K A N S A S D E PA RT M E N T O F H E A LT H A N D E N V I RO N M E N T

BU R E AU O F WAT E R

WAT E R Q UA L I T Y S T A N DA R D S
W H I T E PA P E R
CHLOROPHYLL-A CRITERIA FOR PUBLIC WATER
SUPPLY LAKES OR RESERVOIRS

JANUARY 10, 2011

 CHLOROPHYLL-A NUTRIENT
CRITERIA

ISSUE

Should Kansas adopt chlorophyll-a criteria for public water supply lakes?

It is the mission of the Kansas Department of Health and Environment (KDHE) to protect the
health and environment of all Kansans by promoting responsible choices. One facet of this mission
is the setting of water quality standards based on the best science available.

CURRENT CRITERIA

ƒ Narrative Criteria

o KAR 28-16-28e(b)(7) - Taste-producing and odor-producing substances of artificial origin shall not
occur in surface waters at concentrations that interfere with the production of potable water by
conventional water treatment processes, that impart an unpalatable flavor to edible aquatic or
semiaquatic life or terrestrial wildlife, or that result in noticeable odors in the vicinity of surface waters.

ƒ Domestic Water Supply Use

o KAR 28-16-28e(c)(3)(D) - The introduction of plant nutrients into surface waters designated for
domestic water supply use shall be controlled to prevent interference with the production of drinking
water.

BACKGROUND

What is Chlorophyll-a?

Chlorophyll-a is the most common photosynthetic pigment found in all

plants, algae, and cyanobacteria. It converts sunlight and carbon dioxide into
organic compounds like carbohydrates while generating byproducts such as
oxygen (photosynthesis). Chlorophyll-a is often used as a means to measure
the productivity of plants and algae in a waterbody.

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Lakes or reservoirs are valuable natural resources that also possess tremendous economic value.
They provide enjoyment as well as many beneficial uses such as flood control, recreation, aquatic life
support, domestic water supply, irrigation, and industrial water sources. In Kansas, there are 21
federal reservoirs and 63 state or locally owned reservoirs that are used as water supply. Most of
these reservoirs were built from the 1940s through the 1980s. They have become an integral part of
the Kansas water supply system. It is estimated that more than 67% of Kansans depend on treated
surface waters from public drinking water suppliers (PWS) and many of these suppliers rely solely on
reservoir water for their sources.

By nature, lakes or reservoirs act as settling ponds and will gradually be filled up with silt even in
pristine environments. Human activities tend to speed up the aging process of these man-made
lakes. A huge challenge facing Kansans today is that many reservoirs are experiencing significant
problems caused by sedimentation and/or eutrophication (nutrient enrichment). Some of the
consequences of sedimentation and eutrophication include loss of water storage capacity, loss of
beneficial uses such as recreational activities and aquatic life support, and taste and odor problems
for drinking water suppliers.

A few of the reservoirs have already undergone expensive restoration operations such as dredging to
restore their full or partial usefulness. For some reservoirs like the John Redmond Lake, the
estimated cost to restore the reservoir is so astronomical that options are still being evaluated and
debated by stakeholders. Mission Lake near Horton was recently being dredged to restore its water
storage capacity. The cost for dredging this relatively small reservoir (71 acres of conservation pool)
is estimated at close to $6.6 million.

Excessive algal growth due to eutrophication can have undesirable and/or detrimental effects on
drinking water suppliers and end users. These effects include taste and odor problems, increased
levels of cyanotoxins such as microcystins, higher levels of trihalomethane (THM) precursors, and
increased turbidity levels in source water. Certain algal species known to produce the musty, earthy,
fishy, or grassy odors are often the culprits of taste and odor problems in eutrophic waters. Nutrient
enrichment can cause undesirable species such as cyanobacteria to dominate in a waterbody.
Cyanotoxins produced by cyanobacteria or blue green algae are very toxic and potentially lethal to
animals and humans even in small quantities. There are two main types of cyanotoxins, (1)
hepatotoxins such as microcystins that can cause serious damage to the liver; (2) and neurotoxins
that can cause death in animals. Carcinogenic THMs are byproducts of the chlorination process.
Rapid algal growth increases the levels of organic matter which are precursors to THMs in the water;
thus increasing the levels of THMs in finished drinking water. Higher algal growth may also force
drinking water treatment facilities to use more chlorine for disinfection and further exacerbate the
THM problems.

The treatment cost for dealing with issues caused by excessive algal growth can be very high and
sometimes prohibitive for small communities. For the city of Wichita, an $8.5 million ozone facility
was constructed at Cheney Reservoir to control taste and odor problems. In Kansas, there have
been a few incidences where drinking water treatment plants were forced to shut down during
moderate to severe algal blooms due to their inability to adequately treat the source water. For
example, massive algal blooms have triggered shutdown of drinking water intakes in Cheney
Reservoir, Clinton Reservoir, and Marion Reservoir in the past decade. It has been widely
recognized that prevention is one of the most cost-effective ways for dealing with nutrient related
problems for lakes and reservoirs.

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The danger of toxic algal blooms has been brought front and center to the public’s awareness due to
a series of widely publicized lake closures during the summer of 2010. A total of 9 lakes (including 2
unclassified lakes) were issued public health advisory or warning alerts due to high levels of
cyanobacteria and/or microcystins. Since this is the first year these public health alerts have been
issued by KDHE for lakes affected by toxic algal blooms, the public may be surprised to know the
occurrence or severity of such events. Six out of the 7 classified lakes are known to be impaired by
nutrients and five lakes already have TMDLs1 developed for eutrophication. The problems have
been exacerbated this year by a very wet spring (significant nutrient runoff) followed by an extremely
hot and dry summer. These are the ideal incubation conditions for algae.

Direct counting of algal communities under microscopes is a time-consuming and labor-intensive

process. The high levels of expertise required for algal counting often make the tests very expensive
and the results prone to errors and biases. A good practical alternative for assessing algal biomass is
the measurement of chlorophyll-a in the water.

Chlorophyll-a is the most common photosynthetic pigment found in all plants, algae, and
cyanobacteria. It converts sunlight and carbon dioxide into organic compounds like carbohydrates
while generating byproducts such as oxygen. The concentration of chlorophyll-a provides a good
assessment of the primary production or algal activities in a waterbody. The direct causes of algal
blooms are often associated with increased total phosphorous (TP) and/or total nitrogen (TN) levels
in a waterbody. TP and TN are referred as the causal or contributing variables of nutrient
enrichment by EPA2. Chlorophyll-a is referred to as a response variable. For Kansas reservoirs, TP
is most often the limiting factor for algal productions. Thus, excess TP inputs are more likely the
main culprit of algal blooms for many reservoirs in Kansas. While TN and TP concentrations can
vary widely in producing an algal response of 10 μg/L chlorophyll-a, taste and odor problems begin
occurring once chlorophyll-a values reach 10 μg/L.

For lakes or reservoirs, the intensity of algal response measured by chlorophyll-a is determined not
only by the levels of TP and/or TN, but also by factors such as water turbidity, sunlight, water
depth, temperature, seasons, etc. Algal blooms are more likely to occur from late Spring through
early Fall when there are elevated temperatures and ample sunlight. Chlorophyll-a is a measurement
of response by the algal communities to all the chemical, physical, and biological conditions in a
waterbody. It is regarded as a reliable indicator of the eutrophic conditions in lakes or reservoirs.
Different lakes or reservoirs with similar chemical parameters but different physical conditions can
have very different algal responses. Appropriate TP and/or TN levels can be set specifically for
each lake or reservoir through lake modeling and the TMDL process.

Since chlorophyll-a is used in photosynthesis, the samples for chlorophyll-a are to be collected in the
photic zone (top-most layer where sunlight can reach) of a waterbody. For lakes or reservoirs that
stratify, the top layer or epilimnion should coincide with the photic zone of the waterbody in most
lakes or reservoirs.

1 Total Maximum Daily Load

2 US Environmental Protection Agency

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Currently, Kansas has only narrative criteria for nutrients. Adopting site-specific numeric criteria for
chlorophyll-a will be useful for the protection of public water supply (PWS) lakes or reservoirs. To
assure that the criteria can achieve the intended goal of protecting PWS lakes or reservoirs, a 10%
margin of safety could be incorporated into the proposed criteria. It is anticipated the proposed
value would be the lesser of 9 μg/L (10 μg/L with a 10% margin of safety) or a long-term average.
The 10% margin of safety has been successfully applied to TMDLs for nearly a decade in Kansas
and has been seen as a reasonable offset to uncertainties when dealing with water quality issues.

The long-term average would be the running average of a minimum of 4 samples over a 10 year
period following the standard KDHE sampling protocols for lakes. KDHE will also solicit and
evaluate additional data from external sources such as the Army Corps of Engineers, USGS, Kansas
Biological Survey, etc. Any available external data may be incorporated into the long-term average
calculation if deemed appropriate. The numeric criteria for chlorophyll-a will facilitate earlier
detection and 303(d)3 listing of the impairment, as well as timely TMDL development. The ultimate
goal is to encourage earlier involvement and actions by stakeholders to protect the PWS lakes or
reservoirs that are threatened or impaired by eutrophication.

SELECTED AVAILABLE DATA

The ecoregional criteria developed by EPA were set at values that are equivalent to the 25th
percentiles of all the data (possibly including all seasons) in the ecoregion. The EPA’s aggregated
chlorophyll-a ecoregional summary table and map for Kansas lakes and reservoirs are shown below
in Table 1 and Figure 1. Because of the inherent problems associated with the data and analytical
methods, EPA expected states and tribes to use them as starting points to develop more precise and
region-specific criteria. The actual delineation of Level III ecoregions for Kansas is shown in Figure
2. As depicted by Figures 1 and 2, the Level III ecoregions “Western High Plains” and “Central
Great Plains” were aggregated into Region (V). The Level III ecoregions “Southwestern
Tablelands”, “Flint Hills”, and “Central Oklahoma /Texas Plains” were aggregated into Region IV.

Table 1. Summary of EPA’s Aggregrate Ecoregion Values for Chlorophyll-a for Kansas
Lakes & Reservoirs

Parameter IV V VI IX
Chlorophyll-a (μg/L) 2.0 2.3 8.6 4.9

3 Impaired Water List, Section 303(d) of the Clean Water Act

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 Figure 1. EPA’s Aggregate Ecoregions for Kansas

The EPA Region VII Regional Technical Assistance Group (RTAG) undertook the task of
developing regional nutrient criteria for Kansas, Missouri, Nebraska, and Iowa. The group
proposed a single set of benchmarks (or criteria) for lakes and reservoirs in the region. The
benchmark for chlorophyll-a is listed in Table 2. The general consensus of state natural resources
agencies in Kansas is that one set of TN and TP values can not represent accurately the vast
differences in the region. These benchmarks may indeed represent high quality waters but may also
be over-protective in many areas if adopted as criteria.

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 Table 2. EPA Region VII RTAG’s Benchmark for Chlorophyll-a

Parameter Benchmark
Chlorophyll-a (μg/L) 8

In Kansas, lakes and reservoirs have been categorized and assessed for eutrophication using
chlorophyll-a levels for many years. The annual reports by Kansas Lake and Wetland Monitoring
Program list the following categories for lake trophic state according to chlorophyll-a levels.

Table 3. Lake Trophic State Indicator Used by KDHE

Lake Trophic State Chlorophyll-a (μg/L)

Oligo-mesotrophic ≤ 2.50
Mesotrophic 2.51-7.20
Slightly eutrophic 7.21-11.99
Fully eutrophic 12.00-19.99
Very eutrophic 20.00-29.99
Lower hypereutrophic 30.00-53.99
Upper hypereutrophic ≥56.00

The 2010 Kansas 303(d) list used 10 μg/L of chlorophyll-a as the listing criterion for domestic water
supply lakes. The 2008 Kansas 305(b)4 list used the following thresholds of chlorophyll-a for
domestic water supply uses: < 10 μg/L fully supportive; 10-12 μg/L fully supportive but threatened;
12-20 μg/L partially supportive; and >20 μg/L non-supportive.

Dodds et al attempted to determine the ecoregional reference conditions for Kansas lakes and
reservoirs in 2006. Three methods used were (1) reference lakes identified by best professional
judgment (BPJ); (2) trisection5 method; and (3) regression model (extrapolation). Partial results are
listed below in Tables 4 and 5.

4 Water Quality Assessment Report, section 305(b) of the Clean Water Act

5 A statistical method that determines the median value derived from the best one-third of a data set. This value is considered by

some to estimate a reference condition.

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 Table 4. BPJ Method Reference Values

Table 5. Trisection and Regression Model Methods Reference Values

In 2006, the State of Oklahoma adopted chlorophyll-a criteria for public and private water supply
use lakes. A significant number of Oklahoma water systems have THM, total organic carbon
(TOC), as well as taste and odor problems. Many of the violations may be attributed to excessive
algae. A long-term average of 10 μg/L was established for chlorophyll-a for the water supply lakes.
Site specific phosphorus and/or nitrogen limits are to be derived from lake models and TMDLs.

Downing et al concluded that chlorophyll-a levels above 10 μg/L can exponentially increase the
likelihood of cyanobacteria dominance, thus cause more occurrences of taste and odor problems for
drinking water supply reservoirs (Figure 3). Smith et al suggested the intensity and frequency of
taste and odor events measured by geosmin in Cheney Lake would consistently be reduced if mean
chlorophyll-a concentrations are maintained below 11 μg/L throughout the reservoir (Figure 4).
While the causal parameters TP and TN can vary greatly, chlorophyll-a above 10 μg/L seems to
consistently produce taste and odor problems that can plague public water supply reservoirs.

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 Figure 3. Chlorphyll-a and Cyanobacteria (Source: Downing et al, 2001)

Figure 4. Cheney Lake Geosmin vs. Chlorophyll-a (Source: Smith et al 2001)

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 SUMMARY

Problems caused by eutrophication are a major concern for drinking water treatment facilities and
end users. The cost of treatment can be extremely high depending on the severity of eutrophication.
A good and cost-effective way of addressing the problems is the protection of source water from
nutrient enrichment in lakes or reservoirs. Studies have shown that maintaining chlorophyll-a levels
below 10 μg/L in lakes or reservoirs can prevent or significantly reduce the occurrence of taste and
odor problems. Appropriate targets of the causal factors of algal growth (measured by chlorophyll-
a) such as TP and/or TN can be set on a case-by-case basis for impaired lakes.

OPTIONS

A few options to consider during this review process include:

ƒ Maintain only the current narrative nutrient criteria
ƒ Add chlorophyll-a criteria for public water supply lakes or reservoirs – the lower of 10 μg/L
(with no margin of safety) or the long-term average of chlorophyll-a concentration
ƒ Add chlorophyll-a criteria for public water supply lakes or reservoirs – the lower of 9 μg/L
(10 μg/L with a 10% margin of safety) or the long-term average of chlorophyll-a
concentration
ƒ Adopt RTAG’s benchmark for chlorophyll-a (8 μg/L) as the criterion

Impact Considerations: Since most of the PWS reservoirs or lakes are located in rural areas, few
wastewater dischargers lie above those lakes and reservoirs. Therefore, nonpoint sources are likely
the major contributors of nutrients to these PWS reservoirs or lakes. The cost for controlling
nutrient inputs from the non-point sources will depend on the size of the watershed, current
management practices, and severity of the existing problem. However, the cost may be mitigated by
cost-sharing programs available through the State Conservation Commission or the US Department
of Agriculture’s Natural Resources Conservation Service programs. Reduction in nutrient loads will
likely reduce the operating costs of drinking water plants since fewer chemicals are needed to treat
the water. In the long run, a local community may save a significant amount of money by not
having to upgrade the drinking water plant in order to deal with nutrient enrichment issues. The
benefits to the drinking water plants, consumers, and local communities will offset, and may
outweigh the cost associated with nutrient reduction. Furthermore, adoption of criteria may provide
warning to public water suppliers of threatening conditions developing in their source water,
allowing for more orderly contingency planning to maintain service.

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