By Cheryl Green, PE, CSI  |   May 31st, 2016
On June 1, 2016 Ohio EPA rules codified in Chapter 3745-90 of the Ohio Administrative Code (OAC) will become effective, requiring monitoring and reporting of cyanobacteria and microcystins for all public water supply water treatment plants which utilize one or more surface water sources.  The rules establish additional requirements in the event microcystin is detected during the routine monitoring events:
  • Rule OAC 3745-90-05 requires that a Treatment Optimization Protocol be submitted to the Director of Ohio EPA within 30 days after a detection of microcystin in any sample collected from the raw water or the finished water sampling points.
  • The rule further requires that a Cyanotoxin General Plan for short and long-term actions to prevent exceedances of microcystin action levels be submitted to Ohio EPA within 120 days, if microcystin concentration exceed 1.6 ug/l more than once in the raw water within a 12-month period, or if microcystins are detected once in the finished water or distribution system.  
  • Both of these plans are required for any public water supply systems that have reported microcystin detections after July 16, 2016.
If at any point in time your water plant has experienced algal blooms in the source water, even if microcystins have not been detected, a proactive approach of developing a Treatment Optimization Protocol is strongly recommended to be prepared to meet obligations under the new rule.  Ohio EPA has now issued draft guidance on the Treatment Optimization Protocol, enabling you to start your plan as soon as possible.
The Treatment Optimization Protocol must include treatment adjustments that will be made under various raw and finished water conditions. In developing the protocol, the public water system must review and optimize existing treatment for microcystins and other cyanotoxins, considering effective treatment strategies such as avoiding lysing cyanobacterial cells; optimizing removal of intact cells; optimizing barriers for extracellular cyanotoxin removal or destruction; optimizing sludge removal; and, discontinuing or minimizing backwash recycling.   
The Cyanotoxin General Plan requires both short-term and long-term actions to prevent exceedances of microcystin action levels in finished water.  The plan may include treatment options as described above, as well as source strategies, if available, such as avoidance strategies (alternate intake, alternate source, temporarily suspending pumping); reservoir management/treatment; and/or nutrient management.
The options considered must include those strategies that are available to a public water system as part of their current processes. Treatment additions that can be implemented immediately and may not require significant investment (for instance, powdered activated carbon (PAC) feed system) can be considered but must have Ohio EPA approval before installation.  Therefore, understanding both the short-term and long-term costs of each option is important, and critical to development of an effective plan.
The development of a related public notification protocol and procedures for communication with the regulatory agencies is also encouraged.  A well-established communication protocol is imperative to ensure that, in the case of an exceedance, the public is well informed and understands the ramifications of the situation, while maintaining continued confidence in their public water supply.
Hull has a trained team of engineers, scientists, risk assessors and public outreach professionals that can assist you with developing a Treatment Optimization Protocol and a cost-effective Cyanotoxin General Plan in advance of the regulatory deadlines stated in the rule. 
Cheryl Green, PE, CSI, Senior Project Manager
Cheryl has over 35 years of experience in civil and environmental engineering for public and private sector clients. Her environmental experience includes planning, design, and permitting of municipal sanitary sewers and wastewater treatment systems; collection and treatment facilities for industrial process wastewater and contaminated storm water; and various environmental facilities. Cheryl has designed many pumping and pressurized piping systems throughout her career, including sanitary lift stations and forcemains. Her civil site engineering experience includes industrial plant facilities design such as fire protection storage tanks and pumping systems, plant rail spurs, roadways and truck docks.
She holds a Bachelor in Civil Engineering from Ohio Northern University.
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