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GUEST EDITORIAL
Toxic chemicals in surface waters Toxic chemicals from direct and indirect industrial wastewater discharges and land runoff are often found in surface waters that are used as sources of public water supply. The problem caused by their presence is beginning to receive some of the attention it has long deserved. I am concerned, however, about the narrow focus of much of the activity and about the implications of our failure to address the problem comprehensively. Health effects research is very costly and time consuming. Do we know enough about wastewater discharges and human exposure to set research priorities intelligently? We debate the significance of trace concentrations of toxic chemicals in water supply sources with little or no reference to the validity of sampling strategies underlying these values. How can sound sampling strategies be developed in the absence of reliable data on the quantity, nature, and periodicity of toxic chemical discharges? We have become mesmerized with computerized data management systems and mathematical modeling, while we fail to take the steps necessary to ensure the completeness and reliability of the data we manipulate. A review of NPDES (the National Pollutants Discharge Elimination System) permits quickly discloses our fragmentary knowledge about synthetic organic chemicals in wastewater discharges. Our ambient water quality standards for toxic chemicals cover little more than toxic metals and pesticides. What does it mean to say that a permit holder is meeting permit limitations and ambient standards when both are so incomplete? Our continued certification of public water supply sources from surface water in the face of such incomplete information is nothing less than irresponsible. Underlying the problem is our failure to gain accurate disclosure by industrial dischargers of toxic chemicals manufactured, stored, and used in manufacturing and maintenance operations. The ineffectiveness of reporting on discharges to wastewater can be illustrated by a North Carolina regulatory agency disclosure in 1982 of the extensive use of biocides in the manufacture of socks by textile mills. These highly toxic triorganotin compounds were identified only through the use of state-initiated bioassay W13936x185/0920-wOS01SO10 @ 1985 American Chemical Society
screening techniques. This experience and the recognition of the need to deal more effectively with toxic chemicals in water supply sources have led the state agency to begin a program requiring disclosure of available data on toxic chemicals from all industrial discharges to waters classified for use as water supply sources. The data are often incomplete, however, and to help fill the information gap, the agency is incorporating mandatory metal and gas chromatography-mass spectrometry scans in new and reissued NPDES permits. Water supply classifications are also being modified to afford greater control over discharges and land runoff. The new classification applicable to waters that receive industrial wastewater discharges will require full disclosure of toxic chemicals, development of spill and failure plans, and more extensive monitoring. Concern over the protection of proprietary information made available to regulatory agencies through full disclosure can be met through appropriate legal safeguards. The problem of how to deal with the hoped-for volumes of new data on toxics may be momentarily perplexing, but its very existence and our need to respond should provide the impetus to move forward in this vital area. It is my position that we are misleading the public we ought to protect by failing to require full disclosure of chemical use and wastewater composition to regulatory agencies. That is the key to meaningful regulatory permits, sound monitoring systems, and sensible research priorities.
L h i d H. Howells is refiredfrom the U.S. Public Healfh Service und is profe,ssor emerifus uf Norfh Carolina S m e Universir? and fhe Universify of Norfh Curolina af Chapel Hill. He hus just complefed a six-jeur ferm on the Norfh Carolina Environmenful Commission, where he encouraged program rlnrlopmenf in the area of foxic chemicu1.s in surface wafers. Environ. Sci. Technol.. Vol. 20. NO. 1, 1986 3
