoring E2.16
E2.2
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Treatment E2.16
Communications E2.16
Step 5: Continued Finished Water Cyanotoxin Monitoring, Treatment Adjustments and Public
Communication E2.17
Finished Water Microcystins Monitoring E2.17
Treatment E2.17
Communications E2.17
Long-Term Activities E2.18
Monitoring Activities E2.18
Treatment Activities E2.18
Source Water Protection Management Approaches E2.18
Appendices
Appendix A Cyanotoxin Management Flowchart E2.19
Appendix B Contacts and Stakeholder Information E2.20
Appendix C Notifying the Public of Cyanotoxins in their Water E2.22
E2.3
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Executive Summary
The Village of Perry Water System, with the support of the State of New York and the United States
Environmental Protection Agency (USEPA), developed this Cyanotoxins Management Plan (CMP) to
prepare for and mitigate risks from harmful algal blooms (HABs) and cyanotoxins occurring in Silver Lake
and to protect public drinking water from cyanotoxin contamination. This document provides steps and
activities to prepare for and identify a potential HAB occurrence, make treatment and operational
adjustments to remove cyanotoxins from source waters, provide timely information and (as
appropriate) an advisory to the water system's customers, and document information about
occurrences of HABs so that information can be used to minimize the effect of HABs on the water
system in the future. This plan also contains possible future activities the Village of Perry Water System
could engage in to mitigate the risks from HABs and cyanotoxins, such as long-term source water
protection activities.
The steps outlined in this CMP include:
Step 1: Assess Source Water
Step 2: Preparation, Monitoring for Early Warning Signs and Immediate Actions
Step 3: Raw Water Cyanotoxin Monitoring and Treatment Adjustments
Step 4: Finished Water Cyanotoxin Monitoring and Treatment Adjustments
Step 5: Continued Finished Water Cyanotoxin Monitoring, Treatment Adjustments and Public
Communication
In addition to the five steps above long-term activities are also discussed to enhance the utility's ability
to prevent, mitigate and manage the risks from cyanotoxin occurrence in source and drinking waters.
Village of Perry Water System Cyanotoxin Management Plan - Executive Summary
E2.4
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Village of Perry Water System Overview
The Village of Perry Water System serves the Village and Town of Perry and the Town of Castile, all in
Wyoming County, for a total of 1,660 service connections and 3,673 people. On average, the system
produces approximately 475,000 gallons per day of finished water, with a peak flow of 660,000 gallons
per day. Peak production typically occurs around July 4th, when the plant runs 24 hours a day, seven
days a week to meet demand. While the Village has a permit restricting lake withdrawals to two million
gallons per day, the current plant is likely not capable of treating that much water in a day.
The Village has a 750,000-gallon elevated storage tank as well as a 150,000-gallon storage tank with a
chlorine booster station located on the way from the Village to the Town of Perry. Altogether, the
system has 1.5 - 2 days of finished water storage. The distribution system has one pressure zone.
A description of the water system's treatment process is provided below, as well as a schematic of the
treatment system. In addition to concerns related to HABs, the water system contends with taste and
odor problems stemming from geosmin or MIB production by cyanobacteria growing in its primary
source, Silver Lake.
Source Water
The Village of Perry uses Silver Lake as its primary source of water. There are two intakes referred to as
Intake 1 and Intake 2. Perry only uses Intake 1. Intake 2 is located in shallower water and its valve is
cemented shut. The maximum depth of the lake is approximately 33 feet. There are no interconnections
with other municipalities and there is no backup supply. Silver Lake is located in Wyoming County.
Silver Lake is a Class A lake under New York State's lake classification system. According to this lake
classification system, its best intended use is as a potable water supply. The lake is also used for contact
recreation, non-contact recreation and is protected for its aquatic life and aesthetics. Residents and
visitors access the lake for power boating, fishing and swimming through residential shoreline access
and a state launch near the southern end of the lake. Silver Lake is stocked by New York State with
about 4.2 million 0.5-inch walleye annually.
Treatment Process
Two low lift pumps bring water from Silver Lake to the treatment plant. The Village of Perry Water
System then provides the following treatment:
Clarification: Water flows from the pumps to an upflow clarifier where the following chemicals are
added directly into the water as it enters:
The coagulant, PCH180, at a rate of 22 gallons per day
Orthophosphate for corrosion control at a rate of 2 gallons per day
Pre-chlorination to kill off algae and cyanobacteria in the raw water at a rate of 0.2-0.6 mg/L
using 12.5% sodium hypochlorite solution
Water leaving the upflow clarifier must maintain a turbidity of no more than 0.1 nephelometric turbidity
units (NTU) to meet treatment goals.
Filtration: Water that has passed through the upflow clarifier then flows to one of three filters that are
operated in parallel. Each filter is capped with 18 inches of granular activated carbon (GAC), below
which are two feet of sand. The GAC in each filter is replaced every three years. There are three filter
beds and GAC is replaced in one filter bed a year, rotating among the three beds. The GAC is primarily
Village of Perry Water System Cyanotoxin Management Plan - Overview
E2.5
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intended to remove taste and odor compounds. Routine monitoring includes monthly paired total
organic carbon (TOC) measurements before and after filtration collected under requirements of the
Disinfection Byproducts Rule.
Each filter is backwashed twice a week based on head loss and individual filter effluent
turbidity. When a filter's effluent turbidity reaches approximately 0.15 NTU, it is
backwashed. In the summer, backwashing occurs three to four times per week.
Chlorinated water from the clearwell is used to backwash the filters. Backwash water is not
recycled; it goes to the sewer.
Based on a conversation with the GAC distributor for the Village of Perry (and several other
communities in the northeastern U.S.), it is common for systems with GAC caps on their
filters to use chlorinated water to backwash their filters. These systems factor in any
deactivation of the carbon due to its contact with chlorinated water when considering the
lifetime of the GAC.
Disinfection and Fluoridation: Chlorine and fluoride are added after filtration and before water enters
the clearwell. Plant operators try to maintain 1.4 - 1.6 mg/L free chlorine at the entry point to the
distribution system (EPTDS) after the clearwell. For chlorine CT, peak flow is 660,000 gallons per day, the
highest pH is in the summer and typically around 8.4, and summer water temperatures are in the high
60's to low 70's degrees Fahrenheit. The lowest chlorine residual measured at the EPTDS in the summer
months has been 1.4-1.55 mg/L. The clearwell baffling factor is 0.1, and the clearwell's volume is
350,000 gallons. The required summer CT under the Surface Water Treatment Rule is about 35 mg-
min/L. A chlorine CT of 118 mg-min/L is maintained in the summer.
In early July, when the source water turbidity starts to rise, operators increase the post-filtration
chlorine dose as well as the coagulant dose into the upflow clarifier, according to water and flow
conditions.
Routine Water Quality Monitoring
Village of Perry operators monitor raw water alkalinity and raw and finished water TOC monthly for
compliance with the Disinfectants and Disinfection Byproducts Rules. Raw water pH is measured daily,
and raw water turbidity is measured continuously. The Village of Perry Water System conducts all other
USEPA-required testing at their required frequencies.
In addition, samples are collected and measurements are made in Silver Lake by the New York State
Citizens Statewide Lake Assessment Program (CSLAP). CSLAP is a volunteer lake monitoring and
education program that is managed by the New York State Department of Environmental Conservation
(NYS DEC) and the New York State Federation of Lake Associations (NYSFOLA). NYS DEC and NYSFOLA
provide training, equipment and supplies to volunteers to collect, process and ship water samples for
analysis to a qualified laboratory. CSLAP monitoring measures several water quality parameters in the
Silver Lake water column and near the shore; these parameters include nutrients (phosphorus and
nitrogen), chlorophyll-o and phycocyanin. CSLAP monitoring of Silver Lake takes place biweekly at two
stations during the summer months.
Additionally, the Livingston County Health Department has microcystins test strips available that are
primarily used to monitor recreational waters in Silver Lake. Routine monitoring of Silver Lake for algal
toxins is not currently taking place, but the New York State Department of Health (DOH) and NYS DEC
are working closely together to develop a targeted algal toxin monitoring program. The CSLAP ambient
Village of Perry Water System Cyanotoxin Management Plan - Overview
E2.6
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lake water samples that are collected are analyzed by the Upstate Freshwater Institute for nutrients and
other general water quality analytes, and HAB toxins are analyzed by SUNY College of Environmental
Science and Forestry (SUNY ESF), located in Syracuse. New York State's Wadsworth Laboratories in
Albany performs HAB toxin analysis on raw and finished drinking water samples as dictated by bloom
related water quality concerns.
Table 1. Raw Water Routine Monitoring
Parameter
Location
Frequency
Who Collects
Sample?
Who Does Analysis?
Alkalinity
Raw Water Pump
Discharge
Monthly
Village of Perry
Operators
Commercial Lab
TOC
Monthly
Commercial Lab
pH1
Daily
Plant
Temperature
Daily
Plant
Turbidity2
Continuously
Plant
Chlorophyll-o
Nutrients
Phycocyanin
Total Microcystins
Silver Lake
Bi-Weekly
Citizens Statewide
Lake Assessment
Program (CSLAP)
Upstate Freshwater
Institute analyzes
nutrients, general
water quality
analytes
SUNY ESF analyzes
microcystins for
CSLAP samples
Total Microcystins
Raw and finished
water
As needed
Village of Perry
Operators
Wadsworth
Laboratories
analyzes
microcystins for raw
and finished
drinking water
samples collected
by Village of Perry
JRaw water pH values range from approximately 7.2 to 8.3 depending on the season
2Raw water turbidity ranges from 1.0 to 2.5 NTU
Cyanotoxin Management Plan
The Village of Perry developed this Cyanotoxins Management Plan (CMP) detailed in the steps below.
This CMP provides an action plan to prepare for and mitigate risks from harmful algal blooms (HABs) and
cyanotoxins occurring in Silver Lake in order to protect public drinking water from cyanotoxin
contamination. The plan includes immediate steps discussing monitoring and treatment should HABs
and cyanotoxins occur as well as long-term steps the system can engage in to protect source and
drinking waters and to fully evaluate treatment capabilities. A detailed flowchart of the CMP process can
be found in Appendix A.
Village of Perry Water System Cyanotoxin Management Plan - Overview
E2.7
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Figure 1. Schematic Diagram of the Treatment System
Village of Perry, NY
Treatment Schematic
Prechlorination
(12.5% NAOCI)
PCH180*
Orthophosphate
Filter
(sand media
with GAC cap)
Filter
{sand media
with GAC cap)
Filter
(sand media
with GAC cap)
Intake at
Silver Lake
Low lift
turbine pumps
Upflow clarifier
Chlorinated backwash water from clearwell
Post-
chlorination
(12.5% NAOCI)
Fluoride
Distribution
System
Clearwell
(buried
outside)
High lift pumps
Treatment Plant Building boundaries
* Polyaluminum chloride (PACI)
Village of Perry Water System Cyanotoxin Management Plan - Overview
E2.8
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Step 1: Assess Source Water
1.1 Identify Source Water Protection Areas
A source water assessment is an evaluation of a drinking water source to determine the susceptibility to
contamination. The first step of a source water assessment is to delineate (map) the areas of water and
land that drain into the water supply that are to be evaluated for contaminant sources. This is called the
Source Water Protection Area.
The Village of Perry delineated its Silver Lake Source Water Protection Area using the Drinking Water
Application to Protect Source Waters (DWMAPs). Map 1 shows catchments within 15 miles upstream of
Intake #1 on Silver Lake in addition to land use indicators in the watershed
Legend
Selected Potential Sources
of Contamination matching
query
Selected NHD Flowlines
matching query
Catchments
NPDES Refuse Facilities
NPDES Sewerage Facilities
NPDES Other Facilities
Map 1: Source Water Protection Area for Silver Lake, Intake #1
1.2 Create an Inventory of HABs Risk Factors
1.2.1 Source Water Characteristics
The Village of Perry uses Silver Lake as its primary source of water. There are two intakes referred to as
Intake 1 and Intake 2. Perry only uses Intake 1. Intake 2 is located in shallower water and its valve is
cemented shut. The maximum depth of the lake is approximately 33 feet. There are no interconnections
with other municipalities and there is no backup supply. Silver Lake is located in Wyoming County.
Land Use
The drainage area around Silver Lake is predominantly agricultural or urban land cover. According to the
Total Maximum Daily Load (TMDL) modeling efforts, cropped agriculture and hay/pasture land
Village of Perry Water System Cyanotoxin Management Plan - Step 1
E2.9
-------
contribute approximately 84% of the total phosphorus load to Silver Lake, groundwater phosphorus
contributes approximately 12%, and septic systems make up roughly 2%. The remaining 2% of
phosphorus contributions come from sources such as urban areas, stream bank erosion and forested
land. The Silver Lake phosphorus TMDL can be found at
http://www.dec.nv.gov/docs/water pdf/tmdlsilvfinallO.pdf. A combination of models were used to
determine mean annual phosphorus loading to the lake and the extent to which these various loads
must be reduced to meet the water quality target. In this case, the water quality target is the narrative
phosphorus standard as determined by NYS DEC. Map 2 indicates land use types surrounding Silver
Lake.
* jM* SjTw i*. -
Land Use around Silver Lake
kt v~ flP f it jfl
ฆ
Developed, medium intensity
Developed, open space
Pasture/hay
Cultivated crops
U to MNR Piuvince Dt Onlaio.
Map 2: Land Use in the Silver Lake Source Water Protection Area
1.2.2 Water Quality Parameters
Silver Lake has been assessed for attainment of surface water quality standards under Section 305(b) of
the Clean Water Act (CWA). Based on this assessment, Silver Lake was listed as an impaired waterbody
due to phosphorus under Section 303(d) of the CWA. A phosphorus TMDL was developed in response to
the impairment listing. The TMDL defines targets for phosphorus loading to Silver Lake and outlines
strategies for reducing phosphorus loading, which will ultimately reduce algal growth.
Local stakeholders have already invested in major watershed phosphorus load reduction projects to
improve the water quality of Silver Lake. Some projects and initiatives to decrease loadings include:
transitioning a large portion of the shoreline properties from septic systems to sewers to address failing
septic tanks and The Silver Lake Commission and the Wyoming County Soil and Water Conservation
District have been working together with farmers in the watershed to develop Nutrient Management
Plans and implement agricultural Best Management Practices (BMPs).
One source of funding for implementing the TMDL is CWA nonpoint source program (Section 319) grant
funds. A $1.3 million Section 319 grant project was initiated in 2012 to protect the Silver Lake drinking
water source by reducing phosphorus, nitrogen and sediment loading to the lake by implementing BMPs
and upgrading facilities on nine farms in the watershed. Additionally, the Silver Lake watershed falls
Village of Perry Water System Cyanotoxin Management Plan - Step 1
E2.10
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within the working region of the Triple Divide Watershed Coalition, an alliance that seeks to protect the
public drinking water sources in Alleghany, Genesee and Susquehanna River regions. The Triple Divide
Watershed Coalition is an interstate organization that serves to protect public drinking water sources
from degradation of source water quantity or quality by evaluating susceptibility to contamination,
working to minimize or eliminate potential threats, creating long-range protection strategies, supporting
local planning and inter-governmental cooperation, encouraging public education initiatives, and any
other activity to protect and preserve drinking water resources for future generations. The Coalition's
web site is https://goh2o.net/tripledividewatershed.
Historical Cyanobacteria and Cyanotoxin Events in the Source Water
Silver Lake has experienced a number of cyanobacterial blooms, with blooms historically becoming more
intense as the water temperature in the lake increases. In 2015, there was a bloom from July 6th until
Labor Day. However, warm weather is not a necessity; in 2014 there was a bloom in October when the
water temperature was approximately 50 degrees Fahrenheit. In 2015, CSLAP sampling measured
microcystins levels as high as 7.2 ng/L in open water and 815 ng/L along the shoreline. These results are
consistent with longer-term CSLAP monitoring which indicate that algal toxin levels can vary significantly
within blooms and from shoreline to lake with often much higher levels found in the shoreline blooms
than in open swimming water (http://www.dec.ny.gov/docs/water pdf/cslrptl5silverlw.pdf).
Nutrients
Phosphorus and nitrogen are drivers of algal and cyanobacterial growth in lakes and reservoirs. As
discussed above, CSLAP sampling efforts confirm nutrient-rich conditions in Silver Lake, with the
concentration of phosphorus in the lake exceeding the state guidance value for phosphorus, increasing
the potential for algal bloom formation. In 1998, Silver Lake was added to the NYS DEC CWA Section
303(d) list of impaired waterbodies that do not meet water quality standards due to phosphorus
impairments. The majority of the phosphorus load to the lake is from agricultural sources, with smaller
percentages of sources from groundwater, septic and urban sources as well as from stream bank
erosion and forested land. Based on this listing, a TMDL for phosphorus is being developed for the lake
to address the impairment (http://www.dec.ny.gov/docs/water_pdf/tmdlsilvfinallO.pdf).
Point and Nonpoint Sources of Pollution
A query of the USEPA DWMAPS tool indicates that there is one National Pollutant Discharge Elimination
System (NPDES) permitted wastewater discharger within 15 miles upstream of Silver Lake: Silver Lake
Marine Incorporated. There are no Combined Sewer Overflows within 15 miles upstream of Silver Lake.
Silver lake experiences nonpoint pollution of nutrients through runoff from urban and agriculture land
uses as discussed above.
1.3 Assess Vulnerability
A weight of evidence approach was used to characterize Silver Lake as vulnerable to HABs and
cyanotoxin occurrence (move to Step 2). Evidence includes all of the discussion in this section including:
the dominant land uses in the watershed contributing to phosphorus pollution, the existing phosphorus
TMDL in the lake and the historical occurrence of HABs in Silver Lake.
Village of Perry Water System Cyanotoxin Management Plan - Step 1
E2.ll
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Step 2: Preparation, Monitoring for Early
Warning Signs and Immediate Actions
2.1 Preparation
The Village of Perry Water System determined that its source water is vulnerable to cyanobacterial
blooms; the next step is to consider how to prepare for cyanobacterial blooms and cyanotoxin
occurrence. Preparation includes preparing for monitoring raw and finished waters, preparing for
treatment adjustments and establishing communication plans.
Prepare Staff and Equipment for Monitoring
The Village of Perry Water System intends to carry out the following activities in order to be prepared
for the monitoring steps described in this plan:
Have the appropriate bottles (glass or PETG) on site for Adda-specific ELISA analysis. Also
have sodium thiosulfate available for quenching any samples that have been exposed to an
oxidant as soon as they are collected. Have at least two sets of bottles available on site.
Document all sampling, testing and quality assurance procedures.
Take greater advantage of the analytical capabilities of the equipment that the Village of
Perry has in its own laboratory. In particular, consider analyzing TOC, chlorophyll-o and
phycocyanin. TOC measurements (raw and post-filtration) may be acceptable for complying
with the monthly Disinfection Byproducts Rule TOC monitoring requirements. Raw water
TOC, chlorophyll-o and phycocyanin measurements may provide helpful early warnings of
impending cyanobacterial blooms.
Prepare for Treatment Adjustments
Village of Perry Water System will carry out the following activities in order to be more prepared for
treatment activities during a HAB:
Cover/tint the remaining windows in the room housing the upflow clarifier so that direct
sunlight does not shine on the clarifier water and promote algal/cyanobacterial growth.
Investigate methods for evaluating the efficacy of the GAC media, and determine
parameters that can indicate its effectiveness. Consider having the GAC manufacturer
analyze GAC samples collected from each filter bed annually (prior to HABs season) for
iodine number to improve understanding of the extent to which the GAC is activated and
reliable for removing taste and odor compounds and algal toxins.
Determine if orthophosphate addition directly into the upflow clarifier may be promoting
algal/cyanobacterial growth in the treatment plant. If this is found to be true, consider
moving the point of orthophosphate addition to later in the treatment train (e.g., after
filtration).
Communications
Village of Perry Water System will carry out the following activities in order to be more prepared for the
communications steps described in this plan.
Village of Perry Water System Cyanotoxin Management Plan - Step 2
E2.12
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Establish Communication Plan with other Source Water Users
The Towns of Perry and Castile purchase water from the Village of Perry Water System. Other large
users of Silver Lake's water are a splash park, a farm in the Gardeau Water District (Castile serves
Gardeau), and the Silver Lake Institute's Camp Asbury (primarily used on the weekends). The Village of
Mt. Morris Water System also uses Silver Lake as its supply and has its own intake further north on the
lake. Mt. Morris is located in Livingston County and is therefore regulated and supported by the
Livingston County Health Department. The Village of Perry will communicate with operators from Mt.
Morris, Town of Perry and Town of Castile to find out best practices to coordinate on communicating
the conditions in the Lake.
Communication with Stakeholders
Establish a communication system with programs that are monitoring stations in Silver Lake
to determine when blooms may be occurring. Communications should include: CSLAP, NYS
DEC and Livingston County Health Department. Determine how to receive the biweekly
CSLAP monitoring results for two stations on Silver Lake during the summer months.
Complete the stakeholders list in Appendix B and ensure it continues to be up-to-date.
Consider adding language to the water system's annual water quality report asking home
dialysis and dialysis center customers to contact the water system so they can be added to
the stakeholders list and receive early warning about potential microcystins contamination
of the finished water. Explanations of when stakeholders will be contacted about a HAB are
provided in Step 5 of this plan.
Prepare a public health advisory template that is available and ready for use if necessary.
Also prepare another notice that would be issued to lift an existing public health advisory
(examples are located in Appendix C). Explanations of when a public health advisory will be
issued or lifted are provided in Step 5 of this plan.
2.2 Monitoring the Early Warning Signs
Based on historical bloom occurrence in Silver Lake, the Village of Perry Water System begins looking for
signs of blooms in April. This section identifies early warning signs that the operators can look for during
the system's normal operation.
Early Indicators of a Cyanobacterial Bloom
The Village of Perry Water System operators have identified early warning signs that a cyanobacterial
bloom is likely to occur in the very near future (or has begun to occur). The following early warning signs
are a combination of observations of conditions in the lake itself and in the treatment plant:
Sunny, hot days that increase water temperature
A spike in raw water turbidity
An obvious odor event
A spike in raw water pH
Sludge blanket in the upflow clarifier begins to look greener
High turbidity in clarifier effluent results in an increase in coagulant dose
Decreased filter runtimes
Increased finished water chlorine demand
Village of Perry Water System Cyanotoxin Management Plan - Step 2
E2.13
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Communication: Early Indicators of a Cyanobacterial Bloom
Communication with monitoring programs monitoring for either blooms or cyanotoxins can help
indicate to the utility that the lake may be experiencing a bloom.
2.3 Immediate Actions if a Bloom is Suspected
Monitoring Actions in Response to Early Warning Signs
If any early indicator is observed in the lake itself and in the treatment plant and/or if Wyoming
County Health Department, New York State DOH, or CSLAPs monitoring results indicate a
cyanobacterial bloom in Silver Lake:
o Operators will collect a paired sample set (raw and EPTDS) (moving directly to Steps 3 and 4,
simultaneously) and send the paired set of samples to Wadsworth Laboratories for total
microcystins testing using Adda-specific ELISA analysis,
o Operator will photograph the lake at the intake when he collects the raw water sample for
microcystins analysis. The photographs will be used to inform operators of what the lake
conditions look like when total microcystins are (and are not) detected in the water.
Communication Actions in Response to Early Warning Signs
The Village of Perry's lead operator, will communicate with operators from Mt. Morris, Town of Perry
and Town of Castile to keep them up-to-date of findings. Village of Perry contacts Wyoming County
Health Department when samples are collected and sent to Wadsworth Laboratories.
Source Water Mitigation Actions in Response to Early Warning Signs
Silver Lake is not treated with any in-lake mitigation actions aimed to eliminate the bloom.
Village of Perry Water System Cyanotoxin Management Plan - Step 2
E2.14
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Step 3: Raw Water Cyanotoxin Monitoring and
Treatment Adjustments
Monitoring if Cyanobacteria are Identified or Suspected
Silver Lake has a strong history of cyanobacterial blooms. If a bloom is suspected the system monitors
the raw and finished water (EPTDS) for microcystins. This is indicated in Step 2 as an immediate action
simultaneously with Step 4.
Operational Adjustments Based on Raw Water Cyanotoxin
Measurements
If cyanotoxins are identified in the raw water sample(s) then:
Consider reducing or eliminating pre-oxidation
Increase the coagulant dose at the upflow clarifier for cell removal
Increase chlorine dose in water entering the clearwell, but not to exceed the maximum residual
disinfectant level (MRDL) of 4.0 mg/L
Please note that these proposed operational adjustments and those discussed below are empirical and
have not been comprehensively evaluated or supported by engineering studies. Evaluation of treatment
adjustments will require jar testing. As discussed in long-term activities, the Village of Perry will need to
evaluate the toxin removal capacity of its current treatment process using jar tests spiked with varying
levels of toxins to simulate different operational conditions. In addition, the Village of Perry will need to
evaluate the effectiveness of these treatment adjustments based on sampling results and refine these
approaches as appropriate.
Communications Based on Raw Water Cyanotoxin Measurements
Wadsworth Labs will process the samples and within 24 hours get the results to:
o New York State DOH - Albany
o New York State DOH - Regional Office
o Wyoming County Health Department
o Livingston County Health Department
Wyoming County Health Department will notify the Village of Perry of the sampling results.
The Village of Perry will notify the lead operator at the Mt. Morris Water Department of the
sampling results
If any raw water sample is >0.3 ng/L total microcystins during Step 3 monitoring, continue Step 4 (as
indicated in Step 2. Step 3 and Step 4 will be completed simultaneously).
Village of Perry Water System Cyanotoxin Management Plan - Step 3
E2.15
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Step 4: Finished Water Cyanotoxin Monitoring
and Treatment Adjustments
Monitoring
As indicated in Step 2. if blooms are suspected immediate actions will include evaluating finished as well
as raw water samples.
Treatment
In addition to the treatment adjustments listed in Step 3. Village of Perry Water System will conduct the
following additional treatment optimization activity:
Increase the chlorine dose in the clearwell (without allowing the chlorine concentration at
the EPTDS to exceed the MRDL of 4.0 mg/L).
Communications
Carry out the following communications as soon as possible if the first EPTDS sample collected (i.e. the
unconfirmed sample) contains > 0.3 ng/L total microcystins:
Call the laboratory to let them know the follow up sample will be coming for analysis and
results will be needed as soon as possible.
Fill out the previously prepared public notice template to have it ready should the public
notification step be reached in Step 5.
Village of Perry Water System Cyanotoxin Management Plan - Step 4
E2.16
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Step 5: Continued Finished Water Cyanotoxin
Monitoring, Treatment Adjustments and
Public Communication
Detecting cyanotoxins in the finished water indicates that cyanotoxins have broken through the treatment
barriers. Step 5 contains communication actions, treatment actions and additional monitoring to be carried
out based on the concentrations of cyanotoxins confirmed in the finished water. This fifth step enables the
Village of Perry Water System to act quickly if cyanotoxins are confirmed in the finished water.
Finished Water Microcystins Monitoring
If the first EPTDS sample collected contains >0.3 ng/L total microcystins using the Adda-specific ELISA test at
Wadsworth Laboratories:
Collect a second sample at the EPTDS (with the addition of a quencing agent), as soon as
possible and send the sample to Wadsworth Laboratories for analysis using the Adda-
specific ELISA method.
This sample will be considered the confirmation sample.
If the EPTDS confirmation sample is <0.3 ng/L total microcystins but total microcystins are still detected in the
sample:
New York State DOH scientists or engineers will determine if more EPTDS samples can be
tested by Wadsworth Laboratories (i.e., whether there is lab capacity).
If the confirmation sample collected at the EPTDS is > 0.3 ng/L microcystins, conduct the following
monitoring:
Resample at a frequency and locations that are still to be determined.
Treatment
Continue treatment adjustments described in Steps 3 and 4.
Communications
If the EPTDS confirmation sample result is <0.3 ng/L total microcystins or a non-detect:
New York State DOH will notify Wyoming County Health Department as soon as possible,
and Wyoming County Health Department will notify the Village of Perry operator. The
Village of Perry will then continue looking for early warning signs (return to Step 2).
If the EPTDS confirmation sample is > 0.3 \ig/ L total microcystins, provide the following notifications:
Notify finished water stakeholders that microcystins levels >0.3 ng/L total microcystins have
been confirmed in the finished water.
Issue public health advisory (see Appendix C)
Report finished water results in the Village of Perry's Annual Water Quality Report.
If a public health advisory is issued, the public health advisory will not be lifted until:
o At least two EPTDS samples have <0.3 ng/L total microcystins using Adda-specific
ELISA lab based test.
Village of Perry Water System Cyanotoxin Management Plan - Step 5
E2.17
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Long-Term Activities
Additional long-term activities can be undertaken by the Village of Perry to better understand treatment
capabilities and engage in additional source water protection activities.
Monitoring Activities
Consider conducting monitoring throughout the treatment train to help understand how each process is
performing and help guide adjustments and optimization for cyanotoxins. Consider establishing a
routine raw and in-plant process control sampling/monitoring protocol for HABs. This could be sampling
for cyanotoxins directly, or measuring indicators, such as chlorophyll-o or phycocyanin, or a formal plan
for monitoring and trending the early indicators mentioned in this section. Establishing a baseline for
these parameters (by trending the data) during routine operation and understanding how each unit
treatment process responds can help when a HAB does occur and operators are faced with making
potential treatment adjustments. Planning, documenting and conducting a monitoring protocol would
be good preparation for a HAB and provide good information during a HAB to support treatment
optimization.
Work with the Wyoming County and Livingston County Health Departments and the Village of Mount
Morris Water System to purchase test strips and pilot the use of cyanotoxin test strips to determine if
they can be incorporated into the management plan. Since the test strips have a short shelf life, it may
be beneficial to share their cost and usage with the other organizations. Note, test strips may be useful
for screening and optimizing plant operations; however, they will not be used for public notification
purpose, as these will be determined by sample results from regular lab methods.
Since the algal blooms seem to blow around Silver Lake depending on the wind speed and direction,
determine if there is a weather station at the marina and if/how real-time wind information can be
accessed.
Treatment Activities
Evaluate the toxin removal capacity of its current treatment process using jar tests spiked with varying
levels of toxins to simulate different operational conditions. In addition, the Village of Perry can evaluate
the effectiveness of these operational treatment adjustments and optimization based on sampling
results and refine these approaches as appropriate.
Source Water Protection Management Approaches
The Wyoming County Water Resource Authority and the Village of Perry's Administrator, both sit on the
Silver Lake Commission board. Additional ways the Village of Perry could also engage with source water
protection partners includes working with the Triple Divide Watershed Coalition to identify roles it could
play in the TMDL process, or the Village of Perry could contact county and state officials to identify an
appropriate role for them, which may be in the form of an activity such as providing additional water
quality monitoring.
The Village of Perry Water System's chief operator believes recreational boat traffic on Silver Lake
contributes to water quality challenges at the treatment plant. Evaluate and document the impact of the
boat traffic on the treatment plant. Explore ways to reduce boat traffic in the vicinity of the treatment
plant's intake could be considered.
Village of Perry Water System Cyanotoxin Management Plan - Long-Term Activities
E2.18
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Appendix A
Cyanotoxin Management Flowchart
Is it vulnerable?
No
No
Yes
Yes
Were toxins detected?^
Were toxins detected?.
No
Are there signs
of a bloom or cyanotoxin
occurrence?
Step 2.2 : Monitoring
the Early Warning Signs
Step 2.1 : Preparation
Step 2.3: Immediate
Actions if a Bloom is
Suspected
Step 1 : Assess Source
Water
Step 3: Raw Water
Cyanotoxin Monitoring
and Treatment
Adjustments
Step 5: Continued
Finished Water
Cyanotoxin Monitoring,
Treatment Adjustments,
and Public
Communication
Step 4: Finished Water
Cyanotoxin Monitoring
and Treatment
Adjustments
Continue
monitoring,
treatment, and
communication
activities as needed.
Return to previous
steps as appropriate.
Continue evaluating
for possible bloom
(Step 2.2).
Begin any
preparation, as
needed, for
monitoring,
treatment and
communication.
Concurrently begin
Step 3 and Step 4.
Cyanotoxins: Actions to Monitor
Occurrence and Minimize
Exposure
Village of Perry Water System Cyanotoxin Management Plan -Appendix A
E2.19
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Appendix B
Contacts and Stakeholder Information
Stakeholders
Agency/Company
Title
Contact Name
Contact Phone
Contact Email
NYS Dept. of Health -
Bureau of Water Supply
Protection, Albany
NYS Dept. of Health
Regional Office
Wyoming County Health
Department
Livingston County Health
Department
Neighboring Public Water Systems
Town of Perry Water
System
Town of Castile Water
System
Mt. Morris Water
Department
Stakeholders Whom Wyoming County Health Dept. Will Contact
Silver Lake Association
Camp Arthur Hough YMCA
Camp Asbury
Emerling Farm
Veterinarians in the region
Medical doctors in the
region
Wyoming County Soil and
Water Conservation
District
Perry Central School
Calvary Church Private
School
Licensed Daycares
Registered Dialysis Centers
Village of Perry Water System Cyanotoxin Management Plan - Appendix B
E2.20
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Appendix C
Notifying the Public of Cyanotoxins in their Water
At the time of publication of this document, public water systems are not currently required to notify
their customers of any bloom or cyanotoxin occurrence and are not required to include detections as
part of a system's Consumer Confidence Report under any National Primary Drinking Water Regulations.
Systems should consider consulting with their state or primacy agency to determine if they are subject
to any state or tribal notification requirements. Although not currently required by federal regulations,
water systems may want to consider communicating with their consumers if cyanotoxins in finished
water are confirmed in additional samples. This communication may be received more positively if the
water systems have engaged in prior communication with the public about HABs. A water system is
encouraged to tailor its communications based on the cyanotoxin levels detected.
In fall 2016, the USEPA released the drinking water cyanotoxin risk communication toolbox. This toolbox
is a ready-to-use, "one-stop-shop" to support public water systems, states and local governments in
developing, as they deem appropriate, their own risk communication materials. It includes editable
worksheets, press release templates, social media posts and other quick references. The materials focus
on communicating risk and providing background information to the public prior to and during a
drinking water cyanotoxin contamination event as well as general information on harmful algal blooms
and cyanotoxins. For the full toolbox please the USEPA's Cyanotoxin Risk Communication Toolbox.
Below are some sample templates from that toolbox that are ready-to-use for cyanotoxin Drinking
Water Advisories. Brackets ( [ ] ) are included as prompts to fill in system-specific information. There are
three template options available, one for each of the following scenarios, when toxin levels in finished
drinking water are:
Above the U.S. Environmental Protection Agency's Health Advisory level for children six years
and older and adults;
Above the U.S. Environmental Protection Agency's Health Advisory level for infants and young
children under the age of six, but less than or equal to the Health Advisory level for children six
years and older and adults;
Less than or equal to the U.S. Environmental Protection Agency's Health Advisory level for
infants and young children under the age of six, and a Drinking Water Advisory is lifted.
As means of an example, these United States Environmental Protection Agency's Health Advisory levels
for microcystins and cylindrospermopsin are used as cyanotoxin levels that inform public
communication decisions in these Drinking Water Advisories. Materials can be edited to include any
information determined appropriate by states and public water systems such as different cyanotoxin
levels that inform public communication decisions.
Village of Perry Water System Cyanotoxin Management Plan - Appendix C
E2.22
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DRINKING WATER ADVISORY
[CYANOTOXIN NAME] is present in [WATER SYSTEM NAME]
DO NOT DRINK THE TAP WATER
[Date issued]
Why is there an advisory?
[Cyanotoxin name], a toxin produced by cyanobacteria (formerly known as blue-green algae)
was detected in the drinking water from [System name] on [date],
Elevated levels of toxins have been detected in [source name] that supplies water to
[geographic area, cities, counties, distribution system segments, etc.],
[System name] is taking the following actions to reduce [cyanotoxin name] levels: [list
actions such as: adjusting treatment, changing source, etc.],
Samples collected on [dates] show [cyanotoxin name] in the drinking water at [levels and/or
ranges], which are above the U.S. Environmental Protection Agency's [cyanotoxin name]
national drinking water Health Advisory of [level].
What should I do?
Do Not Drink the tap water.
[Alternative sources of water] should be used for drinking, making infant formula, making ice
and preparing food and beverages.
Do Not Boil the tap water. Boiling the water will not destroy cyanotoxins and may increase the
toxin levels.
Everyone may use tap water for showering, bathing, washing hands, washing dishes, flushing
toilets, cleaning and doing laundry. However, infants and young children under the age of six
should be supervised while bathing and during other tap water-related activities to prevent
accidental ingestion of water.
Drinking water containing [cyanotoxin name] at levels exceeding the national drinking water
Health Advisories can put you at risk of various adverse health effects including upset stomach,
vomiting and diarrhea as well as liver and kidney damage. Seek medical attention if you or
family members are experiencing illness.
Animals may be vulnerable to adverse health effects of [cyanotoxin name] at the detected levels
indicated above; consider providing animals alternative sources of water. Contact a veterinarian
if animals show signs of illness.
If you, your family members or your animals have experienced adverse cyanotoxin-related
health effects, please contact [State or local Health Department] to report the illness.
What is being done?
[System name] is working closely with local and state public health and emergency response
agencies to address the situation and to quickly to reduce [cyanotoxin name] levels in tap water.
[System name] will post an updated advisory when: the [cyanotoxin] levels are less than or
equal to the national drinking water Health Advisories, this Do Not Drink Advisory is lifted
and/or if there are any changes to the conditions of this Do Not Drink Advisory.
Village of Perry Water System Cyanotoxin Management Plan - Appendix C E2.23
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For more information please contact [contact information] or visit [website].
Please share this information with all the other people who drink this water, especially those who may not have
received this notice directly (for example, people in apartments, nursing homes, schools and businesses). You can do
this by posting this notice in a public place or distributing copies by hand.
This notice is being sent to you by [system]. State Water System ID#: Date distributed:
Village of Perry Water System Cyanotoxin Management Plan - Appendix C
E2.24
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DRINKING WATER ADVISORY
[CYANOTOXIN NAME] is present in [WATER SYSTEM NAME]
INFANTS, YOUNG CHILDREN AND OTHER
VULNERABLE POPULATIONS: DO NOT DRINK THE TAP
WATER
[Date issued]
Why is there an advisory?
[Cyanotoxin name], a toxin produced by cyanobacteria (formerly known as blue-green algae),
was detected in the drinking water from [System name] on [date],
Elevated levels of toxins have been detected in [source name] that supplies water to
[geographic area: cities, counties, distribution system segments, etc.],
[System name] is taking the following actions to reduce [cyanotoxin name] levels: [list
actions such as adjusting treatment, changing source, etc.],
Samples collected on [dates] show [cyanotoxin name] in the drinking water at [levels and/or
ranges], which are above the U.S. Environmental Protection Agency's [cyanotoxin name]
national drinking water Health Advisory for vulnerable populations (listed below) of [level].
What should I do?
The following vulnerable populations should Not Drink the tap water because they may be
vulnerable to the effects of [cyanotoxin name]:
o Infants,
o Young children under the age of six,
o Pregnant women and nursing mothers,
o Those with pre-existing liver conditions,
o Those receiving dialysis treatment, and
o As a precautionary measure, the elderly and other sensitive populations should consider
following these advisory instructions.
Vulnerable populations, listed above, should use [alternative sources of water] for drinking,
making infant formula, making ice and preparing food and beverages.
Do Not Boil the tap water. Boiling the water will not destroy toxins and may increase the toxin
levels.
Individuals not considered to be in the vulnerable category, as listed above, may drink the
water.
Everyone may use tap water for showering, bathing, washing hands, washing dishes, flushing
toilets, cleaning and doing laundry. However, infants and young children under the age of six
should be supervised while bathing and during other tap water-related activities to prevent
accidental ingestion of water.
Vulnerable populations, as listed above, who drink water containing [cyanotoxin name] at levels
exceeding the national drinking water Health Advisories are at risk of various adverse health
Village of Perry Water System Cyanotoxin Management Plan - Appendix C E2.25
-------
effects including upset stomach, vomiting and diarrhea as well as liver and kidney damage. Seek
medical attention if you or family members are experiencing illness.
Animals may be vulnerable to adverse health effects of [cyanotoxin name] at the detected levels
indicated above; consider providing animals alternative sources of water. Contact a veterinarian
if animals show signs of illness.
If you, your family members, or your animals have experienced adverse cyanotoxin-related
health effects, please contact [State or local Health Department] to report the illness.
What is being done?
[System name] is working closely with local and state public health and emergency response
agencies to address the situation and quickly reduce [cyanotoxin name] levels in tap water.
[System name] will post an updated advisory when: the [cyanotoxin] levels are less than or
equal to the national drinking water Health Advisories, this Do Not Drink Advisory is lifted
and/or if there are any changes to the conditions of this Do Not Drink Advisory.
For more information please contact [contact information] or visit [website].
Please share this information with all the other people who drink this water; especially those who may not have
received this notice directly (for example, people in apartments, nursing homes, schools and businesses). You can do
this by posting this notice in a public place or distributing copies by hand.
This notice is being sent to you by [system]. State Water System ID#: Date distributed:
Village of Perry Water System Cyanotoxin Management Plan - Appendix C
E2.26
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DRINKING WATER ADVISORY LIFTED
for [WATER SYSTEM NAME]
Everyone May Drink the Tap Water
[Date issued]
Why is the advisory lifted?
Drinking water advisory issued on [date] for [System name] that supplies water to [geographic
area: cities, counties, distribution system segments, etc.] has been lifted.
Samples collected on [dates] shows [cyanotoxin name] in the drinking water at [levels and/or
ranges], which are [less than or equal to] the U.S. Environmental Protection Agency's
[cyanotoxin name] national drinking water Health Advisory of [level],
[System name] took the following actions to reduce [cyanotoxin name] levels: [list actions such
as adjusting treatment, changing source, etc.].
What should I do?
Everyone may resume using the tap water for all uses.
[Insert any suggested activities for customers when resuming consumption of their tap water],
[Insert any actions taken by public water supply to reduce risks of cyanotoxins in drinking water
in the future].
Please share this information with all the other people who drink this water, especially those who may not have
received this notice directly (for example, people in apartments, nursing homes, schools and businesses). You can do
this by posting this notice in a public place or distributing copies by hand.
This notice is being sent to you by [system]. State Water System ID#: Date distributed:
Village of Perry Water System Cyanotoxin Management Plan - Appendix C
E2.27
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Cyanotoxins Management Plan
Akron Water Supply Bureau
Kent, Ohio
November, 2016
E3.1
-------
Table of Contents
Executive Summary E3.4
Akron Water Supply Bureau Overview E3.5
Source Water E3.6
Treatment Process E3.7
Routine Water Quality Monitoring E3.8
Cyanotoxin Management Plan E3.ll
Step 1: Assess Source Water E3.13
1.1 Identify Source Water Protection Areas E3.13
1.2 Create an Inventory HABs Risk Factors E3.13
1.2.1 Source Water Characteristics E3.13
Land Use E3.14
1.2.2 Water Quality Parameters E3.14
Historical Cyanobacteria and Cyanotoxin Events in Source Water E3.14
Nutrients E3.14
Point and Nonpoint Sources of Pollution E3.14
1.3 Assess Vulnerability E3.15
Step 2: Preparation, Monitoring for Early Warning Signs and Immediate Actions E3.16
2.1 Preparation E3.16
Prepare Staff and Equipment for Monitoring E3.16
Prepare for Treatment Adjustments E3.16
Communications E3.17
Water Utilities with the Same Source Water E3.17
Communication with Stakeholders E3.17
2.2 Monitoring the Early Warning Signs E3.17
Early Indicators of a Cyanobacterial Bloom E3.17
2.3 Immediate Actions if a Bloom is Suspected E3.18
Monitoring Actions in Response to Early Warning Signs E3.18
Communication Actions in Response to Early Warning Signs E3.18
Source Water Mitigation Actions in Response to Early Warning Signs E3.18
Step 3: Raw Water Cyanotoxin Monitoring and Treatment Adjustments E3.20
Monitoring if Cyanobacteria are Identified or Suspected E3.20
Operational Adjustments Based on Raw Water Cyanotoxin Measurements E3.20
Communications Based on Source Water Cyanotoxin Measurements E3.20
Step 4: Finished Water Cyanotoxin Monitoring and Treatment Adjustments E3.21
Finished Water Microcystins Monitoring E3.21
Treatment E3.21
Communications E3.22
E3.2
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Step 5: Continued Finished Water Cyanotoxin Monitoring, Treatment Adjustments and Public
Communication E3.23
Continued Finished Water Microcystins Monitoring E3.23
Communications E3.23
Long-Term Activities E3.24
Monitoring Activities E3.24
Source Water Protection Management Approaches E3.24
Appendices
Appendix A Cyanotoxin Management Flowchart E3.26
Appendix B Contacts and Stakeholder Information E3.27
Appendix C Notifying the Public of Cyanotoxins in their Water E3.28
Appendix D Ohio State Monitoring Requirements E3.30
E3.3
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Executive Summary
The Akron Water Supply Bureau, with the support of the State of Ohio and the United States
Environmental Protection Agency (USEPA), developed this Cyanotoxins Management Plan (CMP) to
prepare for and mitigate risks from harmful algal blooms (HABs) and cyanotoxins occurring in Lake
Rockwell (also referred to as Rockwell Reservoir) and to protect public drinking water from cyanotoxin
contamination. This document provides steps and documents activities to prepare for and identify a
potential HAB occurrence, make treatment and operational adjustments to remove cyanotoxins from
the water, provide timely information and (as appropriate) an advisory to the water system's customers,
and document information about occurrences of HABs so that information can be used to minimize the
effect of HABs on the water system in the future. This plan also contains possible future activities the
utility could engage in to mitigate the risks from HABs and cyanotoxins, such as long-term source water
protection activities.
The steps outlined in this CMP include:
Step 1: Assess Source Water
Step 2: Preparation, Monitoring for Early Warning Signs and Immediate Actions
Step 3: Raw Water Cyanotoxin Monitoring and Treatment Adjustments
Step 4: Finished Water Cyanotoxin Monitoring and Treatment Adjustments
Step 5: Continued Finished Water Cyanotoxin Monitoring, Treatment Adjustments and Public
Communication
In addition to the five steps above, long-term activities are also discussed to enhance the utility's ability
to prevent, mitigate and manage the risks from cyanotoxin occurrence in source and finished waters.
Akron Water Supply Bureau Cyanotoxin Management Plan - Executive Summary
E3.4
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Akron Water Supply Bureau Overview
The Akron Water Supply Bureau serves 280,000 people in Summit County, OH and draws its water from
Lake Rockwell, which is fed by upstream East Branch and LaDue Reservoirs via the Cuyahoga River.
Water from Lake Rockwell is treated at a nearby treatment plant, and then pumped eleven miles to
Akron through three transmission mains into equalizing reservoirs. It is then distributed to more than
95,000 households. The treatment plant's average production is 35 million gallons per day (MGD), with
two in-ground finished water reservoirs and several standpipes.
The Water Supply Bureau consists of 3 divisions: the Watershed Division; the Water Plant Division; and
the Water Distribution Division. Each Division has the following responsibilities:
The Watershed Division
Source water quality protection and security
Management of four raw water reservoirs and nearly 20,000 acres of City owned property
Administration of limited recreational programs
Public education programs focused on water treatment and watershed protection
Implementation of an USEPA approved Watershed Control Program
Water Plant Division
Operation and maintenance of an Ohio Environmental Protection Agency (EPA) Class IV drinking
water treatment facility
Regulatory compliance responsibilities including an on-site certified laboratory
Supervisor Control and Data Acquisition (SCADA) System
Current and past Consumer Confident Reports
Water Distribution Division
Operation and maintenance of a more than 1,200 mile water distribution system serving
approximately 280,000 customers
Operation and maintenance of multiple pump stations, finished water holding reservoirs,
elevated tanks and standpipes
Industrial and residential meter reading and backflow protection
Akron Water Supply Bureau Cyanotoxin Management Plan - Overview
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Source Water
CHARDON
Lake Co
CLEVELAND
East Branch Reservoir
La Due Reservoir
Cuyahoga Co
Lake Rockwell'
STOW
.KENT
TALLMADG
AKRON,
AKRON WATER SUPPLY SYSTEM
Lake Erie /
a/
Legend
~ Water Retail Distribution System
Watershed
Mogadore Rese
Medina Co. I
Wayne Co
Stark Co.
Summit Co
Portage Co.
Lake Rockwell is located in Franklin Township, Portage County, Ohio. The reservoir was formed when
the Upper Cuyahoga River was dammed in 1915. Lake Rockwell holds approximately two billion gallons
of water. The elevation of the Reservoir is 1,052 ft. above mean sea level at the spillway crest.
Flashboards are installed in the spring and removed in the fall and bring the elevation up to 1053.5 ft.
above mean sea level during the summer months. Discharge is controlled through three valves in the
dam gatehouse and spilled water exits back out into the Middle Cuyahoga River.
Akron Water Supply Bureau Cyanotoxin Management Plan - Overview
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Lake Rockwell has one active intake. This intake draws the water in through a syphon tank. A second
intake is not being used due to its location in proximity to the bottom of the lake with reduced water
quality and because it does not have the ability to feed pre-treatment chemicals into the structure. The
third intake can be used but powdered activated carbon (PAC) and chlorine dioxide (CI02) cannot be fed
into the intake. It is currently used as a bypass feeding water downstream of the spillway. The hydraulic
residence time of Lake Rockwell is two to four weeks.
There are two upstream secondary source water reservoirs, East Branch and LaDue. The secondary
reservoirs are used to supplement the water in Lake Rockwell. There is no additional redundant source
water. While quantity is usually not an issue, in the summer months water quality can be impaired due
to algal and cyanobacterial blooms, which can limit treatment options.
Reservoir Management
The Akron Water Supply Bureau treats the source water with a commercial chelated copper algaecide
(Cutrine Ultra) to decrease cyanobacterial blooms when cyanobacterial populations are start increasing.
Treatment occurs in a targeted fashion so the entire lake does not need to be treated. Treating source
water for algae like this is Akron Water Supply Bureau's primary approach to ensuring algal toxins do not
make it to finished water.
Treatment Process
A schematic of drinking water treatment provided by the Akron Water Supply Bureau is presented in
Figure 1. Once water enters the plant, it is treated by one of four parallel treatment trains. The hydraulic
residence time of the plant is eight to twelve hours. The following treatment process is provided:
1. Filter Screens: Water first passes through filter screens that keep out fish and large debris. The
screens are cleaned three times a week with compressed air blowing through them to keep
clean of debris.
2. Potassium Permanganate: Potassium permanganate is added at the intake well to control odor
and color problems. The system feeds about 0.5 mg/L but can feed up to 1.2 mg/L. Water
travels a quarter of a mile from the intake well to the treatment plant, which provides enough
contact time for the permanganate to oxidize manganese, iron and taste and odor compounds.
3. PAC: PAC is sometimes added at the intake to remove taste and odor compounds and
cyanotoxins. The low dose of PAC is 3 mg/L; however the plant has the capacity to increase that
dose up to 50 mg/L if needed. The PAC is selected on a yearly basis using jar testing and
fluorescence analysis (note: Akron Water Supply Bureau currently uses fluorescence analysis to
measure organics removal to determine coagulant dose).
4. Coagulation, CI02 and Flocculation: Alum is added as a coagulant and mixed rapidly to form floes
in the water. CI02 is added at one of three points in the intake (one location just before the flash
mix as well as at two locations within the intake closer to the intake itself) to disinfect the water
and oxidize iron, manganese and organic chemicals associated with taste and odor problems
(note: Figure 1 shows CI02 being injected into the rapid mixer, which is discontinued). The
benefit of CI02 over chlorine is that it does not form harmful trihalomethanes or haloacetic acids
when combined with organic chemicals as elemental chlorine can. (CI02 is discontinued during a
HAB event due to concerns with cell lysing.)
5. Settled water: Sodium hypochlorite is added at the end of the basins prior to filtration to
improve filter performance.
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6. Sedimentation: Floe particles settle in one of several sedimentation basins. Sludge is removed
from the basins and dried in drying basins before it is hauled away. By the end of the
sedimentation step, approximately 99% (2-log) of the particles in the water have been removed.
7. Filtration: Akron's plant has 25 rapid sand filters that generally filter flows up to 2 MGD each.
The filter media consists of anthracite coal and fine sand.
8. Sodium Hypochlorite, Zinc Orthophosphate, Fluoride and Caustic Addition: Sodium hypochlorite
is added for secondary disinfection. Zinc orthophosphate is added for corrosion control.
Fluoride, in the form of hydrofluorosilicic acid, is added to reduce tooth decay. Caustic soda is
added for corrosion control by adjusting the pH in the water.
In addition to algal issues, the Akron Water Supply Bureau provides additional treatment and protection
for Cryptosporidium. The Bureau has developed and implemented a Watershed Control Plan and
optimizes its filtration in order to reduce the risk of Cryptosporidium in the finished water.
Routine Water Quality Monitoring
The Akron Water Supply Bureau completes Watershed Control Program annual reports, which have the
most up to date sampling locations, procedures and data that is compiled and sent to the Ohio EPA. The
reports are developed to comply with the Long Term 2 Enhanced Surface Water Treatment Rule.
Monthly stream sampling at 19 points in the watershed includes: temperature, dissolved oxygen,
ammonia, total phosphorus, fecal coliform and total suspended solids. In addition, the Akron Water
Supply Bureau monitors all three reservoirs routinely, as summarized in Table 1 below. The Akron Water
Supply Bureau collects some of its own data and therefore it is immediately available for analysis. The
staff who conduct the sampling are certified lab analysts or are under the supervision of certified lab
analysts.
Table 1. Routine Raw Water Quality Monitoring
Parameter
Locations
Frequency
Who Collects
Sample?
Who Does Analysis?
Temperature
PH
Dissolved Oxygen
Conductivity
Chlorophyll-o
Phycocyanin
Gate houses at
LaDue and East
Branch Reservoirs;
intake pier at Lake
Rockwell from
November through
March and during
summer, at both
intake pier and mid-
lake, near mouth of
Eckert Ditch; every
meter of depth
from surface to
floor
Once a month in winter,
more often if conditions
that deviate from
expected baseline are
observed, minimum twice
per month, but usually
once a week in summer
Akron Water
Supply Bureau
personnel
Akron Water Supply
Bureau personnel
using a sonde
qPCR for Microcystin
Intake, Mid-lake
Once a month in winter,
more often if conditions
that deviate from
expected baseline are
observed, minimum twice
per month, but usually
once a week in summer
Akron Water
Supply Bureau
personnel
Akron Water Supply
Bureau personnel
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Parameter
Locations
Frequency
Who Collects
Sample?
Who Does Analysis?
Algal/Cyanobacterial
Intake, Mid-lake
Once a month in winter,
Akron Water
Akron Water Supply
Identification
more often if conditions
that deviate from
expected baseline are
observed, minimum twice
per month, but usually
once a week in summer
Supply Bureau
Personnel
Bureau personnel
Fluorescence
Basins, tap
Weekly
Akron Water
Supply Bureau
Personnel
Akron Water Supply
Bureau Personnel
Geosmin and MIB
Intake (weekly),
Weekly, when receive
Akron Water
Akron Water Supply
intake and EPTDS (if
complaints or results are
Supply Bureau
Bureau personnel
complaint driven or
high, and every time they
personnel
results have been
collect a raw water
high), Secondary
microcystins sample
Reservoirs
Visual inspection
Intake and at Eckert
Daily
Akron Water
Akron Water Supply
Ditch from the
Supply Bureau
Bureau personnel
shore each day
personnel
At the LaDue and East Branch Reservoirs, monitoring occurs at the gate house. In the winter - roughly
November through March - monitoring at Lake Rockwell occurs at the intake pier. During the summer
months, samples are collected at both the intake pier and mid-lake, just downstream from where the
Eckert Ditch tributary enters into the Lake. Each reservoir is profiled using a sonde unit to obtain
measurements at every meter of depth from surface to floor for temperature, pH, dissolved oxygen,
conductivity, chlorophyll-o and phycocyanin. Additional samples are collected if a visible bloom or
surface scum is detected on Lake Rockwell.
During the winter, monitoring is conducted once per month unless conditions are met to indicate the
need for increased monitoring frequency, such as abnormal pH, dissolved oxygen or turbidity levels
coming into the plant that deviate from expected baseline levels. In the summer, monitoring is
conducted at a minimum of twice per month, but generally takes place closer to once per week.
Akron Water Supply Bureau also measures fluorescence in the raw water and settled water to decide on
coagulant dose. They work with the University of Akron to determine these measurements.
The Akron Water Supply Bureau tests their water for geosmin and MIB paired with a raw water total
microcystins sample. They sample the intake weekly and increase the PAC dose if they receive customer
complaints from the "super tasters" (or those most likely to comment on water taste) or if the geosmin
or MIB results are high. When they look into taste and odor, they pair intake and entry point to the
distribution system (EPTDS) samples for taste and odor compound analysis. They visually inspect the
water at the intake and at Eckert Ditch from the shore each day.
Beginning in June 2016, Akron was required to start weekly monitoring for raw water total microcystins
in order to comply with Ohio EPA's new cyanotoxin regulation. Table 2 below summarizes the total
microcystins monitoring schedule for complying with this new regulation. In summary, Ohio's
requirement establishes monitoring requirements for public water systems using surface water
including routine weekly source and finished water monitoring for microcystins from May 1 to October
Akron Water Supply Bureau Cyanotoxin Management Plan - Overview
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31. Routine total microcystins monitoring drops to biweekly source water monitoring from November 1
through April 30 (total microcystins detections will indicate the need for increased monitoring). If total
microcystins levels greater than 5 ng/L are found in the raw water, the public water system must
increase monitoring to three days a week. Section A(2)(d) of Ohio's regulation requires the frequency of
monitoring at both raw and finished water sampling points to be increased to daily if microcystins are
detected at finished water sampling points.
The Akron Water Supply Bureau has two main EPTDS, and alternates between them for their required
weekly microcystins sampling. The system also samples at a subset of the Disinfection Byproducts (DBP)
Rule monitoring locations in the distribution system, rotating around the DBP sites.
Table 2. Ohio Total Microcystins Monitoring Requirements
Location
Analysis1
During
Which
Months?
Monitoring
Category
Frequency2
Raw Water
Cyanobacteria/cyanotoxin
genetic screening (qPCR
for 16S, mycF, sxtA and
cyrA genes)
Year-Round
Routine
Once every 2 weeks (at the
same time as routine total
microcystins sample)
Raw and
Total Microcystins
May 1st-
Routine
Weekly
Finished Water
October 31st
Raw and
Total Microcystins
November
Routine
Weekly unless not detected
Finished Water
1st-April
30th
in at least 2 consecutive
weekly samples from both
raw and finished water
sampling points. Then
frequency is reduced to one
sample from each raw water
sampling point at least once
every 2 weeks.
Raw and
Total Microcystins
November
Routine if there is
If detected at raw water
Finished Water
1st-April
30th
a detection
sampling point, weekly
monitoring at raw and
finished water sampling
points will begin no later
than 24 hours following
detection.3
Raw and
Total Microcystins
Year-Round
Increased
3 days a week, beginning no
Finished Water
Routine (3 days a
week)
later than the following
week, if microcystins exceed
5 |ig/L at raw water sampling
point.3
Raw and
Total Microcystins
Year-Round
Increased
Daily, if microcystins
Finished Water
Routine (Daily)
detected at finished water
sampling point. Daily
monitoring will include
analysis within 24 hours of
sample collection.3
^otal microcystins measured by the Ohio EPA Total (Extracellular and Intracellular) Microcystins - ADDA
by ELISA Analytical Methodology.
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2See Ohio EPA's regulation in Appendix D for details about what monitoring is required if monitoring
results exceed the action level.
3See Ohio EPA's regulation in Appendix D for details about how to return to routine monitoring.
Cyanotoxin Management Plan
Akron Water Supply Bureau developed this Cyanotoxins Management Plan (CMP) detailed in the steps
below. This CMP provides an action plan to prepare for and mitigate risks from Harmful Algal Blooms
(HABs) and cyanotoxins occurring in Lake Rockwell in order to protect public drinking water from
cyanotoxin contamination. The plan includes immediate steps discussing monitoring and treatment
should HABs and cyanotoxins occur as well as long-term steps the system can engage in to protect
source waters and to fully evaluate treatment capabilities. A detailed flowchart of the CMP can be found
in Appendix A.
Akron Water Supply Bureau Cyanotoxin Management Plan - Overview
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Figure 1. Schematic Diagram of the Treatment System
Chlorine
PAC
Potassium
permanganate
PAC
Intake at
Lake
Rockwell
Fine filter
screens
Chemical Flash
Mixer
Flocculation Sedimentation
Zinc
orthophosphate
Chlorine
Fluoride
Filtration
(anthracite
coal and fine
sand)
Caustic
Soda
Distribution
System
Clearwell
Akron Water Supply Bureau Cyanotoxin Management Plan - Overview
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Step 1: Assess Source Water
1.1 Identify Source Water Protection Areas
Map 1 below delineates (maps) the watershed for Lake Rockwell.
ฆI Akron Water Supply Reservoirs
/\/ Cuyahoga River
LANDUSES
Open Water
Low Intensity Residential
High Intensity Residential
Comm erciail/lndusJrlal/T ransportation
Quarries/Strip Mines/Gravel Pits
Transitional
Deciduous Forest
Evergreen Forest
Mixed Forest
Pasture/Hay
Row Crops
LIrban/Recreatlonai Grasses
Woody Wetlands
Emergent Herbaceous Wetlands
Upper Cuyahoga River Basin
Landuse/Landcover
2 0 2 4 6 8 Miles
1:198490
Map 1. Akron water supply reservoirs and land use
(http://www.eoa.state.oh.us/oortals/35/tmdl/uDCuv final 090304.pdf)
1.2 Create an Inventory of HABs Risk Factors
1.2.1 Source Water Characteristics
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Phosphorus and nitrogen are drivers of algal and cyanobacterial growth in lakes and reservoirs. Sources
of phosphorus and nitrogen can include discharge of domestic and industrial wastewater, septic systems
and runoff from agricultural and urban lands.
Land Use
Map 1 and Map 2 detail land uses within the Lake Rockwell watershed.
1.2.2 Water Quality Parameters
Lake Rockwell is within the Cuyahoga River Basin, which has been assessed for attainment of surface
water quality standards under Section 305(b) of the Clean Water Act (CWA). Based on these
assessments, the Cuyahoga River Basin was listed as impaired for phosphorus and sediment under
Section 303(d) of the CWA, and has had a Total Maximum Daily Load (TMDL) developed in response to
the impairment listing. The Cuyahoga River Basin TMDL includes the main stem of the Cuyahoga River as
well as its feeder stream (Eckert Ditch). The TMDL defines targets for nutrient loading to the Cuyahoga
River and outlines strategies for reducing phosphorus and sediment loading, which will ultimately
reduce algal and cyanobacterial growth.
Historical Cyanobacteria and Cyanotoxin Events in Source Water
Monitoring of Akron's source water has found microcystins on several occasions and toxin-producing
genera of cyanobacteria including Anabaena, Aphanizomenon, Planktothrix, Microcystis and occasionally
Lyngbya. The Akron Water Supply Bureau expects blooms 1-2 weeks after a rain event that is followed
by hot, sunny weather and little wind. Normally Akron staff see a succession of dominant algal
populations, beginning with diatoms until early May, followed by a brief period of green algae. As
temperatures increase and Lake Rockwell stratifies, the phytoplankton population shifts toward
cyanobacteria, resulting in a bloom by mid-May or June. That bloom will then die off, but another will
take its place after a week or two of sun and lower turbidity water. The cycles do not slow down until
the beginning of October, when the cyanobacteria population declines and diatoms become the
dominant phytoplankton. Blooms typically start at the shallow northern end of the reservoir, then often
progress and migrate south toward the dam, in keeping with the lake's detention time. Taste and odor
issues are occasionally a precursor to blooms, but since Akron staff monitor for bloom presence on the
lake often, they normally catch blooms starting before the taste and odor compounds make it to the
plant.
Nutrients
Point and Nonpoint Sources of Pollution
Map 1 shows the delineation of Akron's water supplies, as well as land use in the watershed. Nutrient
pollution within the Lake Rockwell drainage areas results from both urban land cover and agricultural
land cover as both point and nonpoint source pollution. The USEPA Drinking Water Mapping Application
to Protect Source Waters (DWMAPS) tool indicates that there are 11 National Pollutant Discharge
Elimination System (NPDES) permitted wastewater dischargers and no Combined Sewer Overflows
within 15 miles upstream of the intake (Map 2). There are also additional NPDES dischargers further
upstream in the Upper Cuyahoga River Basin. However, the Upper Cuyahoga TMDL report cites only four
significant NDPES dischargers in the Upper Cuyahoga River Basin (Hans Rothenbuhler and Sons,
Middlefield Waste Water Treatment Plant (WWTP), Burton WWTP and Mantua WWTP). In addition to
agricultural nonpoint source pollution, stormwater runoff is another significant source of nonpoint
Akron Water Supply Bureau Cyanotoxin Management Plan - Step 1
E3.14
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urban nutrient pollution as cited in the Upper Cuyahoga River Basin TMDL report. The report can be
found at http://www.epa.state.oh.us/portals/35/tmdl/upCuy final 090304.pdf
Selected 303(d) Listed
Impaired Waters matching
query
Selected 303(d) Listed
Impaired Waters matching
query
NPDES Sewerage Facilities
ฆ
NPDES Other Facilities
Combined Sewer Overflows
(CSO)
9
d use
| Developed, medium intensity
Developed, open space
Pasture/hay
Cultivated crops
Map 2. 24 hours upstream of Lake Rockwell/Cuyahoga intake and land use, point sources in
watershed
1.3 Assess Vulnerability
A weight of evidence approach was used to characterize the source water's vulnerability to HABs and
cyanotoxin occurrence. Evidence includes all of the discussion in this section including: the land uses
that contribute to nutrient pollution in the watershed, the existing phosphorus and sediment TMDL in
Lake Rockwell and the historical occurrence of HABs in Akron's source water. Given these lines of
evidence, Lake Rockwell has been considered vulnerable to cyanobacteria and cyanotoxins (continue to
Step 2).
Akron Water Supply Bureau Cyanotoxin Management Plan - Step 1
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Step 2: Preparation, Monitoring for Early
Warning Signs and Immediate Actions
2.1 Preparation
Akron Water Supply Bureau determined that its source water is vulnerable to cyanobacterial blooms.
The next step is to consider how to prepare for cyanobacterial blooms and cyanotoxin occurrence.
Preparation includes: preparing for monitoring raw and finished waters, preparing for treatment
adjustments and establishing communication plans in order communicate with stakeholders as quickly
as needed.
Prepare Staff and Equipment for Monitoring
The Akron Water Supply Bureau will carry out the following activities in order to be prepared for the
monitoring steps described in this plan:
Ensure that the Akron Water Supply Bureau's procedure for submitting microcystins samples to
the laboratory complies with all of the new Ohio regulation's sampling, analytical and reporting
methods as discussed in Appendix D.
Have coolers, chain of custody forms and shipping labels on site and ready for use.
Ensure that the appropriate bottles (glass or PETG) are on site for sampling.
Have sodium thiosulfate available for quenching any samples that have been exposed to an
oxidant as soon as they are collected.
Document all sampling, testing and quality assurance procedures.
Install another sonde anchored mid-lake that reports data to SCADA so that operators can
observe real-time data in order to make informed treatment decisions. A sonde installed further
north in the lake would provide real-time early warning of water quality changes that have
taken place in the lake but are not yet apparent at the intake. Tying the sonde into the water
system's SCADA would enable the system to set alarms at water quality thresholds that may
indicate the need for operational or treatment changes.
Prepare for Treatment Adjustments
Akron Water Supply Bureau will carry out the following activities in order to be more prepared to treat
its source water during a HAB:
Develop a treatment optimization protocol (a requirement by the Ohio EPA for systems with
raw or finished water microcystins detections).
Work with the University of Akron to determine the optimal PAC type and dose through jar
tests and to perform fluorescence studies for the DBP control. Akron Water Supply Bureau
currently uses fluorescence analysis to measure organics removal in the raw water and
settled water to decide on coagulant dose, in consultation with the University of Akron.
Continue to stay prepared by ensuring that their finished water storage tanks are fully
turning over and remain full.
Utilize reservoir management strategies (including algaecide application) to proactively
control cyanobacteria populations. Note: Ohio EPA's pesticide general permit restricts
Akron Water Supply Bureau Cyanotoxin Management Plan - Step 2
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algaecide application to severe blooms (>100,000 cyanobacteria cells/ml or visible scums)
that cover greater than 20% of a drinking water reservoir or are within 500 yards of an
active intake.
Communications
Water Utilities with the Same Source Water
No other public water systems use the same surface water sources as the City of Akron.
Communication with Stakeholders
The Akron Water Supply Bureau will carry out the following activities in order to be more prepared for
the communications steps described in this plan:
Meet with consecutive systems to review what they have to do if microcystins are detected
in Akron's finished water. Akron will provide sampling bottles and collect samples. (Action
items are described in Ohio EPA's Public Water System Harmful Algal Bloom Response
Strategy available at
http://epa.ohio.gov/Portals/28/documents/HABs/PWS HAB Response Strategy.pdf).
Update the advisories currently in the Emergency Operating Plan (current plan on actions to
take in emergency situations with all contaminants) with the required ones from the Ohio
EPA regulation.
2.2 Monitoring the Early Warning Signs
The Akron Water Supply Bureau anticipates blooms to occur one to two weeks after rain events that are
followed by hot, sunny weather and little wind. Historical sampling results have exhibited increased E.
coli counts and increased nitrogen and phosphorus concentrations upstream of the source water under
these conditions. Normally, Akron Water Supply Bureau operators observe a succession of dominant
algal populations, beginning with diatoms until early May, followed by a brief period of green algae. As
temperatures increase and the reservoir stratifies thermally, they see a shift toward cyanobacteria,
resulting in a bloom by mid-May or June. That bloom will then die off, but another will take its place
after a week or two of sun and lower turbidity water. The cycles typically do not slow down until the
beginning of October, when the flora returns to diatoms. Primary reservoir monitoring is conducted
visually and confirmed with sonde phycocyanin readings.
Early Indicators of a Cyanobacterial Bloom
The Akron Water Supply Bureau's operators have identified early warning signs that a cyanobacterial
bloom is likely to occur in the very near future (or has begun to occur). The following early warning signs
are a combination of observations of conditions in the lake itself and in the treatment plant:
Visual confirmation that there is a bloom present on the source water. Blooms normally start at
the shallow northern end of the reservoir, then progress and migrate south towards the dam.
Taste and odor issues are occasionally a precursor to blooms, but since observation on the lake
occurs so often, typically the Akron Water Supply Bureau watershed staff identify blooms
starting before the taste and odor compounds reach the plant.
Unexpected increase in either pH or dissolved oxygen at the intake.
Increase in chlorophyll-o or phycocyanin levels.
Akron Water Supply Bureau Cyanotoxin Management Plan - Step 2
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When the water temperature reaches 25 degrees Celsius the Akron Water Supply Bureau
watches closely for elevated phycocyanin (2,000 to 5,000 cells/mL with conversion). The Akron
Water Supply Bureau uses a conversion for phycocyanin measurements, with values of 7,000-
10,000 cells/mL in the raw water serving as a cause for concern. (2,000-5,000 cells/mL acts as a
baseline and 7,000-10,000 cells/mL points to the beginning of a bloom.)
2.3 Immediate Actions if a Bloom is Suspected
Monitoring Actions in Response to Early Warning Signs
Conduct weekly routine quantitative polymerase chain reaction (qPCR) analyses paired with
reservoir monitoring, collecting samples from the dam and mid-lake. Sample every week and
run the qPCR analyses in-house.
o If the qPCR determines a potential microcystins producer is present, sample for
microcystins at the same location; send to the laboratory in Cleveland for Adda-specific
ELISA analysis. (qPCR tests for the presence of the DNA for producing microcystin.)
o If a qPCR test result is positive, it means that cyanobacteria that can produce
microcystins are present. It does not, however, mean the toxin is present.
Sample source water with both profiles and surface water samples at mid-lake and at the dam,
close to the intake, using a sonde.
o If the water temperature is high, the pH is abnormal, or phycocyanin is high, collect a
sample and look at it under a microscope. Identify the algae or cyanobacteria, but do
not count.
o When there seem to be approximately 20,000 cells/mL (phycocyanin-derived number)
or microcystins have been identified, then count the cells. The Akron Water Supply
Bureau uses a conversion for phycocyanin measurements, with values of 8-10 cells/mL
in the raw water serving as a cause for concern.
If a bloom is suspected or when routine raw water monitoring is required continue to Step 3
(See Appendix D for monitoring requirements)
Communication Actions in Response to Early Warning Signs
Monitoring results are recorded into the water utility's minutes to coordinate with the Operations
Group in the Water Treatment Division. The Operations Group meets daily and includes bureau
employees in various positions such as operators, managers, engineers and maintenance. The
Watershed Division works with the treatment plant management to make decisions about when to
apply algaecide.
Source Water Mitigation Actions in Response to Early Warning Signs
Discuss the appropriateness of applying algaecide with the watershed group and consult with the
Watershed Superintendent. General decisions are made with these general guidelines:
Treatment does not occur when cell counts are too high due to concerns of cell lysing.
If cyanobacteria counts are > 30,000-40,000 cells/mL:
o If found at Eckert Ditch (stream that feeds into Lake Rockwell), apply algaecide.
o If next to the dam (near the intake), flush water over the dam, algaecide is not used.
Akron Water Supply Bureau Cyanotoxin Management Plan - Step 2
E3.18
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The Akron Water Supply Bureau treats the source water with copper based algaecide when
cyanobacteria populations are between 5,000 and 100,000 cells/mL. Treatment does not occur
when cell counts are too high (i.e. greater than 100,000 cells/mL) due to concerns of cell lysing.
The system applies algaecide roughly two to four times per month at the discretion of the
Watershed Superintendent.
Algaecide treatment is applied only at problem areas based on the sonde monitoring data,
rather than treating the entire lake.
Akron Water Supply Bureau Cyanotoxin Management Plan - Step 2
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Step 3: Raw Water Cyanotoxin Monitoring and
Treatment Adjustments
If a cyanobacterial bloom or its indicators are observed during Step 2. the Akron Water Supply Bureau
plans to begin analyzing samples in raw water for total microcystins as soon as possible in addition to
the required raw monitoring. If monitoring results indicate the presence of cyanotoxins in the raw water
Akron Water Supply Bureau continues to Step 4.
Akron Water Supply Bureau will communicate with its stakeholders and adjust its treatment or
operations based on raw water monitoring cyanotoxin results, as described in this section.
Monitoring if Cyanobacteria are Identified or Suspected
1. If any of the following conditions occur: high cyanobacteria counts detected in the source water
(> 30,000-40,000 cells/mL), cyanobacteria identified in source water as potential toxin
producers, and source water samples showed qPCR presence for the toxin producing gene:
Sample the raw water for microcystins; send to the laboratory in Cleveland for Adda-
specific ELISA analysis.
2. If microcystins are present in the raw water:
Sample at the EPTDS; samples are sent to the laboratory in Cleveland for Adda-specific
ELISA analysis (Step 4).
Ohio EPA protocol contains detailed information for increased monitoring (Appendix D).
Operational Adjustments Based on Raw Water Cyanotoxin
Measurements
1. If potential toxin-producing cyanobacteria are identified in the source water sample(s) or
microcystins are detected in the raw water:
Add PAC when MIB and geosmin levels rise or if cyanobacteria populations begin
increasing. Begin adding PAC to the intake at 15 mg/L or greater, based on the optimal
dose established in Step 2.
Communications Based on Source Water Cyanotoxin Measurements
Communicate the results with treatment plant management to ensure treatment is being optimized.
Akron Water Supply Bureau Cyanotoxin Management Plan - Step 3
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Step 4: Finished Water Cyanotoxin Monitoring
and Treatment Adjustments
Detecting and positively confirming cyanotoxins in the finished water indicates that cyanotoxins have
broken through the treatment barriers. If cyanotoxins have been detected in the finished water, the
Akron Water Supply Bureau continues implementing the treatment strategies described in earlier steps
of this plan and carries out the additional testing and treatment adjustments described in this section.
Finished Water Microcystins Monitoring
Follow the monitoring requirements provided in Ohio's regulation section (A)(2)(d) (found in Appendix
D). In summary, Section A(2)(d) of Ohio's regulation requires the frequency of monitoring at both raw
and finished water sampling points to be increased to daily if microcystins are detected at finished water
sampling points. Daily monitoring includes analysis within twenty-four hours of sample collection.
Samples will be tested by the Ohio EPA Total (Extracellular and Intracellular) Microcystins - ADDA by
ELISA Analytical Methodology.
If total microcystins are > 0.3 ng/L at EPTDS, then:
Re-sample raw and EPTDS as soon as possible or within 24 hours of getting toxin results (Step 5).
Consider optimizing (as discussed in section 2.1, prepare for treatment adjustments) and waiting
for water to move through before re-sampling. (12 to 15 hours hydraulic residence time from
raw to EPTDS.)
Collect daily distribution system samples at total coliform sampling points, rotating sites each
day. Test water for microcystins (and possibly other cyanotoxins based on the qPCR results).
Sample daily at EP001. Test for microcystins.
Sample raw water daily at intake. Test for microcystins.
Consider conducting total and extracellular microcystins treatment train sampling to determine
microcystins removal through each treatment unit process. Ohio EPA is available for support on
this sampling in response to finished water detects. This information can be used to further
optimize microcystins treatment. This should also be considered if raw water concentrations
exceed 5 ng/L (but no finished water detections).
Treatment
If total microcystins are detected (> 0.3 ng/L) at the intake, but not at EPTDS:
Increase the PAC dose (level dependent upon treatment factors and effectiveness of dosing).
Stop adding CI02 if PAC is being added.
If total microcystins is >1.6 ng/L at the intake, but not detected at the EPTDS, then:
Optimize treatment according to treatment optimization protocol (developed in response to
Ohio EPA's requirements).
If total microcystins are > 0.3 ng/L at EPTDS, then follow the treatment optimization protocol to
optimize treatment (protocol developed in response to requirements by Ohio EPA). Potential
optimization strategies include the following:
Akron Water Supply Bureau Cyanotoxin Management Plan - Step 4
E3.21
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Discontinue the use of CI02 and pre-filtration chlorination to avoid cell lysis. If necessary, use
permanganate at doses less than 1 mg/L to minimize cell lysis and follow-up with PAC to
adsorb any toxin released that is not destroyed by permanganate.
Adjust the coagulant dose based on the pre-established jar testing/fluorescence analysis in
Step 2.
Increase the sludge removal frequency from the sedimentation basins to avoid dissolved
toxin release from decaying cells.
Shorten filter runs, if possible, and backwash more frequently to remove cells captured in
the filter bed to avoid lysing.
Maintain the clearwell water pH between 7 and 8.
Increase a chlorine residual (with consideration to DBP formation) and maximize contact
time with chlorine in the clearwell. Maintain CT values on the order of 20 mg.min/L as a
general recommendation, although this target can vary under site specific conditions such
as pH, chlorine dose and residual and temperature.
Minimize pump changes and perform pump rate adjustment using variable-frequency
drives. Reduce plant flow if in town reservoir levels permit.
Communications
Information regarding notification is contained in the Emergency Operating Plan that describes how the
utility will communicate with stakeholders in the event of an emergency (for all contaminants).
Appendix C also discusses Ohio EPA's public notification requirement for microcystins detects in finished
drinking water.
Akron Water Supply Bureau Cyanotoxin Management Plan - Step 4
E3.22
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Step 5: Continued Finished Water Cyanotoxin
Monitoring, Treatment Adjustments and
Public Communication
Step 5 contains communication actions, treatment actions and additional monitoring that should be
carried out based on the concentrations of cyanotoxins confirmed in the finished water. This fifth step
enables Akron Water Supply Bureau to act quickly if cyanotoxins are confirmed in the finished water.
Continued Finished Water Microcystins Monitoring
Continue finished water total microcystins monitoring according to the requirements in Ohio's
regulation (see Appendix D of this plan). Ensure that requirements under Section (A)(d)(4) Response to
Microcystins Action Level Exceedance are fully met, if applicable (shown in Appendix D).
Once the total microcystins event appears to have been resolved, Akron will continue looking for early
warning signs (return to Step 2).
Communications
Information regarding notification is contained in the Emergency Operating Plan that describes how the
utility will communicate with stakeholders in the event of an emergency (for all contaminants).
Appendix C also discusses Ohio EPA's public notification requirement for microcystins detects in finished
drinking water.
Akron Water Supply Bureau Cyanotoxin Management Plan - Step 5
E3.23
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Long-Term Activities
Additional long-term activities can be undertaken by Akron Water Supply Bureau to better understand
treatment effectiveness, be aware of cyanotoxin challenges in addition to microcystin, and engage in
additional source water protection activities.
Monitoring Activities
Akron Water Supply Bureau could consider establishing a routine raw and in-plant process control
sampling/monitoring protocol for HABs. This could be sampling for cyanotoxins directly, or measuring
indicators, such as chlorophyll-o or phycocyanin, or a formal plan for monitoring and trending the early
indicators mentioned in this section. Establishing a baseline for these parameters (by trending the data)
during routine operation and understanding how each unit treatment process responds can help when a
HAB does occur and operators are faced with making potential treatment adjustments. Planning,
documenting and conducting a monitoring protocol would be good preparation for a HAB and provide
good information during a HAB to support treatment optimization. Some specific related activities
include:
Develop a database to record the qPCR and microcystins sample results to determine the
correlation of the data. Akron has recently begun to analyze water samples collected for algal
and cyanobacterial identification for the microcystin myc genes using qPCR. If microcystin qPCR
results indicate the presence of the myc genes, then the water sample is analyzed for
microcystins. If the qPCR results indicate an absence of the myc genes, the water sample may
not be analyzed for microcystins. As more data are collected, Akron will evaluate the
effectiveness of this step at guiding decisions about microcystins monitoring.
Consider investigating whether taste and odor compounds are effective indicators of
cyanotoxins (currently under evaluation in conjunction with the University of Akron).
Install another sonde anchored mid-lake (installation of buoy anticipated spring 2017) that
reports data to SCADA so that operators can observe real-time data in order to make informed
treatment decisions. A sonde installed further north in the lake would provide real-time early
warning of water quality changes that have taken place in the lake but are not yet apparent at
the intake. Tying the sonde into the water system's SCADA would enable the system to set
alarms at water quality thresholds that may indicate the need for operational or treatment
changes.
Source Water Protection Management Approaches
Review Akron's Source Water Assessment Plan, Watershed Control Plan and Drinking Water
Protection Plan to optimize watershed management and protection related to nutrient loading,
algal biomass, taste and odor production and cyanotoxin production.
Actively watch for legislation that could impact watershed protection and proactively represent
Akron Water Supply Bureau's interests.
Continue to be involved with professional organizations like American Water Works Association,
Water Research Foundation, Water Environment Federation and with other water utilities.
Continue to build a support network. Keep supporting Algal Identification Workshop and Dealing
with Cyanobacteria, Algal Toxins, and Taste and Odor Compounds Workshop (hosted by Stone
labs).
Akron Water Supply Bureau Cyanotoxin Management Plan - Long-Term Activities
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Carry out more outreach to educate, inform and share information about watershed protection.
If the Bureau decides to dredge Lake Rockwell in the future, try to apply phosphorus control
methods at the same time (maybe alum application).
Work closely with University of Akron and other researchers to:
o Improve understanding of nutrient loading in watersheds
o Develop a hydrologic and eventually predictive model for Lake Rockwell
o Algaecide study (In progress)
o Nutrient study (In progress)
Akron Water Supply Bureau Cyanotoxin Management Plan - Long-Term Activities
E3.25
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Appendix A: Cyanotoxin Management Flowchart
Is it vulnerable?
No
Yes
No
Yes
Were toxins detected?^
Were toxins detected?.
No
No
Are there signs
of a bloom or cyanotoxin
occurrence?
Step 4: Finished Water
Cyanotoxin Monitoring
and Treatment
Adjustments
Step 5: Continued
Finished Water
Cyanotoxin Monitoring,
Treatment Adjustments,
and Public
Communication
Step 2.1 : Preparation
Step 1: Assess Source
Water
Step 2.3 : Immediate
Actions if a Bloom is
Suspected
Step 3: Raw Water
Cyanotoxin Monitoring
and Treatment
Adjustments
Step 2.2: Monitoring
the Early Warning Signs
Begin any
preparation, as
needed, for
monitoring,
treatment and
communication.
Begin monitoring,
communication, and
source water
mitigation actions.
Continue
monitoring,
treatment, and
communication
activities as needed.
Return to previous
steps as appropriate.
Continue evaluating
for possible bloom
(Step 2.2).
Cyanotoxins: Actions to Monitor
Occurrence and Minimize
Exposure
Akron Water Supply Bureau Cyanotoxin Management Plan - Appendix A
E3.26
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Appendix B
Contacts and Stakeholder Information
Laboratory Contact Information
Northeast Ohio Regional Sewer District (NEORSD), Cleveland, Ohio
Stakeholders
Agency/Company
Title
Contact Name
Contact Phone
Contact Email
Akron Water
Supply Bureau
Cyanotoxins
Management Plan
(CMP) Team Leader
Akron Water
Supply Bureau
Source Water
Protection Manager
Akron Water
Supply Bureau
Treatment Operator
Akron Water
Supply Bureau
Distribution System
Operator
City of Akron
Public Service Director
Akron Water
Supply Bureau
Water
System/Municipality
Spokesperson
Summit County
Health Commissioner
Bureau of
Environmental
Health
Chief
Bureau of
Environmental
Health
Assistant Chief
Ohio EPA
HAB Coordinator
Ohio EPA
Northeast
NE District HAB
Coordinator
Akron Beacon
Journal
Journalist
Northeast Ohio
Regional Sewer
District
Manager of Analytical
Services
Akron Water Supply Bureau Cyanotoxin Management Plan - Appendix B
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Appendix C
Notifying the Public of Cyanotoxins in their Water
Ohio public water systems have specific requirements for making public notification under certain water
quality conditions. The Ohio requirements are provided here. In addition, the Ohio regulation requires
public water systems to address microcystin detections in their Consumer Confidence Reports. Details
related to that requirement, as well as the required Health Effects Language, are also provided here.
3745-90-06 Harmful algal blooms - tier 1 public notification and consumer
confidence reports.
This rule applies to all public water systems, including consecutive water systems.
(A) Tier 1 public notification.
(1) A public water system shall issue tier 1 public notification in accordance with rule
3745-81-32 of the Administrative Code when any of the following occur:
(a) A microcystins action level established paragraph (A)(1) or (A)(2) in rule
3745-90-02 of the Administrative Code is exceeded in a repeat sample
collected at the finished water sampling point in accordance with rule 3745-
90-03 of the Administrative Code, unless the director agrees in writing that
the timeline for notification may be extended or public notification is not
necessary, based on extenuating circumstances, until additional results are
received.
(b) If required by the director based on the results of resamples, distribution
system samples or daily samples collected in accordance with paragraph
(A)(4), (B) or (C)(2) of rule 3745-90-03 of the Administrative Code.
(c) Failure to conduct resampling or repeat sampling in accordance with
paragraph (A)(4)(a), (A)(4)(b), (C)(2)(a) or (C)(2)(b) of rule 3745-90-03 of
the Administrative Code, unless the director agrees in writing that the
timeline for notification may be extended or public notification is not
necessary.
(2) The public notification shall include applicable content in accordance with
paragraph (E) of rule 3745-81-32 of the Administrative Code, the action level
exceeded and the standard health effects language in paragraph (C) of this rule.
(3) The director may allow the system to limit distribution of the public notice in
accordance with paragraph (A)(2) of rule 3745-81-32 of the Administrative Code.
(4) Unless otherwise specified by the director based on public health and safety
considerations, tier 1 public notification shall remain in effect until the following
occur:
Akron Water Supply Bureau Cyanotoxin Management Plan - Appendix C
E3.28
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(a) Microcystins concentrations are below the action level in two consecutive
samples collected a minimum of twenty-four hours apart at the finished water
sampling point.
(b) Microcystins concentrations are below the action level in one set of
samples collected at the distribution sampling points.
(B) Consumer confidence report.
Each community public water system which exceeds a microcystins action level
established in paragraph (A)(1) or (A)(2) of rule 3745-90-02 of the Administrative
Code in a sample collected at a finished water sampling point in a daily, resample or
repeat sample, or a distribution sampling point collected within their own community
water system in accordance with rule 3745-90-03 of the Administrative Code shall
include the following in the consumer confidence report required by Chapter 3745-96
of the Administrative Code:
(1) The microcystins action level.
(2) The range of levels detected and highest single measurement of microcystins
concentration in samples collected at finished water sampling points and distribution
sampling points.
(3) Information regarding the major source of the contaminant: "Produced by some
naturally occurring cyanobacteria, also known as blue-green algae, which under
certain conditions (i.e., high nutrient concentration and high light intensity) may
produce microcystins."
(4) Standard health effects language in paragraph (C) of this rule.
(C) Standard health effects language.
The following standard health effects language shall be used in public notification
and consumer confidence reports: "Consuming water containing concentrations of
microcystins over the action level may result in abnormal liver function, diarrhea,
vomiting, nausea, numbness or dizziness. Children younger than school age, pregnant
women, nursing mothers, the elderly, immune-compromised individuals, those with
pre-existing liver conditions and those receiving dialysis treatment may be more
susceptible than the general population to the health effects of microcystins."
Effective:
Five Year Review (FYR) Dates:
Promulgated Under:
Statutory Authority:
Rule Amplifies:
06/01/2016
06/01/2021
119.03
3745.50, 6109.04
3745.50, 6109.04
Akron Water Supply Bureau Cyanotoxin Management Plan - Appendix C
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Appendix D
Ohio State Monitoring Requirements
3745-90-03 Harmful algal blooms - monitoring.
This rule applies to all surface water systems and consecutive water systems receiving water from a
surface water source. Seasonal systems shall monitor in accordance with this rule during the system's
operating season.
(A) Surface water systems.
(1) Cyanobacteria screening.
Surface water systems shall monitor with a minimum of one sample from
each raw water sampling point at least once every two weeks for
cyanobacteria screening. Cyanobacteria samples shall be collected at the
same time as the routine microcystins sample.
(2) Routine microcystins monitoring.
(a) Routine microcystins monitoring requirements between May first and
October thirty-first.
Surface water systems shall monitor with a minimum of one sample from
each raw water sampling point and one sample from each finished water
sampling point at least weekly for microcystins analysis.
(b) Routine microcystins monitoring requirements between November first
and April thirtieth.
(i) Surface water systems shall continue to monitor in accordance
with paragraph (A)(2)(a) of this rule unless microcystins are not
detected in at least two consecutive weekly samples from both the
raw water sampling point and the finished water sampling point, then
the microcystins monitoring frequency is reduced to a minimum of
one sample from each raw water sampling point at least once every
two weeks.
(ii) If microcystins are detected at a raw water sampling point, weekly
monitoring at that raw water sampling point and the finished water
sampling point shall be conducted beginning no later than twenty-four
hours following the detection. When microcystins are not detected in
at least two consecutive weekly samples from both the raw water
sampling point and the finished water sampling point, then
Akron Water Supply Bureau Cyanotoxin Management Plan - Appendix D
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monitoring once every two weeks may resume in accordance with
paragraph (A)(2)(b)(i) of this rule.
(c) Increased routine microcystin monitoring (three days per week).
The frequency of monitoring at both raw water sampling points and
finished water sampling points shall be increased to three days a
week, beginning no later than the following week, if microcystins
exceed five micrograms per liter (ug/L) at the raw water sampling
point, unless an alternate frequency has been established as part of the
approved cyanotoxin general plan in accordance with rule 3745-90-05
of the Administrative Code.
Routine monitoring in accordance with paragraphs (A)(2)(a) and
(A)(2)(b) of this rule may resume once the following occur:
(i) Microcystins concentrations are equal to or less than five ug/L in
two consecutive samples from the raw water sampling point that are
collected at least one day apart.
(ii) Microcystins concentration is non-detect at finished water
sampling points.
(iii) If samples were collected at distribution sampling points in
accordance with this rule, microcystins are not detected at any
distribution sampling point.
(d) Increased routine microcystins monitoring (daily).
The frequency of monitoring at both raw water sampling points and
finished water sampling points shall be increased to daily if
microcystins are detected at finished water sampling points collected
in accordance with this rule, or distribution sampling points collected
in accordance with this rule. Daily monitoring shall include analysis
within twenty-four hours of sample collection.
Routine monitoring may resume in accordance with paragraphs
(A)(2)(a) and (A)(2)(b) of this rule if the two most recent consecutive
daily samples from the raw water sampling point are equal to or less
than five ug/L, or in accordance with paragraph (A)(2)(c) of this rule
if either of the two most recent consecutive daily samples from the
raw water sampling point are greater than five ug/L, once the
following occur:
(i) Microcystins are not detected in two consecutive daily samples
collected at the finished water sampling point.
Akron Water Supply Bureau Cyanotoxin Management Plan - Appendix D
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(ii) If samples were collected at distribution sampling points in
accordance with this rule, microcystins are below the action level at
distribution sampling points.
(3) Revised cyanobacteria screening or routine microcystins monitoring frequency.
The cyanobacteria screening or routine microcystins monitoring frequency
may be revised (decreased, increased or discontinued) at the discretion of the
director. When establishing the revised schedule, the director may consider
cyanobacteria screening data collected in accordance with this rule,
microcystins data, and other information provided by the public water system
including data from other screening tools (such as phycocyanin sensors or
phytoplankton enumeration) and treatment information. Surface water
systems shall monitor in accordance with the revised cyanobacteria screening
or routine microcystins monitoring schedule established by the director.
(4) Response to microcystins action level exceedance.
If microcystins exceed an action level established in paragraph (A)(1) or
(A)(2) of rule 3745-90-02 of the Administrative Code in routine samples
collected at the finished water sampling point, the public water system shall
do the following:
(a) As soon as possible, but no later than twenty-four hours after receiving the
results of the initial action level exceedance, collect one resample from each
raw water sampling point and one resample from each finished water
sampling point. Analysis of resamples must be completed within twenty-four
hours of collection. These resamples satisfy the requirement for daily samples
as set forth in paragraph (A)(2)(d) of this rule.
(b) Within twenty-four hours of collecting the resamples, collect one repeat
sample from each raw water sampling point and one repeat sample from each
finished water sampling point. Analysis of repeat samples must be completed
within twenty-four hours of collection. These repeat samples satisfy the
requirement for daily samples as set forth in paragraph (A)(2)(d) of this rule.
(c) If the microcystins concentration exceeds the action level in the resample
or repeat sample collected at any finished water sampling point in accordance
with paragraph (A)(4)(a) or (A)(4)(b) of this rule, as soon as practical but no
later than three hours after receiving the resample or repeat sample results, the
surface water system shall notify all consecutive systems served by the water
system. The surface water system with the action level exceedance, and all
consecutive water systems served by the water system, shall within twenty-
four hours of receiving the resample or repeat sample results, collect samples
at representative distribution sampling points in accordance with the
contingency plan required by rule 3745-85-01 of the Administrative Code.
Additional distribution system monitoring may be required by the director
based on sampling results and other relevant circumstances. Analysis of
Akron Water Supply Bureau Cyanotoxin Management Plan - Appendix D
E3.32
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distribution samples must be completed within twenty-four hours of
collection.
(d) Conduct routine daily monitoring in accordance with paragraph (A)(2)(d)
of this rule.
(B) Consecutive water systems receiving water from an in-state surface water system.
Within twenty-four hours of receiving notification of an action level exceedance in
accordance with paragraph (A)(4)(c) or (C)(2)(c) of this rule, the consecutive water
system shall collect samples at representative distribution sampling points in
accordance with the contingency plan required by rule 3745-85-01 of the
Administrative Code. Additional distribution system monitoring may be required by
the director based on sampling results and other relevant circumstances. Analysis of
distribution samples must be completed within twenty-four hours of collection.
(C) Consecutive water systems receiving water from an out-of-state surface water source.
(1) Routine microcystins monitoring.
(a) Routine microcystins monitoring requirements between May first and
October thirty-first.
Consecutive water systems receiving water from an out-of-state surface water
source shall monitor with a minimum of one sample from each finished water
sampling point at least weekly for microcystins analysis.
(b) Routine microcystins monitoring requirements between November first
and April thirtieth.
Consecutive water systems receiving water from an out-of-state surface water
source shall monitor with a minimum of one sample from each finished water
sampling point at least once every two weeks for microcystins analysis.
(c) Increased routine microcystins monitoring (daily).
The frequency of monitoring at finished water sampling points shall be
increased to daily if microcystins are detected at finished water sampling
points collected in accordance with this rule, or distribution sampling points
collected in accordance with this rule. Daily monitoring shall include analysis
within twenty-four hours of sample collection.
Routine monitoring may resume in accordance with paragraph (C)(1)(a) or
(C)(1)(b) of this rule once the following occur:
(i) Microcystins are not detected in two consecutive daily samples
collected at the finished water sampling point.
Akron Water Supply Bureau Cyanotoxin Management Plan - Appendix D
E3.33
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(ii) If samples were collected at distribution sampling points in
accordance with this rule, microcystins are below the action level at
distribution sampling points.
(d) Revised routine microcystins monitoring frequency.
The routine microcystins monitoring frequency may be revised (decreased,
increased or discontinued) at the discretion of the director. When establishing
the revised schedule, the director may consider microcystins data, and other
information provided by the public water system including data from
screening tools (such as phycocyanin sensors or phytoplankton enumeration)
and treatment information. Consecutive water systems shall monitor in
accordance with the revised routine microcystins monitoring schedule
established by the director.
(2) Response to microcystins action level exceedance.
If microcystins exceed an action level established in paragraph (A)(1) or
(A)(2) of rule 3745-90-02 of the Administrative Code in routine samples
collected at the finished water sampling point, the public water system shall
do the following:
(a) As soon as possible, but no later than twenty-four hours after receiving the
results of the initial action level exceedance, collect one resample from each
finished water sampling point. Analysis of resamples must be completed
within twenty-four hours of collection. This resample satisfies the
requirement for daily samples as set forth in paragraph (C)(1)(c) of this rule.
(b) Within twenty-four hours of collecting the resamples, collect one repeat
sample from each finished water sampling point. Analysis of repeat samples
must be completed within twenty-four hours of collection. This repeat sample
satisfies the requirement for daily samples as set forth in paragraph (C)(1)(c)
of this rule.
(c) If the microcystins concentration exceeds the action level in the resample
or repeat sample collected at any finished water sampling point in accordance
with paragraph (C)(2)(a) or (C)(2)(b) of this rule, as soon as practical but no
later than three hours after receiving the resample or repeat sample results, the
public water system shall notify all consecutive systems served by the water
system. The public water system with the action level exceedance, and all
consecutive water systems served by the water system, shall within twenty-
four hours of receiving the resample or repeat sample results, collect samples
at representative distribution sampling points in accordance with the
contingency plan required by rule 3745-85-01 of the Administrative Code.
Additional distribution system monitoring may be required by the director
based on sampling results and other relevant circumstances. Analysis of
distribution samples must be completed within twenty-four hours of
collection.
Akron Water Supply Bureau Cyanotoxin Management Plan - Appendix D
E3.34
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(d) Conduct routine daily monitoring in accordance with paragraph (C)(1)(c)
of this rule.
(D) Monitoring extension.
Upon a request from a public water system, the director may agree to extend the
twenty-four hour monitoring requirement for daily, resample, repeat or distribution
samples required pursuant to this rule on a case-by-case basis when the public water
system has a logistical problem collecting samples within twenty-four hours or
analyzing samples in accordance with the requirements of this chapter. When an
extension is agreed to by the director, the director shall specify in writing how much
time the public water system has to monitor. Examples of potential logistical
problems include, but are not limited to:
(1) Extreme weather conditions create unsafe travel or on-site conditions for the
person collecting the sample.
(2) Limited certified laboratory capacity on weekends and holidays.
(E) Violations.
Failure to comply with routine and distribution monitoring requirements in paragraph
(A)(1), (A)(2), (A)(3), (A)(4)(c), (B), (C)(1) or (C)(2)(c) of this rule is a monitoring
violation and requires the public water system to provide Tier 3 public notification in
accordance with rule 3745-81-32 of the Administrative Code. Failure to comply with
resample and repeat sample requirements in paragraph (A)(4)(a), (A)(4)(b), (C)(2)(a)
or (C)(2)(b) of this rule is a monitoring violation and requires the public water system
to provide a tier 1 public notification accordance with rule 3745-81-32 of the
Administrative Code.
Effective:
Five Year Review (FYR) Dates:
Promulgated Under:
Statutory Authority:
Rule Amplifies:
06/01/2016
06/01/2021
119.03
3745.50, 6109.04
3745.50, 6109.04
Akron Water Supply Bureau Cyanotoxin Management Plan - Appendix D
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Cyanotoxins Management Plan
Ottawa County Regional Water System
Port Clinton, Ohio
November, 2016
E4.1
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Table of Contents
Executive Summary E4.4
Ottawa County Regional Water System Overview E4.5
Source Water E4.5
Treatment Process E4.5
Routine Water Quality Monitoring E4.5
Cyanotoxin Management Plan E4.8
Step 1: Assess Source Water E4.10
1.1 Identify Source Water Protection Areas E4.10
1.2 Create Inventory of HABs Risk Factors E4.10
1.2.1 Source Water Characteristics E4.10
Land Use E4.ll
1.2.2 Water Quality Parameters E4.ll
Historical Cyanobacteria and Cyanotoxin Events in Source Water E4.ll
Nutrients E4.ll
Point and Nonpoint Sources of Pollution E4.12
1.3 Assess Vulnerability E4.12
Step 2: Preparation, Monitoring for Early Warning Signs and Immediate Actions E4.13
2.1 Preparation E4.13
Prepare Staff and Equipment for Monitoring E4.13
Prepare for Treatment Adjustments E4.13
Communications E4.14
Establish Communication Plan with other Source Water Users E4.14
2.2 Monitoring the Early Warning Signs E4.14
Early Indicators of a Cyanobacterial Bloom E4.14
2.3 Immediate Actions if Bloom is Suspected E4.15
Monitoring Actions in Response to Early Warning Signs E4.15
Treatment adjustments in Response to Early Warning Signs E4.15
Communication Actions in Response to Early Warning Signs E4.16
Step 3: Raw Water Cyanotoxin Monitoring and Treatment Adjustments E4.17
Monitoring if Cyanobacteria are Identified or Suspected E4.17
Operational Adjustments Based on Source Water Cyanotoxin Measurements E4.17
Communications Based on Source Water Cyanotoxin Measurements E4.17
Step 4: Finished Water Cyanotoxin Monitoring and Treatment Adjustments E4.18
Finished Water Microcystins Monitoring E4.18
Treatment E4.18
Communications E4.18
E4.2
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Step 5: Continued Finished Water Cyanotoxin Monitoring, Treatment Adjustments and Public
Communication E4.19
Continued Finished Water Microcystins Monitoring E4.19
Treatment and Operations E4.19
Communications E4.19
Long-Term Activities E4.21
Enhancing Monitoring and Analytical Methods E4.21
Source Water Protection Management Approaches E4.21
Appendices
Appendix A Cyanotoxin Management Flowchart E4.22
Appendix B Contacts and Stakeholder Information E4.23
Appendix C Notifying the Public of Cyanotoxins in their Water E4.24
Appendix D Ohio State Monitoring Requirements E4.27
E4.3
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Executive Summary
Ottawa County Regional Water System (OCRWS), with the support of the State of Ohio and the United
States Environmental Protection Agency (USEPA), has developed this Cyanotoxins Management Plan
(CMP) to prepare for and mitigate risks from harmful algal blooms (HABs) and cyanotoxins occurring in
Lake Erie and the Portage River in order to protect public drinking water from cyanotoxin
contamination. This document provides steps and establishes activities to prepare for and identify a
potential HAB occurrence, make treatment and operational adjustments to remove cyanotoxins from
the water, provide timely information and (as appropriate) an advisory to the water system's customers,
and document information about occurrences of HABs so that information can be used to minimize the
effect of HABs on the water system in the future. This plan also contains possible future activities the
utility could engage in to mitigate the risks from HABs and cyanotoxins, such as long-term source water
protection activities.
The steps outlined in this CMP include:
Step 1: Assess Source Water
Step 2: Preparation, Monitoring for Early Warning Signs and Immediate Actions
Step 3: Raw Water Cyanotoxin Monitoring and Treatment Adjustments
Step 4: Finished Water Cyanotoxin Monitoring and Treatment Adjustments
Step 5: Continued Finished Water Cyanotoxin Monitoring, Treatment Adjustments and Public
Communication
In addition to the five steps above long-term activities are also discussed to enhance the utility's ability
to prevent, mitigate and manage the risks from cyanotoxin occurrence in source and finished waters.
Ottawa County Regional Water System Cyanotoxin Management Plan - Executive Summary
E4.4
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Ottawa County Regional Water System Overview
The Ottawa County Regional Water System (OCRWS) serves approximately 25,000 customers with water
collected from intakes on Lake Erie and the Portage River. The treatment plant is designed to treat nine
million gallons of water per day (MGD), but can be expanded to 18 MGD at the present site. The water
serves, in part, seven townships in Ottawa County: Danbury, Catawba Island, Erie, Salem, Portage, Harris
and Bay, as well as the City of Port Clinton and the Village of Oak Harbor. The system has three 500,000
gallon finished water storage tanks. Altogether, these tanks have approximately 12 to 20 hours of
finished water storage. OCRWS has one pressure zone.
Source Water
OCRWS has two intakes: the Lake Erie intake and the Portage River intake. The Portage River intake
(emergency intake) is used primarily when ice is beginning to form on Lake Erie and the water at the
lake's intake is temporarily restricted due to frazil ice. The Portage River intake is near the mouth of Lake
Erie. The Lake Erie intake is their primary intake. Water entering the two intakes is piped into the raw
water wetwell.
Treatment Process
A schematic of OCRWS' treatment is provided below. The OCRWS plant is a conventional plant
consisting of the following treatment steps:
Permanganate Addition: Raw water entering the pump house is fed sodium permanganate
after the sampling well. The sodium permanganate is in contact with the water a significant
distance from the pump house to the treatment plant (9800 feet of a 24-inch diameter pipe).
The raw water entering the plant maintains a permanganate residual of 0.3 mg/L. However,
OCRWS plant is considering lowering this residual level if algal cells are being lysed.
Pre-treatment Basins: Once water reaches the treatment plant, it enters one of four pre-
treatment basins. Powdered activated carbon (PAC) or chlorine can be fed directly into the pre-
treatment basins.
Coagulation, PAC and Rapid Mix: Water leaves the pre-treatment basins and passes through
one of two rapid mix basins, where aluminum chloro-hydrate (ACH) and PAC are added and
thoroughly mixed with the water.
Clarification: Once the ACH and PAC have been added and thoroughly mixed with the water,
the water flows into one of three upflow solids contact type clarifier, where a sludge blanket
removes particles and some organic matter.
Filtration: Water is then filtered by one of eight cluster type dual media sand filters.
Disinfection, Corrosion Control and Fluoridation: After filtration, chlorine, caustic soda and
fluoride are added to the water before it enters one of two clearwells. The water pH entering
the clearwells is typically approximately 7.7 - 7.9, but can be as high as 8.2.
Disinfection CT: Water leaves the clearwells after it has achieved sufficient disinfection CT and
enters the distribution system. Water leaving the clearwell is considered the entry point to the
distribution system (EPTDS).
Routine Water Quality Monitoring
A well in the pump house contains a sonde that measures turbidity, pH, phycocyanin and chlorophyll-o.
Total organic carbon (TOC), alkalinity, total microcystins and Cryptosporidium are also sampled at this
Ottawa County Regional Water System Cyanotoxin Management Plan - Overview
E4.5
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location and samples are collected for phytoplankton identification. The raw water alkalinity is around
100 mg/L as CaC03 and Disinfection Byproducts (DBPs) are not a compliance problem. Operators check
the Langelier Index at the clearwell and the elevated water storage tanks when they conduct DBP
monitoring. A summary of routine raw water quality monitoring is provided in Table 1 below.
Beginning in June 2016, OCRWS was required to start monitoring raw water total microcystins weekly in
order to comply with Ohio EPA's new cyanotoxin regulation. Table 2 summarizes the total microcystins
monitoring schedule for complying with this new regulation. Prior to the regulation taking effect,
OCRWS voluntarily sampled for microcystins weekly during the summer Lake Erie Microcystis bloom
season. The current lab analyzing total microcystins samples for Ottawa County is the Oregon Water
Treatment Plant (WTP) with the Toledo WTP serving as a backup lab. OCRWS also begins monitoring if
the water temperature reaches 20 degrees Celsius. After collecting samples, they look at the water
through a microscope on site to identify the algae and cyanobacteria and to determine whether or not
growth is heavy (i.e., if algae/cyanobacteria are covering the plate). This assessment is conducted with
lake water once a week and with raw water samples collected from the intake twice a week. OCRWS
operators use an algae binder with information from past algae and cyanobacterial events to document
what they see. They take photographs and fill out a phytoplankton identification form formerly known
as the "Sandusky Form."
Every morning, OCRWS reviews satellite data1 and predicted bloom movement and watches the color
near the intakes. This system works well on clear days; however, when the weather is overcast it is
difficult to make observations.
Table 1. Routine Raw Water Quality Monitoring
Parameter
Location
Frequency
Who Collects
Sample?
Who Does Analysis?
Turbidity
Raw Water Pump
Daily
Sonde
N/A
PH
Raw Water Pump
Phycocyanin
Raw Water Pump
Chiorophyll-o
Raw Water Pump
Microcystins
Weekly*
Operators
Lab
TOC
Monthly
Operators
Lab
Alkalinity
Monthly
Operators
Plant
Temperature
Daily
Plant
Relative biomass
Satellite coverage
Daily
Operators
Operators interpret
*See table with (Table 2) Ohio's Microcystins Monitoring Requirements
1 Produced from the National Oceanic and Atmospheric Administration (NOAA's) National Centers for Coastal
Ocean Science Great Lakes Environmental Research Laboratory, the National Weather Service, and the Cleveland
Center for Operational Oceanographic Products and Service as part of an Experimental Lake Erie Harmful Algal
Bloom Bulletin.
Ottawa County Regional Water System Cyanotoxin Management Plan - Overview E4.6
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Table 2. Ohio Microcystins Monitoring Requirements
Location
Analysis1
During
Which
Months?
Monitoring
Category
Frequency2
Raw Water
Cyanobacteria/cyanotoxin
genetic screening (qPCR
for 16S, mycF, sxtA and
cyrA genes)
Year-Round
Routine
Once every 2 weeks (at the
same time as routine
microcystins sample)
Raw and
Total Microcystins
May 1st-
Routine
Weekly
Finished Water
October 31st
Raw and
Total Microcystins
November
Routine
Weekly unless not detected
Finished Water
1st-April
30th
in at least 2 consecutive
weekly samples from both
raw and finished water
sampling points. Then
frequency is reduced to one
sample from each raw water
sampling point at least once
every 2 weeks.
Raw and
Total Microcystins
November
Routine if there is
If detected at raw water
Finished Water
1st-April
30th
a detection
sampling point, weekly
monitoring at raw and
finished water sampling
points will begin no later
than 24 hours following
detection.3
Raw and
Total Microcystins
Year-Round
Increased
3 days a week, beginning no
Finished Water
Routine (3 days a
week)
later than the following
week, if microcystins exceed
5 |ig/L at raw water sampling
point.3
Raw and
Total Microcystins
Year-Round
Increased
Daily, if microcystins
Finished Water
Routine (Daily)
detected at finished water
sampling point. Daily
monitoring will include
analysis within 24 hours of
sample collection.3
1 Total microcystins measured by the Ohio EPA Total (Extracellular and Intracellular) Microcystins - Adda
by ELISA Analytical Methodology.
2See Ohio EPA's regulation in Appendix D for details about what monitoring is required if monitoring
results exceed the action level.
3See Ohio EPA's regulation in Appendix D for details about how to return to routine monitoring.
In addition, Lake Erie water monitoring occurs through a variety of sources which provide their findings
to OCRWS, including:
Ohio EPA's NW District HAB Coordinator serves as a primary point person and actively
contacts water utilities if she sees or hears of blooms.
Jet Express, a boating operation nearby notifies OCRWS of impending blooms when their
captain sees blooms near the lake intake.
Ottawa County Regional Water System Cyanotoxin Management Plan - Overview
E4.7
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A local marina contacts OCRWS if they see a bloom.
The Ottawa County Health Department monitors some beaches for HAB events.
There is also a mechanism for citizen observation and reporting using a state procedure and
form.
The Sanitary Engineer Association of Ohio is a county-organized entity that serves as a
vehicle for information exchange, but is not a key participant in water quality monitoring.
Cyanotoxin Management Plan
OCRWS developed this Cyanotoxins Management Plan (CMP) detailed in the steps below. This CMP
provides for actions to prepare for and mitigate risks from harmful algal blooms (HABs) and cyanotoxins
occurring in Lake Erie in order to protect public drinking water from cyanotoxin contamination. The plan
includes immediate steps discussing monitoring and treatment should HABs and cyanotoxins occur as
well as long-term steps the system can engage in to protect source waters and to fully evaluate
treatment capabilities. A detailed flowchart of the CMP can be found in Appendix A.
Ottawa County Regional Water System Cyanotoxin Management Plan - Overview
E4.8
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Figure 1. Schematic Diagram of the Treatment System
Ottawa County Regional Water
Treatment Schematic
Carbon*
Chlorine*
Carbon ACH
Sodium
permanganate
Raw Water
Meter
Carbon1
Chlorine*
Intake at
Lake Erie
Pretreatment Basin
Pretreatment Basin
Carbon ACH
Upflow clarifier
Upflow clarifier
Upflow clarifier
Filter aid
Filter bed
Filter bed
Caustic Soda Chlorine Fluoride
T
Clearwell
-0
r
Distribution
System
V J
*Both carbon and chlorine are not currently being fed into the
pretreatment basins.
Ottawa County Regional Water System Cyanotoxin Management Plan - Overvievv
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Step 1: Assess Source Water
1.1 Identify Source Water Protection Areas
Map 1 below from the USEPA Drinking Water Application to Protect Source Waters (DWMAPS) tool shows
western Lake Erie, the primary source water for OCRWS. Map 1 also displays several waters that are impaired
for nutrients draining into Lake Erie near Port Clinton.
Legend
Selected 303(d) Listed Impaired waters
matching query
Selected 303(d) Listed Impaired Waters
matching query
303(d) Listed Impaired Waters
d) Listed Impaired waters query
Map 1. Source water protection area with impaired waters for nutrients, Ottawa County
1.2 Create Inventory of HABs Risk Factors
1.2.1 Source Water Characteristics
Many of the streams draining to Lake Erie near Port Clinton have been assessed for attainment of surface
water quality standards under Section 305(b) of the Clean Water Act (CWA). Based on these assessments,
many have been listed as impaired streams due to nutrient-related (phosphorus and nitrogen) issues, under
Section 303(d) of the CWA. Multiple Total Maximum Daily Load (TMDL) in the region have been developed in
response to the impairment listings. The TMDL defines targets for nutrient loading to Lake Erie and outlines
strategies for reducing nutrient loading, which will ultimately reduce algal and cyanobacterial growth. The
western Lake Erie basin shoreline assessment unit is also currently listed as impaired for the public drinking
water supply use due to algae impacts (the state uses cyanotoxin indicators of algae impairment).
One source of funding for implementing the TMDL is the CWA nonpoint source program (Section 319) grant
funds. An approximately $250,000 Section 319 grant project was initiated in 2014 to increase the use of
cover crops, improve agricultural drainage systems, develop nutrient management plans and increase the
use of conservation tillage in the Portage River watershed to reduce nutrient loading to the river.
Additionally, Ohio has a statewide program, the Ohio Balanced Growth Program, that aims to link land-use
Ottawa County Regional Water System Cyanotoxin Management Plan - Step 1
E4.10
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Hancock County
planning to the health of Lake Erie, the Ohio River and Ohio's other watersheds and drinking water source
areas.
Land Use
Map 2 shows the land uses within the Portage River watershed and Lake Erie watershed near the OCRWS
intake.
Ottawa County
Erie County
C3 10-digtlHUC
Land cover
| Open water
| Developed
| Developed, high density
| Barren land
| Forest
~ Grassland / herbaceous
Pasture I hay
[ Cultivated crop
E Wetlands
Wood County
Sandusky County
Seneca County
16 Miles
_J
Map 2. Lake Erie and Portage River Watersheds near OCRWS and their Land Uses
(http://www.eDa.ohio.gov/oortals/35/tmdl/Portaae Report Final.pdf}.
1.2.2 Water Quality Parameters
Historical Cyanobacteria and Cyanotoxin Events in Source Water
OCRWS' primary source of water is western Lake Erie, which has a well-documented history of yearly
cyanobacterial blooms during the warm summer months that produce elevated levels of microcystins. A
review of OCRWS' 2014 and 2015 microcystins monitoring results showed that microcystins were detected
on several occasions at the lake's intake in the summer, with concentrations highest in mid-late August and
detections continuing through September. The highest 2015 microcystins concentration measured was 12.1
|ig/L microcystins on July 7th at the OCRWS intake.
Nutrients
Phosphorus and nitrogen are drivers of algal and cyanobacterial growth in lakes and reservoirs. Sources of
phosphorus and nitrogen can include discharge of domestic and industrial wastewater, septic systems and
runoff from agricultural and urban lands.
Ottawa County Regional Water System Cyanotoxin Management Plan - Step 1
E4.ll
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Point and Nonpoint Sources of Pollution
In Map 3. the IJSEPA DWMAPS tool indicates that there are 13 National Pollutant Discharge Elimination
System (NPDES) permitted wastewater dischargers and two Combined Sewer Overflows within a five mile
radius of Port Clinton. In addition to these point source discharges, the area draining to the OCRWS plant
near Port Clinton is predominantly agricultural or urban land cover; land uses that typically yield large
amounts of nutrients.
l. O
V*
a*
"JjL
fay
/ f
Muddy
Bay
Legend
Selected Potential Sources of Contamination
matching query
o
NPDES Refuse Facilities
NPDES Sewerage Facilities
East
Harbor
State Pari?
NPDES Other Facilities
jjfjf ฆ
Combined Sewer Overflows (CSO)
*
Bay View ^
9
*
>31 c
:ปRsf ^
Map 3. Potential Point Sources of Nutrient Contamination in Source Water
1.3 Assess Vulnerability
A weight of evidence approach was used to characterize Lake Erie as vulnerable to HABs and cyanotoxin
occurrence. Evidence of vulnerability to HABs and cyanotoxins includes all of the discussion in this section
including: the dominant land uses in the watershed contributing to nutrient pollution, the existing NPDES
dischargers in the lake near the intake and the historical occurrence and reoccurrence of HABs and
cyanotoxins in Lake Erie near the intake. The OCRWS has been determined to be vulnerable to cyanotoxin
events and should continue to Step 2.
Ottawa County Regional Water System Cyanotoxin Management Plan - Step 1
E4.12
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Step 2: Preparation, Monitoring for Early
Warning Signs and Immediate Actions
2.1 Preparation
OCRWS determined that its source water is vulnerable to cyanobacterial blooms; the next step is to
prepare for cyanobacterial blooms and cyanotoxin occurrence. Preparation includes preparing for
monitoring raw and finished waters, preparing for treatment adjustments and establishing
communication plans.
Prepare Staff and Equipment for Monitoring
OCRWS will carry out the following activities in order to be prepared for the monitoring steps described
in this plan:
Train operators on identifying elevated blue-green algae (rfu) and pH levels from sonde.
Keep monitoring equipment properly calibrated, calibrate sonde two times per year.
Ensure that the procedure for submitting total microcystins samples to the laboratory
complies with all of the Ohio EPA's regulation for sampling, analytical and reporting
methods.
Have coolers, chain of custody forms and shipping labels on site and ready for use.
Ensure that the appropriate bottles (glass or PETG) are onsite for sampling.
Also have sodium thiosulfate available for quenching any samples that have been exposed
to an oxidant as soon as they are collected.
Document all sampling, testing and quality assurance procedures.
Prepare for Treatment Adjustments
OCRWS will carry out the following activities in order to be more prepared to treat its source water
during a HAB:
Prepare and finalize a Treatment Optimization Protocol for OCRWS (Treatment Optimization
Protocol is a requirement by the Ohio Environmental Protection Agency for systems with
microcystins in their source water).
Educate all operators about the treatment barriers in the optimization protocol, actions that
need to be carried out to ensure those barriers are optimized and effective and conditions
that indicate the need for treatment and operational adjustments.
Based on existing literature, estimate chlorine CT conditions that the treatment plant could
meet that could help provide protection from finished water microcystins detections.
Based on existing literature and results of a recent Comprehensive Performance Evaluation
for cyanotoxins, estimate appropriate PAC dosage to be used under varying raw water
microcystins concentrations, to help provide protection from finished water microcystins
detections.
Conduct jar testing during HABs to help optimize coagulant dose, potassium permanganate
feed rate and carbon feed rate for microcystins removal.
Ottawa County Regional Water System Cyanotoxin Management Plan - Step 2
E4.13
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Communications
Establish Communication Plan with other Source Water Users
Several plants share the same western basin of Lake Erie source water. Water system personnel from
these systems frequently communicate through phone calls, emails and text. Additionally, the OCRWS
has an interconnection with Carroll Township, and they may provide a maximum amount of 100,000
gallons per day. Typically, OCRWS can serve Carroll Township more water than Carroll Township serves
OCRWS. The Lake Erie Water Plant Group allows the lake's water users to communicate with one
another. The group consists of about 20 communities and meets quarterly. Officers are elected to run
the group. In addition to facilitating communication within members, the group also works with Ohio
AWWA.
OCRWS will carry out the following activities in order to be more prepared for the communications steps
described in this plan:
Complete a stakeholders list (Appendix B) and reevaluate the list on a recurring basis to
maintain an up-to-date list.
Review the public advisory language in OCRWS' Emergency Response Plan and update it so
it is consistent with the Health Effects language in Ohio's regulation. Ensure that the
Emergency Response Plan's actions in response to total microcystins detections are also
consistent with the requirements in Ohio's regulation.
Add the language that is required by Ohio's regulation to OCRWS' consumer confidence
report template, if appropriate.
Prepare a public health advisory template that is available and ready for use if necessary.
Also prepare another notice that would be issued to lift an existing public health advisory.
Develop a public health advisory and procedure that is consistent with Tier 1 Public
Notification requirements and the other requirements of Ohio's regulation (see Appendix C
of this plan). Explanations of when a public health advisory will be issued or lifted are
provided in Step 5 of this plan.
Coordinate with other monitoring agencies on how to receive information about early
warning signs.
2.2 Monitoring the Early Warning Signs
Based on historical bloom occurrence in western Lake Erie, OCRWS operators begin looking for signs of
blooms in the early summer months. This section identifies early warning signs that the operators can
look for during the system's normal operation.
Early Indicators of a Cyanobacterial Bloom
When the OCRWS's raw water temperature reaches 22 degrees Celsius, operators watch the
National Oceanic and Atmospheric Administration-produced satellite views for evidence of
HABs (depicted as colored pixels on the maps).
Operators check the Lake Erie water current data and monitor the sonde data daily for any
indications of a bloom, including increases in:
o pH
o Phycocyanin
Ottawa County Regional Water System Cyanotoxin Management Plan - Step 2
E4.14
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o Chlorophyll-o
Operators have identified several early warning signs that a cyanobacterial bloom is likely to
occur in the very near future (or has begun to occur). The following early warning signs are a
combination of observations of conditions in the lake itself and in the treatment plant:
o Visual presence of scums and discoloration of source water near the intake
o Odor events
o Increased raw water pH
o Increased chlorine demand in the clearwell
o Increased temperature
o Increased turbidity from the clarifier effluent
o Shorter filter runs
o Filters blind off (clogging)
o Visual observations of changes in the upflow clarifiers
o Upflow clarifier sludge color and odor
o Increased sodium permanganate demand
View the sonde data of other neighboring plants.
Open communication about water quality and potential blooms with the below
organizations or groups that also use and study Lake Erie:
o Ohio EPA's NW District HAB Coordinator
o Jet Express
o A local marina
o The Ottawa County Health Department
o Citizen science monitoring
o Neighboring water operators
2.3 Immediate Actions if Bloom is Suspected
Monitoring Actions in Response to Early Warning Signs
If a bloom is suspected or when routine raw water monitoring is required continue to Step 3
(see Appendix D for monitoring requirements).
Treatment Adjustments in Response to Early Warning Signs
Perform jar testing to optimize the coagulant dose by measuring turbidity, UV 254 and visual
observations of settling and particle removal.
Optimizing the removal of intact cyanobacterial cells is an extremely important treatment
step for controlling microcystins in the finished water.
Visually monitor all plant operations to make sure all equipment is functioning as designed
and chemicals are being dosed at the optimum amount to provide the best treatment.
Optimal chemical doses and equipment settings are provided in the Treatment Optimization
Protocol.
Ottawa County Regional Water System Cyanotoxin Management Plan - Step 2
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Communication Actions in Response to Early Warning Signs
Contact neighboring water operators and ask them about their water quality and if they
have seen early indicators of a cyanobacterial bloom/cyanotoxin event. Communicate to
neighboring operators about the potential for a bloom.
Ottawa County Regional Water System Cyanotoxin Management Plan - Step 2
E4.16
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Step 3: Raw Water Cyanotoxin Monitoring and
Treatment Adjustments
If a cyanobacterial bloom or its indicators are observed during Step 2. the OCRWS plans to begin
analyzing samples in raw water for total microcystins as soon as possible in addition to the required raw
monitoring. If monitoring results indicate the presence of cyanotoxins in the raw water OCRWS
continues to Step 4. Follow-up sampling will take place within 24 hours after the first detection of
cyanotoxins in the raw water.
OCRWS will communicate with its stakeholders and adjust its treatment or operations based on raw
water monitoring cyanotoxin results, as described in this section.
Monitoring if Cyanobacteria are Identified or Suspected
In addition to routine water monitoring required by Ohio EPA, collect raw water samples in the raw
water wetwell (including a quenching agent as needed) as soon as possible after early warning signs of
cyanobacteria are present, and send them to the laboratory for total microcystins analysis.
Operational Adjustments Based on Source Water Cyanotoxin
Measurements
If potential toxin-producing cyanobacteria are identified in the source water sample(s) (through cell
identification) then:
Potentially lower the permanganate dose in the pump station to achieve a residual level of
less than 0.3 mg/L entering the plant (to avoid cell lysing).
Increase the PAC dose to at least 10 mg/L in the rapid mix and contact management for
further instructions. Lower the sludge level in the clarifier.
Add a filter aid to the water entering the filters. Shorten filter runs for more frequent
backwashing. Lower the caustic soda dose to decrease the pH below 8.0, preferably 7.6-7.7.
Potentially increase the chlorine residual level in the clearwells to 2.2-2.3 mg/L in plant tap.
Adjust clearwells to an elevated level to achieve the maximum contact time with the free
chlorine.
Communications Based on Source Water Cyanotoxin Measurements
Every raw sample and finished result goes to OCRWS and to the Ottawa County Emergency
Management Agency (EMA), who has a distribution list for making further notifications. Additional
communications based on the raw water microcystins results are explained in the OCRWS' Emergency
Response Plan. The Emergency Response Plan contact list includes elected officials, large customers,
schools, nursing homes, hospitals, etc.
Ottawa County Regional Water System Cyanotoxin Management Plan - Step 3
E4.17
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Step 4: Finished Water Cyanotoxin Monitoring
and Treatment Adjustments
Detecting and positively confirming cyanotoxins in the finished water indicates that cyanotoxins have
broken through the treatment barriers. If cyanotoxins are detected in the finished water, OCRWS will
move to continued finished water monitoring in Step 5.
Finished Water Microcystins Monitoring
OCRWS continues to follow the monitoring requirements provided in Ohio's regulation section (A)(2)(d),
also included in Appendix D. A general description of those regulations follows: Ohio's requirement in
Chapter 3745-90 (Harmful Algal Blooms) of the Administrative Code establishes monitoring
requirements for public water systems using surface water including routine weekly source and finished
water monitoring for microcystins from May 1 to October 31. Routine microcystins monitoring drops to
biweekly source water monitoring from November 1 through April 30 (microcystins detections will
determine the need for increased monitoring). If microcystins levels greater than 5 ng/L are found in the
raw water, the public water system must increase monitoring to three days a week.
Section A(2)(d) of Ohio's regulation requires the frequency of monitoring at both raw water sampling
points and finished water sampling points to be increased to daily if microcystins are detected at
finished water sampling points. Daily monitoring shall include analysis within twenty-four hours of
sample collection.
Consider conducting total and extracellular microcystins treatment train sampling to determine
microcystins removal through each treatment unit process. Ohio EPA is available for support on this
sampling in response to finished water detects. This information can be used to further optimize
microcystins treatment. This should also be considered if raw water concentrations exceed 5 ng/L (but
no finished water detections).
Treatment
Continue to take the operational steps identified in Step 3 and follow the Treatment Optimization
Protocol developed to meet the Ohio EPA's requirement.
Communications
OCRWS will carry out the following communications as soon as possible if cyanotoxins are detected in
finished water:
The HAB coordinator will notify local authorities, including Ottawa County Commissioners,
City of Port Clinton, Village of Oak Harbor, Ottawa County EMA, Ottawa County Health
Department, Ottawa County Sheriff's Department, Ohio EPA, local hospitals, nursing homes,
schools, large customers, news agencies and others.
Ottawa County Regional Water System Cyanotoxin Management Plan - Step 4
E4.18
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Step 5: Continued Finished Water Cyanotoxin
Monitoring, Treatment Adjustments and
Public Communication
Step 5 contains communication actions, treatment actions and additional monitoring that should be
carried out based on the concentrations of cyanotoxins confirmed in the finished water. This fifth step
enables the OCRWS to act quickly if cyanotoxins are confirmed in the finished water.
Continued Finished Water Microcystins Monitoring
Continue finished water microcystins monitoring according to the requirements in Ohio's
regulation (see Appendix D of this plan). Ensure that requirements under Section (A)(4) (4)
Response to Microcystins Action Level Exceedance are fully met, if applicable.
Once the microcystins event appears to have been resolved (i.e. no toxin detects in raw or
finished water with lab based methods, no visual blooms), OCRWS will continue monitoring
for early warning signs (return to Step 2).
Treatment and Operations
The water departments in Ottawa County, Port Clinton and Oak Harbor may isolate one of
their elevated storage tanks and have the water in those tanks analyzed for microcystins.
Any tank that tests at or below 1.6 ng/L for microcystins will remain isolated and will be
used for the distribution of safe drinking water for the citizens (for individuals older than 6-
years) into containers, in conjunction with several other sites. It must be noted that, if any
of the overhead storage tanks test above 1.6 ng/L for microcystins, that tank will not be
used as a drinking water distribution point.
Local and state agencies will coordinate with Ottawa County EMA, local water haulers, the
National Guard, local volunteers, etc. to set up water distribution locations for Ottawa
County customers at the Ottawa County Fairgrounds, Erie/Ottawa County Airport, Camp
Perry and the Danbury Township Waste Water Treatment Plant. The State of Ohio EMA and
local American Red Cross will be contacted to help provide bottled water in the event of a
toxin problem lasting more than a day. Ottawa County Commissioners may impose water
restrictions on water consumption, if needed.
In the event of any cyanotoxin detection in the plant tap, the water plant will review all
treatment plant operations to make sure they are performing well in removing microcystins
during the treatment process. The OCRWS water system has alternative sources of potable
water from Carroll Township and the Village of Marblehead, but the quantity of water is
very limited. If OCRWS exceeds the limit for microcystins and Carroll Township water does
not, the interconnection will be opened from Carroll Township to provide water to
customers along Lakeshore Drive to the Portage River.
Communications
OCRWS will immediately notify Ohio EPA of any finished water microcystins detection.
Ottawa County Regional Water System Cyanotoxin Management Plan - Step 5
E4.19
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OCRWS will notify the Safety Service Director for the City of Port Clinton and the
Administrator of the Village of Oak Harbor to brief them on the situation. An emergency
meeting will be convened by the Ottawa County Commissioners, Ottawa County EMA and
the Ottawa County Health Department to discuss current water quality and to see if any
further actions may be warranted. The Ottawa County Sanitary Engineer, Ottawa County
EMA director, or another appointed representative will act as the spokesperson during any
such HAB event.
Ohio EPA's regulation requires a public water system to issue Tier 1 public notification when
a microcystins action level is exceeded in a repeat sample collected at the finished water
sampling point, unless an exemption is granted by the Ohio EPA director based on
extenuating circumstances or additional sampling results. OCRWS will make Tier 1 public
notification according to Ohio EPA's public notification requirements after the repeat (third)
finished water detection above the action level. Public notification requirements are
provided in Appendix C of this plan.
Ottawa County Regional Water System Cyanotoxin Management Plan - Step 5
E4.20
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Long-Term Activities
Additional long-term activities can be undertaken by OCRWS to better understand treatment
effectiveness, be aware of cyanotoxin challenges in addition to microcystin and engage in additional
source water protection activities.
Enhancing Monitoring and Analytical Methods
Explore using phycocyanin and chlorophyll-o levels as indicators of microcystins. ELISA total
microcystins results have been found to generally correlate well with phycocyanin. In the
long-term, OCRWS hopes to be able to identify phycocyanin levels that bracket a range of
concern based on past total microcystins and phycocyanin values.
Consider enhancing the lab testing and results in order to identify intracellular and
extracellular fractions of the total microcystins measured in the water.
Source Water Protection Management Approaches
Identify any ongoing monitoring, committees, government programs and other organized watershed
management activities taking place related to western Lake Erie and the Portage River and how OCRWS
could become more involved. Prioritize which of these may be the most helpful for furthering the
specific interests of OCRWS and its neighboring water utilities.
The Ottawa County Water District could work with the Ohio Balanced Growth Program to identify roles
it could play in TMDL implementation, or could contact county and state officials to identify an
appropriate role, which may be in the form of an activity such as providing additional water quality
monitoring.
Ottawa County Regional Water System Cyanotoxin Management Plan - Long-Term Activities
E4.21
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Appendix A
Cyanotoxin Management Flowchart
Is it vulnerable?
No
Yes
Were toxins detected?.
Were toxins detected?
No
Are there signs
of a bloom or cyanotoxin
\ occurrence? /
Step 2.2 : Monitoring
the Early Warning Signs
Step 2.1 : Preparation
Step 1: Assess Source
Water
Step 3: Raw Water
Cyanotoxin Monitoring
and Treatment
Adjustments
Step 5: Continued
Finished Water
Cyanotoxin Monitoring,
Treatment Adjustments,
and Public
Communication
Step 2.3 : Immediate
Actions If a Bloom is
Suspected
Step 4: Finished Water
Cyanotoxin Monitoring
and Treatment
Adjustments
Continue
monitoring,
treatment, and
communication
activities as needed.
Return to previous
steps as appropriate.
Begin monitoring,
communication, and
source water
mitigation actions.
Continue evaluating
for possible bloom
{Step 2.2).
Begin any
preparation, as
needed, for
monitoring,
treatment and
communication.
Cyanotoxins: Actions to Monitor
Occurrence and Minimize
Exposure
Ottawa County Regional Water System Cyanotoxin Management Plan - Appendix A
E4.22
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Appendix B
Contacts and Stakeholder Information
Laboratory Contact Information
Oregon Water Treatment Plant
Toledo Water Treatment Plant (backup lab)
Stakeholders
Agency/Company
Title
Contact Name
Contact Phone
Contact Email
OCWRS
Cyanotoxins
Management Plan
(CMP) Team
Leader
OCWRS
Source Water
Protection
Manager
OCWRS
Treatment
Operators
OCWRS
Distribution
Operators
Ottawa County
City Sanitary
Engineer
Ottawa County
Water System
Spokesperson
OCHD
Ottawa County
Health Department
Ohio Health
Department
State Health
Department Public
Water System
Contact
Ohio EPA
Ohio EPA
Northwest District
Ottawa County
Ottawa County
Emergency
Management
Director
Ottawa County Regional Water System Cyanotoxin Management Plan - Appendix B
E4.23
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Appendix C
Notifying the Public of Cyanotoxins in their Water
Ohio public water systems have specific requirements for making public notification under certain water
quality conditions. The Ohio requirements are provided here. In addition, the Ohio regulation requires
public water systems to address microcystins detections in their Consumer Confidence Reports. Details
related to that requirement, as well as the required Health Effects Language, are also provided here.
Ohio EPA also provided Health Advisory templates.
3745-90-06 Harmful algal blooms - tier 1 public notification and consumer
confidence reports.
This rule applies to all public water systems, including consecutive water systems.
(A) Tier 1 public notification.
(1) A public water system shall issue tier 1 public notification in accordance with rule
3745-81-32 of the Administrative Code when any of the following occur:
(a) A microcystins action level established paragraph (A)(1) or (A)(2) in rule
3745-90-02 of the Administrative Code is exceeded in a repeat sample
collected at the finished water sampling point in accordance with rule 3745-
90-03 of the Administrative Code, unless the director agrees in writing that
the timeline for notification may be extended or public notification is not
necessary, based on extenuating circumstances, until additional results are
received.
(b) If required by the director based on the results of resamples, distribution
system samples or daily samples collected in accordance with paragraph
(A)(4), (B) or (C)(2) of rule 3745-90-03 of the Administrative Code.
(c) Failure to conduct resampling or repeat sampling in accordance with
paragraph (A)(4)(a), (A)(4)(b), (C)(2)(a) or (C)(2)(b) of rule 3745-90-03 of
the Administrative Code, unless the director agrees in writing that the
timeline for notification may be extended or public notification is not
necessary.
(2) The public notification shall include applicable content in accordance with
paragraph (E) of rule 3745-81-32 of the Administrative Code, the action level
exceeded and the standard health effects language in paragraph (C) of this rule.
(3) The director may allow the system to limit distribution of the public notice in
accordance with paragraph (A)(2) of rule 3745-81-32 of the Administrative Code.
Ottawa County Regional Water System Cyanotoxin Management Plan - Appendix C
E4.24
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(4) Unless otherwise specified by the director based on public health and safety
considerations, tier 1 public notification shall remain in effect until the following
occur:
(a) Microcystins concentrations are below the action level in two consecutive
samples collected a minimum of twenty-four hours apart at the finished water
sampling point.
(b) Microcystins concentrations are below the action level in one set of
samples collected at the distribution sampling points.
(B) Consumer confidence report.
Each community public water system which exceeds a microcystins action level
established in paragraph (A)(1) or (A)(2) of rule 3745-90-02 of the Administrative
Code in a sample collected at a finished water sampling point in a daily, resample or
repeat sample, or a distribution sampling point collected within their own community
water system in accordance with rule 3745-90-03 of the Administrative Code shall
include the following in the consumer confidence report required by Chapter 3745-96
of the Administrative Code:
(1) The microcystins action level.
(2) The range of levels detected and highest single measurement of microcystins
concentration in samples collected at finished water sampling points and distribution
sampling points.
(3) Information regarding the major source of the contaminant: "Produced by some
naturally occurring cyanobacteria, also known as blue-green algae, which under
certain conditions (i.e., high nutrient concentration and high light intensity) may
produce microcystins."
(4) Standard health effects language in paragraph C) of this rule.
(C) Standard health effects language.
The following standard health effects language shall be used in public notification
and consumer confidence reports: "Consuming water containing concentrations of
microcystins over the action level may result in abnormal liver function, diarrhea,
vomiting, nausea, numbness or dizziness. Children younger than school age, pregnant
women, nursing mothers, the elderly, immune-compromised individuals, those with
pre-existing liver conditions and those receiving dialysis treatment may be more
susceptible than the general population to the health effects of microcystins."
Effective:
Five Year Review (FYR) Dates:
06/01/2016
06/01/2021
Ottawa County Regional Water System Cyanotoxin Management Plan - Appendix C
E4.25
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Promulgated Under:
Statutory Authority:
Rule Amplifies:
119.03
3745.50, 6109.04
3745.50, 6109.04
Ottawa County Regional Water System Cyanotoxin Management Plan - Appendix C
E4.26
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Appendix D
Ohio State Monitoring Requirements
3745-90-03 Harmful algal blooms - monitoring.
This rule applies to all surface water-systems and consecutive water systems receiving water from a
surface water source. Seasonal systems shall monitor in accordance with this rule during the system's
operating season.
(A) Surface water systems.
(1) 'yanฐbacteria screening.
Surface water systems shall monitor with a minimum of one sample from each raw
water sampling point at least once every two weeks for cyanobacteria screening.
Cyanobacteria samples shall be collected at the same time as the routine microcystins
sample.
(2) Routine microcystins monitoring.
(a) Routine microcystins monitoring requirements between May first and
October thirty-first.
Surface water systems shall monitor with a minimum of one sample from
each raw water sampling point and one sample from each finished water
sampling point at least weekly for microcystins analysis.
(b) Routine microcystins monitoring requirements between November first
and April thirtieth.
(i) Surface water systems shall continue to monitor in accordance
with paragraph (A)(2)(a) of this rule unless microcystins are not
detected in at least two consecutive weekly samples from both the
raw water sampling point and the finished water sampling point, then
the microcystins monitoring frequency is reduced to a minimum of
one sample from each raw water sampling point at least once every
two weeks.
(ii) If microcystins are detected at a raw water sampling point, weekly
monitoring at that raw water sampling point and the finished water
sampling point shall be conducted beginning no later than twenty-four
hours following the detection. When microcystins are not detected in
at least two consecutive weekly samples from both the raw water
sampling point and the finished water sampling point, then
monitoring once every two weeks may resume in accordance with
paragraph (A)(2)(b)(i) of this rule.
Ottawa County Regional Water System Cyanotoxin Management Plan - Appendix D
E4.27
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(c) Increased routine microcystin monitoring (three days per week).
The frequency of monitoring at both raw water sampling points and
finished water sampling points shall be increased to three days a
week, beginning no later than the following week, if microcystins
exceed five micrograms per liter (ug/L) at the raw water sampling
point, unless an alternate frequency has been established as part of the
approved cyanotoxin general plan in accordance with rule 3745-90-05
of the Administrative Code.
Routine monitoring in accordance with paragraphs (A)(2)(a) and
(A)(2)(b) of this rule may resume once the following occur:
(i) Microcystins concentrations are equal to or less than five ug/L in
two consecutive samples from the raw water sampling point that are
collected at least one day apart.
(ii) Microcystins concentration is non-detect at finished water
sampling points.
(iii) If samples were collected at distribution sampling points in
accordance with this rule, microcystins are not detected at any
distribution sampling point.
(d) Increased routine microcystins monitoring (daily).
The frequency of monitoring at both raw water sampling points and
finished water sampling points shall be increased to daily if
microcystins are detected at finished water sampling points collected
in accordance with this rule, or distribution sampling points collected
in accordance with this rule. Daily monitoring shall include analysis
within twenty-four hours of sample collection.
Routine monitoring may resume in accordance with paragraphs
(A)(2)(a) and (A)(2)(b) of this rule if the two most recent consecutive
daily samples from the raw water sampling point are equal to or less
than five ug/L, or in accordance with paragraph (A)(2)(c) of this rule
if either of the two most recent consecutive daily samples from the
raw water sampling point are greater than five ug/L, once the
following occur:
(i) Microcystins are not detected in two consecutive daily samples
collected at the finished water sampling point.
(ii) If samples were collected at distribution sampling points in
accordance with this rule, microcystins are below the action level at
distribution sampling points.
Ottawa County Regional Water System Cyanotoxin Management Plan - Appendix D
E4.28
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(3) Revised cyanobacteria screening or routine microcystins monitoring frequency.
The cyanobacteria screening or routine microcystins monitoring frequency
may be revised (decreased, increased or discontinued) at the discretion of the
director. When establishing the revised schedule, the director may consider
cyanobacteria screening data collected in accordance with this rule,
microcystins data, and other information provided by the public water system
including data from other screening tools (such as phycocyanin sensors or
phytoplankton enumeration) and treatment information. Surface water
systems shall monitor in accordance with the revised cyanobacteria screening
or routine microcystins monitoring schedule established by the director.
(4) Response to microcystins action level exceedance.
If microcystins exceed an action level established in paragraph (A)(1) or
(A)(2) of rule 3745-90-02 of the Administrative Code in routine samples
collected at the finished water sampling point, the public water system shall
do the following:
(a) As soon as possible, but no later than twenty-four hours after receiving the
results of the initial action level exceedance, collect one resample from each
raw water sampling point and one resample from each finished water
sampling point. Analysis of resamples must be completed within twenty-four
hours of collection. These resamples satisfy the requirement for daily samples
as set forth in paragraph (A)(2)(d) of this rule.
(b) Within twenty-four hours of collecting the resamples, collect one repeat
sample from each raw water sampling point and one repeat sample from each
finished water sampling point. Analysis of repeat samples must be completed
within twenty-four hours of collection. These repeat samples satisfy the
requirement for daily samples as set forth in paragraph (A)(2)(d) of this rule.
(c) If the microcystins concentration exceeds the action level in the resample
or repeat sample collected at any finished water sampling point in accordance
with paragraph (A)(4)(a) or (A)(4)(b) of this rule, as soon as practical but no
later than three hours after receiving the resample or repeat sample results, the
surface water system shall notify all consecutive systems served by the water
system. The surface water system with the action level exceedance, and all
consecutive water systems served by the water system, shall within twenty-
four hours of receiving the resample or repeat sample results, collect samples
at representative distribution sampling points in accordance with the
contingency plan required by rule 3745-85-01 of the Administrative Code.
Additional distribution system monitoring may be required by the director
based on sampling results and other relevant circumstances. Analysis of
distribution samples must be completed within twenty-four hours of
collection.
(d) Conduct routine daily monitoring in accordance with paragraph (A)(2)(d)
of this rule.
Ottawa County Regional Water System Cyanotoxin Management Plan - Appendix D
E4.29
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(B) Consecutive water systems receiving water from an in-state surface water system.
Within twenty-four hours of receiving notification of an action level exceedance in
accordance with paragraph (A)(4)(c) or (C)(2)(c) of this rule, the consecutive water
system shall collect samples at representative distribution sampling points in
accordance with the contingency plan required by rule 3745-85-01 of the
Administrative Code. Additional distribution system monitoring may be required by
the director based on sampling results and other relevant circumstances. Analysis of
distribution samples must be completed within twenty-four hours of collection.
(C) Consecutive water systems receiving water from an out-of-state surface water source.
(1) Routine microcystins monitoring.
(a) Routine microcystins monitoring requirements between May first and
October thirty-first.
Consecutive water systems receiving water from an out-of-state surface water
source shall monitor with a minimum of one sample from each finished water
sampling point at least weekly for microcystins analysis.
(b) Routine microcystins monitoring requirements between November first
and April thirtieth.
Consecutive water systems receiving water from an out-of-state surface water
source shall monitor with a minimum of one sample from each finished water
sampling point at least once every two weeks for microcystins analysis.
(c) Increased routine microcystins monitoring (daily).
The frequency of monitoring at finished water sampling points shall be
increased to daily if microcystins are detected at finished water sampling
points collected in accordance with this rule, or distribution sampling points
collected in accordance with this rule. Daily monitoring shall include analysis
within twenty-four hours of sample collection.
Routine monitoring may resume in accordance with paragraph (C)(1)(a) or
(C)(1)(b) of this rule once the following occur:
(i) Microcystins are not detected in two consecutive daily samples
collected at the finished water sampling point.
(ii) If samples were collected at distribution sampling points in
accordance with this rule, microcystins are below the action level at
distribution sampling points.
(d) Revised routine microcystins monitoring frequency.
Ottawa County Regional Water System Cyanotoxin Management Plan - Appendix D
E4.30
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The routine microcystins monitoring frequency may be revised (decreased,
increased or discontinued) at the discretion of the director. When establishing
the revised schedule, the director may consider microcystins data, and other
information provided by the public water system including data from
screening tools (such as phycocyanin sensors or phytoplankton enumeration)
and treatment information. Consecutive water systems shall monitor in
accordance with the revised routine microcystins monitoring schedule
established by the director.
(2) Response to microcystins action level exceedance.
If microcystins exceed an action level established in paragraph (A)(1) or
(A)(2) of rule 3745-90-02 of the Administrative Code in routine samples
collected at the finished water sampling point, the public water system shall
do the following:
(a) As soon as possible, but no later than twenty-four hours after receiving the
results of the initial action level exceedance, collect one resample from each
finished water sampling point. Analysis of resamples must be completed
within twenty-four hours of collection. This resample satisfies the
requirement for daily samples as set forth in paragraph (C)(1)(c) of this rule.
(b) Within twenty-four hours of collecting the resamples, collect one repeat
sample from each finished water sampling point. Analysis of repeat samples
must be completed within twenty-four hours of collection. This repeat sample
satisfies the requirement for daily samples as set forth in paragraph (C)(1)(c)
of this rule.
(c) If the microcystins concentration exceeds the action level in the resample
or repeat sample collected at any finished water sampling point in accordance
with paragraph (C)(2)(a) or (C)(2)(b) of this rule, as soon as practical but no
later than three hours after receiving the resample or repeat sample results, the
public water system shall notify all consecutive systems served by the water
system. The public water system with the action level exceedance, and all
consecutive water systems served by the water system, shall within twenty-
four hours of receiving the resample or repeat sample results, collect samples
at representative distribution sampling points in accordance with the
contingency plan required by rule 3745-85-01 of the Administrative Code.
Additional distribution system monitoring may be required by the director
based on sampling results and other relevant circumstances. Analysis of
distribution samples must be completed within twenty-four hours of
collection.
(d) Conduct routine daily monitoring in accordance with paragraph (C)(1)(c)
of this rule.
Ottawa County Regional Water System Cyanotoxin Management Plan - Appendix D
E4.31
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(D) Monitoring extension.
Upon a request from a public water system, the director may agree to extend the
twenty-four hour monitoring requirement for daily, resample, repeat or distribution
samples required pursuant to this rule on a case-by-case basis when the public water
system has a logistical problem collecting samples within twenty-four hours or
analyzing samples in accordance with the requirements of this chapter. When an
extension is agreed to by the director, the director shall specify in writing how much
time the public water system has to monitor. Examples of potential logistical
problems include, but are not limited to:
(1) Extreme weather conditions create unsafe travel or on-site conditions for the
person collecting the sample.
(2) Limited certified laboratory capacity on weekends and holidays.
(E) Violations.
Failure to comply with routine and distribution monitoring requirements in paragraph
(A)(1), (A)(2), (A)(3), (A)(4)(c), (B), (C)(1) or (C)(2)(c) of this rule is a monitoring
violation and requires the public water system to provide Tier 3 public notification in
accordance with rule 3745-81-32 of the Administrative Code. Failure to comply with
resample and repeat sample requirements in paragraph (A)(4)(a), (A)(4)(b), (C)(2)(a)
or (C)(2)(b) of this rule is a monitoring violation and requires the public water system
to provide a tier 1 public notification accordance with rule 3745-81-32 of the
Administrative Code.
Effective:
Five Year Review (FYR) Dates:
Promulgated Under:
Statutory Authority:
Rule Amplifies:
06/01/2016
06/01/2021
119.03
3745.50, 6109.04
3745.50, 6109.04
Ottawa County Regional Water System Cyanotoxin Management Plan - Appendix D
E4.32
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Cyanotoxins Management Plan
City of Myrtle Creek
Myrtle Creek, Oregon
November, 2016
E5.1
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Table of Contents
Executive Summary E5.4
City of Myrtle Creek Overview E5.5
Source Water E5.5
Treatment Process E5.5
Routine Water Quality Monitoring E5.6
Cyanotoxin Management Plan E5.6
Step 1: Assess Source Water E5.8
1.1 Identify Source Water Protection Areas E5.8
Land Use E5.8
1.2 Create Inventory of HABs Risk Factors E5.9
1.2.1 Source Water Characteristics E5.9
1.2.2 Water Quality Parameters E5.10
Historical Cyanobacteria and Cyanotoxin Events in Source Water E5.10
Nutrients E5.10
Assess Vulnerability E5.10
Step 2: Preparation, Monitoring for Early Warning Signs and Immediate Actions E5.ll
2.1 Preparation E5.ll
Prepare Staff and Equipment for Monitoring E5.ll
Prepare for Treatment Adjustments E5.12
Communications E5.12
Establish Communication Plan with other Source Water Users E5.12
Communication with Stakeholders E5.12
2.2 Monitor the Early Warning Signs E5.13
Early Indicators of a Cyanobacterial Bloom E5.13
2.3 Immediate Actions if a Bloom is Suspected E5.13
Monitoring Actions in Response to Early Warning Signs E5.13
Treatment adjustments in Response to Early Warning Signs E5.13
Communication Actions in Response to Early Warning Signs E5.14
Step 3: Raw Water Cyanotoxin Monitoring and Treatment Adjustments E5.15
Monitoring if Cyanobacteria are Identified or Suspected E5.15
Operational Adjustments Based on Source Water Cyanotoxin Measurements E5.15
Communications Based on Source Water Cyanotoxin Measurements E5.15
Step 4: Finished Water Cyanotoxin Monitoring and Treatment Adjustments E5.16
Finished Water Total Microcystins Monitoring E5.16
Treatment E5.16
Communications E5.16
E5.2
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Step 5: Continued Finished Water Cyanotoxin Monitoring, Treatment Adjustments and Public
Communication E5.17
Continued Finished Water Microcystins Monitoring E5.17
Treatment E5.17
Communications E5.17
Long-Term Activities E5.19
Monitoring Activities E5.19
Source Water Protection Management Approaches E5.19
Treatment Activities E5.19
Appendices
Appendix A Cyanotoxin Management Flowchart E5.20
Appendix B Contacts and Stakeholder Information E5.21
Appendix C Notifying the Public of Cyanotoxins in their Water E5.22
E5.3
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Executive Summary
City of Myrtle Creek, with the support of the State of Oregon and the United States Environmental
Protection Agency (USEPA), developed this Cyanotoxins Management Plan (CMP) to prepare for and
mitigate risks from harmful algal blooms (HABs) and cyanotoxins occurring in the South Umpqua River
order to protect public drinking water from cyanotoxin contamination. This document provides steps
and documents activities to prepare for and identify a potential HAB occurrence, make treatment and
operational adjustments to remove cyanotoxins from the water, provide timely information and (as
appropriate) an advisory to the water system's customers, and document information about
occurrences of HABs so that information can be used to minimize the effect of HABs on the water
system in the future. This plan also contains possible future activities the utility could engage in to
mitigate the risks from HABs and cyanotoxins, such as long-term source water protection activities.
The steps outlined in this CMP include:
Step 1: Assess Source Water
Step 2: Preparation, Monitoring for Early Warning Signs and Immediate Actions
Step 3: Raw Water Cyanotoxin Monitoring and Treatment Adjustments
Step 4: Finished Water Cyanotoxin Monitoring and Treatment Adjustments
Step 5: Continued Finished Water Cyanotoxin Monitoring, Treatment Adjustments and Public
Communication
In addition to the five steps above long-term activities are also discussed to enhance the utility's ability
to prevent, mitigate and manage the risks from cyanotoxin occurrence in source and drinking waters.
City of Myrtle Creek Cyanotoxin Management Plan - Executive Summary
E5.4
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City of Myrtle Creek Overview
The City of Myrtle Creek's water system serves 3,460 people finished water through approximately
1,400 service connections. The water system relies on two developed surface water sources to supply its
water needs: the South Umpqua River and the Springbrook springs. Treatment facilities include two
filtration plants, one at the confluence of the South Umpqua River and Myrtle Creek and one in the
Springbrook springs, which consists of 8 springs and the Harrison-Young Canyon. South Umpqua River
water, which is the primary source of water for the system, is filtered by microfiltration, polished
seasonally with Granular Activated Carbon (GAC) filtration, and disinfected with both UV and chlorine.
The City of Myrtle Creek's distribution system consists of two 1 MG storage tanks and one 0.5 MG
storage tank, with a working volume of 137,000 gallons, for a total of 2.137 MG of storage. A description
of the water system's treatment process is provided below, as well as a schematic of the treatment
system.
Source Water
The South Umpqua River is the city's primary source from late spring to January. Springbrook springs is
the other source, which is used all year and produces almost half of the treated water over the
year. Since the springs rely heavily on rainfall and seasonal water rights for the springs apply, the
Springbrook springs produce almost all the water from February to April. The amount sourced from the
river and springs varies from year to year.
In the winter, source waters are subject to high turbidity, while in the summer they experience high
temperatures as well as taste and odor events. High levels of E. coli have also consistently been found in
this source water and Cryptosporidium has been detected, leading the City of Myrtle Creek to provide
additional treatment (microfiltration and UV) to protect consumers.
The taste and odor problems possibly stem from geosmin or MIB production by algae. During the
summer months, the dissolved oxygen and pH measurements from the source water are often outside
the ranges that are healthy for aquatic life uses. Nutrient levels are also high, contributing to the growth
of HABs. In the summer after it rains, the water from small pools in the river where algae are attached
to the South Umpqua river bottom, referred to as "frog pools," are washed downriver, creating a pulse
of algae in the water column.
Treatment Process
City of Myrtle Creek provides the following treatment on water from the South Umpqua River: (Figure 1
displays a diagram of the treatment train):
Infiltration gallery: Water is collected in an infiltration gallery in the river that removes some
turbidity before the water is pumped by 3 turbine pumps to the treatment plant.
Coagulant addition: Aluminum chloro-hydrate (ACH) is injected into the transmission line that
carries the water from the river to the treatment plant. The ACH is stored in the treatment
plant and a feed line returns from the plant to the injection point. This allows enough time for
the ACH to fully mix with the water before filtration.
Roughing filters: When it enters the treatment plant building, water passes through 300 pim
mesh Amiad screens, which serve as roughing filters. A streaming current meter is located
before the Amiad screens, but it is not currently relied upon for operational decisions.
City of Myrtle Creek Cyanotoxin Management Plan - Overview
E5.5
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Microfiltration: Water that has passed through the Amiad screens flows through 0.1 pirn
microfiltration units.
GAC: In the summer months, filtered water passes through a GAC vessel for taste and odor (and
possibly cyanotoxin) removal. The empty bed contact time for the GAC is 7.1 min at a design
flow of 1400 gallons per minute. The GAC units are brought into service when the South
Umpqua River's water temperature reaches 70ฐF or if a taste and odor event occurs, typically
between June and October. Total Organic Carbon (TOC) is measured before and after the GAC
units once every two weeks while they are in operation. The GAC filters are currently only being
backwashed once during the time they are in operation.
UV disinfection: Water leaves the GAC filters and undergoes UV disinfection in the treatment
plant.
Chlorination: Water is chlorinated with sodium hypochlorite before flowing into the 160,000
gallon clearwell, where disinfection CT is achieved. The required chlorine CT for Surface Water
Treatment Rule compliance is 14 mg-min/L. Chlorine CT is measured and recorded daily. Based
on records from August 2015, the normal chlorine CT range for that month was 76.7 to 153.4
mg-min/L.
Routine Water Quality Monitoring
Raw water is monitored at the Myrtle Creek treatment plant for pH, temperature, turbidity and
alkalinity. Source water and finished water TOC are measured monthly. TOC is also measured before and
after the GAC units when they are in operation. In addition, samples are collected and measurements
are made for cyanobacterial cell counts and total microcystins in the South Umpqua River by the
Partnership for Umpqua Rivers (PUR). Either the State of Oregon or the PUR notify the City of Myrtle
Creek's operators if high cyanobacterial counts or cyanotoxins are found in the river. A summary of
routine water quality monitoring is provided in Table 1 below.
Table 1. Raw Water Routine Monitoring
Parameter
Location
Frequency
Who Collects
Sample?
Who Does Analysis?
Alkalinity
Raw Water Pump
Discharge
Monthly
Myrtle Creek
Operator
Plant
TOC
Monthly
Lab
PH
Daily
Plant
Temperature
Daily
Plant
Turbidity
Daily
Plant
Cyanobacterial Cells
South Umpqua River
PUR
Microcystins
South Umpqua River
PUR
Lab
Cyanotoxin Management Plan
City of Myrtle Creek developed a Cyanotoxins Management Plan (CMP) detailed in the steps below. This
CMP provides an action plan to prepare for and mitigate risks from harmful algal blooms (HABs) and
cyanotoxins occurring in the South Umpqua River in order to protect public drinking water from
cyanotoxin contamination. The plan includes immediate steps discussing monitoring and treatment
should HABs and cyanotoxins occur, as well as long-term steps the system can engage in to protect
source waters and to fully evaluate treatment capabilities. A detailed flowchart of the CMP can be found
in Appendix A.
City of Myrtle Creek Cyanotoxin Management Plan - Overview
E5.6
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Figure 1. Schematic Diagram of the Treatment System
City of Myrtle Creek , OR
Treatment Schematic
Microfiltration
Infiltration
Gallery
Intake Bldg
Amiad Screens
(300 |im)
Flows N
Streaming Current Meter
Amiad Screens
(300 p.m)
Streaming Current Meter
ACH
S. Umpqua
River
Microfiltration
(0.1 limn)
NaOCl
uv
GAC
Distribution
System
NaOCl
GAC
UV
Treatment Plant Building boundaries
1. ACH (aluminum chloro-hydrate) is stored in the treatment plant and a feed line returns from the TP back to ~l/3 distance from intake
building to the TP, where ACH is injected.
2. 160,00 gallons, ground level, outside.
City of Myrtle Creek Cyanotoxin Management Plan - Overview
E5.7
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Step 1: Assess Source Water
1.1 Identify Source Water Protection Areas
The source water protection area for City of Myrtle Creek within the South Umpqua River was evaluated
using EPA's online mapping tool, Drinking Water Mapping Application to Protect Source Waters
(DWMAPS).
Map 1 shows the delineation of the South Umpqua River source water protection area, as well as point
sources of contamination located nearby (see "Inventory" below). The source water protection area
includes all catchments 15 miles upstream of the Umpqua River intake.
- L
idEM* v
4T*
2f
f, ' ฆ .fi :',fฃ
' * /J ' ฃ
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4 ys&fyr /-* s mk*? mm t
Selected NHD Flowlines
matching query
Catchments
b
NPDES Refuse Facilities
NPDES Sewerage Facilities
, y NPDES Other Facilities
RCRA Facilities
CERCLA (Superfund)
Facilities
~
TRI Facilities
TSC A Facilities
Map 1. Source Water Protection Area for the South Umpqua River Intake and Potential Point
Sources (prepared in DWMAPs: https://www.eoa.aov/sourcewaterorotection/dwmaos)
Land Use
Map 2 shows the land use and land cover in the larger South Umpqua River Watershed which includes
the source water protection area. The majority of the land cover in the South Umpqua River Watershed
is forested, with agricultural and urban land use less prevalent. Even though it is a less dominate land
use, urban point sources are the primary drivers of elevated nutrient (phosphorus and nitrogen) levels in
the South Umpqua Watershed. Wastewater treatment plants in the watershed provide approximately
85% of the nutrient loading while only 5% of the flow. A smaller percentage of nutrient pollution comes
from nonpoint source pollution from surrounding urban and agricultural areas
(http://www.deq.state.or.us/WQ/TMDLs/docs/umpquabasin/umpqua/chpt4nut.pdf).
City of Myrtle Creek Cyanotoxin Management Plan - Step 1
E5.8
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Canyooyille
Tiller -
Glendale
RUSA
Winston-Green
Myrtle Creek
Riddle-
ฎ Waste Water Treatment Plant
Forest / Farm Transition
Agriculture
Forest I Park
Commercial I Industrial I Urban
Rural Residential
A/ South Umpqua River model extent
/V Other rivers and creeks
30 Miles
Map 2. Land use in the South Umpqua River Watershed (Excerpted from:
htto://www.dea.state.or.us/WQ/TMDLs/docs/umoauabasin/umoaua/chot4nut.odf)
1.2 Create Inventory of HABs Risk Factors
1.2.1 Source Water Characteristics
The South Umpqua River is the city's primary source from late spring to January. In the winter it is
subject to high turbidity, while in the summer it experiences high temperatures as well as taste and odor
events. High levels of E. coli have also consistently been found in this source water and Cryptosporidium
has been detected, leading the City of Myrtle Creek to provide additional treatment (microfiltration and
UV) to protect consumers.
Streams in the South Umpqua River watershed have been assessed for attainment of surface water
quality standards under Section 305(b) of the Clean Water Act (CWA). Based on these assessments,
several streams have been listed as impaired under Section 303(d) of the CWA. The South Umpqua River
specifically was listed as impaired for aquatic weeds/algae. The Total Maximum Daily Load (TMDL)
defines targets for nutrient loading and chlorophyll-o concentrations in the South Umpqua River and
outlines strategies for reducing nutrient loading and chlorophyll-o concentrations, which will ultimately
reduce algal growth.
One source of funding for implementing the TMDL is CWA nonpoint source program (Section 319) grant
funds. There have been three local Section 319 granted projects in the Lower South Myrtle Creek
watershed totaling approximately $100,000 in funding to help improve water quality monitoring efforts.
The watershed has two active watershed committees. The larger, more active watershed council is the
PUR. The other is the South Umpqua Rural Community Partnership. Both tend to focus primarily on
activities that promote fish habitat. Myrtle Creek could play a role supporting the TMDL and water
quality improvement process by engaging with these local watershed committees and supporting other
efforts.
City of Myrtle Creek Cyanotoxin Management Plan - Step 1
E5.9
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1.2.2 Water Quality Parameters
Historical Cyanobacteria and Cyanotoxin Events in Source Water
Cyanotoxins have been actively addressed in the South Umpqua River for the past ten years. A dog's
death from exposure to fatal levels of cyanotoxins after swimming in water near Lawson Bar brought
attention to the toxin issue in surface waters. Now a permanent HAB recreational advisory is posted by
Oregon Health Authority on this section of the South Umpqua River.
Nutrients
Phosphorus and nitrogen are drivers of algal and cyanobacterial growth in lakes, rivers and reservoirs.
Sources of phosphorus and nitrogen can include discharge of domestic and industrial wastewater, septic
systems and runoff from agricultural and urban lands.
A query of the USEPA DWMAPS tool indicates that there are four National Pollutant Discharge
Elimination System (NPDES) permitted wastewater dischargers and no Combined Sewer Overflows
within 15 miles upstream of Myrtle Creek. According to the 2006 Umpqua Basin TMDL, which applies to
the entire South Umpqua River Watershed, wastewater treatment plants are the primary drivers of
elevated nutrient levels in the watershed. A smaller percentage of total nutrient pollution comes from
surrounding urban and agricultural areas, including such sources as urban runoff, agricultural runoff,
livestock, failing septic systems, illegal discharges and streambank erosion. To access the Umpqua Basin
TMDL report, go to http://www.deq.state.or.us/WQ/TMDLs/docs/umpquabasin/umpqua/chpt4nut.pdf.
Assess Vulnerability
A weight of evidence approach was used to characterize whether the utility's source water is considered
vulnerable to HAB and cyanotoxin occurrence. Evidence incorporates all of the discussion in this section
including previous bloom occurrences, positive toxin results from limited historical cyanotoxin
monitoring, and the fact that the South Umpqua River is listed as impaired and has a TMDL for aquatic
weeds/algae. The City of Myrtle Creek has been determined to be vulnerable to cyanotoxin events and
should continue to Step 2.
City of Myrtle Creek Cyanotoxin Management Plan - Step 1
E5.10
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Step 2: Preparation, Monitoring for Early
Warning Signs and Immediate Actions
2.1 Preparation
The City of Myrtle Creek has determined that its source water is vulnerable to cyanobacterial blooms
and has considered how to prepare for cyanobacterial blooms and cyanotoxin occurrence. Preparation
includes preparing for monitoring raw and finished waters, preparing for treatment adjustments and
establishing communication plans.
Prepare Staff and Equipment for Monitoring
City of Myrtle Creek intends to carry out the following activities in order to be prepared for the
monitoring steps described in this plan:
Train operators on algae/cyanobacteria identification, counting and identification of gas
vacuoles.
Explore if there are local or regional algae/cyanobacteria genera keys already available from
watershed groups, academics, states and other groups. If not, consider setting up a
microscope and try to start preparing an algae key that is specific to algae/cyanobacteria
genera found in the South Umpqua River.
Buy a set of microcystins test strips and pilot them to determine if they can be incorporated
into the management plan as described here. Consider sharing the cost of the test strips
with other South Umpqua River water utilities. Be sure to have test strips that can reliably
measure at or below 0.3 ng/L total microcystins and test strips that can measure at or above
3.5 ng/L total microcystins.
Train operators on how to use microcystins test strips.
Establish and document sampling and testing procedures.
Establish and document quality assurance procedures.
Enter into an agreement with a laboratory that can reliably and promptly analyze samples
using the Adda-specific ELISA lab-based test.
o Establish a procedure for submitting samples to the identified laboratory for Adda-
specific ELISA analysis. Consider preparing written sampling instructions,
o Document all sampling, testing and quality assurance procedures for lab samples,
o Have coolers, chain of custody forms and shipping labels on site and ready for use.
o Ensure that the appropriate bottles (glass or PETG) are on site for the Adda-specific
ELISA samples.
o Also have sodium thiosulfate available for quenching any samples that have been
exposed to an oxidant as soon as they are collected.
Work to build relationships with researchers at Oregon State in Corvallis and Southern
Oregon University.
City of Myrtle Creek Cyanotoxin Management Plan - Step 2
E5.ll
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Prepare for Treatment Adjustments
City of Myrtle Creek will carry out the following activities in order to be more prepared to treat its
source water during a HAB:
Learn more about ways to measure GAC effectiveness, and what parameters to monitor to
evaluate the effectiveness of GAC for toxin removal. Rapid small-scale column test is a
commonly used method to evaluate the performance of GAC for removal of organics.
Determine if GAC should or should not go biological, and if Myrtle Creek's GAC has gone
biological.
Assuming Myrtle Creek will consistently have at least 75 mg-min/L free chlorine CT, back
calculate (as best possible) to determine what level of raw water microcystins the plant can
handle in order to achieve < 0.3 ng/L microcystins at the entry point to the distribution
system (EPTDS) (i.e. leaving the clearwell). Using American Water Works Association's
CyanoTOX tool, preliminary calculations indicate that the threshold concentration would be
3.5 ng/L mixed microcystins. Myrtle Creek reviewed their 2015 daily CT values during the
summer months and decided on the following values based on that review: pH =8, water
temp = 20 degrees Celsius, CT = 75.
Communications
Establish Communication Plan with other Source Water Users
In addition to the City of Myrtle Creek, nine additional treatment plants use water from the South
Umpqua River. These treatment plants and their contact information are provided in the Stakeholders
List in Appendix B of this plan. The City of Myrtle Creek and the other South Umpqua River water
systems maintain a phone tree through which they can communicate in emergency situations.
Consider using the text group of South Umpqua River water utilities that is being set up for
spill notification as a way to communicate about toxin/cyanobacteria results and related
findings that could be used to warn everyone.
Work with other South Umpqua water utilities at or through the periodic meetings (already
taking place) to develop common identification skills, notification approaches, etc.
Communication with Stakeholders
City of Myrtle Creek will carry out the following activities in order to be more prepared for the
communications steps described in this plan:
Complete the stakeholders list in Appendix B and reevaluate on a recurring basis to maintain
an up-to-date list.
Add language to the water system's consumer confidence report asking home dialysis and
hemodialysis center customers to contact the water system so they can be added to the
stakeholders list and receive early warning about potential microcystins contamination of
the finished water. Explanations of when stakeholders will be contacted about a HAB are
provided in Step 5 of this plan.
Prepare a public health advisory template that is available and ready for use if necessary.
Also prepare another notice that would be issued to lift an existing public health advisory. In
the meantime, consider using the USEPA language provided in Appendix C. Explanations of
when a public health advisory will be issued or lifted are provided in Step 5 of this plan.
City of Myrtle Creek Cyanotoxin Management Plan - Step 2
E5.12
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Prepare and have available a "Frequently Asked Questions" outreach document for water
consumers - have copies available in the office where customers pay their bills and/or
include it with their bills. Use USEPA's Cyanotoxin Risk Communication Toolbox as a
resource for FAQs.
2.2 Monitor the Early Warning Signs
Based on historical bloom occurrence in the South Umpqua River, City of Myrtle Creek begins looking for
signs of blooms in the early summer months. Early indicators that a bloom may be occurring include
drinking water treatment operational challenges. Other early warning signs of bloom occurrence that
operators can look for during the system's normal operation are identified in this section. Also included
in this section are follow-up activities if any of the early warning signs are observed.
Early Indicators of a Cyanobacterial Bloom
City of Myrtle Creek operators have identified several early warning signs that a cyanobacterial bloom is
likely to occur in the very near future (or has begun to occur). The following early warning signs are a
combination of observations of conditions in the river itself and in the treatment plant:
Water temperature in the river is above 70ฐF (approximately 20ฐC).
A summer rain is scheduled that may raise the river level high enough to flush nutrients and
the "frog pools" down river.
Algal mats appear to be forming at Lawson Bar.
PUR or Oregon Department of Environmental Quality (DEQ)/Oregon Health Authority (OHA)
notifies Myrtle Creek that high cyanobacteria counts or cyanotoxins were detected in the
South Umpqua River.
2.3 Immediate Actions if a Bloom is Suspected
Monitoring Actions in Response to Early Warning Signs
During the summer months, visit Lawson Bar at least once a week and visually check the
river for algal mat formation. If algal mats seem to be forming at Lawson Bar, check on them
more frequently.
o The algal mats are considered an indicator that cyanotoxins may be likely present in
source waters.
o If a bloom is suspected continue to Step 3.
Treatment adjustments in Response to Early Warning Signs
If it is a week when TOC is not scheduled to be measured before and after the GAC and any
of the early indicators is/are present (other than water temperature), measure TOC before
and after the GAC.
o TOC removal across the GAC is being used as an indicator of GAC effectiveness. If TOC
removal is less than 60%, then the City of Myrtle Creek will backwash the GAC.
If a summer rain event is expected that may raise the river level high enough to flush the
"frog pools", then before the rain begins, adjust the finished water storage tank set points
so the tanks are filled enough that the plant does not have to run during the river rise.
City of Myrtle Creek Cyanotoxin Management Plan - Step 2
E5.13
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Communication Actions in Response to Early Warning Signs
Check with other water utilities and raw water stakeholders to see if they have observed any early signs
of cyanobacteria, taste and odor or cyanotoxins in the river water.
City of Myrtle Creek Cyanotoxin Management Plan - Step 2
E5.14
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Step 3: Raw Water Cyanotoxin Monitoring and
Treatment Adjustments
Monitoring if Cyanobacteria are Identified or Suspected
If conditions favoring a cyanobacterial bloom are observed during Step 2. the City of Myrtle Creek plans
to begin analyzing samples for microcystins as soon as possible using test strips or ELISA.
1. Test the raw water at the intake for microcystins with a test strip or ELISA under either or both
of these conditions:
If the mats observed at Lawson Bar start bubbling and they are located on the same side
of the river as the City of Myrtle Creek's intake.
If the PUR or Oregon DEQ/OHA notifies Myrtle Creek that high cyanobacteria counts or
cyanotoxins were detected in the South Umpqua River.
2. If a raw water test strip or ELISA sample is >0.3 ng/L for total microcystins during Step 3
monitoring, go to Step 4.
Operational Adjustments Based on Source Water Cyanotoxin
Measurements
City of Myrtle Creek does not wait for finished water cyanotoxin detections to adjust treatment, but
rather begins making treatment adjustments when cyanobacteria or cyanotoxins are detected in the
raw water. If potential toxin-producing cyanobacteria are identified in the source water test samples
that are collected and analyzed for cyanobacteria cell identification by PUR or Oregon DEQ/OHA (see
Step 3 above) then do the following:
Turn on GAC if it is not on already.
Check TOC removal across the GAC. If <60% TOC is being removed, backwash the GAC filter.
Ensure chlorine CT is > 75 mg-min/L in the clearwell.
If the CT was low, increase the chlorine dose before the clearwell to correct CT so that it is >
75 mg-min/L.
Please note that these potential operational adjustments are empirical and have not been
comprehensively evaluated or supported by engineering studies. Evaluation of treatment adjustments
will require jar testing, which is outside the scope of this project. As discussed in long-term activities, the
City of Myrtle Creek can evaluate the toxin removal capacity of the current treatment process using jar
tests spiked with varying levels of toxins to simulate different operational conditions. In addition, the
City of Myrtle Creek can evaluate the effectiveness of these treatment adjustments based on sampling
results and refine these approaches as appropriate.
Communications Based on Source Water Cyanotoxin Measurements
Notify raw water stakeholders, including other public water systems using the South
Umpqua, of any available toxin results and explain the follow-up monitoring and treatment
adjustments that are being made.
City of Myrtle Creek Cyanotoxin Management Plan - Step 3
E5.15
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Step 4: Finished Water Cyanotoxin Monitoring
and Treatment Adjustments
Detecting cyanotoxins in the finished water can indicate that cyanotoxins have broken through the
treatment barriers.
Finished Water Total Microcystins Monitoring
If > 0.3 ng/L total microcystins is found in the raw water:
o Immediately sample water at the EPTDS using a test strip or ELISA.
If > 3.5 ng/L total microcystins is found in the raw water:
o Immediately sample water at the EPTDS using the Adda-specific ELISA analysis including
adding a quenching reagent. Adda-specific ELISA analysis will be carried out by the
laboratory (listed along with its contact information in Appendix B of this plan).
Continue to Step 5 if microcystins are found in finished water.
Treatment
In addition to the treatment adjustments listed in Step 3. the City of Myrtle Creek will conduct the
following additional treatment optimization activities:
Check TOC removal across GAC. If < 60% TOC is being removed, then backwash the GAC filter.
Ensure chlorine CT is > 75 mg-min/L. If the CT was low, correct CT so that it is > 75 mg-min/L.
Communications
City of Myrtle Creek will carry out the following communications as soon as possible if Adda-specific
ELISA sampling has been determined necessary:
Call the lab and let them know additional samples will be coming for Adda-specific ELISA analysis
and results are needed as soon as possible.
Notify raw and finished water stakeholders of preliminary toxin results (from the lab samples)
and alert them that additional samples are being collected.
City of Myrtle Creek Cyanotoxin Management Plan - Step 4
E5.16
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Step 5: Continued Finished Water Cyanotoxin
Monitoring, Treatment Adjustments and
Public Communication
Step 5 contains communication actions, treatment actions and additional monitoring that should be
carried out based on the concentrations of cyanotoxins in the finished water. This fifth step enables the
City of Myrtle Creek to act quickly if cyanotoxins are present in the finished water.
Continued Finished Water Microcystins Monitoring
If the sample from the EPTDS is > 0.3 ng/L total microcystins using the test strip or ELISA:
Immediately collect a follow-up sample at the EPTDS for Adda-specific ELISA analysis. Adda-
specific ELISA analysis will be carried out by the laboratory (listed along with its contact
information in Appendix B of this plan).
If an Adda-specific ELISA result for the follow-up sample collected at the EPTDS exceeds 0.3 ng/L total
microcystins, conduct the following monitoring:
Use the test strips or ELISA to sample raw water daily until clear (or below detection limit).
Use test strips or ELISA at the EPTDS until measurements are consistently <0.3 ng/L for total
microcystins.
When the test strip or ELISA results for raw water are < 0.3 ng/L total microcystins consistently, and
EPTDS strip results or ELISA are also all < 0.3 ng/L total microcystins, conduct the following monitoring:
Collect a follow-up sample at the EPTDS for Adda-specific ELISA analysis to verify that the
microcystins event is over (until microcystins are below detection limit in the finished water).
City of Myrtle Creek will conduct the following monitoring when test strip results and Adda-specific
ELISA results suggest the situation has been addressed (microcystins no longer detected in raw or
finished water):
Continue looking for early warning signs (return to Step 2).
Treatment
City of Myrtle Creek will complete the following treatment optimization step if any Adda-specific ELISA
result is at or above 0.3 ng/L total microcystins:
If the CT was low, correct CT.
Communications
City of Myrtle Creek will provide the following notifications:
If the follow up entry point sample tested with the Adda-specific ELISA lab based method
exceeds 0.3 ng/L total microcystins:
o Notify state regulators and other stakeholders of the toxin results.
o Issue drinking water advisory.
City of Myrtle Creek Cyanotoxin Management Plan - Step 5
E5.17
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If the finished water Adda-specific ELISA follow-up sample is < 0.3 ng/L total microcystins
o If in place, lift the drinking water advisory.
City of Myrtle Creek Cyanotoxin Management Plan - Step 5
-------
Long-Term Activities
Monitoring Activities
Consider establishing a routine raw and in-plant process control sampling and monitoring protocol for
HABs. This could be sampling for cyanotoxins directly (including other cyanotoxins in addition to
microcystins such as anatoxin-a), or measuring indicators, such as chlorophyll-o or phycocyanin, or a
formal plan for monitoring and trending the early indicators mentioned in Step 2. Establishing a baseline
for these parameters (by trending the data) during routine operation and understanding how each unit
treatment process responds can help when a HAB does occur and operators are faced with making
potential treatment adjustments. Planning, documenting and conducting a monitoring protocol would
be good preparation for a HAB and provide good information during a HAB to support treatment
optimization.
Source Water Protection Management Approaches
Additional long-term activities can be undertaken by City of Myrtle Creek to engage in additional source
water protection activities such as identifying all ongoing monitoring, committees, government
programs and other organized watershed management activities taking place related to the South
Umpqua River watershed. For each of these, provide activity descriptions, milestone dates, lists of key
players, funding sources, ways South Umpqua River water utilities could become more involved, and the
benefits to the water utilities of greater involvement. Prioritize which of these may be the most helpful
for furthering the specific interests of the water utilities in the watershed.
Treatment Activities
Evaluate the toxin removal capacity of the current treatment process using jar tests spiked with varying
levels of toxins.
City of Myrtle Creek Cyanotoxin Management Plan - Long-Term Activities
E5.19
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Appendix A
Cyanotoxin Management Flowchart
Yes,
Is it vulnerable?
No
Yes
No
Were toxins detected?.
Were toxins detected?
No
yr Are there signs
of a bloom or cyanotoxin
occurrence?
Step 2.2: Monitoring
the Early Warning Signs
Step 2.1 : Preparation
Step 1: Assess Source
Water
Step 5: Continued
Finished Water
Cyanotoxin Monitoring,
Treatment Adjustments,
and Public
Communication
Step 2.3 : Immediate
Actions if a Bloom is
Suspected
Step 3: Raw Water
Cyanotoxin Monitoring
and Treatment
Adjustments
Step 4: Finished Water
Cyanotoxin Monitoring
and Treatment
Adjustments
Begin monitoring,
communication, and
source water
mitigation actions.
Continue
monitoring,
treatment, and
communication
activities as needed.
Return to previous
steps as appropriate.
Begin any
preparation, as
needed, for
monitoring,
treatment and
communication.
Continue evaluating
for possible bloom
(Step 2.2).
Cyanotoxins: Actions to Monitor
Occurrence and Minimize
Exposure
City of Myrtle Creek Cyanotoxin Management Plan -Appendix A
E5.20
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Appendix B
Contacts and Stakeholder Information
Stakeholders
Agency/Company
Title
Contact Name
Contact Phone
Contact Email
City of Myrtle
Creek
CMP Team Leader
City of Myrtle
Creek
Source Water
Protection Manager
Treatment Operator
City of Myrtle
Creek
Distribution System
Operator
Laboratory Contact
Person
City of Myrtle
Creek
City/Town
Representative
City of Myrtle
Creek
Water
System/Municipality
Spokesperson
Local Health
Department PWS
Contact
City of Myrtle Creek Cyanotoxin Management Plan - Appendix B
E5.21
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Appendix C
Notifying the Public of Cyanotoxins in their Water
At the time of publication of this document, public water systems are not currently required to notify
their customers of any bloom or cyanotoxin occurrence and are not required to include detections as
part of a system's Consumer Confidence Report under any National Primary Drinking Water Regulations.
They should consult with their state or primacy agency to determine if they are subject to any state or
tribal notification requirements. Although not currently required, water systems may want to consider
communicating with their consumers if cyanotoxins in finished water are confirmed in additional
samples. This communication may be received more positively if the water systems have engaged in
prior communication with the public about HABs. A water system is encouraged to tailor its
communications based on the cyanotoxin levels detected.
The state of Oregon has provided the following template for use when issuing a do not drink advisory:
Do Not Drink Water Advisory
Important Information About Your Drinking Water
[System] Has Levels of Algae toxin Above Drinking Water acute toxicity values
(Water System Name) routinely monitors for the presence of contaminants in our finished drinking
water that is provided through our treatment and distribution system. Our water system recently
exceeded the Oregon Health Authority's acute toxicity value for a cyanotoxin [toxin detected, date
sampled and value detected] which is a by-product of certain algae species that naturally grow in water.
Although this is not currently a regulated contaminant, as our customers, you have a right to know this
acute toxicity value was exceeded, what you should do, and what we are doing to correct this situation.
What should I do?
Drinking water above the acute toxicity value of [x] ng/L of [toxin] is not advised. You may want to use
an alternative (e.g., bottled) water supply. If you have specific health concerns, consult your doctor.
What does this mean?
Human health effects from cyanotoxins are diverse and may include skin rashes and lesions, vomiting,
gastroenteritis, conjunctivitis, headaches, eye, ear and throat irritations, abdominal cramps, nausea,
diarrhea, fever, sore throat or hay fever-like symptoms. [Long-term exposure to microcystin can lead to
damage to the liver, including cancer].
What is being done?
[Water system name] continues to work with [Insert Water Body Manager] to monitor and test the algal
bloom for harmful toxins. In addition [water system name] is adjusting their treatment process to more
successfully mitigate for the presence of cyanotoxins. Weekly testing will continue until toxin levels are
below the acute toxicity values.
For more information, please contact [name of contact] at [phone number] or [mailing address].
City of Myrtle Creek Cyanotoxin Management Plan - Appendix C
E5.22
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Please share this information with all the other people who drink this water, especially those
who may not have received this notice directly (for example, people in apartments, nursing homes,
schools, and businesses). You can do this by posting this notice in a public place or distributing copies by
hand or mail.
This notice is being sent to you by [system]. State Water System ID#: .
Date distributed: .
City of Myrtle Creek Cyanotoxin Management Plan - Appendix C
E5.23
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