Mercury TMDL Development in San Francisco Bay

1. Mercury TMDL Developmentin San Francisco Bay • What’s New? • What’s Next? • TMDL Elements • Proposed actions and alternatives • Proposed Implementation • Just do we expect to achieve?

2. This discussion is about: Published historic accounts Public information (hearings, staff reports, peer-reviewed science) Staff recommended actions This discussion is not about: The will or intent of the Regional Board, the State Board, or the State of California The anticipated outcome of any public process The usual caveats...

3. Goals • Reduce mercury concentrations in fish • Focus on resident species • Stop ongoing pollution • Using existing water quality objectives • Implement a new fish tissue objective • Using sound science and whole-watershed approach • Predict the Bay’s recovery rate • Communicate to the public through Use Attainability Analysis

4. The history... • 1994 First RMP fish tissue survey • 1996 Bay listed as impaired for mercury • 1998 First Staff report - northern reach • 1999 Mercury Watershed council convened • Series of meetings and workgroups, 1999 - present • 1999 Regional Board staff form TMDL team • Staff commit to submission of TMDL report to U.S. EPA by April 2000 • 2000 TMDL Report submitted to U.S. EPA • Transmittal letter and resolution commits to TMDL adoption by early 2002

5. Implementation The Future (Months) No LATER than January 2002 Regional Board Hearing Public Comment 2 Responses to Comments Regional Board Adoption State Board Hearing 2-6 Public Comment Responses to Comments State Board Approval 2-6 OAL Approval 2-6 EPA Approval June 2002 - August 2003 Total = 8-20 Months

6. What’s New? (Since June 2000) • NAS review of mercury risk assessment • EPA mercury tissue residue criterion • RMP fish consumption study • RMP 3’rd fish tissue survey • RMP pilot air deposition study • All dischargers begin ultra-clean mercury measurements • FSSD begins near-field methylmercury monitoring • BASMAA fuels study • BADA - Sustainable Conservation fluorescent lamp report • CALFED methylmercury survey in Bay and Delta • U.S. EPA EMAPS survey in Bay • CVRWQCB Clear Lake numeric targets report • Urban runoff program sediment monitoring • USFWS NRDA in Guadalupe River Watershed • Guadalupe River Flood Control Project Collaborative • Guadalupe Creek restoration EIR / Engineers Report

7. Hey, I’ve been no sluggard! • New Idria Manuscript published in ES&T • First author = Priya Ganguli, SFEP (Lead field staff on Gambonini post cleanup monitoring) • Presented at • Environmental Council of States, St. Louis • California Waste Management Association, Berkeley • Water Environment Federation Pollution Prevention Symposium, Monterey (Cori Traub, Clean Water Action presented on same panel) • EPA Mercury in Mines Conference, San Francisco • California Water Environment Association mercury workshop, San Jose

8. NAS Methylmercury Review • Report released in July 2000 • Validated U.S. EPA reference dose • Significant implications for risk assessment

9. U.S. EPA mercury tissue residue criterion • Published in Fed Register December, 2000 • Based on consumption rates • Recommends 0.3 ppm for 17.5 g fish / day • Recommends States develop site-specific criteria using local consumption data • U.S. EPA expects states to adopt tissue-based criteria

10. RMP fish consumption study • Most recent of several available • Good response rate • Pier fishers and party boats • Available at www.sfei.org

11. RMP 3’rd fish tissue survey • Conducted in 2000 • Continue monitoring every 3 years • Mercury data available soon, will be incorporated • Will be available at www.sfei.org • Contact = Jay Davis (jay@sfei.org)

12. RMP pilot air deposition study • Measured ambient airborne mercury • Measure wet deposition rates • Modeled dry deposition rates • Ambient air concentrations very close to global ambient conditions • Ambient rainwater = 5-20 ng/L total Hg • Contact = Pam Tsei, Don Yee SFEI • www.sfei.org

13. Ultra-low detection limits for mercury in wastewater • Ordered by Regional Board staff in 1999 • Purpose was to improve mass load estimates for wastewater • June 2000 report estimated 20-40 kg/yr • Revised estimate is < 15 kg / yr • Average concentration ~ 13 ng/L

14. Near-Field Methylmercury Monitoring • Permit provision for Fairfield Suisun • Measured dissolved methylmercury, unfiltered methylmercury, dissolved mercury, total mercury, TSS, other metals • High-quality data set

15. BASMAA Fuels Study • Began as study of mercury levels in fuels • Additional air deposition monitoring to complement SFEI study • Low (~1 ppb) Hg concentrations in refined fuels • Where is missing mass? (~1 ppm in crude) • Confirmed that mercury air deposition is from remote, not regional sources.

16. BADA - Sustainable Conservation fluorescent lamp report • Requested of BADA by Regional Board staff • Evaluated potential for eliminating mercury in electric light through reformulation • Estimate 20 Years to new technologies • Recycling is our best option • Terminal disposal is a significant barrier to recycling programs • Regional direction consistent with national trends • Partnership results stunned ECOS participants

17. CALFED methylmercury survey in Bay and Delta • 3-year CALFED grant to study mercury bioaccumulation in Delta • SFRWQCB supplemented funds to extend sediment survey into Central, South Bay • Surprises • Delta is a methylmercury sink • San Joaquin drainage is a bioaccumulation hot-spot • No surprises • Methylmercury in our bay highest in margins, especially where total mercury exceeds sediment target

18. U.S. EPA EMAPS survey in Bay • Stratified random sampling of the Bay • Provides statistically robust data set • Complements RMP, CALFED data sets, which are site-focused sampling designs • Data expected within next 3-6 months

19. CVRWQCB Clear Lake numeric targets report • Region 5 is developing a TMDL for mercury in Clear Lake • Numeric Target Report implements U.S. EPA guidance to develop fish tissue target • Contacts = Janice Cooke or Chris Foe, CVRWQCB

20. Urban runoff program sediment monitoring • Ordered by Regional Board staff for TMDL development • Approach is to characterize mercury and PCB concentrations in urban and non-urban stormwater conveyances (~80 Samples this year) • Intent is to use data for evaluation of target attainment, characterize concentrations by land-use, identify any major controllable sources, estimate pollutant loads • Preliminary reports expected in February • Excellent, innovative work by all urban runoff programs • Kudos to Andy Gunther (AMS), Dan Cloak (EOA), BASMAA Program managers

21. USFWS NRDA in Guadalupe River Watershed • Natural Resource Damage Assessment conducted by U.S Fish and Wildlife Services • Assesses value of lost natural resources due to mercury pollution in Guadalupe River watershed • Public agencies and private companies identified, brought to table • Interim, cooperative agreement established • Has potential to assign accountability for remediation • Extremely litigation sensitive • Contact = Jim Haas, USFWS

22. Guadalupe River Flood Control Project Collaborative • Not really new, the collaborative has been in effect as a settlement agreement for years • To date, environmental issues focussed on habitat restoration • Regional Board staff now helping to incorporate mercury remediation in project designs • Partnership approach with SCVWD staff

23. Guadalupe Creek Restoration • Mitigation for downtown flood control project • 1.7 miles of stream • Downcut 8 feet in 30 years • 20-30 ppm mercury in soils • Project will arrest erosive loss of in-stream mercury • EIR produced excellent methylmercury assessment • First step in a journey of a thousand miles

24. SO……. • Yes, we are fighting mercury pollution in our watersheds • Yes, the stakeholders are involved • In fact, they are doing all the work • Yes, the partnership approach can work • But we still have to memorialize our commitment to action through a public process, in the form of a TMDL…...

25. The Game Plan • Reduce watershed pollutant loads by enforcing existing water quality objectives • Build partnerships that promote pollution prevention • Commit to establishing a new objective for mercury in fish tissue within ten years • Conduct a UAA concurrent with new fish tissue objective to predict time to attainment

26. Elements of a TMDL Status in SF Bay Proposed in June 30, 2000 report to U.S. EPA Received substantial stakeholder input Needs scientific peer review • Problem Statement • Numeric Targets • Source Assessment • Linkage Analysis • TMDL, Load and Waste Load Allocations • Margin of Safety, Seasonal Variations, Critical Conditions • Implementation Plan Concepts in place Needs formal public process to adopt

27. Problem Statement: How many grams per day is fishable?

28. Problem Statement: “Pull over, son, you’re over the limit”

29. Why? • Watershed and air sources • Historic sources • Complex cycling in the environment

30. What increases mercury in water? Increasing amounts of sediment in the water mercury sticks to dirt Increasing amount of mercury in sediment polluted sediments Mercury Concentration in Water background sediments Suspended sediments in water

31. What increases mercury in SF Bay water? Data from the San Francisco Estuary Regional Monitoring Program for Trace Substances. http://www.sfei.org

32. Polluted Sediments Data from the San Francisco Estuary Regional Monitoring Program for Trace Substances. http://www.sfei.org

33. Phase 1 Target:Mercury in Sediments • Most of the sediment in SF Bay comes from the Central Valley • Our sediment should resemble that of Central Valley Source • There is usually more mercury in fine clay than in coarse sand Over Target Mercury in Sediment Target Sand Clay

34. Evaluation of Sediment Target Data from the San Francisco Estuary Regional Monitoring Program for Trace Substances. http://www.sfei.org

35. Proposed Action: • Regulate to Sediment target in first phase • Set Sediment Target at current watershed background concentration

36. Proposed Action • Set fish tissue target as success criterion in first phase • Develop load allocations based on fish tissue target in second phase

37. Alternative Actions • Set sediment target below current watershed background level • Calculate load allocations based on fish tissue target

38. Source Assessment

39. Linkage Analysis

40. Forget modeling, let’s measure it Methylmercury concentrations in sediments (ng/g)

41. Phase 1 Action: stop feeding the methylation machinery on the margins

42. Allocate loads based on effect on sediment target This = Sum of these

43. Clean Water Act requires that we express the load in terms of mass per unit time Load Allocation Target allocation x Sediment Load = = Kg Hg / yr mg Hg/kg sed kg sed / yr

44. Happy now?

45. 50 kg total Concentration goals annual average 25 ng/L deep water 15 ng/L shallow Based on twice current flow Credit for Reclamation Stormwater treatment Air emission controls Offset proposals Don’t forget cooling water! Implementation Plan for Wastewater

46. Implementation Plan for Urban Runoff Programs • Continue sediment monitoring for five years • After five years, submit a report telling Regional Board • Do any catchments cause exceedance of target allocation? (0.32 ppm in fine sediments) • Submit action plans for largest exceedances, considering: • What is the total mercury mass flux? • Is exceedance due to upstream source requiring Regional Board or other agency action? • What is effect of airborne deposition? • Are there opportunities for pollution prevention? • Are there potential benefits from reduction of other pollutants? (e.g., PCBs) • Is conveyance cleanout a potential solution? • Is treatment the only alternative? • What are economic impacts? • What are environmental benefits?

47. Goal of urban runoff programs • Identify your biggest outliers • Tell us what it takes to eliminate them • Tell us, once that is done, will the net impact of all watershed inputs be less than the target allocation? • Are there added benefits due to other pollutants?

48. Economic Impacts Effluent loads Watershed loads

49. Implementation Plan for Dredgers • Continue to Use LTMS cover / no cover guidelines • Consistent with 0.4 ppm target • Supported by linkage analysis - don’t put red-hot sediments in a wetland, duh! • Develop Best Management Practices for minimizing methylation potential in constructed and managed wetlands

50. Pollution Prevention • Encourage municipalities to adopt virtual elimination policies, take-back programs • Work with BADA, BASMAA, municipalities to ensure 100% recycling of fluorescent lights • Work with CDA, POTWs to maximize recovery of dental amalgam • Regulatory leverage is EO approval of pollution prevention plans • Adopt a resolution supporting a national terminal disposal strategy