Ammonia Water Quality Criteria Past, Present and Future

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Ammonia Water Quality Criteria Past, Present and Future 2017 OWEA Technical Conference June 26, 2017 Adrienne Nemura Elizabeth Toot-Levy Rishab Mahajan

Ammonia 101 Natural Sources One of several forms of nitrogen present in aquatic environments Excreted by animals as a waste Produced during decomposition of vegetation Atmospheric gas exchange Forest fires Nitrogen fixation Anthropogenic Industrial uses Metal treating Alkali production Pulp and paper Food and beverage Commercial fertilizers Wastewater treatment plant effluent Atmospheric gas exchange

Ammonia Toxicity Direct toxic effects on aquatic life Other forms of nitrogen have indirect effects on aquatic life Ammonia toxicity leads to lower reproduction and growth in sensitive organisms Ammonia toxicity is ph and temperature dependent As temperature increases, organisms are more sensitive to ammonia Ammonia toxicity also increases as ph increases

Freshwater Mussels 101 Native mussel life cycle Each mussel species has adapted to a unique fish host! http://water.epa.gov/scitech/swguidance/standards/criteria/aqlife/ammonia/upload/ii-barnhart.pdf

Mussel Distribution

The Mussel Problem Loss of habitat/mussel beds Reduction in reproduction Causes Dams and stream channelization Siltation Invasive species Lack of host species Sensitivity to ammonia, copper, chlorine, zinc

Federal Regulatory Timeline 1976 Original freshwater ammonia criteria 1985 First update to original criteria 4-day averaging period Unionized ammonia 1999 Significant updates ph and temperature dependent 30-day averaging period Total ammonia nitrogen 2004 Revisions to criteria begin 2009 Revised draft criteria 2013 Final draft ammonia criteria

Debate over the numbers

Increasing Scientific Knowledge 2003 toxicity data indicate larval and juvenile freshwater mussels are more sensitive to ammonia 2005 protocol for testing larval and juvenile freshwater mussels was approved 2011 studies demonstrated that certain snails are also sensitive to ammonia 2013 ammonia criteria includes freshwater snail and mussel data Still Concerns about laboratory studies versus reality Need for more holistic approaches to restoring reproducing mussels beds

2013 Final Ammonia Aquatic Life Criteria One set of freshwater criteria Developed to protect the aquatic community including sensitive mussel species Site-specific recalculations are available when mussels are determined to be absent, when appropriate Removed invasive species from the dataset Updated literature review for toxicity data Renormalized data to ph 7 and 20 C

2013 Federal Aquatic Life Criteria Acute = 17 mg N/L at ph 7 and 20 C Duration = 1 hour average Frequency = not to be exceeded more than once in 3 years Chronic = 1.9 mg N/L at ph 7 and 20 C Duration = 30-day average Frequency = not be exceeded more than once in 3 years Not to exceed the criterion continuous concentration (CCC) as a 4-day average within 30-days, more than once in 3-years

1999 versus 2013 Ohio = 13 Acute 24 17 Ohio = 5.9W / 2.2 S Chronic 4.5 1.9

Impact on Effluent Levels?

Effluent Challenges Competing priorities Even well-designed and well operated WWTPs plants will occasionally exceed criteria Need new permitting approaches Biological nutrient removal (BNR) is one of the most cost-effective technologies to remove nitrogen and phosphorus But not to achieve very low levels of ammonia Spending money to remove ammonia may not restore mussel beds Need site-specific restoration strategies beyond traditional Clean Water Act compliance

REGULATORY FLEXIBILITIES

REGULATORY FLEXIBILITIES Resident Species Recalculation Variances Revisions to Designated Uses Compliance Schedules Stochastic Forecasting of ph and Temperature Mixing Zones Integrated Planning

Mixing Zones Estimate initial dilution in receiving waters Flow of river or stream, or a portion thereof Allowed to mix with effluent before water quality criteria must be met Criteria met at edge of mixing zone

Mixing Zones EPA s Water Quality Standards Handbook A mixing zone is a limited area or volume of water where initial dilution of a discharge takes place and where certain numeric water quality criteria may be exceeded. Small portion of waterbody Protects uses of the waterbody Re-evaluated with NPDES permit renewals Not for bio-accumulative chemicals Not a license to pollute earthisland.org/csaw/mz_files_web_docs/csaw_m

Typical Mixing Zone Models Visual Plumes Limited application to shallow water conditions with no local recirculation Cornell Mixing Zone Expert System (CORMIX) Mix of theory and best professional judgement Most widely used for mixing zone analysis Computation Fluid Dynamics More complex, typically more accurate Addresses non-standard discharges Accommodates geographic features (wind dams, sharp bends in river)

Example Mixing Zone Study The city operates a WWTP discharging to a large river 3-cell aerated lagoon system Design flow of 1.5 MGD IEPA requested mixing zone modeling as part of permit renewal process

Modeling Approach CORMIX model developed to simulate mixing Assess whether discharge has reasonable potential to exceed ammonia criteria Available discharge and receiving water used to parameterize the CORMIX model Worst case effluent concentration - 25 mg/l (based on effluent monitoring data)

Criteria and Mixing Zones Ammonia criteria calculated based on historical 75 th percentile ph and temperature Acute criterion 3.9 mg/l (summer) Chronic criterion 0.7 mg/l (summer) Chronic mixing zone length assumed to be distance at which simulated plume started interacting with river bottom Acute mixing zone length 10% of chronic mixing zone length (USEPA Technical Support Document for Toxics Control 1991)

Model Results Dilution Factors Chronic mixing zone length : 251 @ 640 ft Acute mixing zone : 26 @ 64 ft

Model Results - Concentrations Instream concentration calculated based on dilution factor Mixing occurs within 200-300 feet of outfall Simulated ammonia concentration is below the acute and chronic criteria Acute criterion 3.9 mg/l Chronic criterion 0.7 mg/l

Findings and Future Implications Mixing zone modeling demonstrated Rapid and complete mixing of effluent discharge downstream Discharge does not have reasonable potential to exceed water quality criteria for ammonia Effluent permit limit for ammonia not required If criteria are revised, model can be used to evaluate alternative options for compliance Different assumptions about upstream and effluent concentrations Diffusers Plant operational changes

Integrated Planning New policy in 2012 Response to cities concerns about CWA compliance Costs exceed localized affordability No measurable improvements in water quality Allows communities to prioritize CWA projects Possible incorporation of watershed projects that provide higher value for aquatic life Strengthens ability to make case on high cost low benefit projects that should be delayed

Adrienne Nemura (734) 476-0357 anemura@geosytec.com Elizabeth Toot-Levy (440) 227-9181 etootlevy@geosytec.com Rishab Mahajan (630) 203-3361 rmahajan@geosytec.com