My mentor, Dr. Granger Morgan at Carnegie-Mellon University, once taught me to think of environmental risk and risk management as a roomful of bees. Imagine a roomful of bees, with two doors across from each other. You need to enter through one door, cross the room, and exit through the other door.
The faster you walk (lower exposure duration), the lower the chance of getting stung (risk). Crossing the room once per week is less risk than once per day (lower exposure frequency). The more your skin is covered (lower exposure surface), the lower the risk. The more bees in the room (higher concentration), the higher the risk. The more aggressive (higher toxicity) the bees, the higher the risk.
The more sensitive you are to bee stings (sensitive sub-populations), the higher the risk. The larger the room or the less bees in the room (lower concentration), the lower the risk, if the bees are equally spaced. But the longer the room, the more time available during your walk (higher exposure duration) to get stung. If the bees are clustered in the corner (hot spot), your risk is lower if you don't walk near the corner. If you walk around the outside of the room to get to the other side and don’t enter the room, you eliminate the risk, but at a cost. If you install a screen across the room and keep all bees isolated from the side where you walk (engineered barrier), you eliminate exposure and risk. If you smoke the room with a beekeeper’s smudge pot (treatment), you lower the risk. If you open the door and let some bees out before crossing (dilution), you lower the risk.
I am sure you can add more to this simple model, and of course environmental risk can be more complicated, but I have found it is quite helpful for explaining the basic concepts of risk and risk management to the uninitiated.
Ohio EPA is currently developing new rules for community and nontransient noncommunity public water systems relative to lead and copper sampling, testing, reporting and notifications. Ohio House Bill 512, signed by Governor Kasich on June 9, 2016, requires the Director of Ohio EPA to adopt new rules for lead and copper monitoring and related actions within 120 days after the effective date of the bill. The Ohio EPA Early Stakeholder Outreach period for comments is in progress to solicit input prior to the issuance of Draft Rule(s).
The major provisions under H.B. 512 include the following requirements:
Due to the potential health effects of lead and copper in drinking water, the increased sampling, stricter reporting schedules, and corrosion studies are a step in the right direction. Because of the potentially labor-intensive task of mapping and identifying the potential system areas and buildings that may contain lead components, PWSs may find it necessary to seek professional assistance to meet proposed deadlines. Hull has the water system expertise, sampling experience, and GIS mapping capabilities to provide timely assistance. Our scientists and engineers are experienced in sampling, testing, and recommending treatment adjustments for desired water quality objectives, and can apply their skills to optimize corrosion control aspects of PWS finished water.
Hull can also assist with compliance with the proposed reporting and notifications requirements. The development of a public notification protocol and procedures for communication with the regulatory agencies is highly encouraged in advance of an actual need for this process. 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 PWS. Hull has many years of experience in preparing and presenting public communications related to challenging public water issues, from participating in western Lake Erie harmful algal bloom communications to assisting with public meetings in eastern Ohio related to shale oil and gas water sourcing needs.
Hull will be following the rulemaking process and participating in the Ohio EPA Early Stakeholder Outreach, and will forward updates as appropriate.
The PIPES Act of 2016 (Protecting our Infrastructure of Pipelines and Enhancing Safety Act of 2016 was signed by President Obama on June 22, 2016. Under PIPES Section 16 (Emergency Order Authority), if the Secretary of Transportation determines that an unsafe condition or practice is causing an “imminent hazard”, the Secretary may issue an emergency order imposing restrictions, prohibitions and safety measures on owners and operators of gas or hazardous liquid pipelines and facilities without prior notice.
Imminent hazard is defined as existence of a condition that “presents a substantial likelihood that death, serious illness, serious personal injury, or a substantial endangerment to health property or the environment may occur”. “Substantial likelihood” is not defined, nor are “serious” or “substantial endangerment”. These appear to be at the discretion of the Secretary at this time.
However, Industry representatives will have an opportunity to participate in the development of regulations related to this new emergency order authority. The PIPES Act of 2016 directs PHMSA to issue temporary regulations within 60 days after enactment of the Act to implement the emergency order authority provided. PHMSA then must issue final regulations within 270 days of the date of enactment. Pipeline facilities owners and operators should take an active role in this rulemaking process.
With our background in risk assessment and risk-based rule development, the Hull Risk Analysis Center (HullRAC) intends to carefully review and comment on proposed rules, especially advocating reasonable definitions for the criteria defining imminent hazard under Section 16.
If you have questions or want to know more please reach out to us here at HULL.
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:
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.