Making a case for a third-party water & wastewater forensics agency
It is time to establish an independent public sector Water Wastewater Forensic Agency (WWFA) for investigating water and wastewater treatment failures. Much as a public law enforcement forensic arm does for examining criminal offenses, this water resource equivalent would provide accepted methodological, evidence-based investigatory techniques to determine the circumstances of a water resource process failure that damages a watershed’s ecosystem or results in a compromised public water supply causing illness or death to its consumers.
Municipal wastewater treatment and water supply are essential services crucial for protecting a watershed and public domestic water supply sources, respectively. Water resource recovery facilities (WRRF) are constructed to treat municipal wastewater, and their success is measured against mandated effluent discharge concentrations of legacy contaminants such as biochemical oxygen demand (BOD) and phosphorus. Municipal water treatment plants (WTP) often use raw water sources that also serve as a WRRF final effluent receiving stream, inextricably tying these two services together in an urban hydrological cycle (UHC). The consequences of failing to protect a watershed’s source water or a public potable water supply parallel those from an aircraft inflight emergency resulting in a crash causing injury or death to those on board and on the ground, as well as damaging the environment. Loss of operating performance in either case warrants a formal forensic investigation.
A WWFA lead investigator and the supporting team would need to determine the cause of any process failure leading to the loss of potable water or wastewater final effluent quality. The magnitude of the failure would be determined by comparing historical performance to the degraded product quality caused by the process failure. WRRF and WTP effluent historical records should be available for comparison to their respective contaminant values during the process failure. Currently, legacy contaminants such as BOD, would be available for comparison for all WRRFs; for most, microconstituent values would not be available, but may be included in the future. Potable water is similarly tested for mandated constituent levels from bacteria to chlorine residuals.
However, microconstituents such as pharmaceuticals, their metabolic byproducts and other exotics, which may be endocrine disruptors, provide an increased level of common ground for concern in the UHC for measurement in each of these areas. Often measured at low levels (9 to 10 mg/L), these compounds may pass through or be only partially treated by the activated sludge system. They then are passed on to a receiving stream, where they may become potable water source contaminants. If not removed at the WTP before being distributed to the public’s water supply, these sophisticated compounds may be doing harm through low-level exposure over long periods of time. This makes determining cause and effect a difficult undertaking and highlights the need to have formal forensic methodology in place to best determine possible harm to the public.
In 2004, Metal Finishing published an article I wrote titled “Sampling and Limits Are Your Environmental Fingerprints.” In it, I argued that an industry would do well to ensure it can account for the discharge of its site-specific contaminants to a municipal sewer and put that loading into the context of the full loading of those particular contaminants arriving at the community’s wastewater treatment plant.
Undertaking this provides the industrial source producer with a broader perspective of its percentage contribution to a WRRF’s loading of any specific waste pollutant. In effect, the industry would be “fingerprinting” its waste discharge, seeking to limit any liability exposure to what it can historically demonstrate originates from its site. The article addresses the importance of effective, timely and statistically significant sampling in order to provide a useful evaluation and understanding of a contaminant’s profile.
I had suggested this fingerprinting concept should be expanded to a WTP’s influent and effluent characterization, tying the results as closely as possible to upstream sources of contamination. This holds true especially for the exotics, some of which may be endocrine disruptors. Introducing these harmful chemicals to source water supplies without regard to their effect on the watershed’s fauna or the public is an unauthorized social experiment being forced on an unsuspecting public. Indeed, unless exotics are regulated, should a WRRF process fail resulting in increasing the levels of these contaminants to the receiving stream, a forensic investigation of these compounds may be compromised.
Consider the paper “The Effects of Tertiary Treated Municipal astewater on Fish Communities of a Small River Tributary in Southern Ontario, Canada” by Carolyn Brown et al. addressing the effects of tertiary WRRF effluent from the Guelph, ON, Canada, treatment plant into the Speed River. The author stated that, “One of the largest anthropogenic discharges into many waterways is municipal wastewater effluent (MWWE), which can cause issues such as eutrophication, acute toxicity, contamination and endocrine disruption in receiving environments.” Although the author touched on endocrine disruptors in her statement above, she went on to say, “The primary targets of treatment include reducing biological oxygen demand, total suspended solids, nutrients (phosphorous and/or nitrogen) and pathogenic bacteria.” Further, the author stated at the end of the paper’s discussion that, “This study indicated that high-quality treatment alone may not be sufficient to mitigate effects on aquatic ecosystems, and the management and monitoring of MWWE must be carefully considered to detect impacts and protect aquatic ecosystems.”
In the 2013 paper “Occurenace and Degre of Intersex in Darters Across An Urban Gradiaent in the Grand River, Ontario, Canada” by Gerald R. Tanna et al., the author notes in his introduction that, “Many contaminants that can act as endocrine-disrupting compounds have been detected in treated MWWEs and their respective aquatic receiving environments over the last two decades. Due to their high affinity for biological receptors, a variety of natural hormones, pharmaceuticals and industrial contaminants found in effluents have been shown to have the potential to induce responses in aquatic organisms at very low concentrations (low ng/L range).”
In short, the study of microconstituents already has an established history, with much more work to be done. Also, it is clear there are concerns that these sophisticated compounds may affect human health even at low concentrations, especially as they are consumed over long periods of time, creating incremental harm. The nature of this pollutant type is wholly different from that of BOD, suspended solids or nutrient contaminants. The former often is a specific compound such as estrogen ethinylestradiol (EE2), concentrations are orders of magnitude less than measured for legacy contaminants, very sophisticated measurement techniques are used and these compounds may react biochemically with endocrine receptors when consumed by humans, disrupting endocrine function.
As more is learned about the potential harm legacy and microconstituents can cause to human health, exotics may drive the public awareness of and demand for a wastewater forensic agency.
Timing Is Everything
The failure of an aircraft in flight may result in anything from a safe, unscheduled emergency landing with all onboard safe to continue their journeys to a catastrophic event involving considerable loss of life both from the aircraft and those affected on the ground.
The immediate consequences of a WRRF or WTP failure to perform may be far less dramatic, but no less harmful in the long run, as effluent constituents that are dangerous to humans can affect large numbers of people through municipal water that has been contaminated by both conventional and exotic contaminants. Further, it seems likely that harm may occur over extended periods of time as these compounds are consumed in tiny concentrations, resulting in perhaps ill-defined chronically poorer health of individuals until a threshold is reached and acute health failure is precipitated.
Confounding all of these complexities for investigation are long time frames of exposure and the quality of evaluative evidence. There is no formal “black box” for effluent safety, as there is for an aircraft. Mechanical, hydraulic, energy consumption and chemical usage performance may be monitored via SCADA programs and sophisticated process treatment software. This could include information from real-time nutrient sensors like those used to monitor phosphorus or nitrogen in the effluent. However, there isn’t a “contaminant black box” equivalent in a WTP or WRRF.
Establishing a federal forensic agency to address all these concerns will begin to answer these issues and provide the science-based standard operating procedure protocols that will be used to fairly, legally and systematically investigate failures at both WTP and WRRF facilities, as well as the harm that may have come to our watersheds and fellow citizens. This agency would be grounded in the unique realities of long time frames, precise low concentration measurements of exotic microconstituents and developing a rigorous standard for evaluating cause and effect. In the interest of public health, establishing the foundations of this agency cannot be started too soon.