tact with a plant's processing operations has never been subject to restrictions in any ver Great Lakes Water Quality Guidance: sion of the Guidance," he says. In situations in Bioaccumuiative Chemicals of Concern (BCCs) which water does come into contact with pro cessing operations but there is "no reason Chlordane Lindane able potential" to cause specific contamina 4,4'-DDD Mercury tion, he says, there is also no restriction—for 4,4'-DDE Mi rex instance, in instances in which an industry 4,4'-DDT Octachlorostyrene works with metals but the pollutant of con Dieldrin Pentachlorobenzene cern is a pesticide. Hexachlorobenzene (HCB) Photomirex But intake water still becomes a problem in Hexachlorobutadiene Polychlorinated biphenyls (PCBs) the eyes of the Coalition when a manufactur Hexachlorocyclohexane (BHC) 2,3,7,8-TCDD (Dioxin) ing process creates a specific contaminant and α-Hexachlorocyclohexane (a-BHC) 1,2,3,4-Tetrachlorobenzene treats its waste stream to reduce this contam β-Hexachlorocyclohexane (β-BHC) 1,2,3,5-Tetrachlorobenzene ination. Under the draft guidance, the water δ-Hexachlorocyclohexane (δ-BHC) Toxaphene leaving the plant must meet water quality stan dards for the specific pollutant. This could re quire operators to treat exiting water to levels cleaner Hill also is conducting a follow-up study to exam than when it came into the plant. The final version ine the impact of the revised Guidance. gives states 10 years after implementation to put this The Great Lakes Water Quality Guidance is an am last practice into place, however. bitious, ground-breaking endeavor. The first water quality regulation to tackle the problems of an en New mercury standard tire region, it also introduces a new science-based ap Perhaps the largest numerical change from the draft proach to establishing water quality standards. Yet to the final Guidance is the wildlife criterion for mer its major rationale—benefits to humans, aquatic life, cury. The final value, 1.3 pptr, is more than 7 times and wildlife—may be undermined by current scien the draft value of 0.18 pptr. But the new value is still tific research on the causes of Great Lakes pollu below the detection limits for routine laboratory anal tion as well as antiregulatory fervor. "We're at the ysis, which has drawn complaints from industry and point where we don't know enough about the over municipalities. "The limits are unrealistic," says an all contamination in the Great Lakes to say which industry consultant. "They make false positives a sig sources are most important," says one researcher. "But nificant problem." On the other hand, many states within two years, we'll be trying to tackle contami already have such standards in place, says Jim Grant, nation from the atmosphere and sediments. Those who represented Michigan throughout the Guid are the tough problems." ance development process. "We set up the permit so that the value for compliance evaluation is the level References of detection. Then we put in other conditions to en (1) "Great Lakes Water Quality Initiative, A Summary"; U.S. courage the industry to minimize or prevent pollu Environmental Protection Agency: Washington, DC, 1995; EPA-820-S-95-001. tion. Such standards do not require exotic technol (2) DRI/McGraw-Hill. "The Great Lakes Water Quality Initia ogies," he says. tive: Cost-Effective Measures To Enhance Environmental As a major new environmental rule, the Guid Quality and Regional Competitiveness"; Report prepared for Council of Great Lakes Governors; September 1993. ance has not escaped notice from the antiregula(3) Donahue, M. J., Great Lakes Commission executive di tion proponents in Congress. Wisconsin Republi rector, prepared statement to House of Representatives can Representative Thomas Petri recentiy succeeded Committee on Merchant Marine and Fisheries, "Over in amending the Clean Water Act reauthorization to sight of the Great Lakes Program and Its Applicability to Other Regional Programs"; March 24,1994; Serial No. 103give states more discretion in applying the Guid 98; U.S. Government Printing Office: Washington, DC, ance. The Petri amendment declares that a state's pol 1994. icies will be considered consistent with the Guid (4) Gobas, F.A.P.C. Ecol. Model. 1993, 69, 1-17. ance if they are based on scientifically defensible (5) Phenicie, D., Great Lakes Water Quality Coalition Envi ronmental Policy Advisory Group Chair, prepared state judgments and provide an overall level of protec ment to House of Representatives Committee on Mer tion comparable with die Guidance. chant Marine and Fisheries, "Oversight of the Great Lakes Program and Its Applicability to Other Regional Pro EPA hopes to follow the Guidance with a toxics grams"; March 24, 1994; Serial No. 103-98; U.S. Govern reduction program focused specifically on nonment Printing Office: Washington, DC, 1994. point sources, despite the current regulatory re (6) "Regulatory Impact Analysis of the Final Great Lakes Wa treat. In the meantime, active research, including an ter Quality Guidance"; U.S. Environmental Protection Agency: Washington, DC, 1995; EPA-820-B-95-011. EPA-sponsored mass balance study of Lake Michi gan scheduled to produce results within two years, continues to address the significance of point sources Rebecca Renner is a freelance science writer based in Williamsport, PA. versus diffuse sources of pollution. DRI/McGraw-
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