UNITED STATE
                              APRIL 29,  1977
                       Environmental Protection Agency
                       Office of International

                  APPENDIX I


             REPORT OF SUB-GROUP A

                 IN REVIEW OF


               APRIL  29,  1977
               U.S. Environmental Protection Agency
               Region V, Library
               230 South  Dearborn Street
               Chicago, Illinois  60604


This Appendix contains the Position Papers listed in the Table of

Contents of the Report of Sub-Group A and are reiterated here and

appear in the following order in the Appendix:

             Water Quality Objectives Work Group

             Surveillance Work Group

             Phosphorus Work Group

             Point Source Discharges Work Group

             Non-Point Sources Work Group

             Hazardous Substances Work Group

             Nuclear Wastes (Rad.cactivity) Work Group*

             Research Work Group

These Position Papers forn; the basis for the Sub-Group A Report,   Each

of the Papers were prepared independently by the Work Groups listed in

the Attachment to the main Report,  Tney are published in this separate

document for ease in reference since the main Report makes frequent

reference to these Papers.

As stated in the main Report,  these Position Papers reflect the separate

views of the Work Groups which may not necessarily be the views of Sub-

Group A as a whole.   In most cases any differing views are discussed in

the main Report.  However,  where written differences of views were expressed

within the Work Group, they have been included  following each Position Paper.

                    Minnesota  Pollution  Control Agency
                                                            April  27, 1977
SUBJECT:   Position Paper on Water Quality

   FROM:   Lovell E. Richie, Water Quality
          Task  Leader Sub-Group A

     TO:   George R. Alexander, Jr.,
          Chairman, Sub-Group A
          Great Lakes Water Quality  Review

Attached  is  the final Position Paper on  Water Quality.  This Paper  is the same
as the draft discussed at the Sub-Group  A meeting on April 15 because no comments
have been received.

As I indicated  in my memorandum transmitting the draft paper, I  also favor the
inclusion of the Water Quality Objectives as recommended by the  Water Quality
Board as  was proposed in the draft report of Sub-Group A.                      i

It was a  pleasure to participate in  this Review.

Lovell E.  Richie

                 1935 West County Road B2, Rosevillc, Minnesota 55113
         Regional Offices • Duluth/Brainerd / Fergus Falls/ Marshall / Rochester/Roseville
                             Equal Opportunity Lmpioyer

                          Water Quality


The Great Lakes Water Quality Agreement is a recognition and an

expression of determination by the Government of the United States

and the Government of Canada to restore and enhance the water

quality of the Great Lakes System.

The Governments in their wisdom have defined the Great Lakes System

to mean "all of the streams, rivers, lakes and other bodies of water

that are within the drainage basin of the St. Lawrence River...."

Article I  (d) .

The Governments further expressed their conviction that...."The

best means to achieve improved water quality in the Great Lakes

System is through a system of common objectives, the development

and implementation of cooperation programs and other measures,

and the assignments of special responsibilities and functions to

the International Joint Commission."

With that purpose and policy in mind, the Governments agreed to

undertake a cooperative program.

The Agreement having been in existence now for five years, brings

us an opportunity and obligation to review what has been accom-

plished under the Agreemenr and to suggest changes that might

improve its content and thereby better accomplish its primary

goal of restoration and enhancement of water quality.


Great success has been achieved institutionally whereby the

International Joint Commission  (IJC), under Article VI, has

performed its role well in reporting to governments on present

conditions, status of programs, and has tendered advice to govern-

ments .

This has been accomplished by means of annual reports prepared

for the IJC by the Great Lakes Water Quality Board and from those

reports from IJC has prepared reports to governments.  The attention

given to the Water Quality Board by federal, state and provincial

agencies, and the dedication of various jurisdictions to the work

of IJC, the Board and the various work groups and committees is

admirable, and the participants are to be commended.

Special reports have been prepared under the auspices of IJC on

Lakes Huron and Superior, pollution from land use will be addressed

in a report presently in preparation and recommendations have been

offered on specific problems noted by the Water Quality Board.

Considerable time has been spent by the Water Quality Board and

IJC on refined objectives for water quality as envisaged in the

Agreement.  The Board has taken the position that water quality

objectives should protect the most sensitive use and most such

objectives are based on scientific evidence relating to biologi-

cal effects.

While the need for numerical objectives  (or in the U.S., criteria

for standards) of water quality has been well established, the

purpose  for which such numbers are used under the Agreement has

not been of much value.

Considerable time has been devoted to discussion and creation of

an array of "pigeon holes" such as mixing zones, zones of influ-

ence, source control zones, areas of non-compliance, biological

sensitive areas, environmental value mapping, near-shore zones,

open-water zones, etc.

Whether intentional or not, this has lead to a diversion from the

real issues and the essence of the program in the United States,

i.e., the implementation and enforcement of policy.  The real

issues should be:  what requirements are imposed by the parties

and jurisdictions to control the addition of pollutants;	

how are they enforced and how effective have such programs been.

The latter question, i.e., how effective have such programs been,

should not be a judgement call by jurisdiction, but rather by

complete disclosure of all discharges;  whether or not they

have a legally enforceable permit; whether or not they have

legally enforceable effluent standards, whether or not they have

legally enforceable construction schedules to attain compliance;

whether they are at present in compliance and if not, when they

will be.

In order to make any such comparison meaningful, there must be  an

agreed upon minimum treatment requirement that incorporates an

effluent quality standard.  This is the heart and soul of the U.S.

program and comparisons of progress against any lesser requirements

should be rejected.

The U.S. can take very little pride in the delays that have been

encountered in several major projects under the U.S. system, but

on the other hand, it should be noted that what has been criti-

cized are the time delays and never has it been the quality or

requirements of the basic program.

What has been disheartening is that we have allowed a comparison

to be made of the relative effectiveness of the U.S. and Canadian

programs using general water quality "objectives" of open water

and leaving it up to the jurisdictions to decide if their pro-

grams will meet such general objectives.

That was about where the U.S. program stood in the period 1965-1972

under the 1965 Federal Water Quality Act, which mandated a national

water quality standard program.  Public Law 92-500 changed that and

the program now relies on effluent standards and best treatment

technology.  That program is assured under a rigid permitting pro-

gram shared by the state and federal government.

It is against this program that the U.S. has judged its progress

and not against the Water Quality Agreement, since there currently

exists very little if any direct evidence that would allow compari-

son of existing programs against Water Quality Objectives of the

Agreement.  Even if there were, one could escape the whole issue

by classifying such areas as a mixing zone or zone of influence

or some other term and such comparisons then become nothing more

than a game of semantics.

What is a fair treatment requirement on one side of the lakes

should be fair for the other as well, and whether that turns out

to be the U.S. minimum treatment requirements  (secondary,BPT, BAT)

or something different, the important point is that an agreed upon

minimum effluent requirement is needed in order to make any mean-

ingful comparison of the effectiveness of control programs which

can be the only measure of joint progress under the Agreement.

There is strong disagreement on this question between the U.S. and

Canadian members of the Water Quality Board who make up the essence

of the control programs from all jurisdictions and it will not be an

easy item to negotiate into the Agreement.

If, however, this one change were made to add a minimum effluent

requirement into the Agreement, it would accomplish more from the

viewpoint of control of pollution than has all other activity to

date under the Agreement and allow for meaningful review of progress.

Certainly there has been much accomplished under the Agreement in

terms of studies, surveillance, reporting of existing water quality

and, for what it's worth under present constraints, remedial pro-

grams, but until we are prepared to agree to hard and fast controls

in the form of effluent standards, we have not committed anybody ho

anything other than the business of more study and an exercise of

comparing apples and oranges.

One test of the value of the Agreement would be to ask,  "what have

we done differently because of the Agreement that we would not

have done anyway." The answer is clearly that we have conducted

several worthwhile studies of the system, we have sharpened our

surveillance, refined our interagency and interjurisdictional com-
munications, proposed refined water quality objectives, based upon
joint scientific evidence all of which are valuable accomplishments
and perhaps the best we could expect from a first cut at a very
complex problem.

The Agreement has not, however, changed in any significant way, the
control programs in the U.S. which does not mean that its intent
and purposes have been ignored.  To the contrary, the U.S. program
is now guided by PL 92-500, which became operative after the Agree-
ment was signed and long after it was first envisaged.

PL 92-500 and its attendant requirements in the judgement of the
U.S. participants is adequate without exception to meet the terms
of the Agreement.  If that is not true, we are aware of no instance
where Canada has pointed out its inadequacy.

The single area where Canada has been critical of the U.S., and
justifiably so, is in the U.S. failure to keep major pollution
control works construction on its own self-imposed schedule.  It
is a legitimate and worthwhile role of the parties to review and
criticize each other, but until there is a comparable program of
legally enforceable formal minimum treatment in Canada and pre-
ferably a joint commitment under the Agreement, such criticism under
the Agreement, however, is improper.  It then becomes simply a criti-
cism of an  internal U.S. program based only on U.S. law and not on
any international commitment.

                               — 7 —
The Agreement can be modified to incorporate provisions for minimum

treatment requirement or effluent standards by modifying:

Article III as follows:


1.  The specific water quality objectives and minimum treatment

requirements for the feeuRdasy waters of the Great Lakes System

set forth in Annex 1 are adopted.

2.  The minimum treatment requirements and specific water quality

objectives may be modified and additional specific water quality

objectives for the boundary waters of the Great Lakes System or

for particular sections thereof may be adopted by the Parties in

accordance with the provisions of Articles IX and XII of this


3.  The minimum treatment requirements and the specific water

quality objectives adopted pursuant to this Article represent

the minimum effort of treatment and the minimum desired levels of
water quality in the beuHdasy waters of the Great Lakes System and

are not intended to preclude the establishment of more stringent

requirements .

4.  Notwithstanding the adoption of minimum treatment requirements

    specific water quality objectives, all reasonable and practi-
cable measures shall be taken to maintain the levels of w

quality existing at the date of entry into force of this Aqreenent

in those areas of the beandary waters of the Great Lakes System

where such water quality is better than that prescribed by the

       exceed the specific water quality objectives.

5.  In areas designated by the appropriate jurisdictions as having

outstanding natural resource value and which have existing water

quality better than that prescribed by_ the specific water quality

objectives that water quality should be maintained or enhanced.

Annex 1^ as follows:


1.  (a) through  (h) remains the same

Add a new paragraph #2 as follows:

2.  To accomplish these objectives, the parties shall require

municipal sources to provide a_ minimum level of treatment which

shall produce an effluent of no more than

                  _3£ mg/1     B0d_5

                  ^0. mg/1     TSS

                  200/100 milliliters fecal coliform
                           (seasonal depending on use)

                   _! mg/1     total phos

Where such treatment is inadequate to protect water quality

standards or to meet the objectives of this Agreement additional

treatment will be required.

To  accomplish these objectives the parties shall require industrial

sources to provide a_ minimum level of treatment that shall produce

an  effluent consistent with the best practicable technology for that


Where such treatment is inadequate to protect water quality standards

or  to meet the  objectives of this Agreement additional  treatment will

be  required.

Flow augmentation  should not be used in  lieu of adequate treatment.

Article V as follows:


1. remains the same

(a) first paragraph remains the same

(i) construction and operation in all municipalities  having  sewer

    systems of secondary waste treatment  facilities providing

    levels of treatment consistent with the achievement ef the

    watesf qaaiity objectives,-taking inte aeeeant the-effects

    ef waste fifem ethejf sendees? those specified in Annex !_._

(ii) remains the same

(iii) remains the same

(iv) remains the same

(v)  remains the same

(b) first paragraph remains the same

(i) establishment of waste treatment or control requirements for

    all industrial plants discharging waste into the  Great Lakes

    System, to provide levels of treatment that incorporate  the

    best practicable technology, ea? reduction ef inputs ef sab-

    stanees and effects consistent with the achievement ef the

    effects ef waste fj?em ethes seujfces;

(ii) remains the same

(iii) remains the same

(iv)  remains the same

(v) remains the same

(vi) remains the same

The remainder of Article V is unchanged.

                                     Region V
SUBJECT:   Review Paper - Surveillance
                                                    DATE:  April 25, 1977
Chris Timm
Director, S§A Division '

R. J. Schneider
Great Lakes Coordinator

Attached is the review paper for surveillance including proposed language
for Article V § X of the Agreement.   Please circulate this to all the
other work Groups and participants.

As Stated
              G. Alexander
              W. Wilford
              W. McCracken
              R. Grim
              T. Saylor
 EPA Form 132
                          REVIEW PAPER - SURVEILLANCE
I.  Introduction
            The existing Agreement mandates the following specific surveillance
    requirements to both Parties.
         Article V,l/a),(v).   "monitoring surveillance and enforcement activities
         necessary to ensure compliance with (control of pollution from municipal
         Article V, (b) ,(•"!).  "monitoring, surveillance and enforcement activities
         necessar>' to ensure compliance with (control of pollution from industrial
         Article' V, (c),(v).   "...establishment of a coordinated system for surveil-
         lance and enforcement of regualtions dealing with the abatement and control
         of pollution from shipping activitlss."
         Article VI, 1.(a),   "collection, analysis end dissemination of data....re-
         lating to the quality of the boundary waters. '
         Annex 1, Item 4.   "Sampling Data.    The Parties agree that the determination
         of compliance with specific objectives shall be based on statistically
         valid sampling  data."
         Annex 2, Item 10.     ttMprdLtoring.   The Parties.,w**.  shall continue tojaanitor
         the extent of eutrophication in the Great Lakes system and the progress made
         in reducing or  preventing it."
         Annex 2, Item 11.     "Submission of Information.   The IJC will be given in-
         formation at least  annually....concerning
                 a)  Total reduction in gross inputs of phosphorus achieved as a result
                     of  the  progress implemented..."
    but does not call for an internationally coordinated progian nor is it adequate
    for assessment of fish stocks or the iapacts of atmospheric sources or toxic
                                      -  1  -

         The present status of surveillance activities under the Great Lakes Water
     Quality Agreement  (Agreement)  are accurately summarized in the August 27, 1976
     letter from William Bullard, Secretary, U. S.  Section, IJC to Mr. Vine, U.S.
     Department of State and in the Fourth Annual Report on Great Lakes Water  *
     Qoality presented  to the U. S. and Canadian governments by the IJC on September
     16,  1976.   Copies  of both are attached.
II   Jurisdictional Program Status
     a.   Canadian  Programs
             Overall,the Canadians had a larger surveillance program than the U.S.
        until 1977 in all  areas  - water quality, fish stock assessment, etc.  The
        1977 programs are  in balance  and indications are that the Canadian Govern-
        ment has reduced the Ft  1978  level of funding for surveillance, especially
        for the nearshore programs  which are already underfunded on  both sides.   The
        Canadian program for evaluation of the effects of toxic substances on fish
        is larger  in that more  fish  are collected and analyzed, especially on Lake
        Ontario, but its scientific basis and  long term objectives are poorly defined.
     b.  U. S. Programs
                 The U.S.  EPA programs  are  judged to be barely adequate with re-
         spect to main lake programs, both  in terms of field and lab capabilities.
         Fish stock assessment programs of  the  States and the U.S.Fish and Wildlife
         Service (as coordinated by the Great Lakes Fisheries Commission) have
         grown and improved greatly in the  past years; however, stock assessment
         programs still do not adequately address the major species in all of the
         Great Lakes.  Surveillance of contaminants in fish stocks and evaluations of
         the potential effects of contaminants  and other stresses on fish by the F§WS,
         EPA and the States, are generally  considered inadequate and will remain so
         without increased Federal funding.
       * Fourth Annual  Report  of the IJC  on  Great Lakes Water  Quality
         included  as  Attachment 1  of Sub-Group A  Report

            The state programs which cover the nearshore areas are  all  ir/acleq1.", ie
       due to the low priority for state funds and a  lack of Federal funds
       Tributary and point source monitoring ^re judged to be adequate  at prcserrc.
       Since  the Federal Water Pollution Cj'f.trol Act, Sec. 106 water pollution
       control grants do not allocate extra funds or priority for support of
       the Agreement it is unrealistic  to attempt to use normal Sec. 106 funding
       improve the Great Lakes surveillance program.  The need is for a specific
       section of the  FAfPCA th&t sets  forth an annual appropriation to suppon:
       all activities including surveillance that are necessary for the Gicc i
       Lakes Water Quality Agreement.

Ill    Great  Lakes  Water Quality Agreement
           Articles  V and VI  and Annexes 1,  2,  5,  and 6 of the Agreement adequately
       identifies most of the  surveillance programs  required to assess  the
       of the Great Lakes  except those mentioned in  I  above.   The aajor
       is that the  present agreement  does not contain  any requirements  for  a
       minimum program level of effort or resources  for surveillance.   Theieforj. .
       it is  recommended that  articles that endorse  the  general  surveillance
       plan as outlined in Appendix B to the  1975 WQB  report be added to Article
       V of the Agreement.
            It is  further recommended that  a new section (c) be added to Article X
       of the revised Agreement to stipulate  the minimum level of funding that  vnii
       be provided annually for surveillance  activities.  Unless the resource needs
       for surveillance are specifically addressed in amendments to both the Agree-
       ment and the FWPCA, we will continue to suffer  from fragmented  funding  levels
       that play havoc with long term planning and staffing by both Federal and State

IV.   Recommended Additions

    l.(j) Surveillance.  Notwithstanding the surveillance requirements stated
       above, a coordinated, bilateral program that will meet the following
         (i)   Objective Violations

              Surveillance to detect violations of water quality objectives
              for parameters with numerical limits.

         (ii)  Trends
              Surveillance to determine water quality trends for the purpose

              of evaluating compliance with the non-degradation requirement
              and determining long-term effects of remedial programs.

        (iii)  Cause and Effect

              Surveillance, to describe and quantify cause (loads)  and effect
              (water quality) relationships to understand how the Great Lakes
              physical, biological and chemical system operates. Together
              with mathematical modeling,  this forms the basis for  determining
              whole lake response to remedial programs, the need for new re-
              medial programs such as the  phosphorus control program, alter-
              ing or establishing new water quality objectives, and a means
              to detect new and emerging problems.

    As a minimum the program will include  sufficient sample collection, analysis
    and evaluation including quality assurance to allow assessments of the

        (iv)   INPUTS   including tributaries, points sources, atmosphere, and
                       connecting channels

        (v)    WHOLE LAKE  including nearshore areas such as harbors and embay-
                       ments, general shoreline, and cladophora growth areas;
                       main lake, fish contaminants, and wildlife contaminants.

        (vi)   OUTFLOWS including connecting channels, water intakes and outlets.

                                ARTICLE  X

2.  The Parties conroit themselves  to  seek:
    (c) Appropriation of at least  S year advance funding of the surveillance
        program stipulated in Article v i.[j) above beginning with  FY 1978.
        The minimm funding levels to be requested will be  $9,800,000 per
        annum for the USA and  $6,100,000 per annum for Canada.  The funding
        level will be reviewed  and adjusted as needed annually.

                                           August 27, 1976 !
                                                             'DIR.'   & (l^
 Mr. Richard D. Vine
 Deputy Assistant Secretary of
  State for Canadian Affairs
 Departirent of State
 Washington, D. C.  20520

 Dear Mr. Vine

     The International  Joint Corliss ion wishes  to  brine  to  the attention
 or the Govarnments the urgent need  to provide  adequate  funding  for
 water quality surveillance in the Great Lakes.

     Each year since the signing  of  the Agreement,  the Consnisslon, on
 tne advice of the Water Quality  Board, has  informed  the Governments
 that it cou.d not report adequately  on progress,  or  lack of it
 toward acnleving  the goals of the Agreement since  existing
 surveillance  programs  were inadequate.   The following are some of
 the reasons:

     -   the lack of sampling  in nearshore areas, particularly
        problem areas;

     -   the lack of systematic  quality  control programs in the
        eleven  jurisdictions  concerned  in the Great Lakes Basin;

     - •  the non-coirparability of data and the absence of sampling
        data that  is  statistically valid;

     -   the lack of adequate  staffing at all levels to earn-- out
       water quality assessment;

     -   the lack of specific objectives for many water pollutants; and

     -  the variable conditions, unpredictable natural processes
       and vast size of the Great Lakes System.

    On July 21, 1976, at its Annual  Meeting on  Great Lakes  Water Quality
the Coranssion s principal advisor,  the Great Lakes Water Quality Board
presented an International Surveillance Program for the  Great  La£e«-


..hich in tie view of the Board and  the  Coirtnission represents the
rin-inum effort the Parties should consider  in  fulfilling their most
import^' obligation for surveillance under  the 1972 Great Lakes Water
Quality Agreement.   The following table summarizes the funds required
•for this pro gram during each of the next ten years.

                  (Millions of 197S D^^r-,  per Year)

                          Present        Additional         Total
                       Expenditure:     ;;c'qui regents    Requirements
     UNITED STATES              4.2              5.6              9.8

     CANADA                     4.3              1.9              6.2

         TOTAL                  8.5              7.5             16.0

         The surveillance program described in the  enclosed  report, Chapt?r 4
     Appendix B of the Great Lakes Water Quality Board's  1975  Fourth Annual
     Report, if fully funded and implemented,  will  provide the data and
     information needed for the assessment .r  Great Lakes water quality,
     progress towards achievement of thi or;».,ctives of the 1972 Agreement,
         the need for new or revised remedial  programs  to ensure that  this
        uable resource will be adequately protected for the  full use and
     enjoyment by the citizens cf both countries.   Tne costs for the 1975
     proposal have increased over those of the 1974 proposal due to
     (1) a more coirnrc^rnsive assessment of the ongoing programs and,
     (2) a more finite estimate of the detailed components of  the refined
     and upgraded 1975 proposal.

         In view of the Importance of the Great L.?Kes  as  an  interndtiondl
     water resource, rc.T;prising about 80" of tne .'iorth American supply of
     fresh surface waters, and the fact that over $7 billion are currently
     being expended to restore and protect the quality of this resource,
     the importance of an adequate internationally  coordinated surveillance
     program tc monitor the quality of the lakes cannot be overstated.

         Tne Ccii-jission in its 1974 Third Annual Report to Governments
     recoiwendeo the adoption of an integrated binational basin wide
     surveillance program and presented preliminary cost  estimates which
     did not include those for the monitoring of persistent  toxic
     contaminants in fish.

         The Canadian response to the Commission's  recommendat"1ion stated
     that Canada and Ontario will continue to support  an  IJC cdfrdinated
     surveillance program and that additionally both government? have
     instituted a coordinated program of monitoring persistent contaminants
        owmercial fishery stocks.

      *Xot attached.   Available upon request  from  the  International
       Joint  Commission.                                  •>
                                                         « • J


    The Co~niis:.ion  is gratified by the Canadian response and requests
 r-at funds for  :he  ten year detailed surveillance program be made
 v-liable at the projected leva! on an ongoing basis.

    The Co-nr:iis3ion  has net received a response from the United States
*j its surveillance recommendations contained in the Third Annual
Report.  The Commission urges the United States Federal and State
Governments to  increase the level of present expenditures to meet the
coordinated surveillance program requirements and to corrmit to the ten
year program funds  to ensure that both levels of government meet the
obligations of  this activity of the Agreement.

    The Coi-.i.-'ission also urges the Parties to ensure that fut-jre fiscal
programs provide ongoing funds at the level proposed, for the
Agencies of Federal, State and Provincial Governments having
responsibility  for water quality surveillanc-3 and monitoring
activities in the Great Lakes.  The Commission further believes that
the level of expenditures proposed, an increase over the 1974
preliminary estimate, should meet the surveillance program.
Acquirements over the next ten years.

    A similar letter is being sent to the Secretary of State for
External Affairs by the Secretary of the Canadian Section of the
                                   William A. Bullard
                                   Secretary, U. S. .Section
cc:  D. Charce
     Mr, Fitrhugn Green
         Ken OaCley
     Mr. G. Alexander



SUBJECT:  Position Paper on Phosphorus

   FROM:  Nelson Thomas
         Phosphorus Work Group Leader

     TO:  George R. Alexander, Jr.
         Chairman, Sub-Group A

         Attached is the subject Review Paper including a proposed revised Annex  2

         to the Great Lakes Water Quality Agreement.

E PA For,,, 1 320 4 iRcv 3 76)


The phosphorus control program in the present Agreement for the Great
Lakes has four basic objectives:

     a.  Restoration of year-round aerobic conditions in the bottom
         waters of the central basin of Lake Erie;

     b.  Reduction in present levels of algal growth in Lake Erie;

     c.  Reduction in present levels of algal growth in Lake Ontario,
         including the International Section of the St. Lawrence River;

     d.  Stabilization of Lake Superior and Lake Huron in their present
         oligotrophic state.

To meet the objectives there are three parts of the phosphorus- control

     a)  Construction and operation of municipal waste treatment facil-
         ities to achieve 1 mg/1 in plants in excess of 1 mg d,

     b)  Regulation of phosphorus inputs from industrial dischargers to
         the maximum practical amount, and

     c)  Control of phosphorus inputs from animal husbandry operations.

In addition, programs could include the elimination of phosphorus from

A schedule of expected phosphorus reductions was prepared based on the
above programs.


     Three problems now exist with the control of phosphorus section of
the agreement.  These include the inability of the countries to achieve
the desired reductions in loading, and the general philosophy under which
eutrophication was to be controlled.  Loading reductions were projected
on what was believed attainable through current phosphorus control tech-
nology, rather than what loads are required to meet the objectives.
Finally, in the agreement it is not possible to determine how the load
reductions were to be achieved on a jurisdictional basis.

     Recent studies by the Corp of Engineers indicate that a 1 mg/1 efflu-
ent requirement on municipal inputs to Lake Erie will not be sufficient
to restore desired water quality conditions to Lake Erie.  EPA, through
one of its grants, has developed a phytoplankton-dissolved oxygen model

of Lake Erie.  Currently, this model  is being used  to  estimate the load
reduction required to maintain dissolved oxygen  in  the Hypolimnion of
Lake Erie.   If phosphorus reductions  greater than can  be  obtained from
municipal and industrial control are  required, then information on con-
trol from non-point sources will be required.

     The control of eutrophication ir. the Agreement is based  entirely on
phosphorus loadings.  Experience with t./.,. pr.^.-jent agreement has indicated
a problem with protecting the lakes by r-jlyir.g on loadings alone.   Two
large problems arise with the approver, :.v; first is the  problem of esti-
mating tributary and non-point souro'  ...^uu.3.  There have been significant
errors in estimating these at the present tiir;e.  The second problem arises
from the form of the phosphorus being inputed.   Only certain  forms are
available for phytoplankton growth and these are contained in different
proportions  in the various _nputs.  Reduction in one type of  input by a
specified amount might not Lave the same effect  as  reduction  in another
type of input by the same amount.  A  combination of loadings,  lake phos-
phorus and chlorophyll content for both present  and expected  conditions
would provide for sounder management  of the Great Lakes.  The  use  of three
measurements -will permit evaluation of compliance to agreed upon water
quality improvements.

     In all  the lakes, except for l.a.^.. .v :. ;igan, sufficient data exists to
permit the inclusion of all three type3 ci d'ita.  For  Lake Michigan,  it
will be possible to include values  :o:r ;;~osp:\Grus and  chlorophyll  concen-
trations, however, phosphorus loadir~ information can  only be  estimated at
this time.   The target load provided  in Appendix I  of  the Agreement cannot
be evaluated at this time.  StucLes are new in progress that will  provide
for this analysis, which should be complete in two  to  three years.

The use of a detergent phosphorus ban as a means of controlling  phosphorus
inputs to the Great Lakes should oe reevaluatea based  on  two conditions
that now exist that did not in 1972.

     1.  The main reason for not including a virtual phosphorus  detergent
         ban in the U.S. part of the Agreement was  the risk to public  health.
         There now exists many phosphate substitutes for both phosphorus  and
         NTA if a determination is made that the latter is still not accept-

     2.  Phosphorus reductions that were thought achievable from municipal
         waste treatments are not being realized.  Many operational prob-
         lems make it probable that it will  be many years before satisfac-
         tory phosphorus reduction can be  maintained at all waste  treatment
         plants.   Removal of phosphorus before they reach the treatment
         plants would reduce the phosphorus  loading from the treatment plants
         with unsatisfactory removal.


     It now appears that the basic objectives  of the phosphorus  control pro-
gram are still valid and are achievable.   However,  phosphorus control may
have to include other types  of inputs.  The  basic objectives still address
the key issues of eutrophication and would either restore or protect the

lakes from further degradation.

     One of the major problems in preparing eutrophication remedial pro-
grams"^ in estimating the inputs of phosphorus to the Great Lakes.  In
drawing up the agreement, phosphorus loadings were based on land area.
Only direct input measurements were made for Lake Ontario.  During the
last five years, direct measurements of phosphorus inputs have been made
for all of the lakes, except Lake Michigan.

     There appears to be substantial variations in the loads presented in
the annex, as compared to recently published loads through the International
Joint Commission.  The Upper Lakes Reference group and Corps of Engineers
have prepared detailed phosphorus input data.  These data have been used
in mathematical simulations and appear to be more reasonable than some of
the. 1972 estimates.  The estimates of tributary inputs appears to have been
one of the areas where the largest difference appears.

     The reductions called for through the Agreement are not being realized;
therefore, the residual loads are much larger than called for through the
Agreement.  The phosphorus reductions specified in the Agreement are of a
larger magnitude than can be obtained with present technology.  Many of the
larger industrial sources v/ere under control before the 1972 agreement went
into effect.   The only major reductions that could be achieved were from
municipal sources.  As indicated in the 1975 Remedial Programs Subcommittee
report, many of the major municipalities were not meeting the 1 mg/1 total
phosphorus (?) effluent requirement.  Either the amount of phosphorus reduc-
.tions was overestimated or the amount of phosphorus being discharged has
increased.  Even with all the treatment plants that have been completed in
the Lake Erie drainage, the quantity of phosphorus in Lake Erie has not
decreased and even may be on the increase.

     In recent studies on Lake Ontario and Lake Erie,  it appears that the
target loads are too high to meet objectives a)  and c).   The 1975 Surveil-
lance Subcommittee report presented an analysis of the phosphorus loadings
to Lake Ontario.   In addition, the report presented results on recent mathe-
matical modeling of Lake Ontario phytoplankton.   Results of these efforts
will be used in formulating the total phosphorus (?)  loading limit for Lakes
Erie and Ontario.                              ' ' •
 Note:  The  rest  of this  Position  Paper appears  as  the proposed revised
       Annex 2.


               19,  1977                  REGION  V

SUBJECT. p0int  source Discharges  Work  Group  Recommendations

  FROM: Dale s>  Bryson,  Chairman

    TO: Point  Source Discharges  Work  G,'u,

        I  transmitted to you  ihe nain to,',  or  our  task  group  report.   When  we
        last met,  we agreed  I would  fc.ir j.': some  recommendations  at  the appro-
        priate time.

        On April  15,  Mr. Alexander  held a full Sub-Group  A meeting to review
        the various  task group reports  and  recommendations.

        There  were nc adverse cooents  to eu^  task group  report.   For that
        meeting,  I developed  attachment I,  wnich were draft recommendations  of
        specific  language changes In  the Great Lakes Agreement.  There were
        some minor suggested  charges  in that -draft.  I  have made those changes
        already  and,  therefore,  attachment  1 reflects the final document as  will
        be submitted to  ths full  S'jb-Grr.'"  * ;nd negotiating  team.  The plan now
        calls  for  each task group repor:: •-„ oe submitted  in toto.   From there,
        the negotiating  team  will fasn:or, ";neir negotiating stance.   Therefore,
        the language and our  position car. DC accepted or  reviewed  as  a final

        If you have  any  questions on  zhe above, or violently  disagree with any
        of the recommendations,  please  let  me  know immediately.
                                           Dale S. Sryson


        cc:  R. Schneider
EPA Foim 1320 6 (Rcv. 3.74)

                                               ATTACHMENT  ONE

                               ARTICLE V
                      PROGRAMS AND OTHER MEASURES

1.  The achievement of the water quality objectives  will  only be
accomplished if appropriate pollution control  measures  are fully In-
stituted on all point and non-point sources of pollution  in the entire
Great Lakes Basin.  Pollution control programs and measures in both
Counties should be fully compatible in all  respects  including minimum
levels of treatment, maximum schedules of compliance,  breadth of pro-
gram implementation and public accountability.  These  pollution control
programs and other measures shall be implemented and completed in the
shortest possible time but no later that July 1, 1983.  (This date will be
negotiated.)  The programs and measures shall  include  the following:
    a)  Pollution from Municipal Sources.  Programs  for the abate-
    ment and control of discharges of municipal sewage into the
    Great Lakes System including:
        (i)  construction and operation in all municipalities
             having sewer systems of waste treatment facilities
             providing at least secondary treatment  defined
             numerically elsewhere, including phosphorus  re-
             moval with additional treatment if water  quality
             standards so requires; (Language from another task
             group was found to be more acceptable and will be
             used including the specific definition  of seaway
        (1i)  provision of financial resources to assist prompt
             construction of needed facilities;

                             - 2 -
  (Hi)  establishment of requirements for construction and
         operating  standards for facilities;
   (iv)  measures to find practical solutions for reducing
         pollution from overflows of combined storm and
         sanitary sewers;
    (v)  requirements for the control of the discharge of
         toxic pollutants into the Great Lakes Basin through
         comprehensive programs;
   (vi)  embodiment of all pollution abatement requirements
         including schedules, monitoring and effluent re-
         strictions in a single document that is periodically
         reviewed and placed before the public;
  (vii)  monitoring and surveillance activities  necessary to
         ensure compliance with the foregoing programs and
 (viii)  establishment of effective enforcement  programs  to
         ensure the above pollution abatement requirements
         are fully met.
b)  Pollution from Industrial Sources.   Programs for the  abatement
and control  of pollution from industrial sources,  including:
    (i)  establishment of waste treatment requirements for
         all industrial plants discharging waste into the
         waters of the Great Lakes Basin, to provide levels
         of  treatment at least as restrictive as best avail-
         able control technology economically achievable;

                           -  3 -
 (11)  establishment of  pre-treatment  requirements  for
       all  Industrial  plants  discharging waste  into pub-
       Hcally owned treatment works;
(111)  requirements  for  the control  of the discharge of
       toxic pollutants  into  the  Great Lakes  Basin  through
       comprehensive programs;
 (iv)  embodiment of all  pollution abatement  requirements
       including schedules, monitoring and effluent restric-
       tions in a single document that is periodically re-
       viewed and placed before the  public;
  (v)  establishment of  effective enforcement programs to
       ensure the above  pollution abatement requirements
       are fully met.

SUBJECT:  Position Paper on Non-Point Sources
   FROM:  Ralph G. Christensen, Leader
         Non-Point Sources Work Group

     TO:  George R. Alexander, Jr.
         Chairman, Sub-Group A

         Attached is the subject review paper which includes  appropriate  review
         comments and additional review comments which are attached  for Senior
         Review Group consideration.  The Department of Commerce, the Non-Point
         Source Branch of the EPA, and the Pennsylvania Department of Environmental
         Conservation indicated no comment on the Non-Point Source Work Group
         Position Paper.

EPA For,,, 1320-6 (Rev 3 76)

         League  of Women  Voters
  FROM i
Ralph G. Christensen, Leader
Non-point Sources Work Group
Office of Great Lakes Coordinator
USEPA Region V
230 S. Dearborn St.
Chicago, 111. 60604

League of Women Voters Lake Erie Basin Committee
Janet B. Hutchison for Mary Lewis, Coordinator
Edith Chase, past coordinator
                                      1224 Quilliams Road
                                      Cleveland Heights,  OH
                                      April 21, 197?
  SUBJECTi  Review Papert Non-point Sources
  Page 5«  Please define 'hydr ©modification. '

  Page 6-9«  Shouldn't the Coastal Zone Management Act be included in the listing of
  U.S. legislation?  Implementation and funding of these laws vary; in some states
  little has been done.  What do you see as  the role of the IJC?

  Page 12 i  We agree that consideration only of structural solutions to urban
  drainage problems is inadequate and that management approaches should be emphasized.

  Page 13 »  We support the expansion of Article V (l) (d).

  Page 14 i  A strong education program is essential for public officials and citizens
  as well as landowners.
  The final report of the PLUARG study, due in July 19?8,  should be valuable.  It is
  important to place greater emphasis on controlling nonpoint source pollution in
  order to meet water quality objectives.  Equity demands  that both point sources and
  nonpoint sources carry their fair share of the burden of cleanup,  Funding of
  nonstructural solutions to stormwater runoff and other  nonpoint source problems
  should be considered.

  Thank you for this opportunity to submit comments.
   cc Alexander
     MacDonald - LWVDS
     Strang - LMILG
     Carlson - LWVO

                                               Stephen  M. Yaksich
                                               U.S.  Corps of Engineers
              Article V l.(d)  for Non-Point Sourdes Work Group
The following measures for the abatement:  and control  of  pollution from
agricultural, forestry and other land use activities,  could  be  included in
Article V 1. (d) of the Great Lakes Water  Quality Agreement.

     1.  The appropriate state agency (i.e.  Cooperative  Extension Service
of the State University) shall review soil test  results  and  recommended
fertilizer applicationrates zo determine  if  the  recommended  fertilizer application
rates can be decreased.  In the 1960 's an annual-plus-soil buildup
recommendation was made for many soils in the Great Lakes basin.   Data now
                                     -  -'J^/r. on ^snv of these soils.
      2.  Daily monitoring  stations for sediment, chemistry and flow should
 be established at  key  agricultural basins.  These stations should be
 maintained  a minimum of  20 years.

      3.  Funding and staffing of L;.ise agencies which will be involved
 in the identification  and  control of noa-point sources of pollution should
 begin immediately.

      4.  Land use  decisions which will have a large impact on Great Lakes
 should he reviewed (made)  by the International Joint Commission.

      5.  Deeding of large  traits of underwater land for landfill operations
 should be reviewed (made)  by the International Joint Commission.

      6.  A  series  of demonstration programs (educational and implementation)
 should be made in  select watersheds in the Great Lakes basins.  These sites
 •shall be so situated so visits can be easily made to one of them by everyone
 in the Great Lakes basin.

                     DEPARTMENT OF THE ARMY
                          536 SOUTH CLARK STREET
                          CHICAGO, ILLINOIS  60605
6 April 1977
TO:       Ralph Christensen, EPA, Chairman, Non-Point Sources
          Work Group

FRCM:     Jan Rasgus, Corps of Engineers

SUBJECT:  Conments on Section V-l-d, Great Lakes Water Quality
1.  It might be more inclusive (but perhaps not specific enough) to
change the title of paragraph 5(d) to "Pollution from Non-Point Sources."
Reference should also be made in this paragraph to the control of non-
point pollution from sources such as road construction, mining and urban
development.  For example:

     (d) Pollution from Non-Point Sources.  Measures for the abatement
and control of pollution from agriculture, forestry practices, road
construction, mining, urban development and other land use activities.

2.  Suggest that the following be added to item (iv):

     "...forestry and other land use activities including encouragement
to appropriate agencies to adopt regulations governing the implementation
of Best Management Practices."

3.  If this Section (V-l-d) is expanded to address non-point pollution
from urban run-off, another item (v) may have to be added.  It could be
similar to item (iv).

4.  Suggest changing the wording in item (i) from "pest control products"
to "pesticides."

5.  The Corps of Engineers will probably not be directly impacted by
most of the proposed measures, but they could indirectly benefit.  In
particular, water quality could be improved at or near Corps of Engineers'

                    NON-POINT SOURCE POLLUTION
                            WORK GROUP
                           REVIEW PAPER

          In 1972 the Governments of the United States and Canada entered
into an Agreement on the Great Lakes to develop and implement cooperative
programs and measures to restore and enhance the water quality of the Great
Lakes System.  Article IX of the U.S./Canada Water Quality Agreement requires
that, "The Parties shall conduct a comprehensive review of the operation and
effectiveness of this Agreement during the fifth year after its coming into

          One of the important pollution impacts on the water quality of
the lakes comes from agriculture, forestry, and other land use activities
within the Great Lakes Basin.  The purpose of this paper is to review the
U.S./Canada Water Quality Agreement to see if the goals, objectives, terms,
and deadlines of Article V, 1, (d) and the Pollution from Land Use Activities
Reference have been met.  Measures for the abatement and control of non-point
source pollution from agriculture, forestry and other land use activities
include animal husbandry operations, construction, disposal of liquid and
solid wastes, hazardous materials, nutrients, sediment and in general all
rural and urban drainage.


          During the preparation of the Water Quality Agreement it was
recognized that pollution from non-point sources was a contributing factor
to the water quality of the lakes and its associated tributary streams.   In
order to better understand the extent of the non-point source pollution  problem
a text of reference was proposed to the International Joint Commission to study
pollution in the Great Lakes System from agriculture, forestry and other land
use activities and was then written and incorporated into the U.S./Canada
Agreement.  This reference was developed as a result of Article VI of the
Agreement wherein the two Governments requested the IJC to conduct a study
of pollution of the boundary waters of the Great Lakes System from agriculture,
forestry, and other land use activities.  Article IV of the Boundary Water
Treaty of 1909 provides that the boundary waters and waters flowing across the
boundary shall not be polluted on either side to the injury of health and
property on the other side, and is also referenced in the Great Lakes Water
Quality Agreement.

          The IJC is requested to enquire into and report to the two Governments
upon the following questions:

               "(1)   Are the boundary waters of the Great Lakes System
                     being polluted by land drainage (including ground and
                     surface runoff and sediments) from agriculture, forestry,
                     urban and industrial land development,  recreational and
                     park land development, utility and transportation systems
                     and natural sources?

                (2)  If the answer to the foregoing question is in the
                     affirmative,  to what extent,  by what cause, and in
                     what localities is the pollution taking place?

                (3)  If the Commission should find that pollution of the
                     character just referred to is taking place, what
                     remedial measures would, in its judgment,  be most
                     practicable and what would be the probable cost

The Commission is requested to consider the adequacy of existing programs and
control measures, and the need for improvements thereto, relating to:

                     (a)  inputs of nutrients, pest control products,
                          sediment, and other pollutants from the sources
                          referred to above;

                     (b)  land use;

                     Cc)  land fills, land dumping, and deep well disposal

                     (d)  confined livestock feeding operations and other animal
                          husbandry operations; and

                     (e)  pollution from other agricultural, forestry and land
                          use sources.

          In carrying out its dtudy the Commission should identify deficiencies
in technology and recommend actions for their correction.

          The Commission should submit its report  and recommendations to the
two Governments as soon as possible and should submit reports from time to time
on the progress of its investigation."

          The Pollution from Land Use Activities Reference Group (PLUARG) is the
vehicle for the Commission to carry out these studies.  PLUARG described four
major tasks to accomplish its charge:

               "(1)  Assess problems, management programs and research and
                     to attempt to set priorities in relation to the best
                     information now available on the effects of land use
                     activities on water quality in boundary waters of the
                     Great Lakes System.

                (2)  Inventory of land use and land use practices, with
                     emphasis on certain trends and projections to 1980 and,
                     if possible to 2020.

                (3)  Intensive studies of a small number of representative
                     watersheds, selected and conducted to permit some extra-
                     polation of data to the entire Great Lakes Basin and to
                     relate contamination of water quality, which may be found

                     at river mouths on the Great Lakes, to specific land
                     uses and practices.

                (4)  Diagnosis or degree of impairment of water quality in
                     the Great Lakes, including assessment of concentrations
                     of contaminants of concern in sediments, fish and other
                     aquatic resource^."

          The schedule for the final reporting of the PLUARG studies to the two
governments is July 1978.  This repr-i will provide the best information that
the Federal, Provincial, State and the academic community can provide.  Rec-
ommendations for control measures and remedial programs will be presented.

Ill  Analysis of Article V 1. (d)

          Article V 1. (d) states that the two Governments shall develop and
implement programs and other measures directed toward the achievement of the
water quality objectives as soon as practicable in accordance with legislation
in the two countries.

          Following the signing of ~\^ .. . 5 ./Canada Agreement the U.S. Congress
enacted PL 92-500 - the Federal Water Pc.Iution Control Act Amendments of 1972.
Major programs under this Act have be'-r. utilized as the chief mechanism of
meeting the goals of the Agreement,  t':. 92-500 preserves the constitutional
rights of the States, expands the federal  role in water pollution control, in-
creased the level and amount of funding for construction of municipal sewage
treatment facilities, elevated water quality management planning to a higher
level of significance, and opened new means of public participation.   The
objective of the Act is to "restore and maintain the chemical,  physical,  and
biological integrity of the Nation's waters".

          The Act provides frr achieving its goals and objectives in phases,
with accompanying requirements and deadlines.   Ultimately, all  point source
controls are directed toward achieving & national goal of the elimination of
the discharge of pollutants ly 19S5   The  Act  also requires the development of
comprehensive programs for pi-eventing,  reducing and eliminating pollution.

          Section 208 provides for the development of comprehensive plans by
the States and area wide water quality management agencies to control pollution
from all point and non-point sources.

                1.    EPA has issued guidance to these agencies  with regard
                     to planr.ing, program  development, public participation
                     activities,  outputs expected, management agencies,
                     regulatory programs,  best Management practices for non-
                     pcim; sources such as agriculture, silviculture, mining,
                     urban runoff, and hydromodification.   (Hydromodification
                     means any changes  in  natural water courses or drainage
                     brought about by the  activities of people.)

                2.    Seven Statewide and 25 area wide agencies  have assumed
                     water pollution control responsibilities  in the Great
                     Lakes Basin.

                3.    Grant awards  to State and local area wide  water quality
                     management agencies in the Great Lakes Basin  total  approx-
                     imately $30,000,000.

                4.    Plans are being prepared by all of the  agencies to  prevent
                     or control the runoff of non-point sources of pollution
                     through the use of best management practices and to name
                     management agencies to implement programs.

                5.    EPA is conducting National Conferences  for 208 agencies
                     to present information on regulatory programs and best
                     management practices  for control of non-point sources.
                     In addition to Section 208 of PL 92-500,  Sections 104,
                     105, 106, 108(a), 108(d), 201,  303, 304,  and 305 are all
                     supportive to the development of non-point source pollution
                     control guidelines and control  measures.

          Other U.S. legislation enacted since April of 1972 to support  the
Agreement water quality objectives and address non-point sources of pollution

The Federal Insecticide, Fungicide, and Rodenticide Act - as amended by  PL
94-140, November 1975.

          Objectives of this Act are to provide for the effective and safe
use of pesticides.   It:

                1.    Requires Federal registration of all pesticides sold
                     or distributed interstate as well as intrastate;

                2.    Prohibits the use of any pesticide in a manner not
                     prescribed on the label;

                3.    Restricts the use of certain very hazardous pesticides
                     to certified  applicators.

Funds totaling $71,468,000 were authorized for carrying out  provisions of PL
94_140 up to March 31, 1977.

Safe Drinking Water Act  (PL 93-523)

          A.   This Act became law in December of 1974, it provides for:

               1.    Establishment of primary regulations for  the protection
                     of public health;

               2.    Establishment of secondary regulations  relating to  the
                     taste, odor and appearance of drinking water;

               3.    Measures to protect underground drinking  water sources;

                 4.   Research and studies regarding health, economic and
                      technological problems of drinking water supplies.
                      Specifically required are studies of viruses in
                      drinking water and contamination by cancer-causing

                 5.   A survey of the quality and availability of rural
                      water supplies; and etc.

           B.   The Act provides for protection of underground sources of
                drinking water by means of a regulatory program.   Primary
                responsibility for carrying out these requirements falls
                to the States.  If they fail, EPA will prescribe  control
                programs for them.

           C.   Proposed regulations have been issued for State underground
                inspection control programs and for grants to aid programs
                for underground water source protection at State, Interstate
                and local level.

           D.   A manual of water well construction practices to  protect  ground
                water resources from pollution has been developed, by contract,
                and provided to State and local agencies.

Authorization of appropriations totaling $156 million for fiscal  years 1975,  1976,
and 1977 are associated with the Safe Drinking Water Act.

Toxic Substances Control Act (PL 94-469)

           A.   This Act becarae law on October of 1976.  It provides for  the
                development of adequate data on the effect of chemical substances
                and mixtures on health and the environment and the regulation of
                those substances which prevent an unreasonable risk of injury to
                the health and environment.

           B,   A task force has been organized in EPA to develop procedures
                for implementing the Act.

           C.   Regulations for the labeling and disposal  of Polychlorinated
                Biphenyls (PC3's)  are being prepared.

           D.   Regulations have been issued regarding:

                 1.  General provisions and inventory reporting requirements
                     for toxic substances.

                 2.  Clarification of basic definitions of toxic  substances.

Resources Conservation and Recovery Act of 1976  (PL 94-580)

           This Act became law in October, 1976.  It was built on the foundation
of the Solid Waste Disposal Act of 1965 and the  Resource Recovery Act of 1970.

           The Act statutorily establishes the Office of Solid Waste within EPA
to guide the implementation of the law and establishes a Federal/State/local
government partnership to share the implementation.  The major thrusts of the
efforts that will be required by this partnership are:

                 1.     Land  protection through regulation and control  of wastes
                       and waste disposal  operations.

                 2.     Regulations  and control of the  hazardous waste  stream
                       "cradle to grave."

                 3.     Improvements in all aspects of  waste management at the
                       State,  regional and local  levels.

                 4.     Reduction of the waste stream through increased resources
                       recovery and waste  reduction efforts.

                 5.     Broad public education programs with rapid dissemination
                       of all types of solid waste management information materials.

                 6.     Broad public participation in the development and improve-
                       ment  of solid waste management  throughout  the Nation.

           A review of other federal agency non-point  source activity shows  that
several U.S.  Department of Agriculture agencies provide educational  information,
research,  technical  services and cost-sharing programs for farmers and landowners  to
control soil  erosion.   The agencies of USDA are:

                 (1)   Agricultural  Research Service (ARS)  --Research

                 (2)   Soil Conservation Service (SCS)--Technical  assistance

                 (3)   Forest Service (FS)  --Forested lands

                 (4)   Agricultural  Stabilization and Conservation Service

                      (ASCS)—cost-sharing on practices

                 (5)   Economic Research Service (ERS)--Economic and sociologic

                      costs  and benefits associated NFS pollution control.

           The U.S.  Soil Conservation Service (SCS)  gives technical  assistance  to
fanners and other citizens for the application of soil  conservation  practices.
Many of these practices reduce pollution to streams  and lakes  by preventing  the
loss of soil, nutrients, and pesticides from farm fields.  Assistance is  provided
through 190 local county soil and water conservation districts in the United States
portion of the Great Lakes basin.  Progress of the application of pollution  reducing
soil and water conservation practices may be demonstrated by the following table
which shows the current status of these practices:

                          GREAT LAKES BASIN
                           UNITED STATES
Practice Item
Contour Farming
Crop Residue Management
Field Windbreak
Grade Stabiliz. Structure
Minimum Tillage
Pasture § Hayland Planting
Streambank Protection
Terrace, basin
Terrace, gradient
Terrace, level
Terrace, parallel
Total terraces
Tree Planting
Grassed waterway or Outlet
Land Adequately Protected
Cropland to Grassland
Cropland to Woodland
Ag. Waste Mgt. System

           The U.S. Agricultural Stabilization and Conservation Service (ASCS),
through the Agricultural Conservation Program, provides cost-sharing assistance  to
farmers to help offset the application costs of conservation practices, many of
which directly benefit water quality.  Since the signing of the Great Lakes Water
Quality Agreement ASCS has provided $18,000,000 of cost-sharing assistance for
these practices, in the Basin.

            The Flood Disaster Protection Act of 1973,  administered by the
Housing and Urban Development Administration (HUD),  the Coastal Zone Management
Act (PL 92-583), administered by the National Oceanic and Atmospheric Administ-
ration (NOAA), and the U.S. Army Corps of Engineers  (COE), Lake Erie Wastewater
Management Study will all impact on the non-point source pollution control measures.

           A summary of legislative authority for Canada dealing with water quality
measures and controls is contained in Appendix-C to the 1975 Annual Report on Great
Lakes Water Quality.  Rather than list Canadian water quality legislation in this
review we will reference the 1975 Great Lakes Water Quality Appendix-C Report.

           A comparison of non-point sources of controls on agriculture is difficult
since Canada does not have an Agency equivalent to the U.S. Soil Conservation Service
to manage a sediment control program,  Canada has no system for tracking land use
practices as does USDA-SCS.  Canada does not have the technical assistance program
available at the local level of government to work one on one with the farmer or
landowner in planning and applying conservation practices.

           In Ontario there are Conservancy Districts which have responsibility  for
flood control programs and provide for some sediment and pollutant reduction.

           The general analysis of the U.S. legislation for non-point source pbllution
control shows that there are sufficient programs and controls when fully implemented
to meet the U.S./Canada Water Quality Agreement objectives.  Canada does not have
comparable programs for implementing non-point source pollution control measures.

IV  What Needs to be Done

           The Agreement, as related to PLUARG's charges, requires no change.  How-
ever, for the benefit of future references relating to the Great Lakes, the Agree-
ment should"be more specific regarding water quality criteria according to water
use.  Consideration should be given to continuing the pilot watershed monitoring
work after PLUARG has completed its work so that effectiveness of remedial measures
may be evaluated and refinements made as required.  If there is to be an acceleration
of remedial measures applied to land in the Great Lakes Basin to reduce pollution
levels in the lakes, the appropriate action agencies will require additional funding
and personnel resources.

           Legislative changes at the State level and the U.S. will be required.
Hopefully Section 208 Planning will provide the impetus for these changes.  PLUARG
activities and Section 108(a) projects will also provide  inputs for guiding these

           Rural non-point source pollution control measures might best be
implemented by strengthening local area management institutions.  These institu-
tions should have the ability to educate the landowner in the use of Best Management
Practices, provide technical back-up on practices which will best achieve water
quality objectives, provide cost-sharing incentives and have enforcement support
to accomplish water quality objectives where education and cost-sharing incentives
fail to achieve desired objectives.

           Urban drainage contains a variety of wastes.  Combined sewer overflows
have been addressed to some degree on the U.S.  side through the municipal con-
struction grant program where funds have been available for conveyance and treatment
approachs.  Canada has also provided some support to several municipalities for
addressing combined sewer overflows through a conveyance and treatment approach.
The U.S. has accepted the premise that an approach to the problem which looks only
on the structurally intensive solutions which are inherent in conveyance/treatment
systems is inadequate.  Application of Best Management Practices (BMP) for both
source and conveyance/treatment offer opportunities for ultimate solutions which
indicate the following advantages:

                 (1)  Address pollutant reduction at the source

                 (2)  Provide for opportunities to develop maximum cost effectiveness

                 (3)  Introduce opportunities for greater reliability

                      Involve less intensive allocation of resources

                 C5)  Emphasize optimum use of existing systems

                 (6)  Lead to more facility in solutions

                 (7)  Tend to avoid the development of secondary problems

           Information collected from d,S.  demonstration projects on combined
and storm water overflow control measures strongly suggests that U.S. policy,  when
fully developed for control of the problem, will include non-point source consid-
erations in combination with point source considerations.

           It is suggested that changes be made in Article V 1,(d)  of the Water
Quality Agreement.   The proposed changes are shown in italics as follows:

                      (d)  Pollution from^Agricultural, Forestry, and Other Land
                           Use Activities,   Measures for the abatement and control
                           of" oollution from a-gric-ulture, forestry practices,  road
                           oonstimction,  mining,  urban development,  urban drainage,
                           and other land use activities, including:

                      (i)  Measures for the control of pesticides with a view  to
                           limiting inputs  into the Great Lakes System, including
                           regulations to ensure that pest control  products judged
                           to have long term deleterious effects on the quality of
                           wafir or its biotic  components shall be used only as
                           authorized by the responsible regulatory agencies and
                           that pest control products shall not be applied directly
                           to water except  in accordance with the requirements of
                           the responsible  regulatory agencies;

                     (ii)  Measures for the abatement and control of pollution from
                           animal husbandry operations, including encouragement to
                           appropriate regulatory- agencies to adopt regulations gov-
                           erning site selection and disposal of liquid and solid
                           wastes in order  to minimize the loss of pollutants  to
                           receiving waters;

                   (iii)  Measures governing the disposal of solid wastes and
                          contributing to the achievement of the water quality
                          objectives, including encouragement to appropriate
                          regulatory agencies to ensure proper location of land
                          fill and land dumping sites and regulations governing
                          the disposal on land of hazardous polluting substances.

                    (iv)  Advisory programs and measures that serve to abate and
                          control inputs of nutrients, sediments, and other
                          pollutants into receiving waters from agriculture,
                          forestry practices, road construction, mining,  urban
                          development, urban drainage, and other land use activities
                          including encouragement to appropriate agencies to adopt
                          and implement Best Management Practices,
V   Summary of Conclusions and Recommended Actions.

To summarize:

                 PLUARG reference needs no change.
           (2)   It is suggested that Article V, l.(d) be changed as proposed in
                 the text of this Position Paper.

           (3)   Monitoring of PLUARG pilot watersheds should be continued beyond
                 July 1978 to evaluate an up-date recommendations in PLUARG final
                 report and also evaluate the recommended remedial measures.

           (4)   Consider a strong education and technical assistance program
                 for landowners on non-point source pollution controls and best
                 management practices for preserving water quality in streams
                 and lakes.

           (5)   Consider a cost-sharing program for best management practices
                 implementation for water quality improvement.

           (6)   Consider enforcement alternatives should education, technical
                 assistance and cost-sharing programs for implementing best
                 management practices for achieving water quality fail.

           (7)   Urban stormwater runoff (drainage) needs to be brought into
                 focus as a major source of pollution during wet weather and
                 control measures should be developed for its management.

           (8)   Non-point source pollution controls should be implemented at
                 the local level of government.

           (9)   A progress reporting system for tracking implementation of Best
                 Management Practices should be established for both the U.S. and
                 Canada .

          (10)   A program for long term maintenance of Best Management Practices
                 should be developed whereby changes in landowners will not destroy
                 established control measures.

   3ATE:   April 28, 1977

SUBJECT:   Hazardous Substances Work Group Review
   FROM:   Karl E. Bremer
          Toxic Substances Coordinator

     TO:   Robert Schneider
          Great Lakes Coordinator
          I have attached the final draft of  the Hazardous  Substances Work Group

          All comments received from my work  group have  been incorporated.
EPA Form 1320-4 IRcv 3-76)



     During the past decade more and more emphasis has been placed on the

area of hazardous substances.  This has been acknowledged by the recent

enactment of the Environmental Contaminants Act in Canada and the imple-

mentation of the Toxic Substances Control Act in the U.S.

     In 1972 a Great Lakes Water Quality Agreement was entered into by

Canada and the United States, providing for greater cooperation and team-

work between the two countries in cleaning up and maintaining the Great

Lakes Basin.

     As a result of the 1972 Agreement, huge sums of money have been

granted to control discharges affecting the water quality of the Great

Lakes.  Both countries have been and currently are directing increasing

resources towards surveillance and monitoring activities to determine

what impacts and changes result from these remedial programs.  The main

focus of activity within the framework of the Water Quality Agreement has

been one of abatement and now monitoring by both sides, a priority that

is as it should be.

     The general concept in the Agreement provides for agreement on specific

water quality objectives for the boundary waters, with each country committed

to developing and implementing the programs.

     While the high hopes of 1972 for quick results in cleaning up existing

pollution and preventing further deterioration of water quality have not all

been realized and there have been public expressions of disappointment, much

has been achieved and the stage is set for continued progress towards the

goals of the Agreement.  Both countries are committed to, and have major

programs underway for, municipal sewage treatment and phosphorus removal

facilities.  Both short-term and long-term problems lie ahead.  For now and

the forseeable future, the International Joint Commission (IJC) believes the

basis of the Agreement should continue to be the fundamental principles of

non-degradation and enhancement of water quality.

     The most serious problem we face in terms of the Great Lakes and their

use is the accumulation of toxic substances.  Heavy metals and persistent

organic contaminants may well be the most serious problem governments face

in ensuring future beneficial uses of the Great Lakes.  They pose serious

threats to water quality, the fishery, human health, and the ecosystem in

general.  Too little is known of the identity of these substances, their

sources, amounts present, characteristic forms and behavior, and their

effects on human health and the environment.  Control and monitoring programs

(to establish baseline data) are imperative, but research is urgently required

to permit both the early identification of such substances and the establish-

ment of appropriate water quality objectives.

     The Commission recommends that the Governments make it a matter of the

highest priority to undertake jointly, with the assistance of the Great

Lakes Water Quality Board and the Great Lakes Research Advisory Board, a

special program to assess the problem of toxic contaminants in the Great

Lakes with a view to developing and implementing programs for their control.

It is especially urgent that early warning mechanisms be developed to

identify new chemical substances that might present risks to health and the

environment if discharged into the waters of the Great Lakes Basin.

Statement of Problems

Spills of Hazardous Substances

     During 1972-1975 a number of spill contingency plans were developed to

deal with spills of major proportions to the Great Lakes.  In general, these

contingency plans emphasize the administrative structure necessary for the

countermeasure response to major spills.  They do not include detailed

response procedures for dealing effectively with oils and, in particular,

hazardous substances.  Spill contingency plans rely on the ingenuity and

experience of the responding agency for the effective countermeasures to a

given disaster.  The Joint Canada-United States Marine Pollution Contingency

Plan for Spills of Oil and Other Noxious Substances is one contingency plan.

     At this time, development of response procedures is needed to deal

safely and effectively with spills of chemicals.

Delay in Adoption of Annex 9

     Annex 9 was prepared pursuant to Article V  (1)(i) of the Agreement,

which calls for the development of an Annex that identifies hazardous

polluting substances.  An introduction  to Annex  9 and a part of the Annex

are attached.  The list in Appendix I of Annex 9 was developed to facilitate

the following:

     1.  Prompt joint spill reporting and response  action  (Annex 8) and

     2.  Development of compatible regulations or programs for the
         prevention of discharges of such substances from vessels
          (Annex 3), from shipping activities  (Annex 5),  from dredge
         spoil disposal  (Annex  6), and  from onshore-offshore facilities
          (Annex 7).

     Appendix  II  of Annex 9 was prepared as a guide for  indicating other

potentially hazardous polluting substances.   Provision was made  that

substances could be added to this list if such substances were considered

a potential hazard (based on data on toxicity, persistence, mutagenicity,


     The final technical draft of Annex 9 has been reviewed by the U.S. and

Canada, but has not been adopted.  The U.S. cannot take action on this

Annex until the proposed regulation on designation of hazardous substances

under Section 311 of the Federal Water Pollution Control Act Amendments of

1972 are final.

Toxic Contaminants

     During the past five years, the area of toxic contaminants has been

approached by a number of sub-groups within the IJC.   Contaminants of major

concern in the Great Lakes have included organic compounds, specifically

polychlorinated biphenyls, dieldrin, Mirex, and toxaphene and other sub-

stances such as phthalates, petroleum-related hydrocarbons (polynuclear

aromatics), and heavy metals including arsenic, zinc, cadmium, mercury, and

lead.  Although no major effects on human health have been directly related

to any particular contaminantin Great Lakes fish or water, many contami-

nants have exceeded temporary tolerance levels for human consumption.

     The following problems have been associated with toxic contaminants

in the Great Lakes:

     1.  In setting Water Quality Objectives, the IJC has not made
         adequate use of public health specialists (in particular,
         those qualified experts in the field of environmental

     2.  Laboratories obtaining Great Lakes data on toxic substances
         have not used adequate standarization and/or quality control
         among laboratories;

     3.  The real significance of data obtained on toxic contaminants
         is often not known (quite often inferences have to be made);

     4.   Often the sources of toxic contaminants within the Great Lakes
         are unknown;

     5.   Data on the partitioning of toxic substances between air, water,
         sediment, fish, wildlife, and man is incomplete;

     6.   The prediction of future toxic substances accumulation in the
         Great Lakes has not been approached by any current IJC programs;

     7.   Without the addition of Annex 9 to the Agreement, the area of
         hazardous substances is not adequately addressed in the Agreement,
         particularly with respect to definition and designation of
         hazardous substances;

     8.   Current IJC reports on toxic substances often state the problem
         but fail to put the data in proper perspective;

     9.   The ecological implications of exposure to toxic substances,
         particularly those that are highly persistent or induce
         pathological and behavior effects in man are not understood.

     1.   The IJC should consider the participation of environmental
         health agencies in further deliberations on toxic substances.
         It has been suggested by the Implementation Committee that
         environmental health agencies in both countries should
         consider establishing required action levels for current
         toxic substances of concern and other toxic substances that
         may be identified in the future;

     2.   Further surveillance and monitoring work associated with IJC
         programs should incorporate improved data quality control
         programs and, when appropriate, standard methods in quanti-
         fication and identification of toxic substances;

     3.   Research should be intensified to determine fate and effects
         (human and ecological) of toxic substances.  Other data from
         the chemical and medical literature should also be integrated;

     4.   Using current legislation, including the Environmental Contami-
         nants Act and the Toxic Substances Control Act, a current
         inventory should be established on the types and amounts of
         chemicals manufactured, discharged and used in the Great Lakes
         Basin, their transport, fate, and ultimate disposal;

     5.   Further research should be conducted on partitioning and exchange
         of toxic substances between air, water, sediment, fish and

     6.  An "early warning system" should be  established to predict future
         toxic substance problems.  The recommendation of the Implementa-
         tion Committee adopted at the February  1-2,  1977, meeting is a
         possible approach;

     7.  Annex 9 of the Agreement should be adopted;

     8.  The collection, analysis, and dissemination  of past and current
         data on sources and environmental distribution of persistent
         toxic substances should be performed for  the Great Lakes Basin.
         This analysis should be put in perspective,  using available
         health effects data and related toxicology data;

     9.  A joint program for disposal of hazardous materials should be
         developed to insure that these materials  such as pesticides,
         contaminated petroleum products, contaminated sludge and dredge
         spoils are properly transported and  disposed.
Note:   Annex 9  as  recommended for  adoption is  included in  the
        Sub-Group  A Report.

SUBJECT: Five-Year Review
FROM:    William A. Mills, Ph.D.  ,/
Enrico Conte, Environmental Surveillance Coordinator, USNPC - Mr. Conte
approved the recommendations made in the report and proposed that
additional data on strontium-90 concentrations in the Lakes be included.
Unfortunately, we did not have enough time to include these data in the
final report.  Mr. Conte had a number of other suggestions to improve
the discussion of NRG authority and programs vis-a-vis EPA.  These
suggestions were accommodated except for a request that the EPA ERAMS
monitoring program be discussed more fully.

Paul Giardina, Radiation Representative, USEPA, Region II - Mr. Giardina
suggested that the section on the NSF fuel reprocessing site include a
discussion of current problems at the NFS low-level burial area.  The
final report has been amended to include this information.

Mr. Tom Cashman, Director Bureau of Radiation, New York State Department
of Environmental Conservation - Mr. Cashman had several comments concerning
the scope of monitoring, MRS, and tht. quality assurance program.  He agreed
with the recommendations made in the report.

Peter Tedeschi, Air and Hazardous Materials Division, USEPA, Region V -
Mr. Tedeschi had several comments which indicated where the language in
the final report could be clarified.  All of his helpful comments have
been accommodated.

Ms. Sandra Gardebring, Executive Director, Minnesota Pollution Control
Agency - Ms. Gardebring commented that she believed from the statement
on page U of the draft concerning a prohibition of electric power
generation on the Great Lakes was too strong and that the Minnesota
position did not necessarily require a prohibition but rather more
stringent controls on liquid effluent pathways.  However, she was unable
to ascertain how the aerial deposition of radioactive materials into the
Lakes could be prevented,  Ms. Gardebring suggested also that the report
should mention the burial problems at the NSF facility, (see comments on
NFS above by Paul Giardina).  She felt the statement that the radiological
quality is expected to improve was a misstatement in that it could
improve faster if there were no radiation discharges into the Lakes.  She
also suggested that the first sentence in the discussion on PL 92-500
was misleading in that it did not indicate the narrow scope of EPA permit
controls.  The sentence has been redrafted.

Ms. Margaret Reilly, Chief, Division of Reactor Review, Harrisburg,
Pennsylvania - Ms. Reilly had no suggestions and agreed with the recommen-
dations made in the report.

Mr. Earl Richards, Ohio EPA - Mr. Richards suggested that the words
"prevent harmful effects" rather than "minimizing health effects" be used
in the discussion of the current objective.  The wording has been changed
as suggested.  He stated that the Ohio EPA approved of the report and its

CMDR Corbett, Ninth Coast Guard District, Cleveland, Ohio - had no
comments and approved the report.

Mr. Wilczynski, Office of Environmental Affairs, Department of Commerce -
They have no comments.

Dr. Nat Barr, U.S. Energy Research and Development Administration - ERDA
objected to including as a recommendation the adoption of the refined
objectives.  They consider this inappropriate in view of the fact that
the objectives are now out for public comments.   Written comments will
be sent as soon as possible.  ERDA also objected to the short turnaround

See additional comments from Mr. Walter G.  Belter,  U.S.  Energy Research
and Development Administration, attached.

                                 UNITED STATES
                              WASHINGTON, D.C. 20545

                                     April 29, 1977
Mr. George R. Alexander
Chairman, Sub-Group A
Great Lakes Water Quality
  Agreement Review
U.S. Environmental Protection
  Agency  (Region V)
230 South Dearborn Street
Chicago, Illinois  60604

Dear George:

Reference is made to your memorandum of April 20 requesting comments from
the Federal Advisory Group on the final draft of Sub-Group A Report.  As
I discussed with you on the phone on April 27, it appears to ERDA staff that
continuing, major differences between U.S. and Canadian approaches to water
pollution control will provide continuing inequitable effluent requirements,
especially for industry in the two countries.  In fact, it seems that water
quality objectives as adopted under the agreement will have the force and
effect in the U.S. of legally enforceable Water Quality Standards (under
92-500), whereas they would be little more than "unenforceable criteria"
in one Canadian province (Ontario).

Another shortcoming—when the objectives do become Water Quality Standards
under the FWPCA (92-500), then all U.S. tributary streams would have to
have the same water quality as the Great Lakes, and all EPA or State permits
for discharges to the Great Lakes System would have to contain limitations
that assure compliance with the "standards."  However, in Canada the
"unenforceable criteria" apply only to the Lakes themselves and any "program
orders" have been admittedly ineffective with industry.  It certainly appears
that the objectives could, therefore, result in a substantially greater
effluent treatment, control and monitoring (and economic) burden on the
U.S. discharges only.  The Sub-Group A Report should address this impact.

In view of the above, it seems totally inappropriate for the U.S. to encourage
the adoption of objectives without a clear agreement that they will have the
same force and effect on both sides of the international boundary.  This
should not only be stated in an Article of the agreement, but we believe
should be supported by enabling Canadian legislation before the agreement
becomes binding.  While you seemed to have faith in the Canadian govern-
mental system effectively implementing this point after the agreement is
renegotiated, it would appear to us that too much is at stake to leave this
point to chance.

George R. Alexander                - 2 -
April 29, 1977
Another related point is noted on page 8 under the "General Summary and
Recommendations."  One of the proposed changes to the agreement states
that "the principle of unenforceable objectives" must be replaced by a
recognition that objectives are, in effect, "standards."  If this was
accepted, it would reenforce our earlier concern regarding the refined
radioactivity objective.  In our previous discussions with EPA staff,
it was never indicated that this objective might be regarded as a Water
Quality Standard, enforceable under 92-500,  However, with this possible
change in the agreement being considered by the U.S., we believe that it
is all the more important to delay adoption of the refined radioactivity
objective until technical justification and cost/effectiveness studies
are completed.

We also note under Article III, Water Quality Objectives, that certain specific
objectives, when compared to the EPA Drinking Water Standards and the Quality
Criteria for Water, present some problems.  In some cases, the values given
are more restrictive than in either of the EPA documents; i.e., lead, mercury,
fluoride, and certain pesticides.  In other cases, they are higher and in
most cases the material presented is different enough to make meaningful
comparison or understanding very difficult.  Clarification or explanation
of these differences should be provided.

I hope that the above comments can be accommodated in the final Sub-Group A

                                   Walter G. Belter
                                   Assistant Director
                                     for Technology Liaison
                                   Division of Technology Overview

              REVIEW PAPER
             April 27, 1977

                              REVIEW PAPER



     A.  Agreement

         The Agreement between the United States and Canada on Great

Lakes Water Quality was signed and entered into force April 15, 1972.

This Agreement makes specific reference to radioactivity in the

following manner:

         Annex 1 - Specific Water Quality Objectives

             1.  Specific Objectives.  The specific water quality

objectives for the boundary waters of the Great Lakes System are as


                 (h)  Radioactivity.  Radioactivity should be kept at

the lowest practicable levels and in any event should be controlled to

prevent harmful effects on health.

             7.  Consultation.  The Parties agree to consult within one

year from the date of entry into force of the Agreement, for the purpose

of considering:

                 (b)  Refined objectives for radioactivity...; for

radioactivity the objective shall be considered in the light of the

recommendations of the International Commission on Radiation Protection.

         Relevant to radioactivity are, also, the following Annex 1


             3.  Nondegradation.   Notwithstanding the adoption of

specific water quality objectives, all reasonable and practicable

measures shall be taken in accordance with paragraph u of Article III of

the Agreement to maintain the levels of water quality existing at the

date-of-entry into force of the Agreement in those areas of the boundary

waters of the Great Lakes System where quantity of the water exceeds

specific water quality objectives.

             5.  Mixing Zones.  The responsible regulatory agencies may

designate restricted mixing zones in the vicinity of outfalls within

which the specific water quality objectives shall not apply.  Kixing

zones shall not be considered a substitute for adequate treatment or

control of discharges at their source.

     B.  Ad Hoc Radioactivity Advisory Group

         In accord with Annex 1 7(h) an ad hoc U.S./Canada Radioactivity

Advisory Group was established by the two Parties to consider refined

objectives for radioactivity.  The initial meeting of this Group was

held on April 12, 1973, followed by subsequent meetings and discussions.

Dr. Adrian H. Booth (Canada) and Dr. William A. Kills (U.S.) served as

Co-Chairmen for the development of the refined objectives.  U.S. members

of the Advisory Group were from the Nuclear Regulatory Commission

(earlier representing AEC), the Environmental Protection Agency, the

States of New York and Minnesota, and the Commonwealth of Pennsylvania.

The joint recommendations of the Advisory Group were submitted for

consideration by the separate Parties in late 1975.  A minority position

by Minnesota was included in the submission.

         The Minnesota position focused on the Annex I requirement

"...controlled to prevent harmful effects on health'1 therefore

advocating "...no additional discharge of radioactivity into the Great

Lakes."  By letter dated March 21, 1977, the Energy Research and

Development Administration notified EPA that it does not endorse the

refined radioactivity objectives.  ERDA's position is to focus solely on

the Annex language of "...radioactivity should be kept at the lowest

practicable level...."

         At present, the U.S. has not taken an official position on the

refined radioactivity objectives for the Agreement.  On April 5, 1977,

the Department of State published (42 F.R. 18171 - copy enclosed) the ad

hoc Advisory Group's report, including the Minnesota position, for

review and comment.   Comments are to be sent to EPA on or before June 1,


         Although no official position by the Canadian Government on the

recommendations for the refined objectives has been announced, there

appears to be no dissenting opinion.  Concerns expressed by some

segments of the Canadian Government on the inclusion of existing levels

of "fallout," mainly as strontium-90, in the dose limits have been

resolved.  The amount of strontium-90 in lake waters is decreasing and,

with time, this radionuclide will become a smaller contributor to the

dose received by users of the Great Lakes System.

         In developing the recommendations, the ad_ hoc Advisory Group

considered the relevant statements in the Agreement with respect to

keeping the levels as low as practicable, preventing any health impact,

the intent of nondegradation, and recommendations of ICRP.  Because of

the widespread acceptance of the scientific assumption that there is no

threshold for radiation damage, the prevention of any harmful effects on

health, in an absolute sense, would require zero discharge and no

deposition of any radioactivity into the Great Lakes.  This could mean

the prohibition in the Great Lakes Region of such benefits as the

generation of electric power by means of fossil or nuclear fuels and the

use of radioactivity in medical treatment and research.  For this reason

a zero discharge objective was viewed by the majority of the Advisory

Group as impractical and therefore a specific dose limit objective was

established.  This objective calls for control by specified actions at

defined dose levels so that radioactivity in the Lakes is as low as

reasonably achievable.

         The recommended objective for the general water quality in the

Great Lakes is that level of radioactivity which results in a whole-body

dose commitment not exceeding one millirem from the intake in any year

of waters outside the source control zone.  Source investigation and

corrective action if releases are not as low as reasonably achievable

are recommended for dose commitments between 1 and 5 millirem.  For dose

commitments greater than 5 millirem corrective action by the responsible

regulatory authorities is recommended.

     C.  Water Quality Board Radioactivity Subcommittee

         The Water Quality Board established a Radioactivity Work Group

in 1973 to review Objectives for Radioactivity in the Great Lakes, to

recommend any needed revisions, and to assist in the review and evalu-

ation of radioactivity monitoring data.  This working group was expanded

in 1975 to include Federal nuclear regulatory and radiological health

agencies, as well as Federal, State, and provincial environmental

agencies and made a permanent subcommittee to the Implementation

Committee of the Great Lakes Water Quality Board (WQB).

         Pending acceptance of refined objectives for radioactivity, the

subcommittee has concentrated on developing efficient monitoring

programs for the Great Lakes.  The terms of reference for this

subcommittee, approved by the WQB in March 1976 are:

         1.  Review radioactivity objectives and recommend necessary


         2.  Develop a radioactivity surveillance plan for both land

based and atmospheric inputs to be incorporated into the overall

surveillance planning.

         3.  Annually assess the surveillance data supplied by the

agencies carrying out the surveillance program, indicating the degree of

compliance with the radioactivity objective and any local trends

developing in radionuclide levels.

         4.  Advise on potential transboundary environmental effects of

the siting of nuclear facilities in the Great Lakes Basin.  Nuclear

facilities include, but are not limited to nuclear power stations.

         5.  Comment on public safety and health and the socio-economic

impact of nuclear development at the request of the Water Quality Board

and the Research Advisory Board.

         Current U.S. membership on the subcommittee includes represen-

tatives from U.S. EPA, NRC, New York, Minnesota, Illinois, Ohio, and

Pennsylvania.  Seven representatives, including the Chairman, Dr. R.W.

Durham, Environment Canada, are Canadian.

     D.  Scope of Five-Year Review

         The 5-year review was conducted by examining current sources of

radioactivity contributing to the Great Lakes System, current levels of

radioactivity, projection of future sources and levels, and the impact

of existing U.S. standards and regulations.  Some discussion is provided

relative to defining the responsibilities of the various Federal and

State agencies as it pertains to U.S. control of radioactivity in the

Great Lakes System.  In conducting this review heavy reliance has been

placed on information collected and generated by the IJC's Subcommittee

on Radioactivity and no attempt has been made to go beyond this source

in acquiring information from Canada.

         On the basis of this U.S. review, the Work Group has proposed

recommendations for consideration by Sub Group A of the Review Committee

addressing the Refined Objective, the IJC Radioactivity Subcommittee

role, and the extent of radioactivity surveillance programs in imple-

menting the Agreement.


     Present levels of radioactivity in the Great Lakes are due to three

kinds of sources:  1. fallout, 2. intentional discharge from nuclear

facilities, and 3. naturally-occurring radioactive materials.  The

current concentrations of man-made radionuclides are almost wholly from

weapons testing carried out in the period between 1950 and 1965.

However, recent atmospheric weapon tests, in the autumn of 1976,

indicate that atmospheric fallout is a continuing potential source of

contamination.  A smaller and more controllable source of man-made

radionuclides is liquid and atmospheric discharges from licensed nuclear

facilities.  Some of these facilities such as nuclear electric power

stations are strictly controlled, in the U.S. by the Nuclear Regulatory

Commission (NRC).  Others such as hospitals and research laboratories

discharge limited amounts of radioactivity via conventional sewage

systems.  Municipal waste treatment plants are not licensed dischargers

of radioactive materials and the impact of their discharges on the

radiological quality of lake waters has not been quantified, as yet.

     The largest U.S. licensed source of radioactivity discharge into

the Lakes has been the Nuclear Fuel Services fuel reprocessing plant on

Cattaraugus Creek at West Valley, New York.  Discharges from this plant

enter Lake Erie 25 miles away.  The facility closed in 1972, and its

decommission is being planned.  However, leakage from the low-level

burial area at the site has necessitated the controlled release of

tritium into Cattaraugus Creek.  Corrective action at the site is being


developed.  Provided the wastes stored at this plant are properly

contained, it should not be an important source of future contamination.

     A third source of radioactivity is not man-made but technical

enhanced levels of naturally-occurring radioactive material, such as

radium-226.  In their natural state, the Great Lakes are almost free of

radioactivity because of a favorable geology.  In Canada, a few rivers

flowing into the Lakes have been identified as containing an enhanced

radium content due to waste discharges from uranium mining operations.

No U.S. sources of natural radioactivity have been identified as yet.

     Eleven U.S. Nuclear Power Plants were discharging effluents into

the Great Lakes in 1976.  Table I lists the quantity of materials

discharged from each site.  From Table I it is seen that most of the

current U.S. plants are on Lake Michigan and that Lake Ontario is the

only other Lake receiving direct discharges.  Except for a single plant

on Lake Huron, Canadian nuclear power stations are concentrated or. Lake

Ontario.  This pattern is expected to continue until around 1S80 when

U.S. nuclear power plants sited on Lake Erie become operational.

                                Table I

               Liquid Discharges into the Great Lakes by
                   U.S. Nuclear Power Plants in 1976
Station              Location           Annual Aqueous Release in Curies
                                        Fission £ Activation   Tritium
Big Rock Point       Charlevoux Co, MI         0.77               2.4
Cook I               Benton Harbor, MI         0.26             190
Palisades            Covert Township, MI       0.005              9.0
Zion I and II        Zion, IL                  0.0*
Kewaunee             Carlton, WI               2.8              210
Point Beach I £ II   Monitowoc Co., WI         3.6              690
Fitzpatrick          Oswego, NY                6.0                U.2
Ginna                Ontario, NY               0.69             2^0
Nine Mile Pt.        Oswego, NY                2.2                2.5

*No liquid waste discharge.

REF: Draft Fifth Annual Report, Great Lakes Water Quality Board
     Radioactivity Subcommittee, April 1977.
     Table II provides a limited assessment of the radioactivity in Lake

waters near the discharge streams from nuclear power plants.  The data

is exceptionally incomplete.  However, it is believed that increased

monitoring and reporting requirements by the NRC (and Canadian

authorities) will increase the amount of data available in the future.

     It should be noted that Lake Superior has no nuclear facilities at

present, the levels in Table II indicating fallout contamination.  Lake

Michigan has the most nuclear facilities of any Great Lakes.  Only

tritium and strontium-90 from fallout have been quantifiable on the

basis of their average annual concentration.  On a short term basis,

cesium-137 and cesium-13U have been identified in the vicinity of

nuclear facilities.  On an annual basis these radionuclides are not


found at detection levels currently utilized.  Canadian nuclear

facilities discharge into Lake Huron.  No meaningful data on tritium,

the major Canadian effluent, is available for this Lake; nor is data in

the discharge area available for other radionuclides.

     Because the State of New York has an active surveillance program,

data for Lake Ontario is more complete.  However, these data are not for

samples taken within the one kilometer source control zone of the

discharging facilities.

     Currently, surveillance of the open waters of the Lakes is ir.inijr.al.

While numerous special studies have been performed as part of research

projects, periodic monitoring of rhe open Lake waters as part of a

planned surveillance program is not carried out by any governmental

agency.  Some information on near shore radioactivity is available from

the tritium data provided as part of the USEPA Environmental Radiation

Ambient Monitoring System (ERAMS).  The concentration of tritium in

Lakes Michigan, Erie, and Ontario since 1S72 is shown in Table III.

These measurements were not made using open lake waters but samples were

taken at distances greater than 1 kilometer from a discharge point so as

to exceed the maximum source control area specified in the draft refined

objectives.  Comparison with Table II indicates that the Lakes are

remarkably uniform in tritium content, an indication that fallout is a

chief source of radioactivity.

     Current levels of radioactivity in the Lakes are below the 50-year

dose commitment level in the draft Radioactivity Objective of 1 mrem,

                               -. 11
                              Table II
        Radioactivity Concentrations Near Nuclear Facilities

                                Average Annual Concentrations (pCi/1)
 Location                       Tritium      Cesium-137        Sr-90
Lake Superior
  1974                            	           .076
  1973                            	            	            0.53
Lake Michigan
  1974 Big Rock                   350            BDL             NA
  1974 Palisades                  300            BDL             NA
  1974 Cook                       300            BDL             NA
  1974 Zion                       370            BDL             NA
Lake Huron
  1974 Douglas Point            <1700 (BDL)     .059            0.77*
Lake Erie
  1974 near NFS outlet            320          <.07             0.93
Lake Ontario
  1974 Pickering                 1500           .07*             .87*
  1974 Ginna                      460           .06*            1.0*
BDL (Below Detection Limit)
NA (Not Available)

*Drinking water intake near nuclear facility.
Ref: Fourth Annual Report, Appendix D, Great Lakes Water Quality,
     WQB Radioactivity Subcommittee, June 1976.


                            Table  III

                Ambient Tritium Levels in Great Lakes
   Average Annual Concentration (pCi/1)"1"

1972      1973      1974      1975      1976

  South Haven

New York


  Two Creeks
 S 200 pCi/1

 BDL (Below Detection Limit)
 NA (Not Available)
REF:  1972-1974 Radiation Data and Reports, Reports of the Tritium
                Surveillance System, U.S. Environmental Protection
                Agency, Washington, D.C.

      1975-1976 Environmental Radiation Data, Quality Report on the
                Environmental Radiation Ambient Monitoring System,
                U.S. EPA, Eastern Environmental Radiation Facility,
                Montgomery, Alabama.


total body dose.*  Strontium-90 from weapons fallout, the only important

constituent, is not a source of total body exposure but rather bone

marrow dose for which the 50-year (TED-50) dose commitment limit is

likely to be between 5-10 millirem depending on final risk limits for

bone marrow irradiation now being considered by the ICRP.  Lake Ontario

has the highest Sr-90 concentration, about 0.9 pCi/1.  An annual intake

at this concentration would cause a TED-50 of 0.5 mrem.  It is expected

that Sr-90 in the Lakes will decrease with time as fallout activity is

removed from the water column by sedimentation and decay, as well as by

fresh water dilution.

     In 1976 EPA completed a study of projected radioactivity in Great

Lake Waters due to planned nuclear power operations, "Radionuclide

Transport in the Great Lakes," EPA 600/9-76-016.  According to the

results of this study, Lake Ontario will be the most highly contaminated

Lake and tritium and strontium-90 will be the major sources of dose, the

former predominating.  By the year 2050 it is estimated that the annual

dose from ingesting tritium in Lake waters will be about 0.2 mrad; from

strontium-90, about 0.005 mrem.  It is seen that the dose rate due to

strontium-90 from nuclear power facilities is much less than that due to

fallout and that the radiological quality of Lake waters is expected to

improve even though nuclear facilities are located on the Lakes.
^Permitted levels are in the range of 1 to 5 mrem provided that
discharges are as low as practicable.



     Since entering into force in April 1972, several standard and

regulatory actions have been taken by the U.S. Government which impact

directly on levels of radioactivity in the Great Lakes System.  All

actions taken have been itore restrictive in terms of radioactivity

emissions and upper limits on individual and population dose.  Thus

their impact has been to control radioactivity toward decreasing pollu-

tion of the Great Lakes System.

     A.  EPA

         1.  40 CFR 141

             Interim Primary Drinking Water Regulations (41 F.P. 28^02,

July 9, 1976).  The Agency promulgated the following maximum contaminant


              5 pCi/1    radium-226 plus radium-228.

             15 pCi/1    gross alpha particle activity (including

                         radium-226 but excluding radon and uranium).

             4 millirem/yr  average annual concentration of beta

                            particle and photon radioactivity from man-

                            made radionuclides.   Dose equivalent rate

                            applies to total body or any internal organ

                            and to the sum of radionuclides present in

                            drinking water.


         Application of the drinking water limits to the Great Lakes

System would meet the Agreement criteria of ICRP dose equivalent limits

but would not necessarily result in as low as reasonably achievable

doses.  The drinking water limits are, however, consistent with the

proposed refined objective when a determination has been made that

controllable sources discharging into the Great Lakes System have been

judged by the regulatory authorities to be as low as reasonably

achievable.  Only if the food intake (as well as drinking water) were a

significant source of radioactivity, would the proposed refined

objectives be more restrictive.

         2.  40 CFR 190

             Environmental Radiation Protection Standards for Nuclear

Power Operations (U2 F.R. 2858, January 13, 1977).  The Agency

promulgated these standards for normal operation of the uranium fuel

cycle, excluding mining, transportation, and waste disposal activities.

For planned releases the standard establishes 75 millirems annual dose

equivalent for thyroid, and 25 millirems annual dose equivalent for the

whole body and all other organs.  The standards also limit the discharge

of long-lived materials into the environment based on power generation,

including a limit of 0.5 millicuries per gigawatt year combined of

plutonium-239 and other alpha-emitting radionuclides with half-lives

greater than one year.

             These standards are not specified in terms of a single

pathway but rather for the total exposures to persons.  It is not

expected that the proposed refined objectives would be exceeded by the


actions controlled under these standards, since the primary pathway for

exposure from the fuel cycle is not by the ingestion of water.

Implementation of these standards would be by the U.S. Nuclear

Regulatory Commission.

         3.  FWPCA (PL 92-500, 10/18/72)

             Under this legislative authority, EPA can control the

discharge of naturally-occurring radioactivity into waters of the Great

Lakes System, as well as certain man-made radionuclides.   Under PL 92-

500 effluent guidelines for the phosphate industry have been proposed to

control their discharge of radioactive effluents.  This control is

obtained by maintaining a near neutral or basic pH for stored liquid

wastes so that radium is precipitated before discharge.  A decision by

the U.S. Supreme Court ruled out materials covered by the Atomic Energy

Act as being subject to the FWPCA permit program and EPA  has not

included radioactivity in its water quality criteria.

         4.  Ocean Dumping Act (40 F.R. 2462, 1/11/77)

             This Act administered by EPA prohibits the dumping of high-

level radioactive wastes in "oceans."  The Great Lakes System appears to

not be included by definition.  However, neither the U.S. or Canada

dispose of packaged radioactive wastes into the Great Lakes System and a

no dumping provision is a part of the Refined Objective for



     B.  NRC

         NRC in addition to regulating the nuclear industry under EPA's

Uranium Fuel Cycle Standards has also promulgated Appendix I (10 CFR 50,

40 F.R. 19439, 5/5/75) which has established design specifications for

light-water reactors so that the most likely exposed persons will not

receive more than 5-10 mrem annually from a single pathway.  This

regulation is based on reactors meeting the design criteria of being "as

low as reasonably achievable."

         NRC also has licensing responsibilities for certain radio-

nuclides covered under the Atomic Energy Act.  This includes the

licensing of radionuclides for use in hospitals, industry, and

educational institutions.  Such licensing is regulated to the limits

specified in 1C CFR 20 for maximum concentration of radioactivity in

discharges.  These limits are substantially higher than either the

limits in the U.S. Safe Drinking Water Act or the proposed Refined

Objectives and therefore would not be considered as the controlling

limits for the Great Lakes System.

     C.  ERDA

         ERDA has no regulatory responsibilities in the control of

radioactivity in the Great Lakes System.  Only in those instances of

Federal operations under their administration does ERDA have control

over the release of radioactive materials.  In those operations, of

which none discharge into the Great Lakes System, ERDA utilizes


10 CFR 20 limits which allow a dose limit of 170 mrem/yr to individual

members of an exposed population group.

     D.  States

         Some States bordering the Great Lakes have contracts with NEC

to perform radiological quality analyses of Lake water in the vicinity

of nuclear effluent outfalls.  These analyses are for comparison to data

reported by NRC contractors.  In addition, under their residual

authority to protect health and safety, States have an authority and

obligation to monitor for environmental pollutants.  States provide

these data to the Great Lakes Water Quality Board via the Radioactivity

Subcommittee discussed above.  In addition, all States accepting primary

authority for drinking water purity under the Safe Drinking Water Act of

1974, must provide for the surveillance of radioactivity in corrjriunity

water systems at least once every four years.  Currently, all Great

Lakes States except Pennsylvania and Indiana are expected to accept

primacy for implementation of this Act and by 1978 should be reporting

on levels of natural and man-made radioactivity in community water

systems.  Because most of the larger systems utilize Lake waters, these

data should provide good coverage of ambient radioactivity levels in

near shore waters on a periodic basis.


     A.  While the requirements of the EPA Drinking Water Regulations

will provide near shore data and NRC collects source monitoring data,


responsibility for monitoring the open waters of the Great Lakes System

is lacking.  Surveillance of Lake Superior is particularly poor.  Since

this lake can provide valuable base line data not influenced by nuclear

plant discharges, its inclusion in a long-term surveillance plan is

highly desirable.  Arrangements should be made to increase surveillance

data on the concentration of radioactivity in the Great Lakes System,

including "open waters," and particularly the systematic reporting of

such information to the International Joint Commission through the Water

Quality Board.

     B.  Intercomparison of reported data is not very practicable at

present, because no common quality assurance program exists for sampling

and analysis.  A quality assurance program under the direction of IJC

should be developed with cooperation from the various institutions of

the two Parties in the Agreement.

     C.  Every effort should be made by the two Parties to encourage

adoption of the proposed Refined Objectives for Radioactivity and

appropriate language amended to the Agreement to include these


   ror  the Commission, by the Division
 of  Corporation  finance,  pursuant  to
 delegated authority.
         •' •  GEOHGZ A. PTTZSUIMOKS.
   IFR Doc.77-10039 riled 4-4-7T;8r43 am)

             [Public Notice 533]
 Availability  of Report of th« International
   Working Group on  Radioactivity  Objec-
   tive  for the Great Lakes Water Quality
 -  "Hie Department of State hereby gives
 notice  that  the  report   of  the  joint
 Canada-United  States  Working  Group
 on Radioactivity Objective ?or the Great
 Lakes Water Quality Agreement Is avail-
 able for review  and  comment.  This  re-
 port, which is presently under review by
 both goverrur-fints. wtis prepared  under
 the terms of  the Agreement on  Great
 Lakes  Water  Quality, signed April  15.
   The next of the report,  together with
 the teit of a dissenting opinion  on the
 report's recommendation by the State of
 Minnesota,  follows below.
   Interested persons may submit  their
 comments in writing  to the Office of In-
 ternational  Activities,  Environmental
 Protection Agency. 401 M Street,  SW..
 Washington,  D.C.  20460,  on or  before
 June I, 1977. All comments received will
 be considered prior to completion of the
 review by the tT.S. Government.
   Dated: March 25, 1977.
                   DONALD R. Kmc,
                   Director, Office of
          •  -   Environmental Affairs.
   REPINED RACiOAcnvrrr Oajicmr TO* TTTE
  Thia document represents tlia joint recom-
mendations of, US. and  Canadian advisory
groups  on a radioactivity objective to pre-
«err» th« water quality of tie  Great Laies.
Tim objective is In terms at a dose equivalent
to  ICRP  Reference Man from  a  standard
annual  Intake of the- Great Lakes water. The
recommended oojectlve for the general water
quality  in- the Great L&kas Is thai level of
radlcactftKy which. results In a whole  body
dos« equivalent not exceeding  one  nuUlreui.
RelC£se> of radioactive mt tertalj shall oe as
low QJJ rtaoonobly achievable aad controlled
by  »j>eclfled actions at defined  levoU
.  Tt» Canada-United States  Great. Ljties
Waier Quality  Airreement specified radioac-
tivity- as a  constituent at water for whicn.
there should be- an agreed Water QuaJUy Ob-
JectfT*. Th* relevant statements in the Agree-
ment are as follows:
  Annex  1, Section  l Since the ingestlon of any amouct of
 radioactivity  may  involve  soj.« rUi.  addi-
 tional  controls should be  Instituted  until
 their  ctvrt  la  lE.cstninrr:v- ,o  v '.j  any
 ftcrther redaction In1 pof.r ~-.il hea -a risks.
   In kxaplcy wi:H  these jrtto."^,  several
 recommendations hATu been t-^T •*<. to. T]
 recommendationfl refer to aa -.'.:
 Quality Oojecuve^ the ccntroi or ra
 re-leases, a defined hierarcji"' Ci /cttoa Levels
 and the surveillance of L«,CB Waters  None
 of the proposed levels, including particularly
 t£e  lowest  should be- interpreted  as neces-
 sarily  defining  an acceptable  dose  to  the
 popul^ton. using System Waters. The  ac-
 cep-taoUlty-  of  any  dote  level  depends on
 whether the  tare* criteria given aoove  are
 betag  met  In, a. responsible  manner.  It  Is
 further  proposed  that  these objectives be
 reviewec at least every  five years to consider
 any necirssary changes aaa to  determine if
 tney. co.^tlaue to reflect  "a» low as reason-
 ably aciuevablt".
          ^-smrmt*? WATKK QtrALTTT          ^

   Itb r.^essazy to specify an .isib.ent water
 quality ' svel fo? the Ijlcea as a. whole so that
 contrttrrrtlcnu  from- ail  sources  Including
 aertal dwcsitlon are taken into accouir,. This
 water q-iailty level la expressed In terras of
 the tot*--' equivalent dose to ICH^ Reference
 ?Jan integrated over 50 years. (TSn,,). It la
 propose-,  that water quality outside  of  any
 Source- Control Area, as aefineo.  herein,  shall
 not.  resii:  In.  a.  TSDM  greater than  one
 miiltreni to the whole body frcm dally tnges-
 tlon of  ZJT liters  of  Lake- water for  one
 year Therefore, e-vetr for nrstlme (50 years)
 ingestici, thft  annual  dose rate  will  not
 eiceed i millirern per year. The  total equiv-
 alent (iGie to  &• single Oi^ih. or tissue shall
 be !n proporttoa to th»  dose limit recom-
 mended by the ICHP for that tissue. Because
 levels IE. the lafees may fluctuate as a reauli
of unccaLroiljki)!*- relaaeea,  such aa fallout
 froan wuaooa teatin«t  it  is further recom-
 mended  that   the  on*  miilirem  T»IU&  be
 revlewec at leaat every fivo fears  to ensure
 thai thi  contribution  from  these  uncon-
 troilubl-   releaAes.  do*a  aut constitute  an
 uareasoiiable proportion of the  dene.
 co.vrxos. of n£i_iAi£ or RAOIOACTTVI :
 flned a* any
 or unpaciit;»'f
                                             form  with,  the 1C1?-? r'cornjnenaa'.-cn t.ia:
                                             "all  dco*?^  be Icpi a^ lot? as is :^^^onao.y
                                             achievable  economic  and social  ccn.i.dera-
                                             tlons  bfrtn^ tsJiLen into  account"   (.ICP-?
                                             Pub. 23  :r?3J.
                                               Effiuents snovad be coctrollea  bv -he r»~_:-
                                             latory  bodies having jurlsoiction, taa:n^ uto
                                             account  the  cost of further  red-cticns  tht
                                             eScacy of &\a:i,itle additional co.*;*-rcl  — .eas-
                                             ures. and the stirniacdjcce of tt*  peter :ti.
                                             reduction In public health  .'Uk,  s^i,c--".^-^a
                                             with further ci^char.;e iir-^tot;o^!i
                                               A graded sc<»--e of actict.* for  eao.-  :de^':-
                                             flabie source ihSkil i>s  1^0 '.-c-.srixec j«j,ea en
                                             annual averaeo ^ier«aure^i2nt^  of  '.^e-  T^D ^
                                             In water  inc ru torec at tl_^ peritiicrv o? e^.?n
                                             source  control cjca. la acrcrdir.c"  tr.tn the
                                             action  con^.tlons given belo'af in t^nle I.

                                                    TniL-K f. — .-Ic.'ior. e:'tdii:c-.3
                                                        &nd rorr^ct'.ve wr.c';   ir'1 5.
                                                        !/ rue&5«» WT ^c; A3
                                                        low  AS   n.iHQabl;
                                               ActUia levpis are .o \>f ca'culate-1  In  ac-
                                             cordance with the dose CKOdt^ jsed  ~-i  the
                                               The annual  average itall  be bi^ed  on  the
                                             average  valce of at least 4 sneasu/eaecta la
                                             »  year. SUjr« there is a «lat.veiy  h:qn. prob-
                                             a-tilty  oi  saiiipiiiig   error,  sieasurecieua
                                             *±icuul Cb 7C-r:::c'J be.'ore act.o^i U t^xe-
                                               Wl.cr.  i  • .-..^ciui it.^,v3  •' -i^.j;r_.:  cic;
                                             ;n t;;« «at», c.rrre--pcr_tf v, Coz-iiiicc. X r.a
                                             cirrcct.V"" s>ctlo3 :j» i.iac.tei. Ejwe.i'r.  ~-^-
                                             r:odic HLGimcru;.* u, requlrf'i ^) connrm t«a;
                                             tlie ccndjt.c^ ices  net chaste.
                                               nv^'.-a  th« ccnc?ntra;icns rj rac[or.v.c:.crt
                                             la Lh-; »-i:^r correspoiid to Coc unaccep-jUjie on a continuing basia The
                                             responsUiia  regulatory  authorities snail  de-
                                             tcr^LLne  appropriate-  corrective  actions   &o
                                                        » public Seajth risk,
          ?  of radioactive wastes  or  other
radioactive material Into mtrrs of tn«  Gn>»c
L»ke« system  U prohibited. Dumping  la d»-
            periodic  monitoring of
Witsrs. sediment. »nd- tha appropriate food
orvraniema contained  thersin. shaud be pro-
vided iot til cs e  raoionuclides liiely  to  b«
present la measurable concentrations. Suclx
raonitoring should be conducted under th*
direction  at thw rasponslble Pedsrol.  StatA.
ajid Provincial Jurisdiction* and r»oort«d to
tn# Int«matloojLL Joiac. Commission, TIt«
nuciidem ami  foo4. organism* tnvanlgmttd..
                                    FEDEtAl «GISIEi!,  VOL  41,  NO. 6S—TUH50AT,  APKIL  5,  1977

     and Minpllng locations and frequency should
     Uk« Into account th« kjnown oinutnt source*
     •ad particular auclldo* roleaaed.
       Tn« monitoring reports  should Lnclud*
     calculations of tho TED,. to ICRP .Reference
     Maa  from  standard  annual Intake of taa
     water sine* this Is tho parameter to b» used
     la determining the applicable Action Condi-
     tion. At present It Is not necessary to deter-
     mine  explicitly the dose equivalents due to
     the Intake or food harvested from the Lakes
     aa they are relatively Insignificant.

       1. Total Equivalent Dose (TEDX). For the
     purpose of  this  report, the total equivalent
     doge to a  particular organ, tissue or  the
     whole body Is the cumulated dose equivalent
     over SO years resulting from the dally in*
     gestlon of 2.2 liters of lake water  for one
  WMte to th« Great Lalcr-a will meet tho ICRP
  limits. Consequently, our position has prop-
  erly taken into account the position of the
                   . n-m.           " '
         Zta"total absorbed dow intrprst't] over »
         . •   -"' *> years «ft« intake of th« rarilonticlide
         vj'i- product o< ail other modifying [acton.
            report  No.  10 '• lists the doslmetrte
•"""*  datV Including the TED», for a number of
 C3  ratttondclldes.
 _i    ST. K&ference .Von; For the purpose of this
 *•   rejs»trjleference Maa refers  to  the deflnl-
 Q^.tion*' aod parameters for adult males out-
  CXJlned-UpCRF Report 23.' .
  ^  3. fcni&e Control Area: It Is proposed that
     the 'J»*ifc:e control  area" be defined as fol-
                 source control area shall  be
               a distance of 1 km radius from
     the poTlit of release or. In those cases where
     the release point  la to  a narrow chancel or
     river, the boundary shall be a point 1 km
     downstream from the source."
      It Is further  proposed that  the operator
     of a facility can request a larger source con-
     trol area subject to the approval of the reg-
     ulator? authorities and similarly these au-
     thorities may require a more restrictive area
     from an operator.
      4. Afntnent  Water: The water In the Great
     Lakes  System outside the source control
         AD Hoc GROUT IN SUTIMBEB, 1974

     \An ad hoc  Radioactivity  Objective Com-
     mittee  has been formed to reflne. the  radio-
     activity objectives of the Great Lakes  Water
     Quality Agreement  pursuant  to Annex I,
      Annex I  to the agreement  requires that
    "Radioactivity should be controlled to the
    extent necessary to prevent harmful affects
    on health." It Is unlveraallf accepted by re-
    sponsible bodies that radia;lon damage la a
    linear effect, that Is. that radiation produces
    detrimental effects down to the lowwc levels.
    The  State of Minnesota believes  that the
    linear  theory of radiation damage  and the
    Annex I requirement of preventing "harm-
    ful effects on health" require that any re-
  _ flneaaeat of  objectives  for radioactivity  In
    the  Oreat Lake* allow  no additional dis-
    charge of radioactivity to the Great tafcea.
      Annii I. I 7(b) also requires- that the re-
    fined objective for radioactivity •  • •  shall
    be considered  la the light of  the recom-
    mendations of the International Commission
    or Radiation Protection." Tea  ICRP  dose
    limit* are recommended aa upper limits. Al-
    lowing no additional discharge of radioactive
      »ICRP Pub. 10. 1688 Report of Committee
    IV, Pergamon PRM.
     - «ICBP Pub. a. 1973 Beport  or the Tank
    Group on Reference Ufa. Pergamon Press.
   Minnesota further believe* that  any re-
 flnomenta of  the   radioactivity  objectives
 should be consistent with  the  1072 Federal
 Water  Pollution  Coutrol Act Amendments.
 This would  require that existing facilities
 provide the  best practicable treatment by
 1377. the best  available treatment by 1383,
 and a goal ot zero  discharge by 1985.
    [FR Doc.77-10076 Piled 4-4-77:8:45 am|

    Agency for International Development
              FOREIGN  AID
               .  Meeting
   Pursuant  to  Executive  Order  11769
 and the provisions of section 10(a>(2),
 Pub. L. 92-463,  Federal Advisory Com-
 mittee Act, notice Is hereby given of the
 meeting  of  the  Advisory Committee  on
 Voluntary Foreign Aid which will be held
 on April 25, 1977,  from 9 a.m. to  5 p.m.,
 in Room 1107, New State Building, 21st
 and Virginia Avenue NW., Washington,
   The  purpose of  the meeting is to for-
 mulate recommendations  for  the Ad-
 ministrator  concerning  (1)  the  size.
 composition and   membership  of  the
 Committee, and  (2) to review the status
 of plans for the expanded registry and
 to consider  such other matters related.
 to the  foreign assistance advisory con-
 cerns of  the Committee as may be ap-
   The meeting will be open to the pub-
 lic. Any  interested person  may attend,
 appear before, or file statements with the
 Committee in accordance  with  proce-
 dures established by the Committee and
 to the  extent  time  available  for the
 meeting  permits.   Written  statements
 may be filed before or after the meeting.
   Mr.  Allan Purman will be the A.I.D.
 representative  at the meeting. Informa-
 tion concerning  the meeting may  be ob-
 tained  from Mr.  Robert S.  McClusky,
 Telephone: AC202-632-1892. Persons de-
siring to  attend  tae meeting should en-
 ter the New  State Building through the
 Diplomatic  Entrance,   22nd   and   C
   Dated: March  29, 1977.
                 ALLEN R. FIRMAN,
      Acting Assistant  Administrator
        for Population  and Humani-
         tarian Assistance.
   (?S Doc.77-10038 Piled 4-4-77; 8:45 am J


            Customs Service
           Antidumping Duties
 AGENCY: United  States-Custom Serv-
ice, Treasury.
ACTION:  Notice  of  petition flled  by
American manufacturer,  producer  or
  SUMMARY: This notice is to advise iise
  public that a petition has be«n flled by
  an  American manufacturer requests?
  that antidumping duties be assessed T~.:h
  regard to wrencnea. pliers, screwdrivers.
  and metal-cutting snips and  shears from
  Japan. Interested persons are invited to
  comment on this action.

  EFFECTIVE DATE:  This notice is ef-
  fective on April 5, 1977,

    Michael  Lublinski,  Classification and
    Valve Division, U.S. Customs Service.
    1301 Constitution Avenue NW . Wasrj.--
    ington, D.C. 20229  (202--56&-2938J.

    On March 15,  1977. a petition was re-
  ceived in proper form, pursuant to sec-
  tion 516 of the Tariff Act of 1930.  as
  amended by the Trade Act  of  1974  119
  U.S.C. 1516
 erred, 03 a matter of law. when It concluded
 that an industry "1 the United States  TSS
 not beuig  injured  or Ifiely to  b« injured
 or prevented  from b«lr.g eitabilsned 07 rea-
 son ot  Imports of  wrenches, pllera. screw-
 drivers  and metai-cuttLn? snipa and shears
 from  Japan  sold ac less  than  fair vaiue
  2. The  Secretary  of the Treasury or Ms
 delegate should publish  a flndini; of dump-
 Uj? with respect to wrenches, pliers, screw-
 drivers,  and metal-cutting snips and shears
 Irom Japan forthwith;
  3, Appropriate  Customs  officers   should
 make  Antidumping Act appraisements  (Icr-
 elijn marxet (or constructed)  value and pur-
chase  (or exporter's sales)  price) for every
entry  of \vrenchea.  pliers, screwdrivers, and
metal-cutting sntpa  and  shears  from Japan
 where It has  [yen determined that  the for-
eljn market (or constructed)  value exceeds
 the purchasa  (or exporter's sales) price.
  4. Appropriate Customs offlcers should as-
sesa antidumping duties  on  those entries of
 wrenches, pllera. screwdrivers, and metal-  _
cutting  snips and shears from Japan  wnere
 It haa been determined that the foreign mar-
fcet (or constructed) ralue exceeds the pur-
coaao  (or  exporters  sales) price.

  In  accordance wltii  the provisions  of
 9 175.21 (a)  of the Customs Regulations
                                      RDEKAl MGISTM, VOL 42, NO. 63—TUESDAY, APKIL 5,  1977

        JULY l»79 COITION
              141 CTHt 10I.II.C


TO     : Leader, Research Task  Group, GLWQA Review           DATE:  April 15, 1977

FROM   : J. H. Kutkuhn,  Member

SUBJECT: Draft of Task Group  Position Paper (4/7/77)

        First let me apologize for not having responded more quickly to your
        earlier communication,  the one dated 3/17 enclosing the draft position
        paper of 3/7.  I'd been out of the country for a month and, upon my
        return in late  March,  simply wasn't able to review the draft in time
        to meet your first deadline.  Moreover, I hadn't been made aware pre-
        viously that I  was being named a member of your group, and, frankly,
        am still a little uncertain as to how it happened and why.

        Further, it's been difficult for me to grasp the substance of the
        charge to this  task  group  (#7) as outlined in the Task Description.
        I feel the (3)  interest "areas" listed there are described so simplisticly
        and in such abstract fashion that doing justice to them in the time allotted
        is impossible.   Also,  the suggestion that the scientific community has not
        provided knowledge good enough for "...an accurate assessment and prediction
        of all water quality conditions..." in the Great Lakes strikes me as being
        frivolous and platitudinous, if not completely unrealistic.  As I try to
        point out in the comments that follow, the indictment by implication of
        research as being unresponsive, fragmented, disoriented, and unproductive
        seems grossly unfair,  and masks what many feel is the real issue, viz.,
        our general ineffectiveness to date in mounting and enforcing measures to
        halt the degradation of Great Lakes water quality by agents we already
        know are doing  significant harm.

        I very much appreciate  the difficulties you face as leader of this group,
        and don't wish  to add  to your misery by appearing to be obstructionist.
        But I did want  to take the opportunity to offer some thoughts of my own
        about this complicated matter, speaking as a research administrator who
        agonizes daily  over  whether or not the costly research we administer is
        truly relevant.   Please understand that I can live with the draft report
        as it stands, and am not suggesting you subject it at this .late hour to
        the major surgery these comments may otherwise imply is necessary.

        1.) P. 1, para.  1:   The last sentence is mechanically awkward, unclear
            as to meaning, and, as a result, ambiguous (or at least misleading).
            I'm not sure that  the "vast and diversified data base...(developed)
            over the past decade..." has provided  (is providing) to any
                    Buy U.S. Savings Bonds Regularly on the Payroll Savings Plan

                                                                   _ 2 —
    significant extent for a well-organized, integrated, and effective—
    i.e., "successful"—abatement/monitoring strategy.  What seems to
    have evolved instead is a loose, not-too-well-coordinated approach—i.e., i
    relatively unsuccessful abatement, ^rcgram—resting largely on intuition
    as derived from qualitative assessment of this fragmented base.  [In
    the second sentence, what is meant by the term "...these remedial
    programs?"  It's antecedent afC2_rs to be "...surveillance and monitor-
    ing activities...," which by themselves certainly aren't "remedial."]

2.) P. 1, para. 2:  Similarly unclear; the first sentence implies effec-
    tiveness of controls as mounted from the available data base, the
    last two decry the inadequacy and outmodedness of the same base.  If
    not contradictory, the argument is confusing.

3-) P. 1, para. 3:  The ideas expressed here (first 4 sentences) seem to
    tumble over one another, without conveying a sense of conviction that
    they really have merit.  [It is difficult to build a case on (or gee
    support for)  rationale charact.srj-^^.u by conjecture, marginal proba-
    bility, abstraction, and precc/.dj.tion. ]

4.) P. 2, para. 1;  I have difficult"1 with several implications apparent
    in the last half of the paragraph, where the narrative continues with
    "It is probable that..." (i)  Exclusive concern about toxic pollutants;
    equivalent attention must be given other factors that also directly or
    indirectly threaten Great Lakes water quality, such as lack of effective
    water-level controls/policy,  indiscriminant dredging and filling, in-
    determinate status of radioactive materials, largely uncontrolled influx
    of suspended solids, siting/operation of power plants, and a multitude
    of proposed land-use activities in the "coastal zone" specifically as
    well as in the basin at large.   (ii)  Unrealistic conviction that
    "research" is an absolute prerequisite for solving water-quality -rcolens;
    there seems to be some uneasiness in the ranks about the real (functional)
    utility of vaguely perceived, yet-to-be-attained research findings  in
    setting water-quality standards, planning abatement strategy,  and
    establishing evaluation (monitoring)  programs.  Some folks are asking:
    Why can't we exercise simple common  sense and collective good judgment
    in identifying, preventing,  or  mitigating what we already know is bad,
    or is very likely to be, and get on  with the business of physically
    doing something about it?  Why  should the Lakes suffer further degradation
    while increasingly costly,  time-consuming,  misdirected,  and frequently
    abstract research is pursued?   In other words, why continue to put  the
    burden on, to rhetorically emphasise the need to do more, "research?"
    Why can't tighter and better-coordinated enforcement of abatement
    measures be applied now, where  we all agree it's needed?

5.) P. 2, para. 2;  With reference  to the immediately preceding statement
    (4), I feel the arguments expressed  here are largely academic,  if not
    unsupportable and highly conjectural.  It's one thing to offer a blanket

    criticism of the U.S. research community for failing to match the
    pace set by someone else, it's another to state clearly and precisely
    what the research community at large should have been doing to begin
    with, and whether or to what extent the research performed by anyone
    to date has been truly effective in facilitating the solution of
    water-quality problems.  I feel we need to have a better understanding
    of what the term "research" connotes, and not use either its promise
    or failure as a crutch in excusing the fact that efforts to improve/restore
    water quality have been no more than marginally effective to date.  Could
    we provide examples of research whose results, by design, were or
    would be absolutely basic to a well-conceived abatement or monitoring
    program?  [I often have the feeling that much of our research is under-
    taken more in response to platitudinous, stream-of-consciousness, and
    abstract expressions of need than in the context of practical, carefully
    wrought management schemes lacking only in certain information clearly
    derivable via applied research.  This feeling is sustained by the
    frequent observation that individuals expressing such (research) needs
    either refuse to consider or simply have no conception of (i)  what it
    would cost in time, labor, and money to address them; (ii)  how compli-
    cated logistically the work involved will be; and (iii)  whether indeed
    their pursuit will likely produce anything relevant.]

6.) P. 3, para.  1:  In the second complete sentence at the top of p. 3, it
    sounds as though we're second-guessing ourselves—which is the risk
    one takes when using the "if-then" approach to explaining why something
    failed, or at least doesn't seem to be working too well.

7.) P. 3, para.  2;  Well-stated; relates nicely to what I tried to say in
    (4) and (5)  above about applied research in the water-quality context.

8.) P. 4, para.  2;  The problem of the agreement's overstressing the
    health-hazard aspect of contaminants in the Great Lakes has indeed
    complicated the RAB's task of offering well-balanced recommendations
    regarding bonafide "research needs"—when in fact the human-health
    dimension lacks expert representation on the Board itself.   I agree
    that this deficiency must be eliminated one way or another.

9.) P. 5, para.  2;  I question the usefulness of relating the alleged
    ineffectiveness of the RAB to the character of its composition, i.e.,
    to the dearth of "clout" among its members in influencing the direction,
    funding, etc.  of research programs under their control.   I revert again
    to my observations in (4) and (5)  above, wherein I question whether
    most if not all water-quality "research needs" heretofore identified
    by the Board have been conceived,  in terms of expected results of the
    work involved, as truly relevant as well as logistically feasible.
    The opinion that needs enunciated by the RAB have not been addressed
    with greater vigor may be more an indication of their lack of intrinsic
    merit than of some research manager's unwillingness to apply the

     necessary resources in pursuing them.  Regardless of who makes up
     the RAB, the research it specifies as being necessary must have
     irrefutable merit.

10.) P. 6 and 7, Recommendations:  (1N  Referring back to (9), I doubt
     that this provision would result in the desired effect.  (2) OK.
     (3) OK.  (4) Offhand, this sounds naive and unrealistic.  (5) OK.

11.) P. 7 and 8, Terms of Reference;   Concur.

In summary, I'm not sure the paper adequately addresses the main elements
of the charge made to the group at the outset.  But, as suggested earlier,
I don't think it would have been possible to do more or better in the short
time available.  Closing points I would like to make, however, relate to
what appear to be the three main concerns expressed in the draft document:
(i) toxic substances; (ii) composition of the IJC/RAB; and (iii) human
health v. resource well-being.

   —Toxic substances.  The draft cv.ells too much if not exclusively on
     this topic.  It should strike a herder balance by recognizing other,
     equally important aspects of the total water-quality problem.

   —Composi tionof RAB.   I agree that the effectiveness of this body
     would likely be enhanced by the addition of more "influence."  But
     this kind of restructuring implies also that such representation
     (mainly of the federal establishment)  would fully comprehend—and
     could be counted on to intelligently assess—all research needs,
     strategies, and applications as  to their relevance.  Even if the body
     did prove to be omniscient, which is highly unlikely,  its effectiveness
     could quickly be impaired if, to "get the job ccne," it dictated more
     than it coordinated.  I feel the document could benefit from an attempt
     to better reflect the notion of true coordination throughout the Great
     Lakes community.

   —Human health v. resource well-being.  I agree with the need to get
     better representation in the IJC from the human-health sector of the
     community.  It seems fair to say,  however, that the IJC is  making
     good headway in recognizing that many other living resources are at
     least as sensitive as man to the requirement of good-quality water.
     To set criteria strictly from the standpoint of human health would
     appear to be as much a mistake as  setting them from that of the biota
     at large.  What I feel we need is a good balance in protecting both,
     while (and perhaps more importantly)  protecting the integrity of the
     lakes themselves.

Many thanks for the chance to express some thoughts I've harbored for a
long time.

                         NATIONAL PROGRAM STAFF
                       Beltsville, Maryland  20705

                                                      April 15, 1977

Subject:   Research Work Group Draft Report

To:        D. I. Mount
           Director, Environmental Research
             Laboratory - Duluth
           6201 Congdon Boulevard
           Duluth, MN  55804
I have read the revised draft report.  I believe you have done an excel-
lent job of addressing some of the weak spots in the program.   As I
indicated in my last memorandum, the introduction is especially well

Regarding the problem areas, you mention the need for developing a set
of research priorities.  They have developed a long list of research
needs with some broad indication of degree of urgency, but this needs to
be more selective and definitive.  There also needs to be some mechanism
for directing high priority research to those locations having the best
competence.  I think that this is what you are trying to say in
Recommendation No. 4.

Your statement about the composition of the RAB is good.  It is somewhat
strong, but apparently valid.

You address the funding of the RAB to the extent that  adequate funds
be available for administrative functions.  Our experience has been that
a coordinated program can best be developed if research funds  are made
available to the administering group.  I don't know what funds are avail-
able for this purpose, but one recommendation might be that funding
sources for the RAB be explored.

I note a strong emphasis on human health.  Mention should also be on
conservation of natural resources.

In general, I think your report is very good, and there are no major
changes I can suggest.
J. Lunin
Staff Scientist
Soil, Water, and Air Sciences

                               U.S. DEPARTMENT OF COMMERCE
                               National Oceanic and Atmospheric Administration
                               ENVIRONMENTAL RESEARCH LABORATORIES
                               Great Lakes Environmental Research Laboratory
                               2300 Washtenaw Avenue
                               Ann Arbor, Michigan 48104
April 18, 1977

Donald I. Mount
Director, Environmental Research Laboratory - Duluth
Eugene "J. Hubert
          Director, GLERL

SUBJECT:  Comments on Research Task Group Position Paper, April 7, 1977 Draft
I am pleased to have the opportunity to review and comment on the subject
draft paper.  In overview, I concur with your recommendation to change the
mission/objective (Terms of Reference) of the Research Advisory Board from
that of coordinating Great Lakes water quality research in the U.S. and
Canada to that of the Commission'^ principal scientific advisor on all water
quality matters.  It is undesirable to leave the RAB Terms of Reference
unchanged.  The RAB accomplishment cf tne last five years is not commensurate
with the effort and yet science should play a larger role in the activities
of the Great Lakes Water Quality Agreement.

I do have detailed comments on your paper and suggestions for change which I
trust are constructive.

   1.  Page 1 - Title.  Since several agencies have tneraoers on the Research
       Task Group, I suggest that "EPA" be deleted from the title and it
       should read "Research Task Group Position Paper - Five Year Review
       of the Great Lakes tfater Quality Agreement."

   2.  Page 2, last paragraph, second sentence.  This sentence is confusing
       to me and I'm not sure what point you are trying to make.  If you're
       talking about the fact that there is no single U.S. research program
       addressing Great Lakes water quality at the same level of effort as
       at CCIW, this is true, but so what.  The U.S.  has a multi-federal
       agency program which addresses a set of Great Lakes water-related
       activities.  Each activity has its own mission/objective.  That's
       the way the U.S. is organized.  I don't believe we should copy the
       Canadians on this one.

   3.  Page 3, last paragraph.  Under the circumstances, I believe we have
       as much U.S.-Canadian cooperation in research as could be expected.
       The RAB has fostered workshops and symposia.  U.S.-Canadian joint
       research program will only be pursued if it is clearly advantageous
       (cost effective) to do so to both the U.S. and to Canada.  The RAB
       has not identified specific research programs  for which international
       cooperation would be productive.


 A.  Page 4, second paragraph (fourth problem).   The Water Quality Board
     has been productive due to several reasons:   (1) it has a clearly
     defined and achievable mission and objectives;   (2) it is organized
     to utilize the U.S.  and Canadian agency resources to achieve both
     agency and Water Quality Board objectives.   The RAB Terms of Reference
     are weak and poorly defined objectives.   We  have certainly coordinated
     research and while there are many conference proceedings and a
     Directory of Great Lakes Research, it is not clear that this research
     advisory role has been productive, except for the WQOS/SBWQC relation-
     ship.   The problem is that the RAB mission needs to be changed so that
     we too have a clearly defined and achievable mission and objectives,
     and a mechanism for tapping agency resources.  The RAB Committees and
     Task Forces rely upon IJC funds.  If mutually acceptable research
     objectives could be developed, a multi-agency (U.S. and Canadian)
     joint program could be planned to utilize multi-agency resources.

 5.  Page 5, second paragraph (fifth problem), sixth sentence.  I recommend
     the following rewording:  This-s-heulel-be The role of the Research
     Advisory Board should be that of scientific  advice and scientific
     services, whieh-eaR-be free of such constraints. . . .

 6.  Page 6, recommendation 2.  I don't believe that this sentence as
     written is feasible.   I recommend that the remainder of the sentence
     starting with aad-raeehaftis-iaa-wifehin. . . be  deleted and substitute
     the following: . . .  and to develop proposals and plans for in-
     clusion in the programs and the budget process  of the respective
     agencies, as appropriate.

 7.  Page 6, recommendation 3.  There is an interesting NOAA Technical
     Memo which points out that bridges between operational and research
     programs and between research programs cannot be achieved by direction
     from the top; bridges can be built by $ $ $  $,  however.  How do you
     plan to carry out recommendation 3?

 8.  Page 6, recommendation 5.  While the impact  of  water quality on human
     health is important,  singling out human health  seems to give it greater
     emphasis than the ecosystem.  I recommend in first sentence . . .
     but especially the impact of water quality on human health and the
     ecosystem and should ....

 9.  Page 7, recommendation 7.  I agree.
10.  Page 7, Definitions.   I recommend a rewording.   As used herein,  science
     refers to the use of  factual data, knowledge and theory to arrive at
     objective sound advice that is free of political ef-eeenamie constraints
     of any jurisdictions  or bias from organizational association.  Acceptable
     criteria for water resource planning include economic,  environmental,
     and social considerations.

11.  Page 7, 2(b).  Suggest insert.   . . .research programs and to seek
     budget initiatives as required to fit . .  .


12.  Page 7, 3(b).   Suggest sentence be deleted and replaced by the
     following:   The Science Advisory Board shall investigate such
     subjects and questions which require research, shall participate
     in the development of proposals and plans and shall oversee the
     conduct of  research related to Great Lakes Water Quality as may be
     referred to it by the IJC under Article VI l(f)  of this Agreement.

13.  Page 8, 3(d).   Recommend the sentence be modified as follows .  . .
     should be directed and to recommend references, through both IJC and
     Agency channels,  for those critical subjects and questions which
     can be more cost  effectively pursued by joint U.S.-Canadian

                                                       April  22,  1977

                      WATER QUALITY AGREEMENT

I.   Introduction
     As a result of the 1972 Water Quality Agreement both the United
States and Canada have directed huge sums of money toward the control of
discharges affecting the water quality of the Great Lakes.   More recently,
both countries have been and currently are directing increasing resources
towards surveillance and monitoring activities to determine what impacts
and changes result from these remedial programs.   Clearly the principal
focus of activity within the framework of the Water Quality Agreement
has been one of abatement and now monitoring by both sides and this
priority certainly is proper and in order.  To the extent that these
programs are successful, is in part a result of relying on a vast and
diversified data base that has been generated by many agencies and
organizations through their research programs, especially over the past
     As the effectiveness of these control programs administered by
various agencies within both countries becomes apparent through the
monitoring programs initiated within the framework of the Water Quality
Agreement, it goes without saying that some problem or geographical
areas will be identified which require further remedial programs involv-
ing even more expensive control measures and more expensive monitoring
programs.   It is clearly unwise management from any point of view to
continue to rely on an increasingly more outdated data base to devise
control programs and monitoring activities for the lakes.  Just as we
need to refine control programs and monitoring programs, so we need to
expand the data base upon which such programs must be developed.
     Against this background of activity through the first five years of
the Agreement, it seems safe to conclude that the monitoring  and remedial
programs that will happen in the coming few years are going to be of a

different nature.  Perhaps programs will deal with more specific problems
as opposed to more general problems such as treatment of municipal
wastes.  Limitations on industrial effluents will be more specific than
the general ones such as BOD and suspended solids now used.  If one can
accept this conclusion, then it seems equally obvious that the role of
research and the Research Advisory Bcara will take on new dimensions and
play a significantly more important role in support of the remedial
programs as well as the monitoring activities on the lakes.  Up to this
point, research has not played a major role in the Water Quality Agreement
nor has the Research Advisory Board been serving as a scientific advisor
to the Commission and the Water Quality Board in an effective and continuous
fashion.  It is probable that both remedial programs and monitoring
activities will concentrate on more specific pollutants, especially
highly toxic ones, and it is here that the expertise and experience of
the members of the Research Advisory Board and the research community as
a whole should be tapped to provide more effective monitoring programs
as well as treatment schemes for removing specific problem materials.
Furthermore, having taken a giant step forward in dealing with the more
common and recognized problem pollutants in the Great Lakes, greater
emphasis should be given to the search for and identification of pollutants
before they become problems or emerge into crises.  To do so will again
involve close and frequent contact with the entire Great Lakes research
community in order to profit immediately from new findings that will
not appear in the open literature for some months or years.  In short,
it seems that there must be much closer and more frequent cooperation
between the Water Quality Board and the Research Advisory Board as the
countries tackle these new and more difficult problems.

II.  Problem Areas During the First Five Years
     During the first five years of the Water Quality Agreement a number
of problem areas have developed or have been identified which deserve
special comment.  The research program of the U. S. agencies is not
located in a single center as is the Canadian one and so is less conspicuous,

Part of this problem may be more real than apparent.  If the total
resources expended by the U.S. research community including industry,
universities and public agencies both federal and state are summed
together the collective resources expended are probably far in excess of
what has been presently identified as Great Lakes research activity.  It
is almost certain that, as far as achieving the goals of the Water
Quality Agreement are concerned, these resources could have been more
effective if they had been directed toward those questions which have
arisen as a result of agreement activities.
      In reality, each organizational entity has pursued research which
seemed to it to be most important, based on the priorities and needs of
its funding agency. Since each of the federal agencies have more specific
and usually more defined responsibilities than those contained within
the Water Quality Agreement, the approach has been less than an efficient
one from the standpoint of the agreement needs.  The Research Advisory
Board—probably the only entity within the agreement, who could have
effectively coordinated these activities, has not by-and-large focused
its attention on that aspect of the problem and as a result has been
ineffectual in bringing about coordination of research within the Great
Lakes research community beyond some very specific and relatively small
areas.  A well defined set of research priorities is yet to be developed
by the Research Advisory Board, but lacking the structure with which to
influence the direction of the research community toward such as yet
unidentified priorities, it is difficult to seriously tackle the problem
of setting research priorities with no expectation that they will be

     A second problem area is that the Research Advisory Board and other
entities within the Water Quality Agreement have not adequately brought
about international cooperation between the two countries in the fields
of research.  To be sure, there have been many cooperative research
efforts undertaken.  But by-and-large these have been informal arrangements
between various organizational entities within the Great Lakes research

community, who initiated cooperation on their own outside the framework
of the agreement.  Some better mechanism of sharing the research responsi-
bilities on various problems would indeed result in much more efficient
use of resources and probably more timely answers to the problems being
     A third problem area has been the near absence of activity and
concern for matters of public health as they relate to water quality
conditions in the Great Lakes.  Perhaps this inadequacy stems more from
the nature of the problem than from the inactivity of the Research
Advisory Board.  It is safe to conclude that while one can find experts
on water quality0 ^ec  lvesfor aquatic life for many types of pollutants,
it is difficult to find experts in the area of human health who are
expert for more than a few types of pollutants.  If this assumption is
correct, then it would be very difficult if not impossible to select a
small committee or task force to provide the advice to the Commission
which is needed for health concerns.  It would seem that advice will
have to be sought from hand picked individuals within the research
community after the priority problems have been established.  Then and
only then can the best experts be identified.
     A  fourth problem area has developed as a result of the structuring
of the Research Advisory Board, the method by which representation on
the Board has been established, and the unclear terms of reference.
The Water Quality Board has been a much more active organization and has
accomplished many tangible results because the membership of the Board
is made up of representatives from agencies which have resources that
can be expended to accomplish monitoring programs and institute and fund
waste treatment facilities.  The Water Quality Board has not had a
significantly larger budget than the Research Advisory Board, and yet
when one looks at the accomplishments of the Water Quality Board, they
are gigantic compared to the output of the Research Advisory Board.
Furthermore, all those who have functioned within the research community
realize that one does not declare himself a coordinator of research

activites and thereby automatically become the coordinator.
     There are two ways in which research coordination can be accomplished.
One is by such high respect for the work that has been done that various
members in the research community look to that organization or body out
of respect and therefore accept their guidance.  Second an organization
or committee can achieve coordination of research because it has sufficient
control of research resources so that they are able to influence the
direction of research and the selection of projects by the research
community.  Only the latter is a practical approach for the Research
Advisory Board.
     Until recently few members of the Research Advisory Board were
research managers, within the Great Lakes community, who had substantial
resources under their control.  During the last year this situation has
improved but there still remain a number of research institutions on the
Great Lakes which have no representation on the Board.  When one looks
at the present and past members of the Research Advisory Board, it is
also clear that membership has been picked on a basis other than control
of research resources, knowledge of the Great Lakes, or affiliation with
a major research institution within the Great Lakes research community.
Given this situation, it is little wonder that the Research Advisory
Board has not exercised research leadership and coordination within the
Great Lakes research community.
     Equally important is the need for a well defined and important role
spelled out in the Board's terms of reference.
     A fifth problem area concerns the composition of the Water Quality
Board.  Since each member in practice speaks for his jurisdiction, he is
bound by that jurisdiction's politics, economics and idiosyncrasies.  In
effect, the Water Quality Board's "maximum" equals, at best, the "minimum"
of any of its members.  Money, politics, turf and other considerations
are bound to influence actions of the Board and well they should.  But
the Commission, of necessity, must have an objective viewpoint as well,
free of these constraints, before it reaches a decision.  The role of
the Research Advisory Board, should be that of scientific advice and

services free of such constraints and based on objectivity, fact and
expert opinion.
     Therefore, the Research Advisory Board should be renamed to identify
this principle role and should be the scientific adviser to the Commission
on all matters where unbiased interpretation of fact or situation is

III.   Recommendations
     1.   The membership of the Research Advisory Board should consist
fully of members of the research community who command control of the
major research programs of the Great Lakes research community.    The
only other consideration should be that there be equal membership from
each country and that each of the members be a well recognized scientist
knowledgeable about Great Lakes problems and the Great Lakes research
     2.  The  Research Advisory Board should be charged with the responsibility
of identifying the most important problems on which research effort
should be directed on an annual basis and mechanisms within both countries
should be established to see that the principal research funding agencies
have a responsibility to abide by those decisions and orient their
programs in the directions indicated by the Board.
     3.   The Research Advisory Board cochairmen should be given the
responsibility to assure that proper international cooperation in the
research community is accomplished by giving them the responsibility and
the mechanism through which to accomplish that cooperation.
     4.   The research managers who are members of the Research Advisory
Board whould be instructed by their government that their membership on
the Board carries with it the responsibility to orient the research
programs of their organizations as much as possible to fit the research
priority that is identified by the RAB.
     5.   The Research Advisory Board should be the Commission's principal
scientific advisor on all water quality matters but especially the
impact of water quality on human health and on the ecosystem,  and should be

given sufficient resources for consultants, travel and committee meetings
to tap the vast research community that is knowledgeable about the
effects of various pollutants on public health.  Annually, the RAB
should submit to the Commission a briefing document advising them of the
most important problem areas including human health.
      6.  The two co-chairmen of the RAB and the two co-chairmen of the
WQB should be instructed to meet formally on a quarterly basis to coordinate
activities and resolve differences of the two Boards.
      7.  The Research Advisory Board should be named the Science Advisory
Board and should be the Commission's principal science advisor.

IV.  Proposed Terms of Reference for the Research Advisory Board renamed
the Science Advisory Board.
     1.   Definitions:   As used herein, "science" refers to the use of
factual data knowledge and theory to arrive at sound advice that is free
of political constraints of any jurisdictions or bias from organizational
association. Acceptable criteria for the water resource planning include
economic, environmental and social considerations.
     2.   Membership:    The International Joint Commission shall determine
the size and composition of the Science Advisory Board under the following
          (a)  The voting membership of the Science Advisory Board will
consist of members of the research community who command control of the
major research funds being expended on water quality related Great Lakes
          (b)  The research managers who are members of the Science
Advisory Board will have the authority from their respective agency to
orient that Agency's water quality related research programs and to seek
budget initiatives as required to fit the research priority that is
identified by the Science Advisory Board.
     3.   Functions and Responsibility:  The functions and responsibilities
of the Science Advisory Board concerning the quality of waters of the
Great Lakes System shall be as follows:

           (a)  The Science Advisory Board as the Commission's principal
scientific advisory on all water quality matters, has the responsibility
to promptly assess emerging problems and recommend practical solutions.
           (b)  The Science Advisory Board shall investigate such subjects
and questions which require research, shall participate in the development
of proposals and plans and shall oversee the conduct of research related
to Great Lakes Water Quality as may be referred to it by the IJC under
Article VI (f) of this Agreement.
           (c)  The Science Advisory Board has the responsibility to
identify the most critical problems on which research effort should be
directed and to recommend references, through both IJC and Agency channels,
for those critical subjects and questions which can be more cost-effectively
pursued by joint U.S.-Canadian initiative.
     4.   Authority;     The Science Advisory Board on its own authority
may seek analyses, assessments and recommendations from other professional
academic, governmental or intergovernmental groups about the problems of
The Great Lakes water quality, and related research activities, and
shall advise the International Joint Commission on the application of
their findings to Great Lakes problems.
     5.   Coordination;The cochairman of the Science Advisory Board and
the cochairmen of the Water Quality Board will meet formally on a quarterly
basis for the purpose of coordinating the activities of the two Boards.
     6.   Reporting;     Annually, the Science Advisory Board will
submit to the Commission a summary report of activities, accomplishments,
and an analysis of the critical problem areas (including human health)
with recommendations..

U.S. Environmental Protection
Region V, Library
230 South Dearborn  Street
Chicago.  Illinois  60604