US EPA Comments on Virginia Department of Health (VDH) Proposed Guidance for Cyanobacteria Bloom Recreational Advisory Management

1. Page 2: Please clarify that the U.S. Environmental Protection Agency’s (EPA) document, Recommended Human Health Recreational Ambient Water Quality Criteria or Swimming Advisories for Microcystins and Cylindrospermopsin, published recommended values that could be used in two ways. The recommended values could serve as the basis for recreational swimming advisories for notification purposes to protect public health in recreational waters. The recommended values could be used as ambient water quality criteria when adopting new or revised water quality standards which could be used for all Clean Water Act purposes. The recommended values could also be used for both purposes by a state or authorized tribe. As written in VDH’s document the two options appear to be one.
2. Page 2-3: EPA commends VDH on expanding the types of thresholds used to recommend cyanobacteria bloom recreational advisory thresholds.
3. Page 3: Please clarify if recreational advisories will be recommended when any one of the toxin thresholds, or the PTOX cyanobacteria taxa threshold, in Table 1 is exceeded. Please also clarify how the microcystis species threshold will be used. For example, by explaining that microcystis species are incorporated into the PTOX cyanobacteria taxa.
4. Page 4: Please clarify if VDH may recommend lifting an advisory based on one sample. Would other information also be considered in making this decision?
5. Pages 4, 13-15: EPA commends VDH on the continued recognition of and increased emphasis on the importance of benthic algal mats and efforts to promote public outreach and education on this issue while sharing as much information as possible with the public. EPA is also supportive of VDH’s recommendation to consider posting informational warning signs in impacted water bodies.

The Water Quality Committee Chair for the Lake Anna Civic Association (LACA) has read and understands the proposed guidance and recommends that VDH approve the guidance and use it starting in 2021.  The guidance provides a detailed and structured approach to recreational advisory management when cyanobacteria blooms occur in the State.

LACA requests that VDH continue to consider protocols that could include the use of citizen water monitoring groups like LACA’s for cyanobacteria bloom monitoring and formalize the basic protocols in future iterations of this document.  A citizen monitoring group that has been certified by the Virginia Department of Environmental Quality (DEQ) to collect water samples and field parameters at level 3 quality of assurance levels should be able to collect water samples for cyanobacteria monitoring under approved VDH or DEQ protocols.  These samples could be sent to VDH laboratories for analysis using certified instruments to conduct the cell counts and toxin measurements.  The protocols could include limitations that would ensure limited lab resources (time and funding) are not overwhelmed by the addition of the citizen water sampling activities.