Nutrients and Cyanotoxins, FDEP Triennial Review Workshop, Tallahassee 2019-11-04

Water quality testing for nutrients and cyanotoxins were big topics at yesterday’s Public Workshop in Tallahassee. Apalachicola Riverkeeper Georgia Ackerman was there, but had to leave at noon. So John S. Quarterman ended up speaking as Suwannee Riverkeeper and on behalf of Waterkeepers Florida, in Florida’s Triennial Review of Water Quality Standards.

[Apalachicola Riverkeeper Georgia Ackerman]
Apalachicola Riverkeeper Georgia Ackerman

The FDEP presenters made it pretty clear they preferred putting up warning signs based on clorophyl a measurements and whenever cyanobacteria blooms are sighted, as they ask DOH to do now, to waiting for lab tests to come back to confirm, as EPA currently recommends.

[EPA Recommended Cyanotoxin Criteria/Advisory Thresholds]
EPA Recommended Cyanotoxin Criteria/Advisory Thresholds

They presented 2019 CyanoHAB Sampling Results demonstrating that algal blooms can occur well before the EPA’s thresholds (either recommended or old) are reached.

[2019 CyanoHAB Sampling Results]
2019 CyanoHAB Sampling Results

The presenter for that section (I believe it was Dave Whiting, Deputy Director, Laboratory and Water Quality Standards) revealed that many states have many different Recreational Water Guidance/Action Levels.

[Recreational Water Guidance/Action Levels]
Recreational Water Guidance/Action Levels

California has:

Microcysten: 0.8 μg/l; Anatoxin-a: 90 μg/l; Clindrospermopsin: 4 μg/L

This is because California, unlike EPA, took into account variability, and ended up with far lower thresholds than EPA.

So we have at least this much range in thresholds:

WhichMicrocystinsCylindrospermopsin
California0.84
EPA old48
EPA recommended815

Problems with the EPA’s recommendations include that they assume “100% of child’s exposure (ages 6 – 10) comes from incidental ingestion during swimming”: nevermind solid evidence that airborne cyanotoxins can be as harmful inland as direct water contact, and EPA takes no account of fish consumption, which could occur far away from the water.

[Assumes 100% of child's exposure (ages 6 - 10) incidental ingestion during swimming]
Assumes 100% of child’s exposure (ages 6 – 10) incidental ingestion during swimming

At the end (around 12:30 PM for a meeting that started at 9:00 AM, a fisher of commercial wild tilapia (yes, really, wild and invasive) pleaded with FDEP to do something to protect fish.

[Wild Tilapia Fishing]
Wild Tilapia Fishing

Earlier, they said what they are already doing about that:

[specifically designed to protect human health]
specifically designed to protect human health

  • EPA recommended cyanotoxin criteria are specifically designed to protect human health
  • DEP has already adopted NNC designed to be protective of aquatic life use support, which was determined to be most sensitive use
    • Also protects human health
  • Adopted NNC for streams, springs, lakes and estuaries
  • Highest adopted chlorophyll a criterion is 20 μg/L (for colored lakes at 20 μg/L), and data indicate that microcystin concentrations are well below recommended cyanotoxin criteria at 20 μg/L chl a

More about current Florida practice:

[Current Florida Practice for Algal Bloom Response]
Current Florida Practice for Algal Bloom Response

Why, then, is FDEP considering changing to specific thresholds instead? “DEP received a petition requesting that we adopt EPA 2016 draft thresholds as water quality criteria”. Also, the Harmful Algal Bloom Task Force (on which Whiting serves) has requested FDEP adopt some such criteria, without recommending any specific criteria.

I asked given that, as the presenters had said, there is no obvious direct linear connection between nutrients and cyanotoxins, yet nutrients clearly are linked to algal blooms, would it not be prudent, considering the Precautionary Principle, to do much more comprehensive monitoring for nutrients?

[Precautionary Principle]
Precautionary Principle

The presenter said they were doing that, because the legislature had authorized additional funds, and FDEP was working with regions to implement it. I asked if that would include inland areas such as the Suwannee River Basin where we do not yet have cyanotoxins, but we do have algal blooms? He said funds would be prioritized by need, but probably. Given the Suwannee River Basin BMAPs, I would think that would mean yes. That covered much of what we wrote to FDEP in the Suwannee Riverkeeper letter of May 31, 2019.

After about 3.5 hours of presentation slides, during which they accepted and answered many questions, FDEP opened Public Comments.

Since Apalachicola Riverkeeper Georgia Ackerman had left, I mentioned the Waterkeepers Florida letter of May 31, 2019, which requested that FDEP set some sort of limits for cyanotoxins, suggesting sticking with the old EPA numbers of 4 μg/L Microcystins and 8 μg/L Cylindrospermopsin. I noted that FDEP had now presented possible even lower thresholds, such as the California numbers, as well as arguments for why FDEP’s current approach could be better than waiting for any threshold to be exceeded. I suggested they could do both: set out signs when blooms were observed, and use that to trigger monitoring for thresholds. This would assist in establishing a connection between nutrient numbers and cyanotoxins. They nodded at that, both then, and afterwards, when I explained that suggestion in more detai to Kenneth Weaver, Environmental Administrator.

So, as Waterkeepers Florida discussed with FDEP in Orlando back in April, it’s a policy decision. As FDEP’s slide 5 says:

[Background (cont.)]
Background (cont.)

  • States are not required to adopt EPA recommendations, but under recent revisions to 40 CFR 131.20(a), States must explain basis for the decision if they decide not to adopt

Seems like there are plenty of reasons, most of them explained yesterday by FDEP.

Three more Public Workshops are happening, right now today in Fort Myers, and also Wednesday in Dania Beach and Thursday in Jacksonville, all with the same agenda.

The slides cover many other topics, such as the Florida Reef Tract and effects of turbidity on coral.

[Map: Coral Reefs]
Map: Coral Reefs

Also nutrients such as Ammonia Nitrogen.

[Total Ammonia Nitrogen]
Total Ammonia Nitrogen

Copious information is on the FDEP website.

 -jsq, John S. Quarterman, Suwannee RIVERKEEPER®

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