1. The use of cationic polyacrylamide shall be avoided where there is danger of impacting aquatic organisms because its toxicity to aquatic test species occurs at very low concentrations.
2. Anionic polymer mixtures shall have ≤ .05% free acrylamide monomer by weight as established by the Food and Drug Administration (FDA) and the Environmental Protection Agency (EPA).
3.
Each manufacturer shall provide to the WDNR toxicity information (including acute and chronic water column toxicity test data) from a certified lab, as defined in ch.
NR 149 Wis.Adm.Code, for the polymer mixture.
This data shall include all raw and statistical data regarding death, sub-lethal observations such as immobility, and any other test observations. Standardized toxicity testing procedures should be used and referenced. A use restriction will be calculated by WDNR using the information in Appendix I.
4. Users of polymer mixtures shall obtain and follow all Material Safety Data Sheet (MSDS) requirements, manufacturer's recommendations, and WDNR use restrictions.
B. Application Criteria
1. Maximum application rates, per storm event, in pounds per acre-feet shall be the lesser of WDNR's use restriction multiplied by 1.35 or the manufacturer's recommended application rate (1.35 is a conversion factor that is used to change the use restriction from ppm to an application rate in pounds per acre-feet).
2. Neither the manufacturer's written application rate recommendations, nor the application rate shall exceed the WDNR use restriction. The manufacturer or distributor shall provide for the applicator:
a. Labels affixed to the polymer mixture containers that indicate the recommended application rate and the maximum application rate based on the use restriction.
b. A product expiration date for the polymer mixture based on product expiration dates of the polymer.
c. General written application methods.
d. Written instructions to provide proper safety, storage, and mixing of their product.
3. The application method shall provide for uniform distribution of the product in the sediment control structure and shall consist of either:
a. Passive Applications: Polymers applied by non-mechanically dosing the sediment-laden inflow prior to it entering the impoundment area of the sediment control structure. The manufacturer shall base passive application rates on the dissolution rate and/or the dead storage volume of the sediment control structure.
or
b. Active or Mechanical Applications: Polymer applied by mechanically or hydraulically mixing directly into a sediment control structure.
4. The applicator of the polymer mixture shall at the time of application, document the following:
• Name of applicator
• Application rate in pounds per acre-feet of stormwater runoff
• Date applied
• Product type
• Weather conditions during application
• Method of application
Copies of this documentation shall be entered into the contractor's monitoring log or a project diary and made available upon request.
C. Product Approval Criteria
The manufacturer shall certify, through independent sampling and test results, that their product performs as per the following requirements. (The product approval process is depicted in flow chart form in Figure 1.)
1. The toxicity information required in section V.A.3. of this standard shall be reviewed by the WDNR and used to generate a written product use restriction for the polymer mixture. Appendix I outlines the information that needs to be submitted as a part of this review, and states where they must be submitted.
2. Polymer mixtures shall achieve = 95% sediment reduction as measured by the standpipe method outlined in Appendix II.
3. Performance criteria - active and passive applications shall be field tested and submitted separately:
a. The performance of polymer mixtures shall be verified and field-tested in a body of water that is not discharging directly into the waters of the state. The body of water shall be a minimum of 1/3-acre surface area and an average depth of at least 3 feet.
b. The total suspended solids prior to the polymer treatment must be tested and verified by an independent testing lab, and must have a minimum value of 800 ppm or equivalent Nephelometric Turbidity Units (NTU) and be visibly turbid. The relationship between total suspended solids (TSS) and NTU is site-specific and the derivation of a unique TSS-NTU relationship shall be conducted for each sediment control structure. A minimum of two samples per acre-foot of water shall be taken from random locations within the test site.
c. Within 48 hours from the initial treatment of the water body, the total suspended solids must have a maximum of 80 ppm, or equivalent NTU.
d. Testing sites may not be used for subsequent testing for a period of 3 months from the time of initial application.
e. The Wisconsin Department of Transportation (WisDOT) shall be notified at least 7 days prior to testing, and WisDOT and/or WDNR staff shall be allowed to monitor any such testing.
4. The WisDOT Erosion Control Storm Water/Product Acceptability List Committee will review and approve products as per the process set forth in WisDOT's Product Acceptability List (PAL).
5. The polymer mixture must be resubmitted if any portion of the mixture is altered subsequent to its approval. Such alterations may include:
a. The amendment of base polymers and/or any other additives
b. The ratios of individual components
VI. Considerations
The following are additional recommendations, which may enhance the use of, or avoid problems with, the practice.
A When using products in impoundments immediately adjacent to, or within waters of the state, consider using products for which the manufacturer's recommended application rate is considerably lower than the use restriction.
B. The applicator should use the least amount of polymer mixture to achieve optimal performance.
C. Polymer mixtures should be applied in conjunction with other erosion control BMPs and under an erosion and sediment control or stormwater management plan.
D. Test the pH of the water in the sediment control structure and follow the manufacturer's recommended pH range for their polymer mixture, as pH will impact the effectiveness of polymer mixtures.
E. Ethylene glycol, propylene glycol or any other known environmental toxicants should not be included in the polymer mixture.
F. Care must be taken to prevent spills of polymer mixtures. Follow the manufacturer's recommended cleanup procedures in the event of a spill.
G. Inhaling granular polymer may cause choking or difficulty breathing. Persons handling and mixing polymer should use personal protective equipment of a type recommended by the manufacturer.
H. Polymer mixtures combined with water are very slippery and can pose a safety hazard.
I. Polymer mixtures should be considered as an aid to removing solids from dredge slurries.
J. Where polymer mixtures are used with sediment control structures in the stream, such as during bridge construction, the structure should not be removed until the water is clarified. If the resulting sediment floc is more than a half a foot deep it should be excavated or filtered out.
VII. Specifications
Erosion and sediment control and stormwater management plans specifying polymer mixtures for sediment control shall be in keeping with this standard and shall describe the requirements for applying the practice to achieve its intended purpose.
VIII. Operation and Maintenance
Sediment levels on the bottom of the sediment control structure shall be monitored to measure the loss of storage capacity over time due to enhanced sedimentation by the polymer mixture.
IX. Definitions
Material Safety Data Sheets (MSDS) (V.A.3) Provide basic information on a material or chemical product intended to help someone work safely with the material. This includes a brief synopsis of the hazards associated with using a material, how to use it safely, and what to do if there is an emergency. The retail distributor and/or manufacturer as per OSHA's Hazard Communication Standard,
29 CFR 1910.1200, must provide MSDS, with the purchase of potentially hazardous products.
Nephelometric Turbidity Units (NTU) (V.C.3.b) A measure of the amount of light scattered by suspended and dissolved materials in the sample.
Polyacrylamide (V.A.1) A generic term for polymers made up of many repeating units of the monomer acrylamide (a simple organic compound).
Polymer (I) Polymers are materials that are either natural or synthetic and that have a chain of carbon molecules that are identical, repeating units. Polymers can be positively charged (cationic), negatively charged (anionic) or have no charge (non-ionic).
Polymer Mixture (V.A) Any reference to polymer mixtures refers to the whole manufactured product, including the polymer and any additives. Additional calcium or lime may be added as a buffering agent without being considered part of the whole manufactured product.
Sediment (II) refers to settleable soil, rock fragments and other solids suspended in runoff.
Sediment control structure (I.) A sediment control structure is an impoundment designed to intercept and detain sediment carried in runoff, prior to the runoff reaching the main channel of a waterway or body of water. Placement of these structures must be outside of the main channel of a waterway and shall not span opposing stream banks in channelized flow. The sediment control structure must provide for dedicated sediment storage to at least a depth of two feet, such that the sediment will not be subject to re-suspension during high velocity flow conditions.
Impoundments may be created by a cofferdam, turbidity barrier, earthen berm, sheet piling, self-contained filtering systems or similar material. Examples include properly maintained construction or post-construction sediment ponds, discharging directly or eventually to a water body. They may also include surface water impoundments that are immediately adjacent to a waterway, whose function is to treat stormwater or dredging material. Another potential application is to isolate localized areas surrounding bridge and culvert construction.
Standardized toxicity testing (V.A.2) Examples of such include, but are not limited to, those outlined in the State of Wisconsin Aquatic Life Toxicity Testing Methods Manual (Fleming, et.al, 1996) or Short-term Methods for Estimating the Chronic Toxicity of Effluents and Receiving Water to Freshwater Organisms (Lewis, et.al, 1994). The WDNR use restriction shall be developed from this data.
Surface Waters of the State (III) “Surface" refers to the sub portion of the waters of the state that discharge at the surface. Waters of the state, as defined by s.
283.01(20), Wis. Stats means those portions of Lake Michigan and Lake Superior within the boundaries of Wisconsin, all lakes, bays, rivers, streams, springs, ponds, wells, impounding reservoirs, marshes, water courses, drainage systems and other surface water or groundwater, natural or artificial, public or private within the state or under its jurisdiction, except those waters which are entirely confined and retained completely upon the property of the person.
Use Restriction (V.A.2) Identifies the concentration below which a product is not expected to cause acute toxicity in the aquatic environment.
X. References
Voluntary Use Of Polymers In DNR Programs (A Field Guide) For copies of this companion document contact Mary Anne Lowndes, Water Resources Engineer Bureau of Watershed Management 101 S. Webster St., Box 7921, Madison, WI 53707-7921 Phone (608) 261-6420
MaryAnne.Lowndes@dnr.state.wi.us
Fleming, K., P. Hubbard, N. Krause, R. Masnado, D. Piper, W. Repavich, G. Searle, S. Thon, “State of Wisconsin Aquatic Life Toxicity Testing Methods Manual, Edition 1." Bureau of Watershed Management, Wisconsin Department of Natural Resources, Madison, 1996 (WI. PUBL-WW-033-96).
Lewis, P.A., D.J. Klemm, J.M. Lazorchak, T.J. Norberg-King, W.H. Peltier, and M.A. Heber, “Short-Term Methods for Estimating the Chronic Toxicity of Effluents and Receiving Waters to Freshwater Organisms, 3rd Edition." Environmental Monitoring Systems Laboratory, U.S. Environmental Protection Agency, Cincinnati, OH, 1994 (EPA/600/4-91/002).
Roa-Espinosa, A., Bubenzer, G.D. and Miyashita, E., “Sediment and Runoff Control on Construction Sites Using Four Application Methods of Polyacrylamide Mix." National Conference on Tools for Urban Water Resource Management and Protection, Chicago, pp. 278, February 7-10, 2000.
Roa, A., “Are there Safety Concerns or Environmental Concerns with PAM?" Dane County Land Conservation Department, 1997.
Sojka, R.E. and Lentz, R.D., “A PAM Primer: A brief history of PAM and PAM related issues." Kimberly, ID: USDA-ARS Northwest Irrigation and Soils Research Lab, 1996.
http://kimberly.ars.usda.gov.
Wirtz, J, R., “The Pros and Cons of the Use of Anionic Polyacrylamides to Control Erosion and Sedimentation in the Lake Mendota Priority Watershed". University of Wisconsin-Madison, MS Thesis, 2000.
Interim Sediment Control
Water Application of Polymers
APPENDIX I
REQUIRED TOXICITY INFORMATION FOR WDNR REVIEW
Toxicity information shall be reviewed by the WDNR and will be used to generate a written product use restriction for the polymer. With Chapter 1.7 of the Whole Effluent Toxicity Program Guidance Document (Fleming et. al., 2000) as a basis, the following toxicological information/data is required:
a. Manufacturer of the polymer.
b. Chemical name of the polymer.
c. Active Ingredient(s) (if not proprietary information).
d. Chemical Abstracts Service (CAS) #(s) of the polymer and/or active ingredients.
e.
Material Safety Data Sheet (MSDS) and/or official toxicity test results listing available aquatic life toxicity data for the WHOLE PRODUCT. Toxicity data for active ingredients is not acceptable for use in calculating a use restriction. The following types of data is acceptable:
-
See PDF for table 
LC50 = the estimated concentration of polymer that would cause 50% mortality to the test population following the given time period
EC50 = the estimated concentration of polymer that would cause a given effect in 50% of the test population following a given time period
IC25 = the estimated concentration of polymer that would cause a 25% reduction in some biological measurement of the test population following a given time period
