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POSITION PAPER ON WATER QUALITY
STANDARDS FOR GREAT SALT LAKE
Friends of Great Salt Lake
P.O. Box 2655
Salt Lake City, UT
84110-2655
Introduction
The purpose of this paper is to provide a well-reasoned, scientifically supported statement by
Friends of Great Salt Lake (FoGSL) regarding the current lack of and need for numeric water
quality standards goveming the Great Salt Lake. At present, there are only narrative standards
applied to the Great Salt Lake. This issue is particularly pertinent as recently considerable
public attention has been focused on the potential effects of selenium, among other
contaminants, on the Great Salt Lake ecosystem. As the population of Utah continues to grow
and disposal requirements of the Salt Lake City area grow even greater, the need for
quantitative standards becomes imperative.
Position Statement
The mission of Friends of Great Salt Lake is to preserve and protect the Great Salt Lake (GSL)
ecosystem and to increase public awareness and appreciation of the Lake through education,
researd1 and advocacy. Protection of this ecosystem requires that we have suitable
understanding of the current dlemistry of the lake and how natural variation and changes in the
chemistry of the lake affects the biota. Protection also requires that we have sufficient water
quality standards in place to protect the integrity of GSL as required by the Clean Water Act.
Consequently, on the basis of the great social and biological value possessed by the Lake, and
the potential impact of water pollution on those values, FoGSL is IN FAVOR of numeric water
quality standards for the GSL. Background and reasoning behind this position are summarized
below.
Water Quality Standards and Beneficial Uses
The goal of the Clean Water Act, passed in 1972, is to protect the chemical, physical and
biological integrity of the nation's waters. This legislation allows states to develop water quality
standards to protect water bodies. A standard is a provision of law that consists of a designated
use for a water body and the criteria for supporting the use. A designated use is a description of
what the water will be used for by humans and other organisms. Utah currently recognizes 9
categories of designated uses (agriculture, domestic water, GSL, cold water aquatic life, warm
water aquatic life, non-game fish and other aquatic life, primary recreation, secondary recreation
and wildlife habitat). A criterion is a concentration or level (numeric or narrative) of some aspect
of water that supports a particular use. In many cases this is a "do not exceed" quantity (e.g.
concentrations of nitrate cannot exceed 10 mgn.. in potable water) but in some cases these are
a minimum quantity that must be maintained (e.g. oxygen concentrations cannot be lower than
a 30 day average of 6.5 rngn.. in a cold water fishery). These criteria are established and
supported by scientific research, induding evaluations of impacts on human health (e.g. cancer
potency) or aquatic organisms (e.g. mortality, bioaccumulation). This approach is valuable
because not all bodies of water require the same level of protection. For example. a reservoir
that supplies drinking water may require stricter criteria than one used for irrigation. By
assigning designated uses to a water body. we can then more easily assign appropriate water
quality standards.
The current designated use for the GSL is narrative and protected for primary and secondary
contact recreation, aquatic wildlife, and mineral extraction (Class 5). The standards assigned to
this designated use are different than those applied to other water bodies in Utah because they
are not numeric. That is, rather than being associated with a number or concentration that a
certain pollutant cannot exceed, there is a statement of requirements. Narrative standards state
that "It shall be unlawful... for any person to discharge or place any waste or other substance in
such a way as will be or may become offensive...; or cause conditions which produce
undesirable aquatic life or which produce objectionable tastes in edible aquatic organisms; or
result in concentrations or combinations of substances which produce undesirable physiological
responses in desirable resident fish, or other desirable aquatic life, or undesirable human health
effects, as determined by bioassay or other tests performed in accordance with standard
procedures" (Utah Division of Water Quality).
The GSL possesses unique chemistry and hydrology compared to other water bodies in Utah. It
is a terminal lake basin, i.e., having no outflow. This means that chemicals and pollutants that
are introduced to the lake have no way to exit the lake, and are instead concentrated as water is
removed from the lake by evaporation. This makes GSL more sensitive than flow-through
systems to pollution. Since GSL is also a hypersaline system, special consideration needs to
be taken to determine how salinity may interact with pollutants to affect the biota of the lake and
makes it impossible to assume that effects observed in freshwater systems are applicable to
GSL. GSL is unique among hypersaline lakes because it is located close to a major population
center; Salt Lake City and surrounding counties currently hold greater than 1 million residents,
and projections indicate this will grow to 5 million by year 2050 (Utah Govemor's Office of
Planning and Budget). These factors together mandate that appropriate water quality standards
are assigned to the lake to protect it in the future.
Narrative standards for Great Salt Lake are an inadequate approach for several reasons.
Narrative standards imply that concentrations of pollutants in the GSL currently are not
negatively impacting aquatic organisms. Trlis has never specifically been examined, and we
a!so ha..'e little knowledge of conditions in the lake prior to human disturbance. Narrative
standards do not in dude an implicit compliance gauge and so the assessment of impact to
water quality is open to interpretation. Pollution may not have an immediate effect as assumed
in the narrative standard, and undesirable tastes, smells, physiological responses and human
health effects may accumulate over time leading to severely degraded conditions. Infrequent
and spatially limited monitoring make it impossible to determine what chemistry conditions are
present in much of the lake, and how these conditions may vary through time. Finally, since the
most important water pollution control programs in Utah are based on numeric standards
(National Point Discharge Permits and the Total Maximum Daily Load process); not having
numeric standards for the GSL largely exdudes the lake from these processes and leaves the
lake unprotected.
Potential Standards for Great Salt Lake
As explained above. water quality standards are designed to maintain certain levels of different
chemicals in waters. Standards have many purposes and include a wide range of chemical
substances and compounds. Some general classes of chemicals that should be included in
numeric standards for GSL are: oxygen. metals. inorganic nutrients. and pesticides and other
organic compounds.
Inorganic Nutrients: The two most commonly managed inorganic nutrients in aquatic
ecosystems are nitrogen and phosphorus. This is because in most systems one of these two
nutrients is limiting to algal growth. When nitrogen or phosphorus are added to aquatic
systems, high algal production can occur that has many undesirable side effects, induding
deaeased water darity and growth of toxic forms of algae. Additionally, when algae die they
are decomposed by bacteria that consume oxygen in the water, leading to anoxic conditions.
There is evidence that excess nutrients in Farmington Bay may be leading to high levels of algal
production in Farmington Bay, with potential implications for the health of this ecosystem.
Oxygen: In aquatic systems, anoxia generally occurs when respiration levels are very high. As
explained above, bacteria cause anoxia when they use oxygen to decompose organic matter
that is produced by algal production or delivered by inflowing rivers and streams. Anoxia
commonly occurs in the bottom part of the water column in Farmington and Gilbert Bays in
areas that are under1ain by deep brine layers (relatively stable layers of high salinity water that
infrequently mix with the over1ying water). Oxygen dynamics are further complicated in
hypersaline water, because the high salt content of the water reduces the amount of oxygen
that can be held in the water, leading to low levels of oxygen saturation (typically 3-6 mg/l in
GSL, vs. 8 mg/L in freshwater at this elevation).
Oxygen standards are generally used to ensure sufficient oxygen levels to allow organisms
such as fish to respire. Although the GSL does not contain any fish, it still contains many
important organisms, including brine shrimp and brine flies. Brine shrimp are an important part
of the GSL ecosystem; the brine shrimp cyst harvest on the Lake contributes $80 million to the
Utah economy annually has about 60 percent world market share. Brine shrimp are also an
important food source for many of the up to five million water birds that migrate through the
Lake each year. It is unclear how oxygen levels may affect brine shrimp survival, but it is
possible that brine shrimp would not be able to tolerate low or no oxygen conditions. Anoxia is
an additional concern in aquatic systems, because when oxygen is absent different chemical
reactions occur. In one reaction that occurs under anoxic conditions, sulfates, which are
naturally abundant in the hypersaline water of GSL, are reduced to hydrogen sulfide. Hydrogen
sulfide is commonly known as the "rotten-egg" gas; hydrogen sulfide production in various areas
of GSL may contribute to odor events that frequently plague Salt Lake City and the surrounding
areas.
Metals: Because the GSL is a terminal system, the levels of metals in the lake are generally
higher than observed in lakes and streams because they have been concentrated. For
example, GSL is naturally high in arsenic, with concentrations of approximately 100 ~g/L, which
is 10 times higher than the current EPA drinking water standard of 10 ~g/L. Organisms living in
GSL may have evolved greater tolerances to some metals than would be seen in other aquatic
systems. The examination of metals in GSL is further confounded by interactions with salinity
and oxygen. For example, toxicity of a metal may be different in Gunnison Bay, where salinity is
near 32%, compared to Gilbert Bay where salinity is currently near 16%. Additionally, metals
may be bound or released depending on oxygen concentrations, which could result in variations
in toxicity between anoxic deep brine layers and overlying oxygenated water. These spatial
variations in toxicity should be considered when implementing water quality standards for the
Lake.
Great danger is posed by metals that bioaccumulate (stored in the bodies of animals with
increasing concentrations and adverse effects observed higher in the food chain), including
selenium. Aquatic ecosystems that are shallow and slow moving, such as GSL, are most likely
to accumulate selenium and experience toxic impacts in fish and wildlife. Selenium consumed
by adult birds is passed to their offspring in eggs, where the young absorb the selenium as they
grow, resulting in deformities, reproductive failure, and death. As little as 10-15 ug/L dissolved
selenium can cause reduced weight gain in adult water birds, reduced egg viability and reduced
hatchling survival. Selenium and other metals that bioaccumulate should be of great concem in
GSL because of (1) the large bird migration that occurs each year through the GSL and
surrounding wetlands, making the Lake part of the Western Hemispheric Shorebird Reserve
network (WHSRN) and (2) the removal of brine shrimp cysts for use in aquiculture, with humans
as the ultimate consumer of shellfish fed with brine shrimp cysts. More monitoring and
laboratory examinations need to be completed to determine the current levels and impacts of
selenium and other metals in GSL.
Pesticides and other organic pollutants: Current water quality trends in metropolitan areas have
shown that human-created chemicals are causing some of the greatest pollutant threats to
aquatic ecosystems. Commonly used pharmaceuticals such as estrogen are reaching
detectible levels in water bodies that are highly impacted by human development. Pesticides
are widely used along the Wasatch Front for agriculture and for general pest management, and
the effects of these pollutants may be particularly difficult to detect since they are frequently
delivered to surface water systems in short time periods immediately following application or
storm events. Additionally, these organic compounds are present in very low concentrations
that are difficult to measure, but may have lasting effects on organisms. Some of these
chemicals may also bioaccumulate. With the growing population along the Wasatch Front, the
effects of organic chemicals on the GSL ecosystem should be considered important current and
future threats.
Detem1ining Appropriate Water Quality Standards for Great Salt Lake
A significant amount of research needs to be conducted to ensure that appropriate water quality
standards are applied to the Great Salt Lake. Because the Great Salt Lake is not a drinking
water reservoir, less strict standards may need to be applied than would be inappropriate for
other Utah lakes. However, the lake is still an important source of food for migratory shorebirds
and for aquaculture, and those uses must be reflected in appropriate standards. Also, it will be
difficult to apply standards to Great Salt Lake that have been developed in freshwater systems,
because it is unclear how salinity may interact with pollutants to alter organism tolerances and
toxicity levels. However, numeric water quality standards have been developed for other
hypersaline systems, such as Mono Lake in California, and we should rely on science
developed in these systems as a starting place for GSL standards.
A major cost associated with developing numeric standards will be developing dlemical and
biological analytical tedlniques that are accurate and precise in hypersaline water. Extensive
literature review, laboratory quality control, and development of novel techniques using state-of-
the-art analysis equipment will be essential to meet this goal. This will be a difficult hurdle to
overcome, as all of the current water quality analysis in Utah is based on Standard Methods for
the Examination of Water and Wastewater, a book of analytical tedlniques published by the
American Public Health Association based on freshwater systems. However, tedlnique
development is not impossible, and some individual labs are already working on high salinity
methods used in their researdl. Without a concerted effort to develop techniques, it will be
impossible to implement standards for the Great Salt Lake.
The use of bioindicators may also aid in the development of GSL water quality standards.
Bioindicators can be a species or group of species of fish, insects, algae or plants that show a
quick, dramatic response to a disturbance. For example, if Chemical A is introduced to the
Great Salt Lake, it may quickly kill all the individuals of one algae species in the lake, but may
have a delayed and less detectable effect on brine shrimp and brine flies. The algae species
may be used as a single-species bioindicator for Chemical A, because of its rapid response to
Chemical A compared to other organisms in the Great Salt Lake. Initial work could focus on
determining the species in GSL that are most sensitive to different types of pollutants, followed
by determining the levels of pollutant that cause decline of that species using traditional toxicity
techniques. This could reduce the number of tests ultimately needed to create useful water
quality standards for GSL.
Afterword
FOGSL recognizes that developing water quality standards for GSL is an expensive and
extremely complex undertaking. The success of this undertaking will hinge on a commitment by
its stakeholders to work collaboratively to achieve this goal. Because so little is currently known
about the spatial and temporal variations in chemical concentrations in the lake. we first must
establish the current state of pollutants and other chemicals in GSL. This is further complicated
by little knowledge of historical trends in water quality on the lake. However, this lack of
knowledge is not suffident reason to avoid the development of numeric standards for the lake
as urban growth continues to impact this ecosystem. We must consider the effects of different
pollutants on the GSL ecosystem and on the services that we, as neighbors, derive from the
lake. We must ensure that our own uses of the lake are sustainable and not endangered by
water pollution. We believe that with timely development of water quality standards for the lake,
we can continue to maintain the integrity of the GSL ecosystem along with the growth of our
population.
Acknowledgements
The Friends of Great Salt Lake Science committee would like to thank Joy Emory, Joel Peterson, and one
anonymous reviewer for providing comments and suggestions that greatly improved this paper.
References
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