Document BvoXoomzDdMbV9wBGQax5ZqXk

From the desk et w. b. pAp\r.ra-:GL 6/30/75 Copies to: H. S. Bergen D. R. Bishop T. L. Oossage R. E. Keller/J. P. Mleure R. H. Munch C. Paton R. 0. Potter W. R. Richard W. W. Withers D. Wood P. L. Wright WCNS 076485 .A * MINNESOTA POLLUTION CONTROL AGENCY Division of Water Quality June 24, 1975 Status Memorandum on PCS Problem In Minnesota Introduction The following la an update memo regarding the polychlorinated biphenyl (PCS) problem In surface jrataro_of_the State and specifically the Lake Pepin region of the Mississippi Rlvar. Inter-Agency Task Force The Inter-Agency Task Force on PCB's was formed on May 23, 197S .with the fol lowing agencies having representation: Minnesota Department of Natural Resources, Minnesota Department of Health, Minnesota Department of Agriculture, Minnesota . lr V Pollution-Control Agency, Wisconsin Department of Natural Resources, U.S. fcavlron- bantal Protection Agency, and U.S. Food and Drug Administration. In addition to the above agencies listed, the Agency staff has asked that representatives Iron the Notropolltan Waste Control Commission and U.S. Flkh and Wildlife Service alco pcr- l-cipate on the Task Fores. The Task Porca haa hold two additional mootings sines May 23rd (June 2nd and June 18th, 1975). These meetings have resulted In the development of an action i-.ir to Investigate and identify the extent of the PCS problem in the Mississippi llAr.r below the Twin Cities Metropolitan Area and the source(s) which may be contri- lutors. ' Tae Task Force Is presently compiling the results of a Quality Assurance Pro gram 'evolving seven (7) laboratories conducting fish flesh analyses on species iron Lake Pepin. Also during this same period, the Minnesota and Wisconsin depart ments of natural resources have been collecting representative fish species from Ills rtgmsnt of the Mississippi River as well as the major tributaries. M0N5 074486 the Talk Forca In thatr Investigations to identify aource(s) will be looking at tha following suspected genera1 categories: aunlcipal and industrial wastewater affluents, stack-air calsslons, storm sewer outlets, landfill and dump leachates, and other unknown and possibly ubiquitous sources. Surface Water PCS Concentrations The Agency as part of its routine water quality monitoring program haa ' Identified significant concentrations of PCB's (as Aroclor 1234) within the Mlsslslppl Rlvar in 1973. Also, both Minnesota and Wisconsin's departments of natural resources have reported levels In fish which have been In excess of the V.S. Food and Drug Administration (C.S.F.D.A.) "Action Limit" of 5 parts per million. Tha Staff has Included a meiaoranduu identified as Attactment A for your information in namueb mi as.--..-- - a this regard. Zfi/WlFf ? 'itEhS- Tha high levels of FCB's in tha fish tissue have resulted In the enforcement of the "Action Limit" by tha USFDA and subsequently a temporary ceasing of coamer- clal fishing oparations within tha Lake Papin area. This economic hardship has been raflactad in a loss of jobs and profits to these companies as well as a reduc tion in tourism. - PCB Problem Elsewhere tt is Worthwhile to note that this particular problem has not bean limited to the Manesota-Wleconsln Mississippi Klver waters. For your Information, tha staff has included a copy of tha Lake Michigan Toxic Substances Committee Report. Conclu sions. Mar 22. 1973. listed as Attachment B. Particular attention is warranted to conclusions C and F which reflect n similar situation occurring In Lake Michigan in respect to Lake Pepin. - MCNS 076487 V Of equally significant concern are the effects from FCB's which have been occurring In the waterfowl of Lake Ontario. Again for your Information, the staff baa Included a draft copy of a portion of Appendix A. Annual Report of the Water Quality Objectives Subcommittee to the Implementation Committee and Great Lakes Wstet Quality Board. June-1975. Draft of May 16. 1973 listed as Attachment C. This report will be presented to the International Joint Commission during the week si July 28, 1975, Tour attention Is directed to pages IV-19 through IT-21 which ex,lains the affects of high PCB's In fish resulting In severe reproductive failures observed In herring gulls (fish eating waterfowl) colonies of Lake Ontario. lUthln Lake Superior, the Great Lakes Environmental Contaminant Survey (GLSCS) which la conducted yearly by Michigan's Departments of Natural Resources and Agri culture, the D.S. Pood and Drug Administration - Detroit Region, and the Great Lakaa Ilphary Laboratory have detenined, as a result of PCD analyses of trout, that a patters of elevated residues exists much In the same sense aa observed In Lake Michi gan. The staff has included that report: Contaminants In Pppar Great Lakes Tlahee. Wayne A. Wlllford, D.S. Pish and Wildlife Service, March, 1975 for your Information (Attachment P). Recommends tlon The effects of recent high levels of PCB's observed In the Mississippi River have resulted In concentrations In tha fish tissues graatar than the current USPDA "Action Limit" of 5 parts per million. An economic lose has already resulted to the conmerclal fishery and tourism Industries of the Lake Pepin area due to PCB's. Aa the Agency staff continues to Investigate and ldantlfy sources contributing to this problem (See Attachment E), it Is appropriate to recosmend that the Agency Board adopt a resolution which would control the source of these conpounds. HONS 076488 It ll tKOMtdii that tha raaolutlon, If adopted, ba praaantad to Kapraaantatlva Llonall Tan Deerlin, Chairman, Houa* Subconnlttao on Conauaar Protaction and Pinaoca, and Senator John T. Tunnay, Chairman, Sanato Special Subconadttao on Science, Technology, and Coanarce, and tha Minneeota Congrasalonal delegation. Tha propoaad raaolutlon haa bean included aa Attachment A. HONS 076489 ATTACHMENT A MINNESOTA POLLUTION CONTROL AGENCY Division of Hater Quality June 24, 1975 Resolution NHSSBAS, eft* Agency is charged with the administration and enforcement of all lama relating to the pollution of any watara of the state as given in Minnesota statutes of 1971, Chapter 115.03, and, NHSRBAS, no ravage, Induatrlal easts or other vaataa ahall be dlacharged Into any of the interstate or intrastate eaters classified as flahariea and recre- atlon so as to cause any material change In any other substances or characteristics which nsy impair the quality of Interatate or Intraetata eaters or the aquatic biota In any Banner render than unsuitable or ob jectionable for flahlng, flah culture or recreational urea am per Hlnna- note Pollution Control Agency regulations MFC 14 and 15, (1973 Supplement) , and/ ' WHEREAS, significant concentrations of perelatent organic compounda Anown as polychlorinated biphenyls (PCBa) have been identified eithin the Klealaalppl River near the border areas of Jtlnnesota-Meoansin Anown as CaAa Pepin, and/ WHEREAS, the United Statae Pood and Drug admlnlatratlon hae enforced the "Action Halt* of five (SI parts per million total PCBa on several ehipemnta of commercially caught rough flah from the Lake Papin area resulting in voluntary diapoaal of the flah by the industry, and; NHSRBAS, as a result of the above, commercial flahlng operations have temporarily bean ceased in the CaAe Pepin area, and/ MOWS 076490 * . . . IUIUS, on May 27, 1975 Dr. barren R. Lawson, Minnesota Coassissloner of Health advised the public to limit consumption to no mora than ana maal par vaak of fish taken from tha Mississippi River from the Minneapolis-St. Paul metropolitan area and lower Lake Pepin, and/ NURIAS, and as a result of the above actions significant environmental affects on the aquatic life and economics of commercial and sports fisheries as wall as tourism have occurred, and/ NURIAS, the Croat Lakes environmental Contaminant Survey (GLSCS) conducted yearly by Michigan's Departments of Natural Resources and Agriculture, tha V.S. rood and Drug Administration - Detroit Region, and the Great Lakes Fishery Laboratory has determined that Lake Superior lake trout collected near Isle Royale are showing a pattern of elevated PCS residues similar to Lake Michigan. NON TURtlORI BE IT RESOLVED, that the Minnesota Pollution Control Agency board hereby supports a ban on tha sale and use of PCBa, except in those cases where its use is Judged by tha United states Snvironmental Protection . Agency and the states, to be essential. HONS 036491 --............................ ... ...- MINNESOTA POLLUTION CONTROL ACENCY Division of Water Quality May 20, 1975 ATTACHMENT R Status Memorandum on Polychlorinated Biphenyl Problem In the Mississippi River . , Introduction Polychlorinated blphanyle (PCB's) have bean used In the United Statei (ad elsewhere over the past 40 yearn. The principal uaca for PCS flulda re la the electrical Industry. Because of their dielectric properties, they are widely used In various products such as capacitors and transforuers where insulation or superior cooling is needed. Another large use of PCB's hod bean In carbonless duplicating paper, this use has been discontinued. There Is t strong suspicion that PCB's -may he contained within inks uaed In the printing Industry. Bscently, adequate data has bean accumulated which Indicates thae PCB's are now widely dispersed throughout the environment. PCB's are synthetic (man-made) chemicals which do not occur naturally within tba environment. Monsanto Corporation, St. Louis, Missouri is the . ole. manufacturer of PCB's. It Is reported that Monsanto has voluntarily taken actions to reduce the production of PCB and to limit .its distribution Cm Industries. ` Toxicology .e Studies have been completed that demonstrate accumulation factors of mp to 73,000 in whole organisms. This concept dcpllcts the uptake of PCB MCNS 076492 residues from extremely low environmental concentrations. PCB's like many of tha organic Insecticides, are fat soluble, and are atored In the Ml1*** f animals. Like Insecticides, they are chemically stable, and tand fp bo concentrated (to an oxtent) at exceedingly higher levels as they pass tilrough the various members of the food chain. | . Current Situation ' Iter 7. 1973 The staff was contacted on May 7, 1975 by tha V.S. Food and Drug Administration regarding their confiscation of a shipment of carp from a LOaamrclal fisherman from Wisconsin. Tha fish vara taken from lake Pepin imd the flash whan analysed by ths Food and Drug Administration from Selected samples exceeded the FDA "Action. Limit" of 5 ppm PCB. An estimated 10,000 pounds of carp filets were disposed of due to these concentrations PCI. Because of the action by the Food and Drug Administration as well as, a study eoaplated by the Wisconsin Department of Natural Resources on conesntratIons of PCB within fish flesh, the staff felt that considerable vlfort should bo Implemented to find the source of these compounds srlehlm ' Aha Mississippi klver. The following data summary of the Wisconsin study Illustrates the levels of PCB found within selected fish from ths Mississippi Klver. * Elver Mile - 811 (Below Bastings, Mn.) Ilea. f t i Boecles * Walleye (1970) Walleye (1973) Carp (1970) Carp (1973) Aversee PCB level 30.1 ppe 9.0 ppm 12.8 ppm 8.4 ppm Median PCB level 28.1 ppm 9.0 ppm 10.7 ppm 8.1 ppm River Mila - 765 (At Pepin, Wisconsin) JJo. Soecles . Average PCB level Median PCB level 13 Walleye (1970) ' 32.4 ppm 25.4 ppm HONS 076493 f At. > 5 7 fib. : s 5 > River Mile - 765 (At Pepin, Viaconaln) cont. Soaelea AVdraae PCB level Hedlan PCB level Walleye (1973) Carp (1970) Carp (1973) 21.g ppa 16.2 ppa 7.7 ppa Hn.) River Kile - 756 (At Vabaaha, 25.4 ppa 16.7 ppa 7.4 ppa !h! goeclea Averace PCB lavel Hedlan PCB level -Walleye (1970) Walleye (1973) Carp (1970) Carp (1973) '7.7 ppa 5.9 ppa 31.7 ppa 7.8 ppa '8.6 ppa 5.8 ppa 34.8 ppa 8.0 ppa After looking at tha above data, attention ia warranted to the Median valuaa ridch nora accurately raflact the concentration that could be expected to te found within the fleah. It ia apparent that a elgniflcant reduction in the lavele of PCB'e haa occurred during the period froa 1970 to 1973 ex cept for walleyea at River Kile - 765 (lake Papin) and 75S (lake Papin). ~^ha Viaconaln atudy la in dlaagreaaant with work coapletad by the Mlnneaota epartnent of Katural Raaoureea fron the aana reach of tha Hieaiaalppi River, nth thin in Kind the ataff felt that additional atudiaa ahould be coapletad te delineate whether tha concentration within tha fiah have in fact gone up er have deereaaed or raaalned tha eaae. ' Kfrlf.-W? Pecauae of the problaa indicated prevloualy regarding the Viaconaln and Kinneaota Departaant of Katural Raaoureea etudiea on the eoneentratdena of PCB'e within the fiah of the Hieaiaalppi River the ataff felt . that additional fiah ahould ba collected froa tha river and analyead for PCI levale. With thla in mind, fiah were collected by tha Lake City Area Metrlet of tha Departaant of Katural Raaoureea on the 16th of HONS 076494 Itojr. * total of 23 fish vara collectad and fllatad vlth thraa separate temples bain*obtained from each filet. Plans have been made to split the ' I fllat samples between the following three laboratories: Minnesota Department of Health, Minnesota Department of Natural Resources, and V.S. EPA Central ' Regional Laboratory, Chisago, .'i'/// Jo 'SfttT uf/'J/t***JT^r ' Also on the 16th the staff raeaived the latest update of water quality -- -wata forPCB'sintho-Mississippi River from the routine nonltorlng program. VUlowlng is the data from those stations that we currently have on file. , . Hate Station Concentration I 3-18-75 : 3-18-75 j 3-18-73 UM-840 (Below Wabasha St. Bridge) Vtf-826 (Above Crey Cloud Ialand) OM-813 (Lock 6 Dam *2, Hastings) 25.3 ppb 33.4 ppb 20.1 ppb i J-5-73 ; . 7-3-73 '. UH-738 (Lock 4 Dam #3) OH-698 (Bridge on U.S. 14, LeCrosse) Sal-PPb U.4 ppb `' 4-2-73 . * 4-2-73 OM-738 (Lock 6 Dam #3) DK-698 (Bridge, etc.) 6.8 ppb 12U2 ppb . It should be pointed out that these concentrations are the highest values that the staff haa observed In any aurfsce water of the state to * this data. Because these values are exceedingly high for surface waters Ahm staff recognised the seriousness of the situation and felt that a : t extenalve sampling of the river should taka place vlth possible aplit tackles being sent to the O.S. EPA Central Regional Laboratory to ascertain th* confirmation as to the presence of these levels of PCB's. Kay 19. 1973 ' i Hue to the aerlous nature of this problem, the staff felt that all interaeted parties should be brought together to discuss all aspects of , ' this particular problem. With this In mind the staff has scheduled a eating for Friday, May 23 at the Agency at 10:00 a.a. The meeting will involve state agencies from both Minnesota and Wisconsin snd federal agencies .. . MGM 07S49S ii r , i !% I -3- t River Mile - 765 (At Pepin, Wisconsin) cont. llo. Speciest AVeYsge PCB level Median PCB level > Walleye (1973) S Carp (1970) 7 Carp (1973) 21.8 ppm 16.2 ppm 7.7 ppa 25.4 ppa 16.7 ppa 7.4 ppa liver Mile - 758 (At Wabasha, Mn.) II ]1 Be. Spaclaa Average PCB level Median PCB level . Valleys \(1x9y7tv0t) S Walleye (1973) 5 Carp (1970) 7 Carp (1973) '7.7 ppa 5.9 ppa 31.7 ppa 7.8 ppa '8.6 ppa 5.8 ppa 34.8 ppa 8.0 ppa After looking at the above data, attention le warranted to the aedlan values vhlch aora accurately reflect the concentrations that could be expected to le found within the flesh. It Is apparent that a significant reduction la the levels of PCB's has occurred during the period froa 1970 to 1973 ex cept for walleyes at Klver Mila - 765 (lake Pepin) and 758 (Lake Papin). 'Ike Wisconsin study Is In dlsagraeaent with work coapletad by the Minnesota hspartaent of Watural Resources froa the esae reach of the Mississippi River. Tlth this la Bind the staff felt that additional studies should be coapletad to delineate whether the concentrations within tba fish have In fact gone up ar have decreasad or renalned the saae. ' l*r tfijy?* recause of the problaa Indicated previously regarding the Wisconsin and Minnesota Dapartaant of Watural Rasourcas studies on the concentra tions of PCB's vlthln the fish of the Mississippi River the staff fait that additional fish should be collected froa the river and analysed for >C8 levels. With this In Bind, fish were collected by the Laka City Area Mstrlet of the Department of Natural Rasourcas on the 16th of MOhS 076496 5- tbat also have an lncaraat In thla aatter. t ' i1 ii It la hoped that tha following lttu can be accomplished at thla Mating. 1 I) Present all exlatlng background data on PCB'a In the Klaalaalppl River. , . || ' 2) Dlacuaa proposed additional sampling of the Klaalaalppl liver and aajor trlbutarlea. J) Diffuse jtqyfslble fffluent sources gf~ PCJL!.g.._to (ha Mississippi River. ' Mellowing thla Mating and additional work on this problan to Identify tte aource of the PCB'a tha ataff will present to the Agency Board a coeplet* review of thia situation at the June Agency Board Mating. . . Attachaants Joel 6. Schilling, Head Lake Surveys Sub-Unit ' Section of Surface A Croundvatera Division of Water Quality MONS 076497 tfCMMTMf.nr Pollution Control Agency STATE OF MINNESOTA Office Memorandum TO Barry C. Schade, Assistant Director ( Mvinlon of Mater Quality Of CUUCCT; Joel C. Schilling, Read Lake Survey Sub-Unit John F. McCulre, P.E. ' Chief, Surface A Croundvacar Section PCS problem in the Mississippi River .. DATE: 12 * 19" fhc Staff haa been recently made avara of the fact that the levels of PCB'a in flak fleah within the Mississippi Uver (lake Pepin) are exceeding the USIDA "Action Unit" of 3 ppm. . Mr* Schilling received a call fron Mr. Mike Morehead, U. S. Food and Drug Ad- Snlatratloa oa Wednesday, May 7, 1975 to report that their agency had con fiscated a shipment of carp fron a commercial fisherman from Wisconsin. The fish ware takes from lake Pepin and the flesh, when analysed from selacced Camples, exceeded the IDA "Action Limit", of 5 ppm PCS. The sjecifIcjpoljr- - sfcjprinatad biphenyl found virAicicIor #1254. - *1 Shis particular situation presents further concern to the staff in that car- ..V-tOift guaatio-y this matter need to be r"red very soon. As you may be . cesn, this wee a rather hoc lean la 1972. Dr. Jars Mossier had dona lose ank as this problem as shown within a nano of April 1, 1972 to the Agency Rcatd. That moo had included a study with an accompanying letter from Wisconsin Department of Natural Resources regarding fish collection and analysis for FCB's from tho Mississippi River. The Wisconsin study had indicated high levels of PCB'a in the fish taken in 1970 (data ravealsd . Strait 'at ouch as 10 tines the FDA limit of 5 ppm). Wo have racsntly re- fSlvad an updata (to 1973) to tha Wisconsin study which has added to the tfcsire m oa thin aattar. Tha following data summery of Wisconsin study reveals gfclc problem. . .. River'Mila - 811 (Balov Hastlegs. Mi.) fseciam Average PCB level Median PCB level Walleye (197<tf. , Walleye (1973), \r Carp <1970) Carp U973)T \\ " 30.1 ppm 9.0 ppn 12.8 ppn 8.4 ppn 28.1 ppn 9.0 ppn 10.7 ppn 8.1 ppn MOMS 0 7 6 *9 8 Ik u i $ 7 ' River Mila - 765 (At Pepin, Wiaconaln) Ssecien Average PCB level Median PCB level Walleye Walleye (1973) Carp (1970) Carp (1973) 32.4 ppn 21.8 ppn 16.2 ppm 7.7 ppm 25.4 ppn 25.7 ppe 16.7 ppm 7.4 ppm I *B.C. Schade Hay 12, 1975 ras 2 _ * ' * River MU* - 758 (At Wabasha,, Mh.) 1* | 1. Xta. Soeclea Averat* PCS level Median PCS level 1 Halley* (1970) 1 Halleys (1973) s Carp (1970) f Carp (1973) 7.7 ppm 5.9 ppm 31.7 ppm 7.8 ppm . S.S ppm 5.8 ppm 34.8 ppm 8.0 ppm .' Jtteatlon la warranted to Che median value* which acre accurately reflect the eeacentratlons that could be expected to be found within the fiah flaah. It la apparent chat a significant reduction In the levela of PCS'* has occurred during the interim from 1970 to 1973 excepe for walleyes at River Mile - 763 Qaka Pepin) and 758 (Lake Pepin). Why the levela of PCS'* In the walleyes from Lake Pepin he* remained relatively unchanged la not presently known, A miter ef possibilities exist which could be explored. f particular concern la the role of the Division in this matter to date, flat staff.has been closely monitoring this, problem from the standpoint of that manta soureaa which might be contributing to thla problem. The work done _prarlmisly ir '972 wae aimed chiefly at the 3M - Cheaolite plant In Cottage - dauea as the source of-PCS's.. The data which Is being sutstarired to dace aearn to indicate that 3M la not presently the main'source of these compounds. ' Wa would directly correlate with the reductlotrfn fiah flesh levmla found Inlaw Heatings. Minnesota. However, loot Tanning Company, Red Wing, Minnesota had tha hlghaat level# of PCB'e In their effluent during the surveys of 1972. Par soae reason, no follow-up coapoalte sampling of Foot Tanning was undartakan as was tha caaa at Cheaolite. . ' It Js quits apparent that follow-up studies of this problem should be carried Sat. Tha staff of tha Special Investigations Unit of this Saction would be willing to coordinate additional study with tha asslatanca of tha Faeilitlaa faction to idantify point soureaa which might ba contributing to this prob lem. However, authority to act in this area previously resided in tha Divi- clem of Special Services. Wa therefor* request that you aaak clarification . M Catania* who baa this responsibility. HONS 076499 STATE OF MINNESOTA J3S- 1 Office Memorandum to Barry C. Sehadc Acting Director Divioloo of Water Quality DATE: Hay 16, 1975 Jool C. Schilling, Head lake Survey Sub-Unit John F. McGuire, p.E. Chief. Surface 1 Groundwat Update to FCB Froblen on tho Mleeltelppl River (Mo. 2). Iho follovlng la an update to the flrat nano developed on thla problea dated hr M. 1*75. In astanelva convereatlon with Mr. Chuck Burrows, Chief, Section of Fisheries, Banesote Dept, of Metural Resources on May 15 Involved the natter of fish eol- iMtloo and subsequent lab analysis for PCB's In fish flesh from Lake Pepin Spool00. This particular problea stems from a noticeable discrepancy betveen Into on PCB concentration In fish fron studies completed by Wisconsin Dept, if Natural Resources and Minnesota Dept, of Natural Resources (reference Is nada to a letter froa Conalsslonar Harbst to Mr. Merritt, dated May 13 on this matter). In agreed that fish collection would cake place op May 16 in Lake Papin conducted tp the Dept. of-Matural Resources Lake City Area District both game and rough flOh Species. Haas hors been made to split tim fillets between the f-llijic; hns laboratories:' Minnesota Dept, of Health, Minnesota Dept, of Matural Paoeursea, and US5PA Central Regional Lab Chicago. A more detailed memo will MtliM this situation lstor. . lg discussed briefly the natter regarding a public announcement about the eonM^glen of flab by the public. There is a problem here with the lack of adequate data concerning the human health effects from the consumption of these Mopeunda. We arrived at no conclusion on this matter because of DNR's concern bent tho data discussed previously. It was Indicated that Mr. Burrows would fMbdbly contact the Health Dept, for their advice on this matter. Iha fallowing la the latest update of Wator Quality data on PCB's la tho Mis- faaifpl Rivet fron the routine uonltorlng program. . tut * 3-1S-73 >41-73 3-11-75 Station DM-S40(Balow Wabasha St. Brldga) UM-S26(Abova Grey Cloud Island) OI6-S13(Lock 6 Dam #2, Hastings) Concentration 23.3 ppb 33.4 ppb 20.1 ppb 3-3-73 3-3-73 UK-738(Lock 6 Dam 15) S.l ppb UH-498(Brldgs on U.S. 14, LaCrosss) 11.4 ppb 4-2-75 4-2-73 UN-738 (Lock 6 Dam #5) UM-698(Bridga, etc.) 4.8 ppb 12.2 ppb MOMS 076500 V\ ** !| Barry C. Schade May U. H75 * * .**.#* 4 . ft should bo pointed out thot these concentrations are the highest values the Staff has observed in any surface water of the state to date. Because these sallies are exceedingly high for surface waters the staff feels that a sore extensive templing of the River should take place with split saoples sent to MEPA Central Regional Laboratory for confirmation as to the presence of these aseesntraelona. .Staff anthers of the Section Of Surface and Groundwaters conducted a field serny on Kay IS, 1975 to atcenpt to Identify possible 'sources of PCB'a to the Mississippi River. Effluent samples were obtained Iron the Red Wing Municipal VSstawater Treatment Plant and the S.B. Foot Tanning Co. Also, tributary samples WHS obtained from the Cannon River at Its confluence with the Mississippi River. . *i.\ ` * . , . . ** : * . ' **. V e * * . " ' . *' \ * * . i ........... . . . ' ... MOMS 0 76501 *PAH"J!ENT___ Pollution Control Agency STATE OF MINNESOTA Office Memorandum ggj . Barry C. Sehade, Assistant Director Division of Hater Quality DATE: 19. 1975 moat Joel C. Schilling, Head . Lake Surveys Sub-Unit *H601*1"' P-E- 4 SM^al "rShief, Section of Surface [waters : UIpdate Mono to PCS problem In the Mississippi River (No. 3) tt* following is a currant updata Of tha PCS problem In the Mississippi River. Ms. Schilling, on May 16, 1975, participated In the acquisition of fish sanplas Ics tha haad of lake Pepin, Mississippi River for analysis of PCB's. Tha a"action of fish was acconplishad by the Minnesota Department of Natural kcntireas. Lake City area district. A total of 25 fish were collected and SCated for packaging and subsequent shipment to 3 analytical laboratories. r. Schilling supervised these operations and transported the filets back to Kssaapolis. for storage until they're transferred to the laboratories on sofay, Kay 19. The three laboratories which will be conducting the analysis SM the fish flash specimens will be the Minnesota Department of Health, Minne- amsa Department of Natural Resources and the U.S. EPA Central Regional Labora- Cary in Chicago. Bach laboratory will be receiving 15 total fish specimens, --""srremaining ten specimens will be kept In storage here In the Agency for Smear analysis. , Mr. Schilling received a request for attendance at a meeting on the 27th of gp la Wabasha, Minnesota at 7:30 p.m. to participate in a dlacussion with amamsreial fisherman In the Lake Pepin area with regard to tha PCS problem Dm she Mississippi River. The request was made by Mr. Dan McGulnness from gfea Southeast Planning Commission, 149 Main Street, Wabasha, Minnesota. Mr. Schilling indicated that tha Agency would request chat Mr. McGulnness ask personnel from tha Minnesota Department of Natural Resources to also attend this meeting. gm additional meeting has been sec up a i 'i--*---- on May 23rd at 10:00 a.a. . tern at the Agency to discuss with all participating and interested parties gta PCS problem In the Mississippi River. The meeting will Involve state agencies from both Minnesota and Wisconsin and federal agencies that also have am Interest in this matter. the etaff proposes to conduct additional field surveys the week of May 19-23 am passible sources of PCB's to the Mississippi River. This will Involve both affluents and tributaries to the Mississippi to determine the exact source of Chase compounds. MGNS 070502 Lake Michigan Toxic Substances Committee May 22, 1975 * Conclusions A. The ej/cct,level of PCB's in primates,reproduction Is recently documented as less than 2.5 ppm and Is much lower than has been observed In standard test manuals (rats). I. As a result of recent court decisions the FDA Is now enforcing the 5 ppm residue maximum In fish intanded for human consumption and is likely to re view the 5 ppm maximum allowable based on recent primate toxicological evi dence. . /r/' C The concentrations of PCB's in Lake Michigan fish are probably not decreasing end Salmonids, particularly larger specimens, currently achieved the 5 ppm msrimum.allowable level. ' P. Imported efforts by the manufacturer to restrict distribution and efforts by the agencies to restrict discharges have not resulted in PCS reductions in She lake. . X. Xt is probable that wastewater sources of PCB's to Lake Michigan are ubiquitous cad at or below detectable levels. . ! f. Am economic loss has already resulted to the commercial fishery as a result ; of PCB contamination. A much larger economic loss to the commercial and sport i | fishing Industry is Imminent in light of current FDA food recommendations and enforcement actions. ' 0. Mon-wastewater PCB's are probably still reaching the environment from incinera- tlon, land dlspoaal, and careless dumping. n ' V MGN5 076503 I. The presence of PCB's In many processes and many products, continues to be widespread In spite of Monsanto Chemical Company policy to restrict sale 'for closed systems. , 9 x. Tor many if not for all uses, PCB's can be eliminated or replaced by alterna tive chemicals. ' MOhS 076504 ATTACHMENT D DRAFT OF MAY 16- 1975 APPENDIX A ANNUAL REPORT .OF THE HATER DUALITY OBJECTIVES SUBCOMMITTEE TO THE IMPLEMENTATION COMMITTEE AND GREAT LAKES WATER QUALITY BOARD HATER QUALITY OBJECTIVES FOR THE GREAT LAKES JUNE 1975 MOMS 076505 TOXIC SUBSTANCES - PERSISTENT COMPOUNDS PERSISTENT ORGANIC CONTAMINANTS kecommekdation y *j o' It is recommended that the following numerical objectives for persistent organic contaminants be adopted to replace the ^existing interim objectve in Annex I, paragraph 2 (c) of the Hater Quality Agreement: Persistent organic contaminants should nowhere in the Great Lakes system exceed the water and tissue concentrations specified below for the protection of aquatic organisms and consumers of fish. . . | . Specified aonoentrations Gcmooundt Water (9* V Tiesue Uff/g Phthalate eaters Bibutyl phthalate ' s; - 4.0 0* Bt-(l- ethylhexyl phthalate 0.0 0* Other phthalate esters o.xo B* total P.C.B.'e . V* 0.1 ratal O.D.T./D.D.E. -.0039 1.0 Total Aldrin/Dieldrin .0019 0.3* total Beptaohlor/Heptaohlor epoxide .0019 0.3* Tndrin .0099 0.3* toxaphene . * 1 1000 0* Chlordane Btndane . .000 .010 0* 0.3* Methoxyohlor .040 ' # ' - V* - undetermined at present . t - recommended quantification limit * bated upon O.S.P.D.A. guidelines for edible portions of . fith. ' CNS 076506  for other organic contaminants, the concentrations of Oihioji arc not specified but uhich can be demonstrated to be persistant and are likely to be toxic, it is recommsnded that the concentrations of such compounds in water or aquatic organisms be limited to the detection level as determined *P the best saisntific. msthodology available at the time. ------------- I . --Wotai Such a compound*for which .concentrations cannot be specified 1* Mirex, a rationale for which appears along with those for compounds specified above. MOtot Where waters are found to be contaminated as defined fey exceeding the appropriate objective, all reasonable and practicable measures should be taken by the regulating agencies to reduce the input of the persistent organic contaminant to any part of the Great Lakes system. MXXiTING OBJECTIVE; . . ._ The recommended numerical objectives are intended to replace the existing interim objective in Annex 1, paragraph 2 (e) of the Agreement which states: "Persistent Organic Contaminants. Persistent pest control products and other persistent organic con taminants that are toxic or harmful to human,, animal or aquatic life should be substantially absent in the waters." .. - BATIONAtJ Introduction . MCNS 0 7650 7 Synthetic organic contaminants entering surface waters nay be broadly divided into persistent and non-persistent compounds. The distinction is important since the organic contaminants known to present the greatest hazard to human, animal and aquatic life arc those which are resistant to degradation and which arc thus available for dispersion in the environment and for incorporation into biological tissues. Concentrations of persistent organic contaminants in the aquatic environment seldom achieve acutely-toxic proportions except in localized situations due to accident or misuse. "Of much greater concern are effects due to long-term exposure at sub-lethal levels and bio-concentration of residues resulting in tissue accumulations of increasing suignitude with each higher level in the aquatic food chain. For these reasons it is necessary to consider persistent contaminants separately from those which are readily decomposed to non-toxic constituents. . Persistent organic contaminants are, according to the Canada-U.S. Agreement, to be "substantially absent" from Crest Lakes waters. While the Water Quality Objectives Subcommittee would like to interpret this as completely absent from the aquatic ecoysystem, it is constrained by the need to justify selected levels based upon protection of all potential uses. Consequently, it recommends levels based upon (l)pro- tection of all aspects of aquatic life and human health as measured by water and tissue levels, (2) quantification limits for water concentrations, and (3) drinking water and food Standards when these levels are limiting. Recreational 4 affects of persistent organic compounds in water, with the possible exception of oil (covered under a separate objective), do not present any limitations to the introduction of such material into the water system. Agricultural use levels also are not likely to provide adequate protection for aquatic life. HONS 076508 PERSISTENCE A persistant compound ,is defined as one vhieh either fa) bp itself or aa its transformation product, has a half life for degradation under natural environmental conditions f more than eight uceks, or, (b) by itself or as its trans formation product, on entering surface uaters mag bioaoneentrate in the biota of the receiving system. . ...Persistence is the..property..of -chemical-compounds, measured in units of time, which describes their ability to resist structural alteration under specific Dhysical and chemical conditions. Under similar environmental conditions, different compounds exhibit different persistences depending on their molecular configuration. No standard test of persistence has yet been developed and, consequently, the term lacks precise definition. This is reflected in the common practice of arbitrarily classifying environmental contaminants as persistent when their presence can be demon strated in different substrates several days or weeks after release. The development of a standard test of persistence is a desirable precursor to the introduction of an objective for persistent contaminants in water. However, such a test cannot be arbitrarily selected, will require careful research and evaluation, and must be generally acceptable to the acientific community before its application for regulatory purposes. Whereas such research should be stimulated at the earliest opportunity, there is no possibility that an acceotable test for 'persistence' can be developed for incomoration into the impending revision of the U.S.-Canada Agreement on the Great Lakes' Water Quality. Thus, if the word 'oersistence' is to appear in the objectives it must include the present broad meaning indicated in (a) of the above definition. A laboratory study of eight organochlorine, ten organophosphorus and seven .carbamate compounds showed marked differences t'J - a. RONS 0 7 6 5 0 9 in persistence in river water over an eight week period (Elchelberqcr and Lichtenborg, 1971). The results indicated, however, that SOS or more of the initial concentrations (10 ug/13 of all major environmental contaminants studied remained at the termination of the study. Thus a half life of eight weeks would appear to be a reasonable criterion for the separation of persistent and non-persistent ooepounds in water. In keeping with the intent of the objectives that persistent organic contaminants be substantially absent, the definition has been modified to include the property of bioconcentration potential so as to provide for the distinct possibility that levels in tissue may accumulate from water concentrations below those which can be detected. This effect is provided for in part (b) of the definition. ... Mills the.problem of bioconcentration is real and is the Beeson for the inclusion of tissue levels in the objectives, bioconcentration factors are not standardized, sometimes Combining dietary and direct water uptake, and sometimes being acquired from systems considerably above the solubility 2 the compound under examination. As a consequence of these, and othar difficulties in determining this factor, no Cafensibla objactive can presently be made based primarily ^on this influenca. It is hoped that future work in this area may allow the situation to change. aaatic_Life ' Body burdens of persistent organic contaminants in aquatic biota and those of their predators may became . limiting for species survival. Most of such compounds are classi fied by organic chemists as "non-polar"\and as such they are very insoluble and are liable occur predominantly as adsorbed ~) MQNS 076510 tutorial on the particulate load. From therc.it may be ingested along with the particulates, thus entering the food chain, or it may be deposited in the sediment from . where it can enter via benthic organism. Fish may also absorb these compounds directly through the gills. In higher trophic organisms, the persistent material usually ends up in the liver or in the adipose tissue due to its 'preferential solubility in fats and oils over that in * aqueous fluides. In many cases, bioconcentration occurs as wall sin'ce the material then may not readily be excreted by the organism. As a consequence of these considerations, sediments, plankton, fish tissue and predators of fish are probably better indicators of the presence of persistant organic contaminants than is water. Predators are of concern - sines avian and other non-aquatic predators feed on aquatic life and their body burdens may accumulate to toxic levels -.as a result. Since fish are the food source of concern for these predators, levels are largely set for fish tissue, but Where it can be shown that detrimental effects oc.cur in the predators the tissue level objective should be extended to include the predators. . , . ' The dynamics of adsorption also give rise to increased levels of persistent organic contaminants in the sediments. However, sediments are prone to movements over large distances through current action and additionally, present technology does not permit the determination of their deposition rates on e useful time scale for these monitoring purposes. Hence, they presently can only give indications of the presence of tho contaminants but cannot easily be related to detri- 'SMntal effects. It is recommended that studies be under taken into such sampling methods as would permit the use of sediment levels for measuring contamination but for the . present, criteria are not recommended for this compartment of the ecosystem. . MCNS 076511 - Specific recoramondations have been made for those cases where significant studies have determined "safe" levels for representative fish and invertebrate species by chronic toxicity experiments. Zn cases whore subtle and deleterious offsets were noted at the lowest chronic dose level (e.g. a partial reduction in hatchability of eggs), an arbitrary aoafety factory of 0.2 was applied to estimate the 'safe* level. In cases where the acute toxicity studies indicated that some species of fish were more sensitive than those actually investigated, an experimentally determined appli cation factor for fish for the compound in question was Utilized to estimate a "safe" level for the more sensitive species of fish. Data for invertebrate studies were handled la the same fashion. .. .. When chronic field studies were available which documsnted water concentrations and used intensive ecological analyses, these were given greater weight than laboratory atodios. Concentration factors for pesticides from water to aquatic life were found to be too variable (often greater than an order of magnitude) to Utilize meaningfully in the establishment of water quality criteria. Therefore, body -hardens of various persistent chemicals in fish were utilized ' directly, when appropriate information existed. Protection of wildlife which consumes aquatic life, is based on chronic feeding studies of sensitive species and calls for restrictions ea body burdens. ' Xt is the intent of the Agreement to protect boundary waters of the Great Lakes System as a raw public water supply which will produce a safe drinking water after treatment. Xn addition, the use of fish for human consumption should bo protected. Existing standards for most of the toxic persistent I./-*/ *0,IIS 076512 organic contaminants are inadequate to protect aquatic life. Protection of fish as a resource is provided by quidelines of.the U.S.F.D.A. for throe persistent organics. (See recommendations). As new standards related to raw water supplies or drinking water which are lower than recommended water concentrations are developed and adopted by Canadian -federal -agencies. .They , should be adopted as part of the specific objectives, as should new edible tissue guidelines from U.S. Food and Drug Administration or the i Canadian Food and Drug Directorate. - QUANTIFICATION LIMITS ' The water quality objectives proposed for persistent organic contaminants have been based on the intent expressed within the existing Agreemtn which is that such materials Should be "substantially absent" within the boundary waters Of the Great Lakes. The assumed philosophy, which is perpetuated here, is that danger exists in allowing persistent SMterials of unknown fate or biological significance to be added to surface, waters within arbitrarily established limits because there is no assurance that bioconcentration will not occur and reach unacceptable levels. Corrective action may come too late to offset serious enviornmental consequences. Therefore, the philosophy of substantial absence of these substances is endorsed. In a practical senea, this is that concentration which is below that which can be quantified. That such quantification limits Should be the objective for compounds without "safe levels is indicated in the preceeding, but it should be particularly so for proven carcinogens. In a survey of some ten labor atories in the Great Lakes region which are currently doing routine determinations of pesticides and other persistent organic contaminants, the following means and ranges of quantification limits were reported. MIMS 076513 Table 1 - Persistent Organic Contaminants Quantification Limits. Compound Lindane Reptachlor Beptachlor Epoxide pp'-DDD pp'-DDE . pp'-DDT op'-DDT Aldrin Dieldrin Sndrin Chlordane Total PCB pp* Nethoxychlor Phthalate esters i' Mean (g/i / Range ug/1 .oo .000 .004 .012 .011 .011 .014 .004 .008 .008 . *005 -.035# .020 .6 .001-.010 .001-.010 .001-.010 .001-.050 .001-.050 .001-.125 .001-.045 .001-.010 .001-.025 .001-.020 .002-.010 .020-.100# .010-.050 .1 -1.5 Recommended quantification limit ug/1 .001 .001 .001 .002 .002 .003 .003 .001 .001 .002 .002 .010 .010 .2 I does not include a single high value of 1.5 ug/1. the mean of the lowest three values reported. The third column is the mean of the lowest three quantification limits reported. Since it is desired to provide incentive to the development of more sensitive procedures, and not to condone insensitive determinations, it is these means which are recommended. They are employed, where appropriate, for specification of concentrations for which experimental data are not available to produce "safe* water levels but where there are data to establish "safe" tissue levels. HONS 0 76514 ft/ ' Where an organic compound can be demonstrated to bo persistent and likely to be toxic and for which data are unavailable to establish either "safe" water or tissue concentrations, it is recommended that its concentration in water or aquatic organisms be limited to the detection level as determined by the best scientific methodology available at the time. These quantification and detection limits, however, should not be accepted as permanent substitutes for experi mentally determined "safe" concentration - rather it is intended that they should stimulate research on safety evaluations and analytical methods, plus provide a mechanism for action in the case of newly observed contaminants. LITERATURE CITED ` Xichelberger, J.W., and J.J. Lichtenberg. 1971. Persistence of pesticides in river water. Env. Sci. Tech. 5 16)s 541-549 HCMS 076515  persistent organic contaminants. POLYCI1LOP.I MATED DI PHENYLS RECOMMENDATION It ia recommended that the following new objective for polychlorinated biphenyls be adopted: 'TA# concentration of total polychlorinated, biphenyls in fish tissues (whole fish, calculated on a wet weight batit), should not exceed 0.1 micrograms per gram for the protection of fish consuming birds and mammals. Mote: The Subcommittee expresses.concern that a water concentration objective for this ubiquitous contaminant (is unavailable. Based upon poorly defined bio-concantraticn factors it may be concluded that PCB's in water should -`inot exceed 0.C01 sticrcgrans per litre. However, this level may not be adequate to provide protection to certain predators, and could presently not be enforced . because of insufficiently sensitive quantification . limits. '. RATIONALE Introduction .. In North America polychlorinated biphenyls (PCB's) are Manufactured solely by the Monsanto Chemical Company and are distributed under the trade name AROCLORR. Each Aroclor is a mixture of various isomers of which 210 may occur in `theory, the actual number of isomers formed chemically is probably closer to 103. In addition, a significant per centage of these isomers has been predicted to exist in pairs of optically active forms (Kaiser, 197<l) . HONS 076516 Polychlorinated biphenyls are now known to constitute the third most widely distributed pollutants on Earth, . exceeded only by the chlorinated insecticides DOT and dieldrin. Similar to tha latter compounds, PC3 residues are found in tho fat deposits of numerous warm and cold-blooded animals including Man. Their persistance is generally considered to be greater than most chlorinated insecticides.' In the "guatic. environment, PCB's have been"detected in water, sediments, invertebrates, fish and waterfowl with highest levels being recorded in predatory organisms high in the food chain. While greater quantities are found in areas close to heavy industrialization, substantial residues have been detected in fish from undeveloped localities suggesting thet aerial transport may play a significant role in their distribution. . * -m>CB*s In Great Lakes Waters . ' Contamination of the Great Lakes by PCB's has been, and continues to be, extensive. Fifty-seven per cent of water .samples from 30 major tributaries analyzed by Michigan Water Kesources Commission (1971) contained detectable concentrations .Of PCB ( 0.01 ug/1). Mean values determined for Michigan tributaries of Lakes Michigan, Huron, Superior, St. Clair end Erie were .023 ug/1, .228 ug/1, .010 ug/1, .081 ug/1, SBd .186 ug/1 total PCB respectively. The Canada Centre fer ' Inland Waters examined open waters of Lakes Ontario and Erie daring 1971 and measurable quantities were found in 60 percent and 63 percent of the samples respectively. Sumseries of data from the three basins in each lake are presented in the Report of the XJC Boards to the IJC (1572). . The highest mean valua was 0.062 ug/1 for bottom waters of Zcke Ontario (western region), while the lowest was .012 ug/1 for M0NS 076517 1 I the surface of Lake Ontario (eastern region). Lakewide ' aoans for surface and bottom samples were .030 pg/1 and .032 jsg/1 respectively for Lake Ontario, and .027 pg/1 and .025 P9/1 for Lake Erie. Samples taken from Hamilton Harbour . (Lake Ontario) by the Ontario Ministry of Environment in ,Jl972.showed ranges of. PCD's..in water of .035 -.095 pg/1 and 0.2 - 10.1 pg/g in sediments (Berg et al., 1974) FCB'l In Biota ' . Fish contamination is also widespread. The U.S. Food and Drug Administration guideline of 5 pg /g in edible ' tissue has been exceeded in numerous species in Lake Michigan including lake trout, coho' salmon, ahinook salmon and chub. Xn Lake Huron, walleye, whitefish, and catfish are above the # tolerance level and likewise smelt and coho salmon in Lake Ontario. PCB concentrations in Lake Erie fish are generally below 5 pg/g with the exception of white bass (Report of the XJC Boards to the IJC, 1972). Recent analyses by the Ontario Ministry of the Environment on fish from the St. Clair River revealod muscle concentrations of 4.3 - 12.3 Jig/g in white bass, 0.1 - 6.8 pg/g in pike, 0.1 - 2.8 in Vhite suckers and 1.5 - 4.7 pg/g in coho salmon. Perch from Lake St. Clair showed levels of 0.1 - 0.25 pg/g and in the * Bene area walleye contained 0.2 - 3.0 pg/g (Berg et al., 1974}. . 4 ( A serious situation exists with respect to populations ` Of fish eating birds iu the vicinity of the lower Great Lakes. Severe reproductive failure has been identified in ' herring gull colonies around Lake Ontario. While eggshell thinning has been correlated with DDE content of tjie eggs there is a positive correlation between early embryonic HONS 076518 Mortality and PCB contamination (Gilbertson and Fox, 1975). Ceomotric moans for PCB's in eggs of four fish-eating bird specios are given below (National Research Council Canada, . Associate Committee on Scientific Criteria for Environmental Quality, 1974). i PCB RESIDUES .IN.BIRDS EGGS (u.g/g, dry weight basis) location . Herring gull Ring-billed gull Common tern Double-crested cormorant take Nipigon taka Huron Detroit River take Erie Hamilton Harbour "take Ontario 368(5) 520(2) 300(6) 565(16) . 113(2) 81.7(8) 243(4) 379(4) 156(15) 258(71) 268(20) 77.5(52) 140.0(55) 63.7(18) 114(7) ' The major affect of PCB's on young birds is to produce . symptoms of chick edema disease. The symptoms are subcutaneous pericardial and abdominal edema, prophyria, liver necrosis and high mortality (Gilbertson, 1974; Gilbertson and Hale, 1974i Gilbertson and Fox, 1975). In herring gull chicks from . take Ontario colonies poor hatching success is associated with these forms of edema, increased porphyrin synthesis but not liver necrosis. These signs were associated with levels of KB's of over 900 ug/g on a dry matter basis in the liver . amongst the highest levels in the world. Less severe signs Vera seen in Lake Erie chicks at about 600 ug/g, but were not completely absent in a control group from outside the Great MGNS 076519 Lakes at about 3S ug/g. Clearly, even the Lake Erie group is contaminated by more than an order of magnitude above these. In summary there can be little doubt that the existing State of PCB contamination in the Great Lakes system is xcessive. Of particular concern must be the higher forms of life in which the process of bioconcentration causes the greatest residues to be accumulated. At present, there are insufficient data to estimate water concentrations of FCB's which will assure protection of predatory fish, fish eating birds and other predators; this will require greater under standing of the correlation of dietary intakes and biocon centration factors. i ** E11ffec-ts--o-f -PCB's On Biota _ `- "PCB's are toxic to aquatic life by direct exposure and jure hazardous also to consumers of contaminated fish. Reproduction of midges and Daphnia magna was reduced at 0.45 ug/1 (Aroclor 1254) and 1.3 ug/1 respectively (Kebeker and Puglisi, 1974). The highest concentration of Aroclor 124S having no effect on the fathead minnow was about 0.3 ug/1 (National Water Quality Laboratory, 1974), a concentration which resulted in tissue residues of about 90 ug/g or 18 tines the guideline for human consumption recommended by 0.S. and Canadian federal health authorities. This indicates a bioconcentration factor for fathead minnows of approximately 3 x 10. The factor for bluegills with Aroclors 1248 and 1254 has been estimated at 7.1 x 10* (Stalling and Mayer, Jr.# 1972) while large Lake Michigan coho salmon have, mean tissue levels of about 15 ug/g (Veith, 1973) which is 1.5 x 10 times greater than the maximum open water concentration ' of around 0.010 ug/1 (Lake Michigan Toxic Substances Committee Report). HONS 076520 . Two ug/g PCB's in fish flesh has been shown to prevent survival of newborn commercial ranch mink (Ringer et al., 1972) while reproduction was eliminated in mink fed a beef dlot containing 0.68 ug/g Aroclor 12S4 (Platonow and Karstad, 1973). While thi3 is not a subtle effect, it is the lowest dietary concentration observed to produce a deleterious biological effect. The safety factor of 0.2 applied to this .results in the recommended tissue level of 0.1 ug/g. The recommendation for PCB's is designed to protect the aquatic biota as well as the consumer of aquatic life. A conservative bioconcentration factor of 10 could be used to calculate a water concentration for total PCB's which Should prevent tissue levels greater than 0.1 ug/g. This would result in a PCB concentration in water of less than 0.001 ug/1, a concentration which would be beyond the present routine analytical sensitivities and therefore impossible to Monitor or enforce. It is therefore recommended that the regulatory agencies undertake fish and bird monitoring programs to determine compliance with the recommendation regarding tissue levels. ' XITERATORE CITED ' ' Derg, O.W. et al., 1974. PCB contamination of the squatic environment in Ontario. Ontario Ministry of _ Environment. Laboratory Branch Report. Gilbertson, M., 1974. Pollutants in breeding herring gulls in the lower Great Lakes. The Can. Field Naturalist, 8i 273-280. Gilbertson, M. and R. Rale, 1974. Early embryonic mortality in a. herring gull colony in Lake Ontario. The Can. Field Naturalist, 88:354-358. Gilbertson, M. and G.A. Fox,' 1975. Pollutant associated pathogenesis of embryos of Great Lakes herring gulls. Science, (in' press) . HONS 076521 Kaiser, K.L.E., 197a.. on the optical activity of polychlorinated biphenyls. Environ. Pollution. 7i 93-101. Lake Michigan Toxic Substances Committee Report, 1974. PCB's in water intakes in Lake Michigan. Michigan Mater Resources Commission, 1971. MAS/NAE, 1974. Hater quality criteria 1972.. National "gtefedemy of Sciences, National Academy of Engineering 0.6. Environmental Protection Agency, Ecological Research Series, EPA - R3-73-C33, 595 pp. Super intendent of Documents, Washington, D.C. Rational Hater Quality Laboratory, 1974. Unpublished reports. Duluth, Minnesota. Rational Research Council of Canada, 1974. Associate _ Committee on Scientific Criteria for Environmental Quality. PCB's in Canadian ecosystems. Ottawa, ---Ontario. Rebeker, A.V.and P.A. Puglisi, 1974. Effect of poly chlorinated biphenyls (PCB's) on survival and reproduction of Daohnia, Gammarus, and Tanytarsus. Trans. Amer. Pish. Soc. 103:722-723. Platonow, N.S. and L.H. Karstad, 1973. Dietary effects of polychlorinated biphenyls on mink. Can. J. ' Comp. Med. 37: 391-400. . Report of the IJC Boards to the IJC, 1972. Confidential report on polychlorinated biphenyls in the Great Lakes Environment. ' MONS 076522 Ringer, R.X., R.J. Aulerich, and H. Zabik, 1972. Effect of dietary polychlorinated biphenyls on growth and reproduction of mink. Amor. Chem. Soc. National Meeting Preprints of Papers, 12: 149-154. - Stalling,' D.L. and F.L. Mayer, Jr., 1972. Toxicities of PCB's to fish and environmental residues. Environ, Health Perspectives, 1: 159-164. Velth, G.D., 1973. Chlorinated hydrocarbons in fish from Lake Michigan. Final Report U.5. EPA Crant %nnr MINNESOTA POLLUTION CONTROL AGENCY Division of Hater Quality ATTACHMENT E Proposed Polychlorinated Biphenyls Sampling Progri June It, 1975 (' The objectives of the polychlorinated biphenyl (PCB) field sampling pro gram are to determine the source or sources of PCB's to the Mississippi River and to dateralne the extent of the problem. To accomplish these objectives the field sampling program will Include surface water sampling, bottom eedl- ' r ant sampling, fish flesh sampling,^HTPjludge sampling^ air sampling, and point source discharge sampling. The location of the study area Is that segment of the Mississippi River from Elk River, Minnesota to Lock and Dam No. 4 nsar Alma, Wisconsin (Figure 1). The study segment was divided Into sub-segments In order to delineete specific problem areas and facilitate data analyses (Figure 2, Table 1). A surface water sample will be taken In each of the sub-segments at tvo wsak Intervals. Hater samples will be collected in 250 ml hexane-rinsed glass bottles which have glass stoppers. Direct bottle sampling should be used whenever possible. Composite or spilt samples will not be used because the low levels of FCB's may be altered by adsorption to the sample container walls. Op to 2 or 3 bottom sediment samples will be taken In each of the sub segments (Flgurs 2, Tsble 1). Samples will be collected by either a stationary core sampler or a Shlpack grab sampler. The sediment eamples will ba trans ferred to either a hexane-rinsed glass bottle with a glass stopper or all natal cap or to aluminum foil. The first sedlmsnt sampling trip should Identify critical sub-segments which may require additional sampling In the future. MCNS 026523 Fleh flash ssmplss will be taken in all sub-segments where it la reasonably possible (Figure 2, Table 1). Fish will be collected by boon shocking or any other suitable equlpaent. Two species of sport fish and two species of rough fish will be Included In each saaqile. Five Indivi duals of each species will be collected to aake a total fish saaipla of twenty Individuals. The spades of sport fish which nay be used are wal leye, sauger,. white bass, channel catfish and small-south bass. Rough fish species which nay be used are carp, buffalo, glzsard shad, and fresh water drum. Fish removed from the river for the sample should be large enough to be considered of edible site by sport fishermen. Only the edible fish fillet should be used for the PCB analyses. Frequency of sampling and areas or sub-segments for specific Intensive sampling will be determined after the initial eaapling trip. Sludge samples will be taken at the major wastewater treatment plants^ la the study area which burn or Incinerate the sewage sludge. If high levels of FCB's are found In the sludge, air eampllng of the Incinerators may be necessary to determine If these are major sources. Point source discharge sampling will be conducted on all known or sus pected sources of PCB'a. The exact procedures or frequency of sampling will be determined for each discharger. Possible methods of sampling may Include grab sampling once every two weeks or over a 24 hour period. HONS 076524 TABU 1 Description of Sub-Segment and Sampling Areas for FCB Investigations A. St. Croix Klver 1. Taylors Falls to Stlllvatar 2. Stlllvatar to Prescott. Wisconsin B. Minnesota Klver 1. Jordan to Shakopea 2. Shakopea to confluence with Mississippi River C. Mississippi Klvar 1. Ilk River to Coon Rapids Dam (Mila 866) 2. Coon Rapids (866) to St. Anthony Falls (Mila 8S6) 3. St. Anthony Falls (Mila 854) to Lock and Dan il (Mila 848) 4. Lock and Dan fl (848) to Wabasha St. Bridge (Mile 840) 3. Wabasha St. Bridge (Mile 840) to Rock Island RR Bridge (Mile 830) 6. lock Island RR Bridge (Mile 830) to Lock and Dan #2 (Mile 815) > 7. Lock and Dan 12 (Mile 815) to Lock and Dam 13 (Mile 797) 5. Lock and Dan #3 (Mile 797) to Pepin (Mile 765) 9. Papin (Kile 765) to Lock and Dam #4 (Mils 753) I. Crow liver At confluence with Mississippi River J. Run River At confluence with Mississippi River F. Tamllllon River At confluence with Mississippi River C. Cannon River At confluence with Mississippi River I. Rush River At confluence with Mississippi River I. Chippewa River 1 At confluence with Mississippi River . HONS 076525 DELINEATION OF PCS STUDY AREA i 3'OO* MONS 076526 MINN. POLLUTION CONTROL AGENCY OIV. Of WATER QUALITY JUNE . I9T5 Flour* n DELINEATION OF SUB-SEGMENT AREAS FOR PCB INVESTIGATIONS .I **'oo" MCNS 076527 MINN. POLLUTION CONTROL AGENCY OIV. Or WATCH QUALITY JUNE. I9T5 I j FF fmjf&v'i.tQ-- Contarainants In Upp< r* L 1/ fishes-- Wayne A. W&&&*<*-**' u. s. Fish anti Wildlife Service Great Laku* Fishery Laboratory ' P. 0. Box 640 Ann Arbori Michigan 48107 ATTACHMENT P cj *er JUNO 7 1975 MPCA - DULUTH DULUTH, MN. At a recent meeting (January 30) of die Governor's Greet Lakes Regional Interdisciplinary Pcscicida Council, Mr. Donald C. Ileal ton, Ragional Director, U. S. food.and Drug.Administration, Chicago, announced chut future interstate shipments of Lake Michigan chubs, lake trout, or saloon will be subject to seizure because of contamina tion by polychlorinated biphenyls (Pen's). Mr. Ilealton'a statement has resurfaced past concerns and questions about the status and trends of fC' s and other contaminants in Great Lakes fishes, and the implications (.these contaminants In future management decisions on fisheries. The issue it further confused by reports over the past year or two that problems associated with contaminants in the Great Lakes were rapidly declining in importance, because of the Croat Lakes Fishery Labora tory's (GLFL) past and current program of contaminant monitoring, . together with our participation In several interagency studies on contaminants in fish, I have been asked to review the current status f "problem" contaminants in the Great Lukas and discuss what successes r failures va hsvs observed in the control of those contaminants. Tbs four fishery contsmlnancs of major concern over the past 5 to 10 years have been DDT, dieidrin, mercury, and TCB's. fur the purposes of this presentation, it would be most convenient for me to discuss ech of those four contaminants individually in the chronological ordar ( tboir recognition as a problem. Source material' for my discussion will be date obtained by tha CLFL and the Great Lakes Environmental Contaminant Survey (CLECS). CLECS Is a cooperative program of fish sampling and analysis conduetsd yearly by Michigan's Departments of natural Resources and Agriculture, the U. S. Food and Drug Administration-- Detroit Region, end the Crest Lakes Fishery Laboratory. m Several investigators, Including Dr. Robert Kcincrt of the CLFL, identified DOT end Us Metabolites as a contaminant of Croat Lakes fishes in the mid I960'*. Dr* Kcincrt olso soon determined that, Although present in fishes from each of the Croat Lakes, OUT rouc.ilna tion wes particularly severe in those from Lake Michigan where residues in tcvorul spec (os exceeded the KDA guideline >!' $.0 ppm. Thin information Contributed ultimately to a decision by tha Stales (1909-70) and eventually Presented at: Great Lakes Fishery Commission Upper Croat Lakes Committee Meetings Milwaukee, Wisconsin 53203 March 25-26. 1975 . MOMS 076528 -2- by the Faderal government (1972) to ban the use of DDT. Ve feel that ths reduction in residues that followed the 1969-70 ban of DDT In tha Lake Michigan watershed will eventually be considered as a classic exanple of che impact of legislative controls in a large aquatic system. Within 2 years of the ban, we were able to detect a significant decline of DDT residues in fish taken at our index stations on Lake Michigan (Table 1). And now, only i years after the ban, DDT in bloaters la down 87Z from the high in 1969-70 and is no longer considered a problem In bloaters or coho salmon, and Is fast approaching this status in lake trout. Thus controls do work--and even fish, which are considered the slowest indicators of change, show such a rapid response to Che . elimination of contaminant sources thac even the mosc opcimiscic of us in the business were surprised. DOT was never considered to be a particular problem in Lake Super ior fish, but somewhat elevated levels (2.8-7.4 ppm) of this contaminant were observod in larger lake trout from the lake during the mid 1960's. Recent collections (1973) of lake trout ,from Lake Superior as part of CLECS show that "elevated" levels of DDT still exist in certain areas. Large fish taken from near Isle Koyale contain DDT residues in excess of the FDA guidelines (Table 2). Residues are considerably lower, however, in fish collected to che southeast or southwest of this central region. Although the data are limited, there is some indication thac perhaps DDT residues have not really declined much in Lake Superior since the mid 1960's. If true, it is possible chat che ollgotrophlc nature of che lake may have resulted in a different behavior of the compound or else the sources of DOT to the lake were not eliminated ns rapidly as in Lake Michigan. Dleldrln Although never receiving as much publicity or concern as DDT, dleldrln has been a nagging problem in Croat Lakes fishes (particularly) Lake Michigan) for aa long as DDT. Residues of this insecticide have routinely averaged Just below the FDA guideline of 0.3 ppm in Lake Michigan fish sampled as part of our monitoring program (Table 1). In addition, we have observed no decline In dieldrin residues -inco tho. 1960'a. This type of information again contributed ultimately to che EFA ban on dieldrin in 1974. We would hope th.it this ban will ahurdy raault in daclinaa of dieldrin reeiduea In Lake Michigan fish. Mercury Mercury wns first reported by Canadian investigators as a con taminant of Lake St. Clair fishes in aarly 1970. Within l to 2 yuats of this announcement, mercury had been found to exceed the FDA guide line of 0.5 ppm In et least one species of fish from uach of the Great MOMS 076529 Lakes except Lake HIchiRan, and appropriate fishing restrictions or warnings were issued for each of the affected lakes. Even in Laka Michigan, wo found that largo walleyes and an occasional very large lake trout exceeded the Guideline.. The presence of mercury in fish from each of the lakes, combined with the results of studies of mercury In siuseum fish, soon made ic apparent that elevaced background levels of mercury were common co the Croat Lakes, and that the existence of few point sources, as in Lake St. Clsir, were sufficient to cause problems in practically all of the lakes. Based on characteristic background levels of mercury in Great Lakes fishes and the known persistence of mercury in the environment, the best scientific judgument in 1971 was that even with the elimination of known sources of mercury, s severe problem would continue co exist in Lake St. Clair for tens of years. Well--so much for science. In late 1970, the alleged major source of mercury to Lake St. Clair was eliminated, and by 1972 the levels of mercury residues in our monitoring samples of rock bass, channel catfish, and probably yellow perch had fallen precipitously co below 0.3 ppm (Table 3). Mercury concentrations In walleyes had also declined mure than 30Z by 1972, and tha decline Is continuing yet today, though at a much lower rate. Again, as with DOT in Lake Michigan, the elimination of sources brought about an almost lsniedltte doclino of residues in fish to the surprise, and possible chagrin, of several investigators including myself. In dafense of science, it must ba realized that mercury still is, and will continue to be, a problem in the Great Lakua. Walleyes in Lake St. Clair remain above 1 ppm and it is possible that the larger fish may never get below 0.3 ppm because of the apparent natural background of mercury in the Great Lakes. Laka trout in Lake Superior also contain excessive amounts of mercury, particularly in the area Of Isle loyale (Table 2). This is probably related to the past problems with mercury in Thunder Bay and hopefully will improve in the near fucure. Becent (1973) samples of walleyes from southern Lake Huron contained average mercury concentrations of 0.9 ppm, and samples of walleyes from Lakes Ontario and Erls (1974) show enneinuod high levels, with most fish of about 300 mm or larger exceeding 0.3 ppm. There are, however, tome indications of a decline in average residues in Lake Erie walleyes. KB'S PCB's sru by no means a recently recognized problem in Crvat Lakes fish. Their presence in Laku Michigan fish has been known since the late 1960's and initial actions to reduce I'CIl losses to water were taksn by El'A and tha Munnsnco Chumicnl Company in 1971. . Hie rcccnc actions srs primarily the result of a strengthening by court decisions MONS 076530 o( FDA's ability to enforce their Cuideline of 5.0 ppm. The GLFL lias been routinely analyzing [or PClI's in Lake Michigan fieh alncc 1972. Average concentrations of PCtt's in bloaters, lake trout, and coho salmon have consistently exceeded the FDA Cuideline and, baaed on our samplings of bloaters, it would appear that residue levels have remained "static" since 1972. Analyses of lake trout performed as part of tha CLECS confirm the presence of high TCIS residues and indicate a pattern of greater contamination in the southern portion of the lake Similar to that routinely ohservod over the years with DDT (Table 4). (scent reports of lake trout taken from southern Lake Michigan lndicaca that 'ndlvidual fish may contain as much as 40 to 60 ppm of rcB's. Our data -ad those of the CLECS show that average residues are considerably lower than that. Hut, regardless of whose data is used, FDA is correct in stating that Lake Michigan bloaters, lake trout, and salmon do not meet their Cuideline. Size and origin of the fish are, of course, considerations in the marketability of any fish, and it is probable that residues in smaller bloaters and luka trout, particularly from the northern portion of the lake, would average below the Guideline. The greatest concern from an environmental standpoint is the question of why we have nut observed a reduction in PCS levels since tha initiation of voluntary controls on their sales and use in 1971. One possible explanation is that PCii's behave differently in the environment than DDT ur mercury. This may be technically true, but I do not foel it explains tha complete absence of change. ' A more likely cause is that the controls imposed to date have failed to eliminate the major sources. The Michigan Dillt has shown, fur example, that tllmlnation of PCI) sources tu the Saginaw River drainage resulted in an Immediate reduction of residues in fish from the river. It would assn reasonable that after ] years wc would have observed at least a small decline in Lake Michigan if the sources were truly eliminated. One benefit of the recent "scare" will undoubtedly be a closer look by EPA at what tha curront sources of l'CB's are in the Lake Michigan watershed. As inferred earlier, PCIl's are not peculiar to Lake Michigan Slona. PCli analyses of Lake Superior lake trout as part of the CLECS have shown thu same disconcerting pattern of elevated residues near Isle Royalc as previously noted with DDT and mereury (Table 2). (cause of Lite similarity i:i geographical distribution of mercury, DDT, and FCB residues In Lake Superior lake trooc, it would appear that the Thunder Bay area was. and i jy still be, a major point source for thasa contaminants tu the lakt. Future Contaminant "i'ri'hlems" . A long List i-.i! 11.!. nai poionilul contaminants including chlordanc, hcxachlorobciiccne, phchalutcs, arsenic, cadmium, chromium. Copper, an!, most recently. mi rex, have been found in Great Lakes fishes ever the years by cilh.i the tl'A, State Unit's, or university * research groups. Tlie sore presence of dies* lesser contaminants does not represent a problem as such, but It does-suggest a strong need for con tinued surveillance of known or potential contaminants, and more aggres sive regulatory controls on the loss of contaminants to the lakes. The problem of contaminants is a double-edged sword in that they affect not only the utilil.it ton of fishes but probably also play A subtle role In thair growth, reproduction, survival, and long-term potential. Ue at the CI.FL will coniinuu to monitor known or potential contam inant problems in the Croat Lakes to the best of our ability. Ue will else continue to participate as much as possible In Interagency programs attempting to define and control contaminant problems such as the CLCCS, the Lake Michigan Toxic Substances Committee, the tJC Reference Croup oo Upper Lakes Pollution, and Che National Pesticide Monitoring Program. Hopefully, we can contribute through these groups to e better coordination of contaminant research and monitoring programs in the future. Our ultimntc goal Is the elimination of problems before they become "crises'' similar to thosa created by OUT, mercury, and PCB's. And finally, we are making every reasonable effort to improve our Ability to evaluate vital these contaminants moan In terms of possible toxicological effects an fish, and their adverse role. If any, in cartailing the productivity of Great Lakes fish stocks. I '. : I' rI i MOhS CJ6532 I Table 1.--Concentrations of pesticides and PCH's in.fall collections of Lake Michigan bloaters and lake trout off Saucatuck, Michigan, and coho salmon from batwocn Ludington and Frankfort, Michigan. Species and year Ntsnbar of fish Average langth (nm) Total DDT (ppm)--^ Dieldrin - (ppm)i/ Total PCB's (ppm)i^ Masters 1969 1970 1971 -1973 1973 . 1974 Coho salmon 1999 1970 . 1971 1973 1971 Lake trout *970 1971 1972 1973 130 20 602/ 1302/ ioo2/ noy 11 13 IS 10 39 It 20 .9 10 270 9.94 (0.33) 0.27 (0.01) 263 9.87 (1.44) 0.19 (0.02) 364 6.24 (1.13) 0.27 (0.06) 2SS 4.33 (0.48) 0.18 (0.03) 250 2.09 (0.26) .0.28 (0.02) 2S7 1.33 (0.14) 0.28 (0.03) -' 5.66 (0.95) 5.24 (0.37) 5.57 (0.31) 621 11.92 (2.69) 651 14.03 (1.29) 674 9.85 (1.41) 693 7.17 (1.09) 630 4.46 (0.34) 0.21 (0.02) . - 0.12 (0.02) - 0.11 (0.01) - 0.13 (0.04) 10.93 (2.12) 0.09 (0.01) 12.17 (0.77) 613 19.19 (3.27) 579 13.00 (1.76) 646 11.31 (3.26) 602 9.96 (1.36) 0.27 (0.05) 0.20 (0.03) 0.20 (0.06) 0.27 (0.03) * 12.86 (4.75) 18.93 (2.08) ^Concentrations in whole fish, wet weight with 951 confidence interval in parentheses. ^Composite samples, 5 fish/sam(>le. -^Composite samples, 10 fish/samplc. . MOMS 076533 1 .TABLE 2 I SUMMARY or 197] CLIICS UATA ' .i Prep.-irud by llic Mlclilfrin IViMiiuint nt A|'.r ini liurr LAKE TROUT tana LRU SUPERIOR MS-1 MS-2 SUe <I7" 17-20" >20" <I7" 17-20" >20" Nunber 4 1 b 3 3 5 MS-3 MS-4 MS-S ' <17" 17-20" >20" 17-20" >20" 17-20" >20" 12 16 19 6 n 4 5 KS-6 <17" 17-20" >20" 1 1 6 Total DDT'n PCll'n PIMM l'P 2.1 2.4 7.9+1.4 ;3 .9 1.8+ .6 .9+ .7 1.1+ .7 3.3+1.4 0.71 .3 2.1+1.7 .5 1.5+ .2 .1. 1.0 1.4+.] 2.4 2.9 5.3+ .9 .5 I.R 4.2 + 1.8 1.9+1.1 4.7+2.2 1 . * 3.J.+7.7 .8 1 .HI .* .0 1.0 1.4+ .2 llU blcldrlt PPM PP .57 .51 .80 + .10 .18 .36 .43+.17 .29+.12 .32+.1' .69+.27 .?5+.n:i .48+.17 .32 .30+.05 .21 .21. * iV* tr tr .08+.05 tr tr .04 .03 .04 .06 .in .01 .0? .03 .01 .0.? .04 HONS 076534 Table 3.--Mercury concentrations in fillets of selected Lake St. Clair fishes collected in the fall of the year. Species and yaar Number of fish Walleye 1*70 1972 1973 1974 meek beta 1970 1972 1973 1974 Tallow parch 1970 1973 7.174 Channal catfish 1970 19722/ 197j2/ 19742/ 56 60 77 60 45 40 36 50 45 45 43 IS 9 20 Average length (mm) Averago weight <9> 506 1214 445 831 48S 1105 SOI 1174 185 * 174 178 309 164 121 126 an 198 106 191 91 228 158 518 1807 363 519 ' 461 1023 490 1135 Total mercury (ppm)2/ 2.83 (0.37) 1.18 (0.16) 1.18 (0.10) 1.07 (0.10) 1.24 (0.27) 0.49 (0.08) 0.37 (0.07) 0.37 (0.06) 1.22 (0.17) 0.31 (0.08) 0.28 (0.04) 1.62 (0.45) 0.17 (0.19) 0.35 (0.08) 0.35 (0.04) 2/Concentrations expressed as elemental mercury in wot weight of tissue with 951 confidence intorval in paronthoses. 2/whole fish. I