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Ohio River Valley Water Sanitation Considering New Pollution Standards
Elimination of mixing zones for BCCs is called for in Section 4.F of the Commission Standards. This requirement was adopted in 2003, disallowing such mixing zones for new discharges and calling for elimination of mixing zones for existing discharges no later than ten years from the date of adoption.
Bioaccumulative chemicals can be concentrated in the tissue of aquatic organisms. Very low concentrations of such chemicals in water can lead to elevated levels in fish tissue making consumption of the fish unsafe for humans. The elimination of mixing zones for such chemicals would minimize the effects of direct discharges as potential sources of fish tissue contamination.
Subsequent to the adoption of this requirement, a number of concerns have been raised, primarily related to discharges of mercury:
- The most stringent criterion for mercury in the Commission Standards is a limit of 0.012 ug/L Total Mercury which was adopted to prevent unsafe levels in fish tissue. Elimination of mixing zones for BCCs means that this limit could not be exceeded in any discharge to the river.
- US EPA has promulgated, and the Commission has adopted, a mercury limit in fish tissue of 0.3 mg/kg Methyl Mercury.
- The relationship between discharges of total mercury to a waterbody and levels of methyl mercury in the tissue of fish inhabiting that waterbody is highly complex and site specific. The Commission has undertaken a single study of this relationship which has not yet been completed.
- Improved analytical techniques for mercury have enabled detection at extremely low concentrations. Since 2007, dischargers have been required to use low level analytical methods. Sources previously reported as discharging no detectable mercury may now be identified as discharging concentrations greater than the Commission’s most stringent criterion.
- The Commission’s most stringent criterion is expressed as “not to be exceeded” whereas criteria adopted to prevent long term effects are typically expressed as mean or average concentrations at a particular stream flow.
- Elimination of mixing zones for BCCs is an approach developed for the Great Lakes Initiative. Questions have been raised as to whether or not this approach is appropriate for a river.
The Commission will initiate a formal review of its Standards in March, 2014. That review is scheduled to conclude with recommended revisions for Commission action in October, 2015. The Commission has committed to address the concerns listed above in that review. In the interim period, the Commission proposes to defer implementation of the requirement for elimination of mixing zones for BCCs until the completion of the review in October, 2015.