United States
        Environmental Protection
        Agency
£EPA
           Great Lakes National
           Program Office
           230 South Dearborn Street
           Chicago, Illinois 60604
EPA 905/9-89/006
GLNPO 05-89
U.S. Progress in
Implementing The
Great Lakes Water
Quality Agreement

Annex Reports to the
International Joint
Commission

1988

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        U.S. Progress in
Implementing the Great Lakes
   Water Quality Agreement

      Annex Reports to the
 International Joint Commission

              1988
           ,, .,-:.-n c , Llo •
           .i..)u S. Doarboj.i
           QLioago, IL  6060
  U.S. Environmental Protection Agency

     Great Lakes National Program Office
         230 South Dearborn Street
          Chicago, Illinois 60604

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                        TABLE OF CONTENTS

                                                              Page

INTRODUCTION


ANNEX 1:  SPECIFIC OBJECTIVES                                     1


ANNEX 2:  REMEDIAL ACTION PLANS AND LAKEWIDE
 MANAGEMENT PLANS                                             3

   INTRODUCTION                                                 3
   REMEDIAL ACTION PLANS                                        3
   LAKEWIDE MANAGEMENT PLANS                                19


ANNEX 3:  CONTROL OF PHOSPHORUS                               29


ANNEX 12: PERSISTENT TOXIC SUBSTANCES                          31

   RESTRICTIONS ON THE DISTRIBUTION OF CRITICAL
    POLLUTANTS IN COMMERCE                                   31
   WASTE REDUCTION AND RECYCLING                             33
   TOXICITY REDUCTION ACTIVITIES                                40


ANNEX 13: POLLUTION FROM NONPOINT SOURCES                    43

   INTRODUCTION                                                43
   PHOSPHORUS REDUCTION PROGRAMS                             43
   MANAGEMENT PLANS TO CONTROL  TOXIC LOADINGS
    FROM NONPOINT SOURCES                                     45
   1987 AMENDMENTS TO THE CLEAN WATER ACT — STATE
    NONPOINT SOURCE ASSESSMENTS AND MANAGEMENT PROGRAMS   46
   OTHER  ACTIVITIES                                             46


ANNEX 14: CONTAMINATED SEDIMENT                              49

   INTRODUCTION                                                49
   COORDINATION OF RESEARCH AND OTHER STUDIES                49
   SURVEILLANCE PROGRAMS                                      50
   TECHNOLOGY PROGRAMS                                       56


ANNEX 15: AIRBORNE TOXIC SUBSTANCES                           67

   INTRODUCTION                                                67
   GREAT  LAKES ATMOSPHERIC DEPOSITION NETWORK                68
   GREEN  BAY MASS BALANCE STUDY                               69
   AIR TOXICS EMISSION INVENTORIES                               70

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                   TABLE OF CONTENTS (Continued)

                                                               Page

ANNEX 16: CONTAMINATED GROUND WATER                        71

   INTRODUCTION                                                71
   U.S. ENVIRONMENTAL PROTECTION AGENCY ACTIVITIES            71
   U.S. GEOLOGICAL SURVEY ACTIVITIES IN THE GREAT LAKES
    BASIN                                                       74
   WELLHEAD PROTECTION ACTIVITIES                              75
SPECIAL REPORT TO THE INTERNATIONAL JOINT COMMISSION
 ON POINT SOURCE CONTROLS                                     77

   INTRODUCTION                                                77
   COMBINED SEWER OVERFLOW STRATEGY                          77
   STORM WATER PERMITTING IN THE ROUGE RIVER                 78
   STORMWATER REPORT TO CONGRESS                             78
   SECTION 304(1) OF THE CLEAN WATER ACT                        78
   IMPLEMENTING WATER QUALITY-BASED POINT SOURCE
    EFFLUENT LIMITATIONS FOR TOXIC SUBSTANCES                 79
   PRETREATMENT                                               80
   NATIONAL MUNICIPAL POLICY                                   80
   DEMONSTRATION PROJECTS                                     81
   MONITORING DATA FOR TOXIC LOADINGS FROM
    POINT SOURCES                                              81

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                         LIST OF FIGURES
FIGURE 1.  LOCATION OF AREAS OF CONCERN IN THE GREAT LAKES    4

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                          LIST OF TABLES

                                                              Page

TABLE 1.  STATUS OF U.S. REMEDIAL ACTION PLANS                  5


TABLE 2.  CONTRIBUTIONS OF SELECTED RECENT ACTIVITIES
           TO THE EVOLUTION OF  LAKEWIDE
           MANAGEMENT PLANNING                              21


TABLE 3.  SUMMARY OF THE 1990 PHOSPHORUS LOAD REDUCTION
           GOALS FOR LAKE ERIE, LAKE ONTARIO, AND
           SAGINAW BAY AS COMPARED TO 1988 REDUCTION
           IN PHOSPHORUS LOADS                                 45
TABLE 4.  SUMMARY OF STATE AMBIENT WATER AND SEDIMENT
           MONITORING PROGRAMS                                55
TABLE 5. STATE PROGRAMS FOR CLASSIFICATION AND DISPOSAL
           OF DREDGED SEDIMENT                                 58
TABLE 6.  SUMMARY OF STATE PROGRAMS AND ACTIVITIES
           RELATED TO CONTAMINATED SEDIMENTS                 63

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                                     INTRODUCTION


       The  1987  revisions  to the Great Lakes Water Quality Agreement (GLWQA) strengthened
many of the Agreement's provisions, including clarification of the responsibilities of the United
States and Canada as Parties to the Agreement. One significant revision requires that the Parties
report on progress in addressing Annexes 1, 2, 12, 13, 14, 15 and 16.  In response, this document
was prepared as  the first Report to the International  Joint  Commission (IJC) on U.S. progress
towards responding to  these Annexes.

       In addition to the specific reporting  requirements to which this document responds, Article
IX of the GLWQA states  that "the IJC  shall be given,  at its  request, any data or information
relating to water  quality in the  Great Lakes system...."   Such information  is used extensively in
preparing the reports of the Water Quality Board to the Commission. One very important category
of this  information relates  to  point  sources of  pollution  and  progress  towards its  control.
Therefore,  a special section has been included  at the  end of this  Report to provide current
information  on U.S. programs for the control of  point sources.

       U.S.  programs  and  activities that address provisions of the GLWQA not covered in  this
report are discussed in the  1988  Report to Congress on the Great Lakes Water Quality Agreement
and in the Five-Year  Strategy for the Great Lakes National Program Office.  Readers desiring
copies of those documents  should contact the Great Lakes Program  Office, 230 South Dearborn
Street, Chicago, Illinois 60604.  Further information on U.S. and Canadian activities related  to the
GLWQA can be found in the Great Lakes Water Quality Board Report to the IJC, available from
the Windsor Regional Office of the IJC, Post Office Box 32869,  Detroit, Michigan 48232.

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                            ANNEX 1: SPECIFIC OBJECTIVES


       Annex 1 and its 1987 Supplement call for the development of Specific Objectives, which
are defined in the GLWQA as "the concentration or quantity of a substance or level of effect that
the Parties agree, after investigation, to recognize as a maximum or minimum desired limit  for a
defined body of water or portion thereof, taking into  account the  beneficial  uses or  level  of
environmental quality which the Parties  desire  to secure and protect;..."

       In addition  to the existing Objectives categories in  the  GLWQA  --  Chemical,  Physical,
Microbiological and Radiological -- the Supplement added Ecosystem Objectives, to emphasize the
aspect of "level of effect" in the above definition.  Achievement of Ecosystem Objectives is  to be
evaluated through ecosystem health indicators, which will be developed as  described in Annex  11.

       The  Supplement  to  Annex 1  modifies  the  Annex by  clarifying  responsibility and
establishing  a framework for developing Specific Objectives. To  assist in sorting out the many
chemicals that could be considered in this task,  the Supplement requires the development of  three
lists of substances believed  to  have toxic effects and  found within the Great Lakes System, or
having potential for discharge  into it.  In proposing substances  for new Specific Objectives, the
Parties are to be guided by  these lists.

       Although no  new Objectives  have been  added,  important work  on  identifying and
characterizing substances found within the Great Lakes was done by  IJC committees.   Of the
approximately  1,000 compounds  reported  to have been found, the  committees  confirmed the
presence of 264, as reported  in the 1987 Water Quality Board Report. The 1987 revisions to the
GLWQA shifted the responsibility for such work from the IJC to the Parties.  In response, the
United States and Canada formed an Objectives Development Committee and began the process
to developing lists of compounds and reviewing extant and prospective Objectives.

       Although implementing this new responsibility has progressed somewhat slowly,  progress
is being made. The effort will be  supported in  part by the well-established United States process
for developing  regulatory criteria and standards  for  ambient conditions  that are analogous to
Specific Objectives. In the November 1988 semi-annual meeting of the Parties,  initial agreement
was reached on  definitions to be used in creating the three substance lists, and a preliminary list
was derived for substances  that  are  toxic and present in  the  Lakes (List  1).   Also, initial
agreement was reached on a new Specific Objective for dioxin, and on revisions in the Objectives
for  selenium  and  toxaphene.   These  objectives  will  not  be officially adopted  until public
consultation occurs  and official communication  is completed between the U.S. Department of State
and External Affairs Canada.

       Efforts by the Parties to develop definitions, lists and objectives will continue. This  work
will be reviewed regularly in the  semi-annual  meetings  of the Parties.  Considerable progress is
expected before the next formal report on the development  of objectives is due, in December
1990.

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     ANNEX 2: REMEDIAL ACTION PLANS AND LAKEWIDE MANAGEMENT PLANS


INTRODUCTION

        The basic  management framework of  the GLWQA  defines  environmental  quality
objectives and beneficial uses, requires monitoring the state of the Lakes and pollutant inputs, and
outlines management plans to identify the remedial actions needed to attain the desired objectives
and beneficial uses.  Nonattainment of Agreement  objectives  is addressed on three geographic
scales:   Lakewide Management Plans (LMPs) will address critical pollutants that are  impairing
beneficial uses  in  waters  of the  open Lakes, Remedial Action Plans  (RAPs) will  address use
impairments within designated  Areas of Concern (AOCs), and Point Source Impact Zones adjacent
to discharge points will be identified and minimized.

        Annex 2 of the amended GLWQA endorses and builds upon the existing efforts of the
Parties, States, Provincial governments, and the International Joint Commission (IJC) to develop
RAPs and LMPs.  The major provisions of Annex 2 include specifications for the content of RAPs
and LMPs, and requirements for designating critical pollutants for the boundary waters  of the
Great Lakes System with regards to LMPs.  The Annex also introduces the concept of Point  Source
Impact Zones, defining them as zones that "...exist in  the vicinity of some point source discharges,"
the size of  which "...shall be  reduced  to the maximum extent possible by  the best available
technology." Methods for identifying and delineating point source impact zones will be developed
and progress must be reported  beginning September  30, 1989, and reviewed biennially  thereafter
(Annex 2, Section 7).

        The Annex  also requires that  the Parties report to the IJC by December 31,  1988, and
biennially thereafter, on their progress  in developing and implementing RAPs and LMPs,  and  in
restoring beneficial uses to the Great Lakes System.


REMEDIAL ACTION PLANS

        RAPs are the result of a process that began in 1981 when the Great Lakes Water Quality
Board identified a number of geographic areas within the Great Lakes Basin (subsequently called
Areas of Concern) that had severe water  quality problems.  These areas were  seriously  out  of
compliance with Agreement objectives or jurisdictional standards, criteria, or guidelines established
to protect beneficial uses.  The present 42 AOCs include Lake areas adjacent to most of the major
metropolitan and industrial centers  within the Basin (Figure 1).  Of the total number  of  AOCs,
41  suffer  from toxic substances  contamination.   Most of  these  have  problems related  to
contaminated bottom sediments.

Responsible Parties

        Thirty AOCs are located wholly  or  in part within the United States.  The States have
taken responsibility for developing RAPs with assistance from various Federal agencies, including
the U.S. Environmental Protection  Agency's (USEPA's) Great Lakes National  Program  Office
(GLNPO), U.S.  Army Corps  of Engineers (USCOE),  U.S. Fish and  Wildlife Service (USFWS),  U.S.
Department of Agriculture, and U.S. Geological Survey (USGS).  Table 1 presents a  summary  of
the States  responsible for RAP development  and the completion status of U.S. RAPs.

        Illinois and  Indiana are both responsible for one AOC.  The Illinois EPA is coordinating
efforts on the Waukegan Harbor AOC, and  the Indiana Department of Environmental Management
is  developing a  RAP for the Grand Calumet River/Indiana Harbor AOC.

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Source,  (ireul Lukes Wuier Quuliiy Board, 19X7.
        Report lo llic liilernalioiiul Jouu Coiinnission,
        Windsor, Omurio, und Delroii, Michi^un, p .
                                  Figure I. Location of Areas of Concern in the (>reat Lakes

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         TABLE  1.  STATUS OF U.S. REMEDIAL ACTION PLANS
                                                Projected Date to
Areas of Concern                                Submit Completed RAPs
by State                                         for IJC Review
Illinois
Waukegan Harbor                                       Deferred

Indiana
Grand Calumet/                                         1989
  Indiana Harbor

Michigan
Torch Lake                                             1987
Deer Lake/Carp River                                   1987
Manistique River                                        1987
Kalamazoo River                                 Pending Civil Litigation
Muskegon Lake                                         1987
White Lake                                             1987
Saginaw River/                                         1988
  Saginaw Bay
Clinton River                                           1988
Rouge River                                            1988
River Raisin                                            1987

Michigan/Ontario
St. Marys River                                         1989
St. Clair River                                          1989
Detroit River                                           1989

Minnesota/Wisconsin
St. Louis River                                         1990

New York
Buffalo River                                           1989
Eighteenmile Creek                                      1990
Rochester  Embayment                                   1990
Oswego River                                           1989

New York/Ontario
St. Lawrence River                                      1990
Niagara River                                           1991

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        TABLE 1.  STATUS OF U.S. REMEDIAL ACTION PLANS
                              (continued)
                                               Projected Date to
Areas of Concern                                Submit Completed RAPs
by State                                        for IJC Review
Ohio
Maumee River                                         1989
Black River                                            1990
Cuyahoga River                                        1991
Ashtabula River                                        1989

Wisconsin/Michigan
Menominee River                                      1989

Wisconsin
Fox River/                                            1987
  Southern Green Bay
Sheboygan Harbor                                      1989
Milwaukee Estuary                                     1990

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         Wisconsin  contains  three  AOCs in their  entirety and shares two  others:  One with
Minnesota and one with Michigan. The Wisconsin Department of Natural Resources is responsible
for coordinating RAP  efforts.  The State uses the  Clean  Water Act, Section 208 Water Quality
Management  Plans  (WQMPs) as  a  management tool  for statewide prioritization.   The  State is
currently updating  the WQMP  for  the Lake Superior Basin and will incorporate their findings
into the St. Louis River RAP that Wisconsin is developing in cooperation with Minnesota.

         Michigan  has ten AOCs within its boundaries and, in addition, shares one  AOC with
Wisconsin and three with Ontario. The Michigan Department of Natural Resources is responsible
for developing  and/or coordinating RAP  initiatives.   Michigan  has several  other  statewide
initiatives related to the  restoration of  beneficial  uses called  for in Annex 2.   For example,
Michigan voters recently  supported  a $425  billion  bond issue to fund environmental protection
programs.  This fund will finance the cleanup of toxic waste sites  and other contaminated areas,
contribute to a regional Great Lakes protection fund, address solid waste problems, treat sewage
and other water quality problems, encourage reuse  of industrial sites, and preserve  open space.

         Four AOCs are located  in Ohio. The Ohio  EPA  is preparing  the RAPs in cooperation
with various  citizen advisory committees.

         There are  four AOCs located within  New York's boundaries  and two that  New York
shares  with Ontario.   All of New  York's RAP development and  coordination and cooperation
initiatives are managed through the New York State Department of Environmental Conservation.

         The following is a Lake-by-Lake discussion of the AOCs  and the progress that has been
made on the  RAPs  since the IJC's 1987 Report on  Water Quality.

Lake Superior
                                             2
         Lake Superior, is the largest (82,100 km )and the deepest (maximum depth of 407 m and
mean depth of 149  m)  of the Lakes, and has remained the most pristine and oligotrophic system.
Concentrations of polychlorinated biphenyls (PCBs) in lake trout  in Lake Superior continue to
exceed the Agreement  objective, while the DDT, dieldrin, and mercury  objectives are being met.
Public  health fish consumption advisories  have been issued for lake trout taken from Lake Superior
waters.

         The Water Quality Board has identified seven AOCs in Lake  Superior where GLWQA
objectives are not being met.  The following three  AOCs are located within the United States.

St. Louis River/Bay

         The St. Louis River/Bay AOC is  located  on  the  extreme southwest shore  of Lake
Superior.  The lower part of the river acts as the border between Minnesota and Wisconsin. Most
of the  river's watershed is in Minnesota. The AOC includes the St. Louis  Bay, Superior Bay,
Allouez Bay, the nearshore waters of Lake Superior and the St.  Louis River  below  the  Fond du
Lac dam.

         Historically, water quality has been  affected primarily by discharges from local industrial
and municipal sources.  Although water clarity above the zone  of  dischargers is fairly good,  the
water is stained slightly brown because of high content of humic  acids and  naturally occurring
related compounds.  Current  water quality data generally show no significant problems,  although
past data have indicated elevated levels of mercury at some  stations.  High levels of PCBs, dioxin,
and mercury  have also been found  in northern pike,  walleye, and  carp  tissue samples.

         The RAP  for  this AOC is being written by both Minnesota and Wisconsin.   Minnesota's
Pollution Control Agency has accepted the  lead role for this RAP, and Wisconsin is providing
technical assistance  and review. A RAP Coordinator was hired in June 1988, and initiation of the

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RAP development process has begun. Two public meetings were held in November, and a survey
of meeting participants' concerns and ideas has been completed.  A Citizen's Advisory Committee
will  be established in January  1989,  and soon after,  technical advisory  committees  will be
established for each issue area.  The RAP will identify the beneficial uses impaired, data gaps, and
remedial actions to restore the  beneficial uses.  Completion of the RAP is scheduled for June 30,
1989.

Torch  Lake

         Torch Lake, located at the base  of the Keweenaw Peninsula in the Upper Peninsula of
Michigan, is a tributary to Lake Superior.  Degradation has been caused by mine tailings disposed
of in the Lake  and sediments contaminated  with  creosotes and xanthates that were  used  in a
copper-concentrating  process from 1926 to 1969. These substances are thought to have caused a
high incidence of liver tumors and other malignant deformities in older, larger walleye and sauger
fish.   In recent years, the  incidence of tumors seems  to  have  decreased, however; fish of the
affected size class  can no longer be found.

         The Michigan Department of Natural Resources submitted a first draft of the Torch Lake
RAP in October 1987 and  received comments from IJC in June  1988.   Those comments are
currently being  addressed.   Most of the possible remedial actions have already  been taken.  No
effective method for sediment removal has been developed and remedial action will entail allowing
sediments from  upstream to cover the copper-contaminated sediment layer.

Deer Lake/Carp Creek/Carp River

         The Deer  Lake/Carp Creek/Carp River AOC includes Deer Lake, Carp Creek, and 20
miles of the Carp River  downstream to Marquette, Michigan, on Lake Superior.  Deer Lake is  a
907-acre impoundment located near Ishpeming in Michigan's Upper Peninsula.  In 1981,  mercury
was found at high concentrations in fish,  sediments,  and fish-eating birds.  A fish consumption
advisory has been  in  effect  since 1981.

         The  RAP for  Deer  Lake was  submitted in  October  1987.  In  1988, extensive  fish
monitoring was  conducted; fish were collected and their tissues analyzed for mercury  content.

St. Marvs River

         The St. Marys  River is one of the  four  Great Lakes connecting channels.  The  river
flows approximately 110 km from Lake Superior to Lake Huron.  The United States and Canada
share responsibility for developing remedial actions for the St. Marys River. Degradation  of water
quality can be attributed to power  generation, shipping traffic, and discharges of nutrients and
toxic substances from industrial and municipal point sources, as well as urban nonpoint source dis-
charges and combined sewer overflows. In particular, sediments are contaminated with  iron,  zinc,
cyanide, oils and  greases,  phenols, and wood particles,  while  the water column  has  elevated
concentrations of phenols, iron, zinc, cyanide, and ammonia.

         Completion of the  St. Marys River RAP has been delayed until September 1990 to allow
completion  of  the  Upper Great Lakes Connecting Channels (UGLCC) Study.  The  study  will
provide the region with new data that will be  incorporated into the RAP. The Cannelton Tannery
has  been designated as a Superfund site  by  USEPA.  No new site specific studies or  remedial
actions have been  undertaken since  1987.  The site has  a Binational  Public Advisory Council that
contributes to RAP development efforts.

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Lake  Michigan

         Lake Michigan lies completely within the United States, and is the second largest Lake
in terms of volume and depth, but the third in terms of surface area (57,800 km"2). PCB and DDT
concentrations are gradually  declining in  Lake Michigan lake trout, but still remain above the
Agreement objectives.  Public health fish consumption advisories have been issued for lake trout,
salmon, and brown  trout taken from Lake Michigan waters.

         There are ten AOCs on  Lake Michigan. A brief discussion of each AOC and the status
of RAP development follows.

Manistique River

         The Manistique River is located  in Michigan's central upper peninsula and flows from
the northeast, discharging into Lake Michigan at Manistique City.  Impacts to  biota were first
noted in the mid-1950s and were  attributed primarily to deposits of wood fiber and other organic
waste from sawmill  and papermill operations and to sanitary wastes.  Later studies also identified
several chemical wastes that contributed to degradation.  Environmental  degradation  at this site
is  primarily sediment contaminated with PCBs and  heavy metals, which adversely impacts biota
and causes fish consumption  advisories.

         The Michigan DNR submitted a  draft RAP in October 1987, received comments from
the IJC, and is revising the RAP accordingly. In addition, several studies  have been conducted
in the past  year  to  test  for  additional sources of contamination.   Specifically, fish  have been
collected from above the Manistique dam (outside the AOC).   In  summer  1988, fish tissue was
tested primarily  for  the presence  of PCBs. The results were not available  as of February  1989.
Sediment samples have also been  collected from within the AOC and from above the dam  to test
for and compare contaminant levels to State and Federal criteria.

Menominee  River

         The Menominee River AOC is shared by the States of Wisconsin and Michigan.  It acts
as Wisconsin's northeastern corner border and flows between Menominee, Michigan, and Marinette,
Wisconsin, emptying into Sturgeon Bay,  Lake Michigan.   The river generally receives  heavy
recreational use.  In addition, lake sturgeon use the area for spawning and there is an extensive
walleye fishing industry located at this site.  The primary concern here is the presence of arsenic
in the sediments of the Marinette  Harbor.  In addition,  PCBs have been detected in area fish, and
local beaches have been closed occasionally due to high counts of  fecal coliform bacteria.

         Officials plan to submit a RAP for  this area in 1989.   A Citizens Advisory  Committee
was established in early 1988.  The Committee's role is  to develop community support and review
recommendations. A technical work group is also being established and will hold its first meeting
in November 1989.  The RAP will be developed in conjunction with a Consent Order between the
USEPA and the  Ansul Fire Protection Company,  which is being held responsible for discharges
of arsenic to the local publicly owned treatment works.  More detailed information is confidential
to date and  further  RAP development  is dependent  upon disclosure.  Wisconsin has the lead role
in this joint endeavor with  Michigan and will hire a full-time RAP coordinator when  funds
become available.

Fox River/Southern  Green Bay

         The Fox River/Southern Green Bay AOC  is located in northeastern Wisconsin near the
west shore of Lake Michigan.  The AOC includes the City of Green Bay, the lower 7 miles  of the
Fox River, and the southern end  of Green Bay, extending  north to an imaginary line from Long
Tail Point to Point au Sable (approximately 20 square miles).  Although there have  been marked
improvements in the water quality and  fisheries in this AOC, major problems still exist regarding

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toxic contaminants, excess nutrients and turbidity, and habitat loss.  Over  100 toxic substances,
including  37 priority pollutants  and 11 different resin  and fatty  acids, were identified in the
discharges  to the Lower Fox River from  14 pulp and paper  mills and five major municipal
wastewater treatment plants.

        The first draft of the Fox River/Southern Green Bay RAP was submitted in 1987. The
Wisconsin Department of Natural Resources (DNR) has  received comments from  the IJC on the
first draft and will address these concerns in a letter to the IJC.  The RAP has also been submitted
to the Secretary of the DNR as part of a statewide water quality management plan.  The RAP  is
now being implemented, and an implementation coordinating committee has been established. This
committee  is chaired by a county executive, ensuring that local citizens will be involved with the
RAP process.  The committee acts  as an advisory council to the DNR and is divided into two
subcommittees:    a  nonpoint source subcommittee and a public education and participation
subcommittee.

        In support of the RAP, the Wisconsin DNR and the USEPA are coordinating the Green
Bay Mass  Balance Study.  Wisconsin is conducting numerous studies on the Fox River that will
contribute  data to the mass  balance modeling  effort.   The State  is also developing a  detailed
program for cleaning up the East River, which is a State-designated  priority watershed.  This
includes Best Management Practice  development and a cost-sharing plan to aid  local counties  in
nonpoint source pollution cleanup.  In addition, the Green  Bay Municipal Sewerage District  is
upgrading  its system to meet current effluent limits.

Lower  Sheboygan River and  Harbor

        The Lower Sheboygan  River and Harbor  AOC includes  the  entire Sheboygan  Harbor
and approximately 12 miles of the  river from its mouth to  Sheboygan Falls.  Problems include
PCB-contaminated fish and  sediments resulting in a fish consumption advisory, high  bacteria
levels,  excess sediment and  turbidity, and a poor  quality community of  aquatic organisms  as
indicated by an overabundance of pollution tolerant insects and algae.

        The Sheboygan River Task Force  and the Citizens Advisory Committee are cooperating
with the Wisconsin DNR to develop the RAP for this site.  Currently, a definition  of the  problem
has been distributed for public  comment,  and recommendations for corrective action are  being
drafted.  A draft of the RAP is now under public review.  The final draft is  expected  to  be
submitted  to the IJC  by April 1989.  The  State is cooperating  with Superfund and priority
watershed designations to prevent a duplication of effort. In addition, the State recently completed
an update  to the  Sheboygan Water Quality Management Plan (as required by Section 208  of the
Clean Water Act). The State will submit this  as a supplement to the RAP, which is projected for
completion in early  1989.

Milwaukee Harbor

         The Milwaukee Harbor  AOC  encompasses the lake  level  portions  of  three  rivers,
Milwaukee Harbor,  and the  nearshore areas of  Lake Michigan.  The  rivers  are the  Lower
Milwaukee River, the  Menominee River, and  the  Kinnickinnic  River.   Major water quality
problems  include sediments contaminated with toxic  inorganic  and  organic substances, low
dissolved oxygen  levels, a fish consumption advisory, excess nutrients and sediments, high bacteria
levels, lack of spawning habitat, and conditions  that detract from  recreational use of the area.

         The Wisconsin DNR is currently completing a  paper evaluating the need for developing
a traditional RAP.  This paper discusses the problem, objectives, activities and responsibilities, a
timetable,  and the public role in the process.  It is currently  being  circulated among communities
for public comment.  Other RAP components are being coordinated with at least 11 completed  or
emerging  management plans.  The RAP is  scheduled for completion in October 1990.
                                             10

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         Currently, a minimum of five projects  related to the restoration of beneficial uses  in
Milwaukee Harbor are being conducted:

         •  Currently, efforts are being conducted to identify nonpoint source pollution,
            establish objectives for nonpoint source management, and ultimately provide
            a cost-sharing plan to aid cleanup efforts.

         •  The Southeast Wisconsin  Regional  Planning  Committee completed  the
            Milwaukee Estuary Study in 1987, which  involved intensive modeling of
            the rivers and harbor to determine the level of pollution control needed to
            meet water quality standards.

         •  The University of Wisconsin is  developing a strategic management plan for
            navigation and environmental management for the Milwaukee Harbor.

         •  The Port of Milwaukee Authority is conducting an economic plan for the
            Harbor, which will address revitalization.

         •  Wisconsin DNR is developing an  integrated resource management plan for
            nonpoint source pollution, fisheries,  and wildlife.

In addition, a Citizens Advisory Committee is being established,  consisting  of a single advisory
committee for the RAP, the watershed,  and  the integrated management plan. The State has also
established a  Milwaukee  Revitalization Council  to  assess  the economic,  environmental,  and
recreational revitalization of the Milwaukee  River Basin.

Waukegan Harbor

         Waukegan  Harbor is located on the western shore of Lake Michigan, approximately 40
miles north of Chicago in Waukegan, Illinois. The Illinois EPA is responsible for coordinating the
development of  the RAP for the  37 acres of contaminated harbor sediments and soils.

         Specifically, the  harbor's  sediments  and soils  are  ladened  with PCBs.  The principal
source  is  thought to be discharges from the Outboard  Marine Corporation  (OMC) in the early
1970s.  As much as  1.1 million pounds of PCBs contaminate the site, 300,000  pounds of which are
in the harbor itself.

         In 1984, USEPA  set forth a Record of Decision authorizing expenditures of $21 million
to clean up the  site.  The project was suspended, however, pending the conclusion of litigation
regarding access to  CMC's property.  Negotiations have been under way since late 1986 between
USEPA,  Illinois EPA, and OMC regarding a specific  proposal  for  corrective action that was
submitted by OMC.  In 1988, these negotiations led to  a Consent Decree, which  established the
areas to be remediated, the methods to be used, and the financial responsibility, both immediate
and long-term, for  the cleanup. OMC will finance a trust to implement cleanup and  will  ensure
performance of  that trust.  Once these remedial actions  have  been completed, the State will  then
reassess the necessity of a RAP.

Grand  Calumet  River/Indiana Harbor

         The Grand Calumet River/Indiana Harbor Canal is located in northwest Indiana.  The
AOC includes the entire Grand Calumet River (13 miles long) and the Indiana Harbor, which is
approximately 15  miles south of  downtown  Chicago.   Many years of heavy  industrial and
municipal activity along the Grand Calumet River and  the Indiana Harbor Shipping Canal have
created severe water quality problems that have only recently begun to diminish.  Degradation is
primarily  reflected in severely polluted sediments  contaminated with oil and grease, PAHs, PCBs,
heavy metals,  and many other priority  pollutants.  Despite improvements over the past  5  to 7


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years, the capacity to assimilate pollutants in the River and  Canal is diminishing.  The Indiana
Department  of Environmental Management (IDEM) is  primarily  responsible for  coordinating
cleanup initiatives.

          A preliminary draft RAP for the Grand  Calumet River/Indiana Harbor, prepared in
1986, identified numerous data gaps including information on the harbor and nearshore areas, air
quality, solid and hazardous wastes, and sediment management issues.  By January 1988, a revised
RAP  had been drafted  and distributed  for  public comment.  The primary mechanism  for the
development of  this second draft was  the  Remedial Action  Plan  Work  Group,  composed of
individuals from the IDEM, USEPA, USCOE, USFWS, USGS, and several public interest groups.
The State is negotiating for expanded public participation, as reflected in  the development of a
draft  public participation/outreach workplan published in October 1988.  The work plan,  to be
implemented in FY 1989, includes recommendations for making videotapes, buying television time,
conducting workshops and seminars, and providing other general outreach  to neighborhoods and
others the RAP will affect. The goal of the workplan is to rally community support  for the  RAP.
The State plans to submit a final RAP draft to IJC  in early  1989.

         The  Indiana  RAP will  focus on corrective action for  solid and hazardous  waste
management issues  and will recommend further assessment  of sediment  contamination  and air
deposition.  Some studies pertaining  to the contaminated sediment issue are  in progress.  IDEM
has contracted with the USCOE to write an Environmental Impact Statement by early 1989 that
defines  management options for contaminated sediments  in  the  River  and Canal.   In addition,
work  has begun on  a State-funded study  to define the amount and characteristic of sediment
buildup in the Grand Calumet River. The USCOE  is conducting a similar study in the Indiana
Harbor.

Kalamazoo River

         The Kalamazoo River is located in the southwest portion of Michigan's lower peninsula.
The river flows in a westerly direction and discharges into Lake  Michigan.  The major problem
in the Kalamazoo River  is PCB contamination of biota, water, and  sediments. Historically,  the
primary source of PCBs has been wastewater discharges from paper industries.  Presently,  how-
ever,  problems  are  directly attributable  to inplace PCB-contaminated  sediments, where an
estimated 230,000 pounds of PCBs reside.

         The  draft  RAP for  the  Kalamazoo River, prepared  in  1986,  includes  cost/benefit
analyses, tentative timetables, and feasibility studies. In addition, specific  remedial actions have
been  evaluated,  although no particular methods  have been officially selected.  Georgia Pacific
Corporation completed a State-requested study of PCB-contaminated waste disposal ponds, as well
as a follow-up study to recommend options for  remedial action.  The  Michigan Department of
Natural  Resources  (DNR) is  currently evaluating  these  options.   Other  studies reported  in
Appendix A of the 1987 Water Quality  Board Report to the IJC are ongoing.  No  new research
initiatives were undertaken in late 1987 or 1988.

         The Michigan DNR has  reviewed and  responded to public comments on the first draft
of the RAP.  The final RAP was planned for submission to IJC in October 1988;  however, the
deadline was postponed because of the State's involvement in civil litigation against Allied  Paper
Incorporated and other parties that  may be contributing PCBs to the river.

Muskegon Lake

         Muskegon Lake is a 4,ISO-acre  inland  coastal lake located  in Muskegon  County along
the eastern shoreline of Lake Michigan, north of the City of Muskegon. Before 1973, Muskegon
Lake received direct discharges of industrial process wastewater,  municipal wastewater treatment
plant effluent, combined sewer overflows,  and urban runoff.  The excess nutrient enrichment and
solids and   toxic  substance loadings  resulted  in nuisance algal  blooms, reduced  oxygen


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concentrations  in  the  water column,  tainted  fish,  and  contaminated sediments.   Petroleum,
chemical, and other heavy industries in the area have also contributed to  contaminated ground
water.

         The Muskegpn Lake RAP  has been submitted to IJC for secondary review.   Most of
the remedial actions included in the RAP have already  been taken.   Proposed actions concern
studies regarding the environmental health of localized areas (i.e., tributaries and tributary mouths)
that do  not affect  the AOC as a whole.

         Michigan is currently submitting fish  tissue samples of bass and walleye for laboratory
analysis. Data is expected by April 1989 and should provide information on the sources of PCBs,
chlordane, and mercury.   Preliminary analysis indicates that atmospheric deposition, rather than
point or localized sources, is responsible for increased contamination. Remedial action to contain
seepage of contaminated  ground water into Little Bear Creek has begun.

White Lake

         White Lake is also  located in Muskegon County, along the eastern shoreline  of Lake
Michigan in the vicinity  of Montague and Whitehall, Michigan.  This AOC includes White Lake
proper  and  a  0.4  km zone  around  the  lake.   The major  environmental problem   here  is
contaminated ground water entering White Lake from the Occidental (Hooker) Chemical Company
property.   The  contaminants of  concern  include trichloroethylene,  carbon tetrachloride,  and
perchloroethylene  in ground  water, as  well  as hexachlorobutadiene,  hexachlorobenzene,  and
octachlororcyclopentene in the soil. Michigan DNR recently tested sediments as a potential source
for PCBs and chlordane found in carp.  Preliminary  results indicate that these two contaminants
are below the  detection level for sediment.

         The RAP has been submitted for secondary review by the IJC and most of the remedial
actions embodied in  the plan have  been taken.   Attention is now being focused on more localized
problems that  do not affect the AOC as a whole.

Lake Huron

         Lake Huron is the second  largest Great Lake in terms  of surface area (59,700 km2).
Like Lake Superior, Lake Huron has  a drainage  basin that supports lower population densities and
more forested  lands than  the other Great Lakes.  Consequently, the quality of the open waters of
Lake Huron is generally high, with levels of nutrients and major ions within GLWQA objectives.


         Concentrations of dieldrin and DDT in Lake Huron lake  trout are below the Agreement
objective, although there  appears to be no decreasing  trend in concentrations since 1979.  As with
most of the other Great Lakes, Lake  Huron's PCB concentrations in lake trout continue to exceed
the objective.  There also does not appear to be a trend of decreasing  PCB concentrations since
1979.  Public health fish advisories have been issued suggesting that the consumption of lake trout,
rainbow trout, and brown trout caught in  Lake Huron  waters be restricted.

         Of the four AOCs on Lake Huron, only Saginaw Bay exists within U.S. boundaries.

Saginaw Bay

         Saginaw Bay is  a western extension  of Lake  Huron located in the east central  portion
of Michigan's lower  peninsula.  Anthropogenic inputs to the Bay are dominated by agriculture in
the rural areas of the  Basin and by industrial  and municipal wastewater discharges  from four
major urban areas  — Flint, Saginaw, Bay City, and Midland, Michigan.  The major water quality
issues of concern are eutrophication  and toxic  contamination, including PCBs and heavy  metals.
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         The final version of the Saginaw  Bay RAP was produced in October 1988.   The most
significant action taken since  1987 is the development of a mechanism for public education and
outreach under the auspices of the Saginaw Bay Natural Resources Steering Committee (SBNRSC).
This Committee was formed in July/August 1987.  In  September, the State submitted a rough
version of the RAP to SBNRSC, which the Committee reviewed for about 6 months, providing the
State with comments that  were later incorporated into the RAP.  A similar process was followed
for a second draft of the  RAP.

         The Committee is also in the process of establishing a nonprofit corporation to set up
a fund  that would respond to natural resource  problems throughout Saginaw Basin.  SBNRSC
activities for  1989 include completing  the  nonprofit  application process activities;  gathering
personnel to administer the nonprofit corporation; maintaining interaction between the public and
the Michigan DNR regarding  RAP activities; producing a lay version of the RAP consisting of a
55-page  brochure to be distributed to  the public; issuing  a quarterly newsletter dealing with
Committee  activities,  as  well as RAP  issues and general  resource  issues;  and establishing a
nonpoint source committee to coordinate and direct the nonpoint source  management  efforts on
a basin-wide scale.

St. Clair River

         The  St. Clair  River  is a connecting channel  that  serves as  an  outlet of Lake Huron,
flowing south to Lake St. Clair. The St. Clair River is  shared by  the United States and Canada.
The river is an important international waterway with heavy demands placed upon it as a shipping
channel and as a source of water for commercial, industrial, and domestic uses. Sediments have
been contaminated by chlorinated organics and volatile hydrocarbons, while the water column has
been degraded by discharges of nutrients and toxic substances from industrial and municipal point
and nonpoint sources and from inplace  pollutants.

         The St. Clair River RAP's schedule has been extended to September 1990.   Delays  can
be  attributed to extensive efforts in this region  to complete  the UGLCC  Study.  The  study will
contribute  new data that will be incorporated  into the RAP.   A Binational Public Advisory
Council is in place that contributes to RAP development efforts.

Lake  St. Clair

         Lake St. Clair is a small shallow lake that connects  the St. Clair  River with the Detroit
River between Lakes Huron and Erie.   It  supports an  active recreational  fishery, as well as  an
international navigation channel.

Clinton River

         The Clinton River AOC is located on the eastern shore of Michigan, approximately 15
miles north  of Detroit's Belle Isle and discharges into Lake St. Clair at Mount Clemens, Michigan.
In  the past, nutrients, oxygen-consuming substances, and heavy metals have been discharged to
the Clinton  River  by  industries and municipal wastewater treatment plants, resulting  in  low
dissolved oxygen and  degradation of  biological communities  downstream of  the  discharges.
Impaired uses have been caused by exceedingly high fecal coliform bacteria counts, heavy metals,
and PCB-contaminated soil.

         A  RAP for this site was completed  in  October 1988 and was submitted to the IJC in
early  November. Thus far, sources of contamination have been identified, but no remedial action
has taken place.  The  State is waiting for RAP recommendations to be approved.
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Detroit River

        The Detroit River connects Lake St. Clair and Lake Erie and serves as an international
boundary between Michigan and Ontario. The Detroit River AOC is the third international AOC.
The  Detroit River is used extensively  for shipping,  recreation, and public and industrial water
supply.  The river receives treated wastewater from numerous municipal and industrial facilities,
direct storm runoff, and combined sewer overflows.  Sediments contain high levels of PCBs, heavy
metals (mercury,  cadmium, chromium, copper, and zinc), and oil and grease.

        This AOC has been a major focus of the UGLCC Study. The information gathered will
be particularly useful in developing the Detroit River RAP.  The Detroit River RAP is scheduled
for submission to the IJC by December 1989.

Lake Erie

        Lake Erie is the fourth largest Great Lake in  terms of surface area (25,700 km2)and is
the most shallow  lake, with a mean depth of only 19 meters. It consists  of  three distinct basins
that  differ  in water quality characteristics.  Lake Erie's shores are highly urbanized and its major
tributaries  drain  intensively farmed soils.   Lake Erie was  the first of  the Lakes to  show
systemwide signs  of cultural eutrophication, but was also quicker to respond than the other Lakes
to cleanup  efforts because of its relatively short retention time.

        Concentrations of DDT and dieldrin in Lake Erie remain below the Agreement objective
for fish tissue concentration.   PCB concentrations are  elevated  above the objective level, with
concentrations in  walleye being about five times the objective level.  Both  carp and catfish are the
subject  of public health  fish  consumption  advisories,  with  restricted  consumption  being
recommended in New York and no consumption being recommended in other States bordering the
Lake.

        The Water Quality Board has designated seven AOCs within the U.S. boundaries of Lake
Erie, discussed below.

Rouge River

        The Rouge River flows through Metropolitan Detroit and empties into the Detroit River.
The  lower  Rouge  River is  the most severely polluted river  in the Basin.   Sediments  are  heavily
contaminated with toxic substances and organic sludges, precluding the presence of normal aquatic
life.   Toxics include cadmium,  chromium, copper, lead, mercury, nickel, and zinc.  The  river is
also  moderately polluted with PCBs that  are bioaccumulating in carp and catfish.

        The  first draft of  the RAP  was  submitted to the  IJC  in  1988.   The  State  is
simultaneously conducting discussions with local communities. The RAP recommends implementa-
tion  and remedial action rather than further investigation and assessment. The State  plans to make
a final submission to IJC in January 1989, but views the RAP as a fluid document that  will be
revised continually to reflect yearly efforts until the Rouge River can be removed from the AOC
list.

River Raisin

        The River Raisin is located in  the southeastern portion of  Michigan's lower  peninsula
in Monroe County, Michigan.   Problems that exist include  heavy  metals (copper, zinc,  and
chromium) and  PCB  contamination of  sediments  and the water column,  sedimentation,  and
siltation from nonpoint sources.

        The RAP was submitted in October 1987 and IJC's comments have been incorporated.
The  RAP will be updated as needed.  Public meetings  were held before the  RAP was developed


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to gain community input, and the public was asked to review the draft upon its completion.  The
RAP already had a strong base of public support, however, building upon an existing Rouge River
Watershed Council, to the north  of the River Raisin.  The Council acted as a Citizens Advisory
Committee, developing and contributing to community support and providing publicity.

        The Michigan DNR has undertaken several studies to date in support of the River Raisin
RAP.  The State completed a caged-fish study in July and August 1988 (fish were held for 28
days in cages suspended  in the  water column,  then the  fish tissue  was  sampled) to  test for
bioaccumulation/bioconcentration.  Samples have  been submitted to a laboratory for analysis, but
there are no  results to date.  The State is also conducting preliminary sediment samples in six
different locations to  identify  hot spots and other sources of PCBs and  heavy metals.   Both of
these studies were funded with an $87,000 grant under Michigan's Act 307.  Several other cleanup
projects that  were recommended in the RAP  are  being  conducted independently  of  RAP
implementation.  Both the Ford  Motor Company and Port of Monroe  have  been  designated Act
307 sites, and remedial action programs are being developed.

Maumee River

        The Maumee River AOC has been tentatively identified as the area from river kilometer
33 to the mouth, Maumee Bay, the nearshore  area southeast of the mouth, and the lower segments
of several streams tributary to  the main stem and the Bay.  Water  quality violations  include
dissolved oxygen,  ammonia,  arsenic, lead,  copper,  zinc, cadmium,  iron,  mercury,  and  fecal
coliform bacteria.  Fish tissue samples indicate elevated PCB levels in whole-body composites and
sediments polluted with oxygen-consuming materials, cyanide, arsenic, copper, nickel, zinc, iron,
ammonia, total phosphorus, and  oil and  grease.

        The Toledo  Metropolitan Area Council of  Governments (TMACOG)  has initiated  a
baseline investigative study describing the problems of this AOC. The report has  been submitted
to Ohio EPA, and the two groups are now in  the process of negotiating the  next  step  (i.e.,
determining who will take the lead  for the draft  RAP).  The  RAP completion date is set for
August 1989.  TMACOG will draft and revise as  necessary a recommendation paper on which
Ohio EPA  will base its RAP development.  TMACOG will continue to lead local involvement
since they were responsible for organizing the local  communities into a  Remedial Action Advisory
Committee, which is composed of both a technical and a public outreach component.

Black  River

        The proposed boundaries for the Black  River AOC are the lower  15 miles of the river
from Elyria  to the mouth, the  harbor,  and the  adjacent  nearshore.   Violations of Ohio  water
quality standards for protection of warm-water habitat are noted in the Black River for dissolved
oxygen, ammonia, fecal  coliform bacteria, iron, lead, phenol,  cyanide, cadmium, and copper.
Elevated concentrations of biological oxygen demand, total phosphorus, and zinc are also common.
In addition, sediments in  the harbor are heavily polluted with metals, oils and grease, and  oxygen-
consuming  materials.  A  fish consumption and contact advisory is still in effect  for the lower  5
miles of the  river.  The advisory was issued in 1983 due to a high incidence of tumors in fish.
The occurrence  of tumors has been  linked  to comparatively high PAH levels in the sediment
adjacent to the old U.S. Steel Coke Plant.

        GLNPO's contractor  completed a background  report for this AOC in  1986.  A RAP
process integrating public participation  has  not  yet been developed for the Black River,  but  a
number of major remedial activities  are in progress and nearing completion.  Activities include
major  improvements to the Elyria and Lorain municipal treatment plants and sewers. In addition,
U.S. Steel is planning to dredge PAH contaminated sediments from the river in the summer 1989.
Currently, it is anticipated that Phase  I of the Black River RAP will be submitted to IJC in 1990.
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Cuyahoga River

         The  Cuyahoga  River winds  its way  from  a  reservoir just  south  of East Clarendon
southwest to Cuyahoga Falls and then flows north northwest through  Cleveland, emptying into
Lake Erie.  The most impacted area of the Cuyahoga  River is the shipping channel.  The natural
hydrology and morphometry of this segment have been altered through channel dredging and
shoreline development.  The lower river is also  affected by industrial dischargers, including steel
mills and  chemical  companies,  urban  runoff,  combined   sewer  overflows, and municipal
dischargers.  Violations of Ohio water quality standards occurred with dissolved oxygen, cyanide,
iron, and copper, as well as ammonia,  fecal coliform  bacteria, phenol,  lead, cadmium, -and zinc.
Sediments are heavily  polluted with ammonia,  total Kjeldahl nitrogen, phosphorus,  cyanide, oil
and  grease,  cadmium, chromium, copper, lead,  manganese, nickel, zinc, iron, and volatile solids.

         The  first public meeting  was held regarding a RAP for the site  in November  1987.
Ohio EPA identified approximately 30 individuals to create the Cuyahoga Coordinating Committee
(CCC).  The CCC is further divided into three work groups:  Communication, Technical, and
Resource. A Policy Advisory Committee  will be  established to  review and  comment on the
implementability of the RAP recommendations. The  Ohio EPA is anticipating RAP completion
in 1991.

Ashtabula River

         The Ashtabula River AOC includes the lower 2 miles of the river, the harbor, and the
adjacent nearshore.  The major concern is sediments  that have been contaminated with  oxygen-
consuming materials, metals, industrial chlorinated  organics,  and PCBs.  The primary source of
these pollutants was past industrial discharge  to Fields Brook, a tributary to the lower  river.
Fields Brook sediment was subsequently classified as  hazardous and cleanup is being addressed
under Superfund.

         A  local  advisory  council  was  established  in  February  1987   and  divided  into
subcommittees to provide both technical  and public outreach  support.  Recent RAP efforts have
focused on coordination  with the Fields Brook  Superfund site to dredge contaminated sediments
in the river.  The river has not been dredged since 1962, and the water is becoming too shallow
to support the extensive marinas that  now  line the  shores.   The dredging  program  is being
coordinated with the USCOE.  RAP activities will stress corrective action, rather than assessment
or management practices. The Ashtabula River RAP  is scheduled for  completion in late 1989.

Buffalo River

         The Buffalo River is located  in western New  York  and  empties into Lake Erie.  The
River is approximately 6 miles long  and is fed by three major tributaries: Cayuga, Cazenovia, and
Buffalo Creeks. The AOC includes the lower  portion of the river, the  river's mouth, and the
nearshore lake area surrounding the harbor. The  Buffalo River  has  been subject to pollution
problems such as bacteria, oil, excessive levels of phosphorus, chlorine, phenol,  mercury, and
general discoloration since the 1940s. New and  updated municipal wastewater treatment  facilities
and  controls  on industrial point  source  discharges  have  reduced significantly most of the
conventional pollutants. The major  problem in the Buffalo River aquatic system currently is toxic
substances, including heavy metals,  pesticides, dioxin,  and industrial organic compounds (such as
PCBs, chlorobenzenes,  and  PAHs).

        A draft RAP is scheduled for January 1989.  The draft will receive public review and
submitted to IJC by May 1989.  The RAP will recommend corrective action, but will not provide
a detailed  workplan.  This  site also  has a Citizens Advisory  Committee  that  has  played  a
significant role in the development  of the RAP.
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Niagara River

        The Niagara River, the fourth connecting channel, connects Lake Erie and Lake Ontario
and forms  the international boundary  between Canada  and the United States.   The  river is  a
source of drinking water and industrial process and cooling water; is an energy source and a major
tourist attraction; and receives discharges and wastes from industries and municipalities along its
shores.  The  major  issue in the Niagara River is toxic substances and their potential effects on
human health and the ecosystem.  Water quality criteria are exceeded for heavy metals, including
aluminum,  cadmium, chromium, copper,  lead,  and  silver.   Mercury,  arsenic, cyanide, and
selenium, as well as several pesticides, have begun to pose water quality problems.  Sediments are
also contaminated with conventional pollutants, heavy metals, industrial  organic chemicals, PCBs,
and pesticides.

        The preliminary steps for developing a RAP began in 1988. RAP development  will  begin
in January  1989, with  an anticipated completion date of January 1991.  The development of  a
Citizens Advisory Committee is also forthcoming.  The  RAP will incorporate the 1984 findings
of the Niagara River Toxics Committee and the Niagara River Toxics Management Plan discussed
later in  this report.

Lake  Ontario
                                                                 2
        Lake Ontario  is the  smallest of the Great Lakes (19,520 km ),but with a mean depth
of 86 meters, is deeper than Lake  Erie.  Located at the end of the Great Lakes  chain,  Lake
Ontario  receives nutrients and toxic contaminants contained in the outflow of upstream systems.
Because of this source and those  within the basin, Lake Ontario generally has high open  water
pollutant concentrations.

        Lake trout in  Lake  Ontario contain  PCB concentrations that  greatly exceed the
Agreement  objective. Even though  there appears to be a slight downward trend  in concentration
over the last 9 years, PCB levels still are ten times the Agreement objective.  DDT concentrations
in lake  trout approach the GLWQA objective and  apparently have not declined  significantly  in
recent years.  Dieldrin concentrations in lake trout appear to be declining in Lake Ontario and are
already  lower than the Agreement objective of 0.3  mg/kg, however.  Public health consumption
advisories have been issued for numerous fish species taken from Lake Ontario.

        The Water Quality Advisory Board also identified four AOCs within the U.S. boundaries
of Lake Ontario. These areas, which exceed GLWQA water quality objectives for at least one
parameter,  are as follows.

Eighteenmile Creek

        The Eighteenmile Creek AOC  includes Eighteenmile Creek, Olcott Harbor,  and the
nearshore waters of  Lake Ontario at Olcott, New York.   Water quality, sediment, and fish have
been contaminated by heavy  metals, PCBs, pesticides, and other volatile organic  compounds.

        GLNPO's contractor prepared an initial draft RAP  in September  1988.   NYSDEC has
no timetable  for completion.

Rochester Embayment/Genessee River

        The Rochester Embayment AOC is defined as nearshore Lake Ontario at Rochester and
Rochester Harbor, New York, and the Genessee River located in Monroe County. Major problems
include  toxic contamination of the water column and sediments, PCBs and mirex in fish flesh, and
ammonia toxicity.
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         GLNPO's contractor prepared an initial draft RAP in 1987.  The draft RAP for this
site is under way and should be completed by December 1990.  The Monroe County government
will be the primary agency to develop issues presented in the RAP.  Public participation will be
achieved through several existing citizen committees already involved with environmental issues.

Oswego River

         The Oswego River AOC includes  the Oswego River, Wine  Creek,  and the adjacent
nearshore waters of Lake Ontario at Oswego, New York.  Major problems include nutrient and
toxic substance contamination of water and sediments, PCBs and mirex in fish flesh, and probable
ammonia toxicity.

         GLNPO's contractor prepared an initial draft RAP in 1987.  The draft RAP for this
site is  scheduled  to be completed by  November 1989.  A Citizens  Advisory  Council has been
designated and has been very active in providing both technical and political support.

St. Lawrence River/Massena

         The  St.  Lawrence  River has  been  identified  as  an AOC   because  of  degraded
environmental conditions in the Cornwall/Lake St. Francis and Maitland areas in Canada and the
Massena, New York, area in the United States, which are contaminated with heavy metals, PCBs,
and other toxic substances.  RAPs for this site are being developed in parallel by both  New York
and the governments of Canada and Ontario.  Quebec and the Mohawk Nation at Akwesasne are
participating in the effort.  The New  York State Department of Environmental Conservation is
directing GLNPO's contractor in preparing an environmental data base to assess the information
available on impaired uses in the AOCs. In addition, SAIC is analyzing 1984 sediment data from
seven segments of the St. Lawrence River.  The anticipated  date of RAP completion is June 1990.


LAKEWIDE MANAGEMENT PLANS

         Lakewide Management Plans  (LMPs) provide an approach for  reducing contaminant
loadings in open lake waters and involve the same  basic principles as those for  RAPs.  However,
LMPs differ from RAPs in the breadth of their focus, since they address entire lakes rather than
the more  localized AOCs.  Given  this scope, monitoring becomes  more  complex  and airborne
deposition  becomes a far more  important factor.  In addition,  the appropriate mix of remedial
actions and coordination among jurisdictions differs from that of the RAP process.

         The concept of lakewide management planning  involves  a stepwise problem-solving
process.   In  developing  and implementing LMPs,  the U.S.  and  Canadian  Governments, in
cooperation with the States and  Provinces,  are to:

         •  Define the problem, in terms of threats posed by specific critical  pollutants

         •  Select remedial measures

        •  Implement remedial programs

        •  Monitor ecosystem  recovery

        •  Remove designation of a  Critical Pollutant, once it can be demonstrated  that it no
            longer presents a problem.

        GLNPO, in consultation with the  States and other EPA offices,  has initiated  a detailed
study of technical and management options  for the  development of LMPs.   In particular, GLNPO
is working with the States to relate this process to existing programs and requirements  under the


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Clean Water Act. This study will identify specific approaches for accomplishing each LMP step,
analyze the  advantages  and disadvantages  of  these approaches, and develop  a prototype  LMP
outline.

         This analysis of alternatives is  expected  to draw heavily upon the experience gained to
date in a number of recent studies and model lake management efforts,  including the Niagara
River Toxics Project, the Green Bay  Mass Balance Project, the Lake Michigan Toxic Pollutant
Control/Reduction Strategy, the Lake Ontario Toxics  Management Plan,  and  the Upper Great
Lakes  Connecting Channels Study.  As summarized in Table 2,  these efforts  have  contributed
substantially  to the evolution of  the  lakewide  management planning  concept.    Additional
information on each of  these and other  key studies and planning  activities is provided below.

Niagara  River Toxics  Project

         The Niagara  River  Toxics  Committee  was  a binational  group  formed  in  1981 to
investigate toxic chemicals in the Niagara  River, its tributaries, and a small part of  Lake Erie.
The objectives  of the project were to identify specific contaminants of concern; determine the
relative contribution of sources of contaminants to the total load levels; monitor concentrations of
key contaminants in water, sediment, and  biota;  and assess the effectiveness of existing control
programs.

         In  1984, the  Committee reported on the  results of its study.  The Committee identified
261 manmade chemicals that occurred in the Niagara River, but focused on the distribution and
sources  of  eight  contaminant groups  (e.g., acid extractables,  PAHs,  PCBs).    Numerous
improvements in regulatory programs were recommended to reduce point source loadings.  Other
recommendations included expediting hazardous waste site cleanups, improving waste management
practices, and supporting additional studies on the local hydrogeology  of contaminated ground
water.

         A  number of  areas of contaminated sediment were  identified as  potential  targets for
remedial action.  Requirements for long-term monitoring  were discussed and  recommendations
were made  on  quality assurance requirements.  The Canadian members of the Committee also
recommended that the Niagara River serve  as a pilot site for implementing a toxic loading alloca-
tion plan based on a  mass  balance concept, and that regulatory  programs be designed to
progressively reduce discharges of key contaminants toward a "zero discharge"  goal.

         Subsequently,  the  USEPA,   Environment  Canada,  the  Ontario  Ministry  of the
Environment, and the New York State Department of Environmental Conservation signed a four-
party agreement to restore Niagara River water quality. The agreement,  signed in February 1987,
is embodied in the Niagara River Toxics Management  Plan that calls for a 50-percent reduction
of the total  loads of persistent toxicants from point and nonpoint sources  over  the next decade.

         The first  phase of  the agreement,  completed  in August  1987, created  a list of 92
persistent toxic pollutants  of  concern.  From that list, ten chemicals were identified  for a 50
percent  reduction  based  upon exceedances  of  various  standards,  guidelines, or  objectives.
Although this effort occurred outside the IJC framework, it is  an  example of an  institutional
arrangement among multiple jurisdictions to reduce the total loadings of persistent toxic chemicals
to a Great Lakes water body not presently achieving all attainable uses.
                                            20

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TABLE 2: CONTRIBUTIONS OF SELECTED RECENT ACTIVITIES TO THE EVOLUTION
                OF LAKEWIDE MANAGEMENT PLANNING
Elements ot'Lakewide Management Plans
Defining the Problem
Surveillance and Monitoring Methods/Strategy
• Sources
• Ambient Ecosystem
Fate/Distribution Assessments by Contaminant
Effects/Risk Assessments by Contaminant
Source/Pathway Characterisation
• Source Inventory
• Load Measurements/Estimates
Establishing Load-Concentration Relationships
Exposure Pathway Characterization
Establishing Exposure/Dose Relationships
Priority-Setting Process for Selecting Remedial Measures
Water Bodies Areas
Pollutants
Sources
Setting Load Reduction Objectives
Evaluating the Effectiveness of Existing Remedial
Action Programs
Niagara River
Project/
Niagara River
Management Plan

•
o
o


•
o




o
•
•
O
Upper Cireat
Lakes
Connecting
Channels Study

•
•
1


•
•
O
0





o
Lake Michigan
Toxic Pollutant
Control/Reduction
Strategy

•
•
O
1

o
o
o
0


o
•
•
•
1
(ircen Hay
Mass
Balance
Project

•
•
•


•
•
•
•





•
Lake Ontario
Toxics
Management
Plan

•
•
•

O
•
O
•
•
0

o
•
•
•
1

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                TABLE 2: CONTRIBUTIONS OK SELECTED RECENT ACTIVITIES TO THE EVOLUTION
                               OE LAKEWIDE MANAGEMENT PLANNING (continued)
Elements ol Lakewule Man;igcnicnl Plans
Priority Setting Process for Selecting Remedial Measures
Evaluating Remedial Action Alternatives
Reaching Agreement on Remedial Measures Strategy
Implementing Remedial Programs
Developing Operational Plans lor Remedial Measures
Tracking Remedial Measures Implementation
Evaluating Program Cost-Effectiveness
Monitoring Ecosystem Recovery
Surveillance and Monitoring to Determine
Effectiveness of Remedial Actions
Removing Critical Pollutant Designations
Determining When Objectives Have Been Met
Niagara River
Project/
Niagaia Rivei
Management Plan


o

1
(3

•

O
Uppei (ireal
Lakes
Connecting
Channels Sliuly










Lake Michigan
Toxic Pollulanl
Control/Reduction
Slialegy

•
O

o
•

•

o
Ciicen Bay
Mass
Balance
Project

1








Lake Ontario
Toxics
Management
Plan

•
O

o
•

•

»
* Indicates to what degree the study dealt with a paiticular element of LMPs
' ) element discussed
1 element discussed in some detail
• element discussed in gieater detail
K)

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Upper Great Lakes Connecting Channels Study

         The Upper Great  Lakes Connecting Channels (UGLCC) Study is a binational effort
initiated  in 1983 to address four key contaminated waterways within the Great Lakes Basin.  This
Study has served,  in many  ways, as a key model for  the more recent lake management  efforts
described above.  The objectives  of the Study were to:

         •  Determine  the existing environmental condition of the  St. Marys River,  St. Clair
            River, Lake St. Clair,  and the Detroit River and identify information gaps

         •  Undertake  additional,  needed studies to:

            -  Identify and quantify the impacts of conventional and  toxic substances from point
               and nonpoint sources

            -  Determine the adequacy of existing or proposed control programs to ensure or
               restore  beneficial uses

            -  Recommend appropriate control and surveillance programs to protect and monitor
               these waterways and  the downstream lakes.

         The results of this Study, which involved  12 government agencies and a multitude of
academic institutions  and cost approximately  $20 million,  are presented in a draft final report
issued in July 1988. This final report represents a distillation of 19 media-specific reports, which
were based on  170 individual data  reports.

         An overview of the findings of the UGLCC  Study are summarized below;

         •  The UGLCC  Study  confirms that many  of the environmental quality problems of
            the region cut across political  jurisdictions   and can  only be  resolved through
            coordinated, long-term planning  efforts by the jurisdictions affected.

         •  There have been substantial reductions in conventional pollutants, however, ongoing
            and historical discharges continue to affect the  system.   Elimination of combined
            sewer overflows is strongly recommended.

         •  All four water bodies suffer from contaminated sediments, high  concentrations of
            oil and grease (except Lake St.  Clair), and the  bioaccumulation  of certain toxic
            pollutants in  local aquatic organisms. Levels of contaminants in waterfowl need to
            be examined.

         •  Point sources continue to contribute the largest loadings of contaminants.  Nonpoint
            loadings  can  be locally  significant, but  quantification of  these inputs is needed.
            Information is  also needed on the relative contribution of waste sites.

         •  Accidental spills are an insidious problem that requires immediate attention.

Specific  recommendations  for remedial action in each connecting channel are outlined  in the
report.
                                            23

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Green Bav Mass Balance  Project

         The USEPA, in conjunction with a number of other U.S. Government agencies and the
States of Michigan and Wisconsin, is developing and testing a modeling framework to increase the
information base on sources, transport, and fate of toxic  compounds in the Fox  River/southern
Green Bay area.  The overall goal  of the Green Bay Mass Balance Study is  to  test models for
toxics to improve our understanding of the sources, transport, and fate of toxic compounds, to
evaluate  the technological capability to measure multimedia loadings to a  system, and ultimately
to guide and support regulatory activity.   The Study will serve  as a pilot for future modeling
studies of Great Lakes ecosystems.

         The Mass Balance Study will apply models to PCBs, dieldrin, cadmium, and lead.  The
physical/chemical models  will be coupled with a food chain model to allow estimation of body
burdens in target fish species:  carp,  brown trout, and walleye.   The integrated model will then
be used to predict concentrations in the water, sediment, and biota under alternative regulatory
and remedial actions.

         The project was  initiated in  1986, with the development of a monitoring plan and the
establishment of a quality assurance program for  evaluating analytical and field methods to be
employed.  During  FY  1987, field reconnaissance was done in the Bay and tributaries, and the
first atmospheric deposition  monitoring stations were established in preparation for the main field
season, August  1988 through September 1989.  Samples to be collected include bottom sediments,
Bay-Lake exchange, atmospheric deposition, water and suspended  sediments, tributary loads, point
and nonpoint sources, ground water, and  biota.

  As envisioned, the study will incorporate the following  components:

         •  Comprehensive quantification of loads from all significant sources (e.g., atmosphere,
            tributaries, ground water, point, and  nonpoint)

         •  Determination of  the net rate of exchange of contaminants between environmental
            compartments (e.g., sediment, water,  biota, and air)

         •  Net rate of exchange with Lake Michigan.

         Analysis of field data, modeling,  and interpretation is scheduled to begin in 1990.  These
activities will be guided by  several specific requirements, including:

         •  Usefulness in predicting concentrations of key contaminants in fish to help determine
            human  cancer risks

         •  Utility  for EPA and the State in making regulatory  decisions

         •  Applicability of the  pilot study as a model for larger, lakewide studies.

Modeling results will be determined and the final report  will be  completed in 1991.

Lake Michigan Toxic Pollutant Control/Reduction Strategy

         EPA's Region  V and the States of Illinois, Indiana, and  Michigan have prepared a Lake
Michigan Toxic Pollutant  Control/Reduction Strategy.  The objectives of the strategy are to fully
restore the multiple  uses of Lake Michigan and to protect human health and  the Lake Michigan
ecosystem  by  achieving a significant reduction in the loading  rates of  toxic pollutants.   The
strategy  includes  specific  commitments   for  each  State, by  fiscal year,   which  have  been
incorporated into the annual State program plans  negotiated with the Region V  Water Division.
The strategy anticipates using  a whole-lake mass  balance approach to modeling  toxic pollutants


                                             24

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and evaluating potential regulatory controls.  The Green Bay Mass Balance Study is identified as
a key milestone  in the development of a LMP for Lake Michigan.

         USEPA  Region V's  Water  Division   has  negotiated  performance   objectives  for
implementation of the Lake  Michigan Strategy into the State Water Program Plans of the Lake
Michigan States.  Included are elements requiring a status summary of technology-based permit
limits, including those for the Lake Michigan Pollutants of Concern; an initiative to acquire the
capability to calculate and sum loads from point sources to specific Lake Michigan tributaries and
to Lake  Michigan as  a whole; and an inventory  of municipal waste combustion sources, cross-
referenced in the Lake Michigan State Air Program Plans.

         To assist the Lake Michigan States in developing a load quantification capability, GLNPO
is accessing the Permit Compliance System data base and roughly calculating loads by multiplying
average flow with average concentration.  Such  screening level estimates are intended to focus
additional monitoring  attention  on those sources contributing significant loads  of pollutants  of
concern and select toxic metals to Lake Michigan.  As a complement to this effort, GLNPO has
also obtained loading inventories of pollutants of concern and select toxic metals to Lake Michigan
tributaries using Michigan's Critical Materials data  base.   While strictly applicable to Michigan
sources,  the  information  may assist  in  identifying significant  point  source categories and  in
defining screening level discharge factors applicable to other Lake Michigan sources.

Lake  Ontario Toxics  Management Plan

         In February  1987, EPA, the State of New York, Environment Canada,  and the  Ontario
Ministry of the Environment signed a declaration of intent to prepare a Toxics Management Plan
for Lake Ontario.  The draft plan, prepared in 1988, cites bioaccumulation of toxic chemicals in
fish to levels that make them  unsafe for human consumption as the most serious known problem
in the Lake.  To address the  problem of toxic pollution in Lake Ontario, the draft plan calls for
three  major actions:

         •  Full implementation of  current  programs,  such as the  State Pollutant Discharge
            Elimination System program in New York State and  the newly developed Municipal
            Industrial Strategy for Abatement program in Ontario.

         •  Development  and  implementation   of RAPs  to  address the  problems in  eight
            geographic AOCs, such  as the Niagara River and Hamilton Harbor.

         •  The development and implementation of chemical-specific management  plans  to
            reduce the levels of problem toxics  (e.g., PCB, mercury,  mirex, chlordane, dioxin,
            DDT, dieldrin,  hexachlorobenzene,  iron, aluminum, and  octochlorostyrene) below
            protective ambient standards.  As a check on the effectiveness of chemical-specific
            management  plans,  ecosystem  objectives  will   be   developed  and  monitored
            independently.

         Together,  the administrative  and  technical initiatives  described  above represent a
concerted effort by the United States to develop the institutional arrangements, programmatic
structure and function, and technical tools necessary to carry out this crucial mandate, despite  its
unprecedented scope and complexity.

Other Activities Related to Lakewide Management Plans

         The Great Lakes States have also worked jointly towards achieving the goals  of the
GLWQA. In June 1986, the Governors of the eight Great  Lakes States signed the Great Lakes
Toxic Substances Control Agreement.  This Agreement pledges the States to treat the  Lakes as a
single ecosystem despite political boundaries, acknowledges that toxic pollutants are the foremost
problem  to be addressed, and lays out goals for the States. More recently,  the Governors agreed


                                            25

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to establish a permanent fund for Great Lakes studies. Many of the activities under both of these
State agreements  will lead directly and indirectly to the completion  of  and implementation of
management plans, and ultimately  to the attainment  of the Agreement objectives.  Considerable
progress  has already been made toward this goal by USEPA Headquarters and States' Regional
regulatory and remedial programs.

         GLNPO has begun to develop and test a number of technical  tools that will be necessary
for  LMP implementation.   In  terms  of  technical guidance,  GLNPO and  the Office of Water
Regulations and Standards have discussed  the writing of a Great Lakes Waste Load Allocation
Guidance Document.  GLNPO also continues to work with  Region II and V Superfund programs
to institutionalize sediment cleanup priorities based within the  Superfund Program on Great Lakes
area and lakewide exposure/load reduction needs.  With respect to technical  tools for problem
characterization,  GLNPO is  developing, via grants  to  Great Lakes  academic institutions, the
following:

         •  Statistical methods for determining the relationship between sampling frequency and
            tributary waste quantification, accuracy, and precision

         •  State-of-the-art atmospheric concentration/deposition monitoring station

         •  Computerized concentration  volume-weighting  scheme  to  systematically calculate
            area lakewide concentration averages

         •  Mathematical models  of the Great Lakes system  capable  of relating loading  rates  to
            ambient concentrations in water, sediment,  and biota (in cooperation with the Large
            Lakes Research Station, Grosse He, Michigan)

         •  State-of-the-art  effects   monitoring  tools,   such  as  sediment   toxicity  and
            bioaccumulation test methods, the fish embryo-larval carcinogen assay, and  the fish
            or sediment extract liver hepatoma P450 induction assay.

USEPA's Office  of  Research and Development will also  be testing  proposed sediment quality
criteria in the Fox River/Green Bay system.

         In addition, GLNPO has  developed a pesticide inventory for Erie County  in Ohio via
Interagency Agreement (IAG) with Ohio State University's Cooperative Extension Service.  The
inventory will complement the work on nutrient and  pesticide concentrations during storm events
being conducted  under a GLNPO  grant by Heidelberg University in  Tiffin, Ohio, and previous
demonstration projects funded through an IAG with USDA's Soil Conservation Service.  Together,
this information can be used to develop aids for quantifying  nonpoint source loading factors for
pesticides of concern based on  application  rate, crop type,  tillage practice, land slope,  soil types,
and distance to surface water.

         The National  Oceanic and Atmospheric Administration's Great Lakes Environmental
Research Laboratory.(GLERL) has continued its research to evaluate the role of chemical kinetics
versus chemical  equilibrium in contaminant-fate modeling.   The  results  show  that  even  in  a
relatively stable environment, contaminants in organisms are  not at a  steady state with respect to
local sources.  This research represents a significant contribution to our  ability to model fate  of
contaminants and will be useful in AOCs and for LMPs.

         Additional  research at GLERL has shown that situations exist in which toxicant fate
cannot  be accurately  predicted if toxicant effects  are not  modeled.   This  is contrary to the
traditional approaches to modeling toxicant fate  that implicitly assume  that toxicant  effects on
organisms have no effect on subsequent  toxicant  fate.
                                             26

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         With respect to problem remediation, GLNPO is providing contractor support to Great
Lakes municipalities to test innovative phosphorus removal  technologies and has funded  studies
of best available  technology-equivalent  metals  removal.  In addition, Region  V  is currently
conducting specific air emissions control studies to identify potential remedial measures  for air
toxicants.  Furthermore, GLNPO,  with technical assistance from the USCOE, USFWS, and
Region  V,  is developing design criteria for  in-lake contaminated sediment disposal facilities that
minimize loss rates to  the lakes and  human  or  wildlife exposure to dredged  toxicants via the
aquatic  or terrestrial food chains. Plans for such disposal facilities, however, will be scrutinized
closely given that, in some States, any in-lake disposal of contaminated sediments is considered
a violation  of State water quality  standards and requires the responsible party to obtain a variance
from  the State rules.   Other innovative sediment cleanup  technologies will  also be tested on
Waukegan Harbor sediments, the most heavily PCB-polluted sediments in the entire Great Lakes
system.
                                            27

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28

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                         ANNEX 3: CONTROL OF PHOSPHORUS


       Annex 3 of the GLWQA sets  targets for total phosphorus loads to the Lakes, which, when
achieved, would produce acceptable conditions in terms of aerobic conditions in the bottom waters
of Lake Erie, and algal biomass in all of the Lakes.  The 1983 supplement to the Annex confirmed
target loads, quantified  the further load reductions necessary to attain the targets, and called for
the preparation  of Phosphorus  Load  Reduction Plans to guide  their  attainment.   The U.S.
Government and  the States have prepared and transmitted  Phosphorus Load Reduction  Plans to
the IJC for Saginaw Bay of Lake Huron, and for Lakes Erie and Ontario.

       The Supplement requires  the Parties to review the effectiveness of the Plans by December
1988, and identify any  remaining load reduction measures required  to achieve the target loads.
The  reviews have not yet been completed, although it is apparent that the target loads have not
yet been attained for any of the three water  bodies.  Phosphorus loadings to  Lakes Superior,
Michigan and Huron all achieve  the  target loads, except for Saginaw  Bay.

       The  United States expects  to  provide an update  of  its plans  during  1989.   Further
discussion of Phosphorus Load Reduction Plans and nonpoint source control programs are provided
in the  section on  Annex 13.
                                            29

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30

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                      ANNEX 12: PERSISTENT TOXIC SUBSTANCES
INTRODUCTION
       The goal of the GLWQA is the virtual elimination of persistent toxic substances from the
Great  Lakes  ecosystem; the philosophy  is zero discharge.  To  that  end,  Section 2(a)(iii)  of
Annex 12 requires the Parties  to  pursue "the  reduction of the generation of [Great  Lakes]
contaminants,  particularly persistent toxic substances,  either through the reduction of the  total
volume or quantity of waste  or through  the  reduction of the toxicity of waste,  or both."
Significant progress has been  made  in  reducing the quantities of persistent toxic substances
entering  the Great Lakes system from air emissions, wastewater discharges, leaks and spills, and
stormwater runoff. The reporting requirements  of  Annex 12 focuses on activities under Section
       A variety of regulatory and nonregulatory approaches are under way in the United States
to reduce new sources of toxic pollutants.  The approaches include:

       •  Eliminating or restricting the use of toxic chemicals (e.g., bans)

       •  Reducing the concentration of  toxic substances in commercial products

       •  Limiting concentrations of toxics in non-hazardous waste streams

       •  Regulating disposal of hazardous waste streams

       •  Reducing the amount of toxic substances used in manufacturing  processes

       •  Reclaiming and recycling toxic substances from manufacturing processes or commercial
          products.


RESTRICTIONS ON THE DISTRIBUTION OF CRITICAL POLLUTANTS IN COMMERCE

       Several environmental statutes apply to restrictions on the distribution of critical pollutants,
including the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA);  the Toxic Substances
Control Act  (TSCA);  and to a limited  extent  the Resource Conservation and Recovery Act
(RCRA).

Federal Insecticide. Fungicide, and Rodenticide  Act

       In the United States, the manufacture, use, and disposal of some 50,000 pesticide products
and devices are regulated under FIFRA as amended in 1978 (40 CFR Parts 152 to 173).  The U.S.
Environmental Protection Agency (USEPA) carries out this responsibility by requiring all pesticides
to be registered  with the USEPA,  based on data adequate to demonstrate that the pesticide's use
will  not pose an unreasonable risk to humans or the environment.  When a product  is registered,
certain labeling requirements must be met, including explicit directions for legal use; information
on the method, rate, and site  of application; directions  for storage and disposal; and restrictions
on use. Any application deviating from  the  labeled one is  considered an  unlawful use of the
product.

       The  regulations  provide  standards  for  the  certification  of   commercial   and private
applicators  of restricted-use pesticides to ensure that these pesticides are handled and used in a
safe  manner.  For commercial and professional  applicators, methods of storage and disposal of
excess pesticide products and pesticide  containers are also recommended under  FIFRA.   In
addition, RCRA regulates the treatment, storage, and disposal of some pesticide wastes. The above


                                            31

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measures are intended  to  reduce  the  quantities  of pesticides entering  the  environment  to  the
minimum required for efficacious use.

       If the environmental or health risks associated with a pesticide's  registered use outweighs
its benefits, USEPA  may further limit its use in terms of pests, crops, environmental conditions,
or geographic areas.   In  extreme cases,  USEPA can move  to cancel  all  uses  of  (i.e., ban)  a
pesticide.

       The following  Critical Pollutants have  been banned by  the  USEPA:   DDT,  dieldrin,
hexachlorobenzene, and toxaphene.  Mercury's  use in pesticide formulations has been severely
curtailed, although some seed treatment uses continue. Voluntary restrictions on the concentrations
of 2,3,7,8-tetrachlorodibenzo-para-dioxin (2,3,7,8-TCDD)  in  chlorophenoxy  herbicides were
adopted by manufacturers  in  1971.

Recent Activities

       In  1987, the  ban on  the use of herbicides containing 2,4,5-trichlorophenoxy carboxylic
acids  (e.g., 2,4,5-T;  Silvex) and derivative esters went into effect.  Historically, such herbicides
were  a significant source of  2,3,7,8-TCDD.  Also in 1987, USEPA announced its intention to
severely restrict the use of pentachlorophenol, which is contaminated with various polychlorinated
dibenzo-p-dioxins (PCDDs) and polychlorinated dibenzofurans (PCDFs) and to cancel all remaining
uses of chlordane.

       In addition,  USEPA's Office of Pesticide Programs has initiated an accelerated  review
process  for the  registration of existing pesticides.  One area of  focus  is lawn  care herbicides,
including dacthal, one  of the few herbicides identified  in fish tissue collected under  the Great
Lakes fish monitoring program.

       Pesticide manufactures are more frequently initiating the removal of problematic pesticides
from  the marketplace  prior  to USEPA action.   For example, the sole U.S.  manufacturer of
chlordane agreed not to contest the proposed registration cancellation notice, thus avoiding lengthy
administrating  hearings.  As  a result of a similar voluntary  action on  the  part of various  U.S.
manufacturers, all remaining  uses of Endrin are  likely to be cancelled  in the near future.

       Serious concern over the extreme toxicity of alkylated tin compounds detected in Great
Lakes waters prompted the State of Michigan to propose a ban on the  use of paint formulations
containing tributyl  tin biocides  on surfaces that  could contact  the aquatic environment.   Of
particular concern was the  use of antifoulant paints containing tributyl tin as the active  ingredient
to prevent algae growth on recreational boat hulls. The  ban went into effect in  November 1988.
Subsequently, Wisconsin began to pursue a similar initiative.

Toxic Substances Control  Act

       TSCA provides USEPA  with regulatory authority  (40 CFR  Parts 702-799)  over the
manufacture,  transport, storage, use, and disposal of chemicals on the TSCA Inventory intended
for commercial distribution in the United States.  The Act provides a broad range of authorities
including reporting and notification  requirements and the imposition of manufacturing and use of
restrictions or bans.

       TSCA also requires manufacturers of new chemical substances not on the TSCA Inventory
to submit  a  Premanufacture  Notification prior  to the  manufacture of  the chemical, supplying
information on the  properties of the new substance, its intended use,  the method and extent of
manufacture,  description  of byproducts, and  other  data.   TSCA also requires manufacturer
notification of "significant new uses," which must be designated by rule, of chemical  substances
currently on the Inventory.
                                             32

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       In addition,  TSCA provides for Federal information  requests of manufacturers and for
systematic testing of existing chemicals according to priorities set by USEPA in consultation with
the Interagency Testing Committee.   Where new test results indicate substantial risk  to human
health or the environment, USEPA can restrict manufacture, storage, use, or disposal.   Where
unreasonable risks are found, USEPA  can  ban manufacture of the  chemical and severely restrict
its disposal.

       The use, manufacture, processing, and distribution of polychlorinated biphenyls (PCBs) and
PCB items are effectively banned by  TSCA (40 CFR Part 761).  In addition, TSCA regulations
require manufacturers and processors of certain chemical substances to analyze these chemicals for
the presence of halogenated dibenzodioxins (HDDs)  and halogenated dibenzofurans  (HDFs).  If
testing confirms the presence of HDDs or HDFs  above the prescribed level  of  quantitation,
additional information is required on  production, process, exposure,  and  disposal.

Recent Activities

       The private sector has become  increasingly concerned about the number and quantities of
toxic substances used in manufacturing and  waste treatment processes. The sources of concern are
four-fold:

       •  Existing  occupational and  environmental  liabilities associated with toxic substances
          manufacture or use

       •  Growing  paperwork burden associated with existing or  new local, State,  and Federal
          reporting requirements

       •  Increasing costs of solid and liquid waste disposal containing one or more listed toxic
          substance

       •  Existing public perception  that the onsite storage  of large quantities of highly toxic
          substances presents an unreasonable threat to nearby communities.

       In response,  many communities are  voluntarily pursuing the use of various raw materials
or product substitution strategies.  For example, every Michigan facility discharging unsanitary
wastewater is required to report annually the quantities of Critical Materials used or produced,
discharged, and disposed of in solid residues.  A substance is considered a Critical Material once
it  is added  to  Michigan's  Critical  Materials  Register  (CMR) by  the  Director of Michigan's
Department of Natural Resources, who is advised by a committee of scientific experts.  In response
to this program, several Michigan industries have systematically started  to eliminate the use of
CMR-listed substances in  product  manufacture or wastewater treatment  processes.  The  recent
expansion of the CMR under the Clean Water Act Section 205(j) grant from USEPA Region V
may further encourage this practice.

       The use of PCBs in transformers and capacitors continues to be  phased out, with disposal
of recovered PCB oils via high-temperature incineration only.  Since  1987, regulations governing
the closure,  cleanup, and disposal of structures contaminated with chlorinated dibenzo-p-dioxins
and dibenzofurans in PCB transformer fires have been implemented, and  USEPA's National PCB
Spill Cleanup Policy is now in effect.  Such regulations and policies will reduce the volume of
contaminated  matter  capable  of  being released to the air, soil,  and water  of  the Great  Lakes
ecosystem.


WASTE REDUCTION AND RECYCLING

       Management  of solid and hazardous  waste in the United States, including waste  reduction
and recycling, is regulated in part by the Solid Waste Disposal Act (SWDA). The SWDA, amended


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in 1976, is commonly referred to as RCRA.   In 1984,  the SWDA  was again amended via the
Hazardous and Solid Waste Amendments. Subtitles C, D, and I of the SWDA regulations describe
the three distinct programs: the Hazardous Waste Program (Subtitle C), the  Solid Waste Program
(Subtitle D), and the Underground Storage Tank Program (Subtitle I).

       The Hazardous Waste Program is designed to ensure the safe and effective management of
hazardous waste (40 CFR Parts 260-272).  As part of the Hazardous Waste Program requirements,
a paperwork manifest system is  utilized that  records the location  of hazardous wastes.   This
Uniform Hazardous Waste Manifest system provides specific information  on the quantity and
nature of the waste and the parties involved in the waste's production, transportation, and disposal.

       Specific  requirements exist  for  generators, transporters, and owners  or operators of
treatment, storage, and disposal facilities.  All facilities must, at a minimum, possess a USEPA
identification  number.   Requirements  for generators include proper  labeling,  packaging, and
limited accumulation of the waste; adequate training of personnel; and development of contingency
plans  and temergency procedures.    Transporters  must be   trained to adequately  respond to
discharges, such as spills.

       The  primary goal of the  Solid Waste  Program  is to  encourage solid waste  management
practices that  promote environmentally sound disposal methods, maximize re-use of recoverable
resources, and foster resource conservation. There are two facets of the Solid Waste Program: the
technical standards for facilities, referred to as Subtitle D  Criteria (40 CFR Part 257),  and a
voluntary State solid waste management  program (40 CFR Part 256).

       The Underground Storage Tank (UST)  program is concerned with tanks having 10 percent
or more of their underground volume containing petroleum products  or hazardous substances (40
CFR Part 280).  The UST program  has  five parts:  a ban  on unprotected new USTs (i.e.,  USTs
without  cathodic  protection  to protect  against corrosion),  notification to authorities of existing
USTs, development of performance  standards, State management of the program, and inspection
and enforcement authority at the  State and Federal levels. For an UST to be permitted, the tank's
design  must  be shown to prevent  release due to  corrosion  or structural  failure, and  that the
construction of the tank is compatible with the stored waste.

        To limit the quantities of sediments, nutrients, and pesticides entering water bodies from
agricultural land use, USEPA has recently developed a multi-agency nonpoint source management
strategy, involving, among other Federal agencies, U.S. Department of Agriculture, particularly the
Soil Conservation Service.  The  approach to  source reduction is through the encouragement of
alternative tillage practices, the use of buffer strips around agricultural fields, and the transfer of
technology on integrated pest management and alternative nutrient and  pest management methods
from the academic center  to the  farmer.

Recent Activities

        Waste  reduction and recycling  activities occur  at the Federal, State,  and local  levels.
Recent activities are discussed below.

Federal

        Effective enforcement of existing RCRA regulations,  the banning of the land disposal of
liquid hazardous waste, and  increasingly stringent limitations  on the land disposal of solid wastes
and  sludges  have raised the costs of  waste disposal in   the United States  and  placed an
ever-increasing waste  disposn;  burden  on a  small handful  of  fully  licensed  hazardous  waste
incinerators.  At  the same time,  new RCRA restrictions on the emissions of PCDDs and PCDFs
from such incinerators are likely to further increase disposal costs.   Onsite storage of liquid and
solid hazardous wastes awaiting proper disposal also creates environmental and occupational risks
and liabilities.


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       In response to these  regulatory and economic pressures, manufacturers are increasingly
interested in reducing the volume of hazardous waste generated in their processes.  To this end,
they are pursuing substitution of nonhazardous chemicals  for  those listed under Subtitle C of
RCRA  (40  CFR Part 261), process modifications  to reduce the volumes of liquid and solid
hazardous waste produced as manufacturing byproducts, and wastestream recycling within the plant
if possible,  but  between plants if necessary.

       USEPA has recently announced the creation of a new Pollution Prevention Program (PPP)
to be administered by a newly created  Pollution Prevention Office within USEPA's Office of
Policy,  Planning,  and Evaluation in  Washington,  DC.   An agency-wide advisory committee,
consisting of senior managers, will be established to coordinate waste reduction efforts in USEPA's
program offices.

       The  PPP will adopt an agency-wide, multimedia and multiprogrammatic approach to source
reduction and  recycling.    Although there  are many  cultural  and  institutional  barriers to
implementing such an approach,  the PPP will  aggressively pursue the reduction of hazardous and
toxic wastes, as  well as other wastes  of environmental concern such as municipal and agricultural
wastes.   This Program will become  fully operational  during  FY 1989  fulfilling the  Agency
commitment to  four objectives:

       •  Promote a new culture  both within  and outside  USEPA  that  emphasizes pollution
          prevention, primarily  through source reduction and secondarily through recycling

       •  Encourage development of  State and local pollution prevention programs

       •  Create incentives  for and eliminate barriers to pollution prevention

       •  Develop reliable  indicators  of progress in  source reduction and recycling.

       To  achieve these objectives  across the Agency,  PPP will concentrate on four  primary
functions.  First, the program will develop a cross-media pollution prevention policy and strategy
and will promote the pollution prevention ethic both within and outside USEPA.  Central to this
activity will be the advice of the  Pollution  Prevention Advisory Committee. Second, the program
will develop technical assistance  tools  and  coordinate outreach programs to deliver these  tools to
State and local governments,  the industry, the  agricultural community, and the public.  Third, the
PPP  will foster  the development of  innovative approaches to pollution prevention.  Finally, the
program will  develop a coordinated information management strategy to  assess  and report on
pollution prevention and will report on progress and problems.

Illinois

       The  Illinois Hazardous Waste Research and  Information Center  (HWRIC) and the Illinois
EPA promote waste reduction  through technical assistance, research information  services, waste
exchange operation, promotion of recycling, and related regulations.

       The  Illinois EPA does not require mandatory waste  reduction or permit large  generators
to landfill their hazardous waste unless  they  can prove that there is  no technically feasible or
economically reasonable alternative.  In their annual reports, generators must submit a description
of the waste minimization techniques considered and tried. The Illinois  EPA,  in cooperation with
the State Chamber of Commerce, operated the Industrial Materials Exchange Service. The Illinois
EPA is also  implementing a waste minimization student  intern program.
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       Recently, the  Illinois EPA and  the Department of Energy and Natural Resources  were
awarded a RCRA Integration Training and Technical Assistance (RITTA) grant.  The majority of
the money will be used in a pilot project to integrate and expand the activities of the Illinois EPA
and HWRIC through training and a student intern program.  They will also work  with two local
organizations, the Center for Neighborhood Technology in Chicago and Community Contracts, Ind.
of Kane and DuPage counties, to reach industry.  Activities include using the computerized waste
reduction advisory system and industry audits to quantify the amount and toxicity of hazardous
waste reduced,  developing  a  State action plan, providing  training  in waste  management and
minimization,  and providing public outreach  through  seminars and workshops.

       HWRIC's activities include sponsoring research, onsite technical assistance, two Statewide
waste reduction conferences, and a Governor's award  for innovative waste reduction.   HWRIC is
active with the National Roundtable of State Waste Reduction Programs and has been working with
several  member programs and the USEPA  to  develop an  online national computerized waste
reduction advisory system called the Multi-Option Model.

       HWRIC maintains five programs: research, industrial and technical assistance, information
services, data  management, and laboratory services.   HWRIC's $9 million Hazardous Materials
Laboratory will open in spring 1990 and will include state-of-the-art analytical services to support
bench-  and pilot-scale laboratories for minimization and treatability studies. Research sponsored
by HWRIC focuses on problem assessment  and solving.  This includes $200,000 for waste reduction
studies, including  matching-fund  projects with industry.  Technical assistance services  include
information on  chemical processes, waste treatment,  siting,  and permitting requirements.  The
Center serves industries, State and local governments,  and the public.

Indiana

        Indiana  is  in  the process of  formalizing a hazardous waste  minimization program that
includes developing waste minimization audit procedures.

        Indiana has held annual training workshops on waste minimization practices,  including audit
procedures.  Pertinent waste minimization and  audit procedure articles have been included on a
regular basis in  the bimonthly Technical Bulletin, prepared by the Office of Technical Assistance,
and  in  the Indiana Waste Exchange Catalog, prepared by Environmental Quality Control, Inc.,
under contract to the  Indiana Department  of Environmental Management.  In addition, the Office
of the  Governor provides annual awards to private industries  that have made outstanding progress
in voluntary waste minimization.

        The State has  commenced efforts to build a  library of waste reduction case histories.
Indiana is also  planning to adopt a waste  minimization policy.  Although  waste minimization is a
high priority in Indiana, continued efforts will  depend on Federal and local funding.

Michigan

        Michigan State statutes enacted in December  1987 created a  Waste Reduction Assistance
Service, an Environmental Technology Board,  and an Office of Waste Reduction, each charged
with furthering specific  waste reduction needs.  The Waste Reduction  Assistance Service will
provide educational services and onsite technical assistance to help firms  identify  and implement
waste reduction practices.  The Environmental Technology Board will report to the Governor and
Legislature by  June 1989 on methods in which the State can  better support research needs in  the
field of waste reduction.  The Office  of Waste Reduction will  focus  its efforts  on identifying
regulatory barriers to waste reduction,  recommending how waste reduction might be encouraged
through  existing  regulatory   programs,  and  analyzing  waste  reduction   potentials  and
accomplishments in various industrial sectors.
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       All three programs, which became operational in late 1988, have a multimedia focus. While
the responsibilities are officially housed in two separate departments (the Department of Commerce
and the Department of Natural Resources), they are expected to be  managed as a "joint venture"
between  the  departments, with a shared budget of approximately $450,000  and four  or five
full-time personnel.  Future program activities include public information and education, onsite
technical assistance, analysis  of waste reduction potential, and identification of regulatory barriers
to waste  reduction.

       Current Michigan law does not mandate waste reduction, but it is encouraged  through the
above programs  and through a hazardous waste landfill disposal fee and credit system.  Through
this system, firms may receive a refund of landfill fee payments upon documenting reductions in
the volume of waste generated due to implementation of source reduction practices.

Minnesota

       The State of Minnesota enacted a Waste Management Act that encourages waste reduction,
processing, treatment, separation, and resource recovery.  Waste minimization responsibilities are
divided between the State Planning Agency (SPA) and the Minnesota Pollution Control Agency
(MPCA).  The SPA has planning authority in the area of solid and hazardous waste.  The MPCA
develops hazardous waste regulations.

       The SPA funds the Minnesota Technical Assistance Program (MnTAP) at the University
of Minnesota. MnTAP is a State program that performs confidential  onsite consultations, manages
a resource information clearinghouse, administers a student intern program, and offers research
awards for minimization projects.  The program also  publishes a  quarterly newsletter and has
published several industry case studies.

       The SPA and MPCA plan to share funds received from the recently awarded  RITTA
grant.  The State will implement a State action plan, a RCRA  training program,  and a pilot
project.  The pilot project will focus  on reducing the volume of the State's solvent waste stream
in a variety of industries. Activities will include  providing a public outreach program, conducting
seminars and workshops, performing  onsite audits,  implementing  a telephone hotline,  and
publishing a newsletter. The project is intended to encourage industries to voluntarily utilize waste
minimization  techniques.

New York

       The New York State Department of Environmental Conservation (NYSDEC) encourages
waste minimization through the Bureau of Hazardous Waste  Program Development.  The Waste
Reduction Implementation  Section within  the Bureau is developing regulations,  implementing
source reduction policies, developing public outreach programs, publishing manuals and fact sheets,
sponsoring conferences and  workshops, and applying for Federal grants.  The Waste Reduction
Evaluation Section will be reviewing and evaluating  waste reduction  impact statements, inspecting
facilities, developing a computer-based information  system, assessing incentives and disincentives
for waste minimization,  and  preparing waste reduction forms.  The  NYSDEC has formed an
intra-agency  task group to develop a  uniform, multimedia approach to waste minimization.  The
NYSDEC also provides funds to the New York Center of Hazardous Waste Research  for research
in new technology areas, Superfund cleanup efforts, and hazardous  waste reduction.

       The State established  a preferred waste management hierarchy in August 1987.  In addition,
the NYSDEC issued an organization and delegation  memorandum directing each division director
to consider utilization of a Waste Reduction Impact Statement to analyze the potential for reducing
the generation and/or toxicity or hazardous  waste across  all media.
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       The  Waste Reduction Sections are  currently conducting two  major projects.  The first
project  is a hazardous waste reduction guidance  manual that will  promote  the  State's  waste
management hierarchy, provide a measure  for waste reduction efforts,  and help ensure  that the
State  has  adequate hazardous waste  disposal capacity over  the next 10 years.  An  additional
component is two sets of workshops.  The first set will solicit industry's comments on the guidance
manual, and the second set will educate industries on the techniques described in the manual. The
second project will provide an update of the hazardous waste treatment needs survey for the State.
The project will forecast hazardous waste generation and gather information on future hazardous
waste reduction opportunities.

       The  State  imposes regulatory  and  Superfund fees  on hazardous  waste generators and
facilities designed to encourage "preferred" waste management practices.  In  addition,  pending
legislation addresses waste minimization plans for hazardous  waste generation.

       The  Environmental Facilities Corporation (EFC), a public benefit corporation established
by New York in  1970, is  also involved in waste management efforts. Among  other duties, EFC
conducts onsite industry  audits for  small  quantity  generators (SQGs).   Under the Industrial
Recycling Act, some of the confidential audits  are  free.

       Other  EFC  responsibilities include financing of environmental projects  for industry;
providing technical assistance, an advisory service, and inactive hazardous waste site remediation;
and financing an  information clearinghouse. The EFC also helps to fund the Northeast Industrial
Waste Exchange.

       The  Department of Environment  and Planning  in Erie County conducts  an additional
waste reduction program of its own that  focuses  on SQGs.   The County operates  a technical
assistance and educational program  that  includes  onsite  consultations  and an  information
clearinghouse.  In addition, the County has published several industry specific small  quantity
hazardous  waste  generator guidebooks, has sponsored several  hazardous  waste  minimization
workshops,  and publishes a quarterly newsletter.

Ohio

       Ohio's efforts related to hazardous waste reduction and/or minimization are  conducted by
two agencies:  the Ohio EPA, Division of Solid and Hazardous Waste Management, and the Ohio
Department of Development, Ohio Technology Transfer Organization (OTTO).

       The Ohio EPA has sponsored Ohio's  participation in the  Northeast Industrial  Waste
Exchange since 1983; requires waste  minimization plans when reviewing applications  for land
disposal  in  Ohio; sponsors and participates in  waste minimization seminars; sponsors annual
Governor's  Awards  for Outstanding  Achievement  in Waste  Management and  Pollution  Control,
which includes waste minimization candidates; participates in a Hazardous Waste Minimization Task
Force to advise the  State of Ohio on appropriate government actions; and offers daily technical
assistance and regulatory interpretation related to waste minimization. These activities  are funded
by Federal  and State sources as part  of the general hazardous waste management program.

       The Ohio EPA requires waste minimization to be addressed as part of  the conditions  for
land disposal of hazardous waste.  This requirement applies  to all generators  proposing to dispose
of more than 200 tons per  year in an Ohio land disposal facility.  Such generators must address
waste minimization  or lose  their disposal approval.  Disposal may also be denied upon the initial
request for  disposal approval.

       OTTO  provides  technical  assistance and oversees technology  transfer related  to  waste
minimization.  OTTO is composed of a network of 32 field  agents working at 5 universities and
23 technical and  community colleges in Ohio.  These agents acquire  the technical expertise from
academic institutions, State  and Federal agencies, and  other public and private resources associated


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with Ohio's business  and industrial sectors.   Although OTTO's responsibilities address a broad
spectrum  of business  issues,  this non-regulatory organization  is  the  mechanism for technical
assistance in waste minimization.

       Specifically,  OTTO conducts  waste  minimization  seminars  and  provides  site-specific
technical  assistance on effective waste minimization practices.   In addition, OTTO agents will
either  train  employees themselves or locate the appropriate experts  to provide training and
introduce new technologies.   Ohio EPA  was  recently awarded a  RITTA  grant  and will be
formalizing its coordination with OTTO in an expansion of the State's waste minimization program.
The Great Lakes Rural Network, located in Fremont, Ohio, is also working with OTTO to expand
the technical assistance program, including that under RITTA. The OTTO program would include:

       •  Establishing a waste minimization training program for industry, agency staff, and local
          officials

       •  Providing site-specific technical assistance

       •  Continuing to  conduct outreach seminars through Ohio EPA  and OTTO,  including
          technical assistance and referrals

       •  Surveying  the business community to assess waste minimization information needs

       •  Publishing  waste  minimization manuals that target  specific  industries  (yet  to be
          determined)

       •  Publishing articles on  waste minimization practices and potential savings

       •  Producing a quarterly newsletter that will  be provided free of charge to Ohio businesses
          for the first year

       •  Conducting technology transfer workshops

       •  Coordinating a waste minimization trade fair, during which Ohio businesses can exhibit
          waste minimization and management  products

       •  Providing speakers for waste minimization lectures.

Pennsylvania

       In Pennsylvania, waste minimization has currently been reorganized under the Department
of Environmental Resources as the Division of Waste Minimization and Planning.  The Division
is divided into three sections:  municipal waste planning, waste minimization (which encompasses
municipal to hazardous waste), and information management systems (which manages data for solid
waste facilities).  Pennsylvania currently has no waste minimization legislation, but the State does
encourage waste minimization through research funding and fees for waste disposal facilities. In
addition, the Hazardous Waste  Facilities  Plan, published in  1986, emphasizes source reduction as
the primary waste management technique and reclamation of waste  as a secondary alternative. A
Hazardous Waste  Minimization Act is now pending.

       The State helps to fund  the Center for Hazardous Materials Research (CHMR), a nonprofit
subsidiary of the University of Pittsburgh Trust.  The Center provides technical assistance through
a  hazardous materials hotline,  seminars,  workshops,  training courses,  onsite  consultations,
publications, and a quarterly newsletter.  CHMR focuses on providing technical assistance to small
business,  industry, and government,  as  well  as providing hazardous materials worker training,
pesticide research, and education. The Center has published the "Hazardous Waste Minimization
Manual for Small Quantity Generators."


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       The State also contributes to the Pennsylvania Technical Assistance Program (PENNTAP)
at Pennsylvania State University.  PENNTAP, founded in 1965, focuses on technology transfer by
responding to questions from industries and municipalities and by distributing new information
through workshops and  consultations.  PENNTAP  also conducts confidential onsite  audits  of
industries on their request.  The president of Pennsylvania State University appoints an advisory
council of industrial executives to discuss current and future policy decisions.  PENNTAP has a
special task force for hazardous and solid waste.

       Pennsylvania initiated a Governor's Waste  Minimization Award in  1987.  The award
program is open to individuals,  companies, institutions, and government agencies in the State who
have established innovative waste minimization  projects.   The  annual  award is given in two
categories:  industrial and  municipal waste management.   The criteria for  selection include
environmental  benefits  through waste minimization  achievements,  technological/management
innovation,  economic  benefit,  dissemination  of innovative techniques,  and  commitment  to
environmental compliance. Summaries of successful projects are published to help publicize waste
minimization as an alternative to disposal or treatment.

Wisconsin

       Wisconsin's  Department of Natural Resources  (DNR) has a  comprehensive solid  waste
minimization program in place.  The Waste Reduction and Recycling Program provides information
and education, technical assistance, financial assistance, and regulatory compliance assistance to
the RCRA-regulated community.  Wisconsin has done little to minimize the production of waste,
but has a comprehensive program for minimizing the landfilling of waste.  As a result of these
solid waste minimization activities, Wisconsin's DNR has compiled  an extensive publications list
regarding recycling and resource recovery technologies.   The State is now turning  its attention to
hazardous waste minimization  and has recently been awarded a RITTA grant to facilitate the
effort.  Hazardous waste minimization program efforts  will include:

       •  Conducting site-specific waste audits

       •  Sponsoring industry-specific seminars

       •  Developing process-specific workshops

       •  Establishing  a waste  reduction information clearinghouse  pertinent  to Wisconsin's
          regulated community.

Local  Programs

       Many communities,  some with the encouragement and assistance of local industries, are
providing for the collection and proper disposal of household hazardous wastes, ranging from old
containers of pesticides to paint, paint thinners, and waste oil. For example, in recent  years Dow
Chemical Company's facility in Midland, Michigan, has sponsored an annual household hazardous
waste  disposal  week for area residents.


TOXICITY REDUCTION ACTIVITIES

       Toxicity reduction activities center largely on the National Pollutant Discharge Elimination
System (NPDES) Pretreatment Program and the inclusion of Toxicity Reduction Evaluations (TREs)
in select  NPDES permit requirements.
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Pretreatment Program

       A Pretreatment Program is required for all municipal wastewater plants treating significant
quantities of industrial process wastewaters.  The Pretreatment Program Plan for each city  is
approved by the USEPA or the delegated  State and  implemented by the  State via wastewater
discharge permit requirements of the NPDES permit.   Each major  industrial contributor  must
install, operate, and maintain treatment equipment capable of removing select Priority Pollutants
to a degree specified  for  its  industrial  category(ies)  by the Best  Available Technology (BAT)
Economically Achievable guidelines or local limits set by the discharger.  In most cases in Region
V, local  limits are more stringent than BAT guidelines.  Full implementation of the Pretreatment
Program will have the effect of reducing not only the volume of municipal  sludge containing
hazardous  quantities of   toxic  substances,  but also  the toxic  contaminant  concentrations in
wastewater discharges.

       To facilitate Pretreatment Program implementation, USEPA continues to sponsor technology
transfer  workshops for State and local regulators and publicly owned treatment works operators.
In November  1987, USEPA published its Guidance  Manual for the Implementation  of Local
Discharge Limitations Under the Pretreatment Program.

       Once the  program  is fully successful, one of the original  intents of the  Water  Pollution
Control Act Amendments of 1972 will have been fulfilled: to restore municipal sludge quality to
the point where it can be used as a soil amendment on agriculture, silviculture, and horticulture
without unacceptable risks  to the public health or the environment.  When this occurs, significant
sources of pollution associated with dewatering and  disposal or incineration  of  contaminated
municipal sludge will  have been  virtually eliminated  while maximizing  the  benefits associated
with nutrients recycling.

Toxicitv Reduction Evaluations

       With the publication of USEPA's Technical  Support Document for  Water Quality-Based
Toxics Control in September 1985, whole effluent toxicity as a component of the NPDES permit
program added a major tool to EPA and  the States'  abilities to control toxics.

       The number of Great  Lakes Basin permits  with whole effluent toxicity  monitoring and
limitations continues to grow as NPDES permits are  re-issued. These limits vary from restrictions
on end-of-the-pipe acute  toxicity to chronic toxicity limits of the low flow in-stream waste
concentration to back-to-back  flow-through chronic toxicity tests.

       When whole effluent toxicity limits are in permits and the discharger has problems meeting
those limits, it  is often necessary for the  discharger to reduce whole effluent  toxicity  in  a
systematic fashion.  USEPA developed two approaches  to conducting TREs to identify and reduce
the source(s) of toxicity in the discharged effluent.

       A TRE is conducted if  an unacceptable level of toxicity is detected  in short-term (acute)
or long-term (chronic) tests using sensitive indicator organisms with a reproducible response. If
the toxic component or  components and  their sources  can  be readily identified, improved
housekeeping, chemical substitution,  process  modification, or  wastestream  pretreatment can be
instituted to reduce  the toxicity below unacceptable levels.  If the cause(s) and source(s) of the
toxicity  are not  obvious,   a  more  sophisticated  TRE procedure can  be  used that   involves
fractionation of the wastewater to isolate  the toxic fractions.  Once toxic components are  isolated,
source reduction efforts can be targeted at the most  significant sources of the problem pollutants
amenable to improved  housekeeping, chemical substitution, process modification, or wastestream
pretreatment.

       In  1987,  USEPA  published  a  TRE Implementation Guidance  Manual  to  facilitate
implementation of toxicity-based effluent limitations and toxicity reduction  permit requirements.


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A  companion  volume  is  being developed  to  provide  further  standardization and  quality
assurance/quality control of toxicity testing methods used in the TRE program.

       GLNPO has contributed to the body of methodologies available for implementing  toxicity
reduction  in wastewaters  with the development of  a Process Characterization  Users Manual.
Although  targeted to a chemical-by-chemical approach to effluent monitoring  and  limitations
requirements development, the same methodology can be applied to chemical substitution, process
modification, or wastestream pretreatment goals. The Manual is in the final stages of completion.
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                   ANNEX 13:  POLLUTION FROM NONPOINT SOURCES


INTRODUCTION

       Annex 13 mandates  a number of measures to  address nonpoint sources of pollution from
land-use activities in the Great Lakes Basin.  These  measures specifically encompass efforts to
further reduce nonpoint sources of phosphorus,  sediments, toxic substances, and microbiological
contaminants that drain into Lake waters from surrounding urban and rural lands, including waste
disposal sites. Under  this Annex, the Parties are required to identify land-based activities that
contribute to the water quality problems described in Remedial Action Plans (RAPs) for Areas of
Concern (AOCs) or in  Lakewide Management Plans (LMPs) (under Annex 2), and to develop and
implement watershed  management plans that will reduce  nonpoint source inputs  to priority
hydrologic units.

       The  Parties must  also identify, preserve, and rehabilitate (where necessary)  significant
wetland areas that are threatened  by urban  and agricultural development and  waste disposal
activities,  determine nonpoint source pollutant inputs in order to estimate loadings to Great Lakes
boundary waters, and identify the extent of change in land use and land management practices that
significantly affect water quality in order to track the effects of remedial measures.

       Finally,  Annex 13 requires the Parties  to  report biennially on progress in  developing
specific watershed management plans and implementing programs and measures to control nonpoint
sources of pollution.

       Historically,  the  primary U.S.  activities to identify  and control  nonpoint  sources  of
pollution in the  Great  Lakes have focused on  reducing the phosphorus  load to the Lower Lakes
(Lakes Ontario and Erie) and to the  eutrophic embayments  (Green  Bay in Lake Michigan and
Saginaw Bay in  Lake Huron).  However, in  addition to recent efforts led by the USEPA to meet
the requirements of Annex  13, a variety of  programs  at  both State and  Federal levels (including
Department of  Agriculture's Soil Conservation  Service,  Department of the Interior's Fish and
Wildlife Service, and State Coastal Zone Management programs) also address nonpoint  issues such
as soil erosion, construction  site  runoff, and  wetland protection on an ongoing basis. Often these
efforts are conducted in cooperation with USEPA.  These and more recent strategies for meeting
the requirements of Annex  13,  such  as nonpoint source  assessments and management programs
under the Amendments to the Clean Water Act (CWA), are briefly discussed in this section.


PHOSPHORUS  REDUCTION PROGRAMS

       Annex 3  of the GLWQA sets forth a  general framework for Canada and the United States
to reduce phosphorus  loadings  to the Great  Lakes.   In 1983, a  Supplement to Annex  3  was
approved, delineating phosphorus loading levels  to be achieved by 1990, and restating the belief
that phosphorus  loading objectives could be attained through existing programs  in  the  Upper
Lakes.

       Additional  action  was required to obtain target loads for Lake Erie, Saginaw Bay, and
Lake  Ontario, however. Consequently, the 1987 revisions to the GLWQA modified the reductions
needed for Lake  Ontario, based on new analyses.  In setting these load reduction requirements,  the
GLWQA recognized that nonpoint source controls on phosphorus, particularly from agricultural
activities,  would be required to meet Agreement goals. To achieve these target goals, each State
and Province was required to develop and implement a detailed phosphorus load  reduction plan
for these Lakes.  The last State Plan was completed in September 1986.

       In  1986,  the Great  Lakes Phosphorus Task Force (representing the States of Indiana,
Michigan, New York, Ohio,  Pennsylvania; the Soil Conservation Service, Agricultural Stabilization


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and  Conservation Service,  and  Cooperative  Extension Services  of  the  U.S. Department of
Agriculture (USDA); and the USEPA Regions II, III, and V, as well as GLNPO), allocated Lake
Erie target load reductions among each responsible State.  In addition, Michigan and New York
were assigned a  target  load  reduction  for Saginaw Bay and  Lake  Ontario, respectively.  The
nonpoint source pollution abatement components were based upon obtaining new funds to support
an accelerated effort that would meet the 1990 goal.

       This phosphorus load reduction strategy evolved from the cooperative efforts of USEPA,
USDA,  and the States to conduct demonstration  programs, public  outreach efforts, and other
projects  to promote the use of  conservation tillage, animal  waste, and  fertilizer management
techniques by farmers throughout the  Great  Lakes Basin.  As part of these activities, under an
Interagency Agreement with the USDA Soil Conservation Service, USEPA  is conducting a 3-year
project  to track conservation tillage  practices  using  highway transects and remote  sensing
techniques in 58 counties  in  Indiana, Michigan, and Ohio.  The study has provided an estimate
of phosphorus  load reductions  that would be  achieved  as  a result  of  expanding the  use of
conservation  tillage.  A special  study  was  also  carried out  in Ohio, an area where  nonpoint
phosphorus discharges are particularly high because of regional conditions.

       These  studies indicated  that USDA programs would have  to be expanded  in  Ohio,
Pennsylvania, and New York in order to decrease nonpoint  source phosphorus  loads sufficiently
by  1990  to meet the Agreement goal.  Based on the allocated load reductions and State  plans to
comply with the allocations, the nonpoint source components of required load reductions have been
isolated and tracked.  For each  State,  the majority of the  nonpoint source  load  reduction was
expected  to come  from agricultural sources.   Although  increased  attention has been paid  to
encouraging the agricultural communities in these States to adopt conservation tillage and animal
waste management activities, program expansion has not occurred to an appreciable degree.  Thus,
the States are generally behind schedule in reducing nonpoint source phosphorus loads.

       The 1990 target load reductions  for Lake  Erie, Lake Ontario,  and  Saginaw  Bay are
compared with load  reductions  achieved by 1988 in  Table  3.   New York has already made
substantial progress reducing nonpoint source phosphorus  loads to  Lake Ontario, achieving more
than 45 percent of the targeted load reduction  goal. Similarly, Michigan  has attained more than
90 percent of its load reduction goal for Saginaw Bay and  an acceptable 25-percent reduction for
Lake Erie.  Phosphorus load reductions to Saginaw Bay and Lakes Erie and Ontario as of 1988
were 207.8, 330.2, and 105.5 metric tons, respectively. Although these reductions were significant,
given that they  were achieved with existing programs and  competing priorities, the apparent
success  must be  tempered  by the realization that  1988  was  a  drought year, resulting in reduced
land runoff.  In  any case,  the reductions fall short of  meeting the 1990 goals.
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TABLE 3.     SUMMARY OF THE  1990 PHOSPHORUS LOAD REDUCTION GOALS FOR
              LAKE ERIE, LAKE ONTARIO, AND SAGINAW BAY AS COMPARED TO
              1988 REDUCTION IN PHOSPHORUS LOADS (METRIC TONS)


       Lake Erie                                      Units of Measure

          1990 Goal                                          1700
          1988 Reductions                                     330
          Reduction Needed to Meet 1990 Goal                 1370

       Lake Ontario

          1990 Goal                                           235
          1988 Reductions                                     106
          Reduction Needed to Meet 1990 Goal                  129

       Saeinaw Bav

          1990 Goal                                           225
          1988 Reductions                                     208
          Reduction Needed to Meet 1990 Goal                   17
MANAGEMENT PLANS TO CONTROL TOXIC LOADINGS FROM NONPOINT SOURCES

       In FY  1988, GLNPO  sponsored a workshop on developing lakewide management plans
for State agencies in the  Great Lakes Basin.  This workshop was the first step toward fulfilling
the requirements of the GLWQA for controlling toxic pollution from nonpoint sources.

       RAPs for AOCs and LMPs (both required by Annex 2) also provide opportunities to focus
on nonpoint sources of toxic loadings. In particular, the USEPA, Environment Canada, New York
Department of Environmental Conservation, and the Ontario Ministry of the Environment have
committed  to developing a LMP for Lake Ontario to  control toxic loadings.   Because  of  the
importance of  leachates from  land disposal sites in the drainage basin, significant aspects  of this
plan will be directed toward nonpoint sources.  The Lake Ontario Toxics Management Plan will
be completed in  February 1989.

       In  1986,  USEPA  and the  States  of Illinois,  Indiana, and Michigan prepared  a Lake
Michigan Toxic Pollutant Control/Reduction Strategy. The objective of the strategy is to  restore
multiple  human  uses to  Lake Michigan and to protect human  health  and  the  Lake Michigan
ecosystem by achieving a significant reduction in the  loading  rates of toxic pollutants.  The
strategy will use  a whole-lake mass balance approach to  modeling toxic pollutants and evaluating
potential regulatory controls.

       The  Great  Lakes States  also have worked jointly towards achieving the  goals  of  the
GLWQA.  In June 1986,  the  Governors of the eight Great Lakes  States signed the Great Lakes
Toxic Substances Control Agreement. This Agreement pledges the States to  treat the Lakes as a
single ecosystem  despite political boundaries, acknowledges that toxic pollutants are the foremost
problem  to be  addressed, and  lays out goals for the States.  More recently, the Governors agreed
to establish a permanent fund  for Great Lakes studies. Many of the activities under both of these
State  agreements  will lead directly and  indirectly  to  the  completion and  implementation of
management plans  and ultimately to the attainment of the Agreement  objectives.  Considerable
progress  has been made  toward  this goal by USEPA Headquarters and regional regulatory and
remedial programs by the States.


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       In FY 1989, USEPA will continue to characterize the extent of nonpoint sources of toxic
pollution and identify opportunities for conducting demonstration projects to assist with programs
for conventional pollutants.


1987 AMENDMENTS TO THE CLEAN WATER ACT -- STATE NONPOINT SOUR* E
ASSESSMENTS AND MANAGEMENT PROGRAMS
             recent U.S. efforts to identify and control nonpoint sources of pollution are derived
from Sc  ion 319 of the CWA, as amended in 1987. Under this Section, each State was required
to develop a Nonpoint Source Assessment.  Having accomplished this, the Great Lakes States are
now developing Nonpoint Source Management Program Plans.  The assessments  are  intended to
determine the waters of each State that will not meet designated uses due to nonpoint source
inputs, to identify the categories and  subcategories of  nonpoint sources that contribute to water
quality degradation,  and to describe existing programs designated to control each category and
subcategory.  Many programs  are  required to address all the categories  and subcategories of
nonpoint sources identified in  assessment reports  as  causing water quality  impairments.  In
addition, programs must include an identification of implementation strategies as well as milestones
and schedules for remedial activities.

       Consistent with Annex 13 and Clean Water Act requirements,  USEPA issued  guidance to
the States encouraging the use of a watershed approach in developing these management programs,
with areas designated as AOCs receiving priority  attention.

       The  federal government provided limited funding for assessment and management program
development under Section 205(j)(5) of the Act.  Although use of these funds was optional,  all of
the Great Lakes States availed themselves of these additional resources, and have prepared  draft
assessments  and programs that are currently under by USEPA review.

       The  draft nonpoint source management programs cover a wide range of control activities,
including those for nutrients (particularly  phosphorus), and sediment pollutants.  Significant gaps
in this effort remain,  however, as  most States have not had the time or the  resources to  fully
develop all aspects of their programs.  Over the next year, additional effort will be made to  more
fully develop  the State management programs.  Once the programs are completed, Congress may
allocate funds under Section 319 of the Act to assist in program implementation.  Additional funds
will be needed for States to meet the agreed phosphorus load reductions, regardless of  the amounts
needed for toxics controls that may be part of their nonpoint source management programs under
the CWA.

       USEPA's Office of Groundwater Protection,  in coordination with USEPA's  Nonpoint
Sources Branch and GLNPO,  is  initiating a project to examine and refine methods to quantify
nonpoint source contamination of groundwater discharge to surface waters. These methods will
ultimately assist the States in developing nonpoint source management programs where groundwater
is a significant transport mechanism of  nonpoint  source pollution to surface waters.


OTHER ACTIVITIES

       Because an important function of wetland areas is to act as a filter for nonpoint sources
of pollution from upland, wetland protection is an  important component of watershed management.
The U.S. Army Corps of Engineers, in cooperation with the USEPA, administers a permit program
under Section 404 of the Clean Water Act to  regulate  the dredging and filling activities in U.S.
waters, including wetlands. In  1988, the number of dredge and fill permits issued  in the  Great
Lake States declined  19.5 percent from  1987, with a total of over 680 standard permits.
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       Other efforts to protect wetlands include the advanced identification (ADID) of significant
wetlands, which assists in determining wetland  areas that are unsuitable for filling.  In Region V,
four ADID studies have been completed, involving over 2,500  acres of wetlands.  The study areas
include the Grand Calumet River/Indiana Harbor Canal, Indiana; Lake County, Illinois; Green Bay,
Wisconsin; and Lake Calumet, Illinois.

       The  National Oceanic and Atmospheric Administration (NOAA) currently oversees and
supports  approved coastal zone management (CZM) programs in four of the Great Lakes  States.
These State programs address not only wetlands  protection, but  also land use, energy facility siting,
and  other activities affecting the wetlands and coastal  areas.  CZM programs  are  particularly
important as regulatory mechanisms for controlling  upland  activities that contribute  to nonpoint
source discharges. Federal activities that affect the coastal zones of these States must  be certified
by the State as consistent with its CZM program.

       Another example of recent State activities in nonpoint source programs is Minnesota's Clean
Water Partnership Program, established in 1987.  This program's goal is to protect and  improve
surface and  ground  water  in  the  State  through  financial  and  technical assistance  to local
governments.  The Program focuses primarily on water pollution associated with land management
activities.

       NOAA also has a diverse research  and monitoring  program addressing nonpoint  source
pollutants ranging from collecting data  on inputs,  transport,  fate,  and effects of pollutants to
studies on the  interactions of these pollutants with the marine environment.  NOAA research is
conducted and/or supported through its National Sea Grant  College  Program and its Great Lakes
Environmental Research Laboratory (GLERL).

       GLERL supports a small project  in  cooperation with the Soil Conservation Service of the
USDA and  several State  agencies on the effectiveness of Best Management Practices (BMPs)
implemented as part of the Saline River  Rural Clean Water Project for the reduction  of major
nutrients  and sediments to the small  streams in the basin.  This project is intended to  assist in
providing estimates  of loadings  of  nutrients  to  the  boundary  waters, and also serves as a
demonstration project  on  the importance  of land-use and land management  practices that affect
water quality.

       Demonstration  projects for nonpoint source  pollution  control techniques  have had  many
successes  in the Great  Lakes, over the years. In 1972, Section  108(a) of  the CWA authorized $20
million for USEPA to demonstrate the engineering and economic feasibility of pollution control
in the Great Lakes Basin.   GLNPO worked closely  with USEPA's Office of Research and
Development, Headquarters and regional water program, as well as with State and local government
organizations, to  conduct demonstration  programs that covered a range of objectives, including
demonstrating  specific control  technologies, controlling agricultural pollution  through  BMPs,
increasing public awareness of water  pollution  issues, documenting water quality results through
monitoring, evaluating combined sewer systems, and evaluating various sewage land application
techniques.

       Management projects conducted under  the Section 108(a) program included development
of a watershed management computer model for identifying important  pollution sources,  model
ordinances for  pollution  control, and  other management   tools.   Other projects  involved
demonstrating sewage sludge land application techniques and conservation tillage practices.  A key
aspect of the tillage demonstration projects was  that by providing funding and technical assistance
to local soil and water conservation districts, tremendous amounts of local support was developed.
Thus, these projects have provided important institutional and technical insights beneficial to State
and local  programs.

       The  USDA also  supports  demonstration  programs that  address nonpoint  sources of
pollutants, including  the  USDA/Agricultural  Stabilization  and Conservation Service-sponsored


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Rural Clean  Water Program.   The  goal of  this program is  to  develop  agricultural  BMPs by
providing technical and financial assistance to farmers for nonpoint source pollution control.

       Similarly, the USEPA  Nationwide Urban Runoff Program has  funded demonstration
projects focused on an  evaluation of the effectiveness of alternative nonpoint source pollution
control techniques.   USEPA will continue to sponsor nonpoint source demonstration projects to
ensure that the reductions in phosphorus discharges already achieved in the basin are maintained.
If ongoing evaluations show that more controls are necessary,  USEPA will work towards further
reductions through  new demonstration and public education projects.

       A  new  program for permitting stormwater discharges, which  is being developed by the
USEPA under Section 402(p)(2)(E) of the Clean Water Act, provides an additional mechanism for
controlling pollutants contained  in urban runoff.
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                        ANNEX 14: CONTAMINATED SEDIMENT
INTRODUCTION
       Annex 14 requires the Parties, in cooperation with State and Provincial governments, to
identify the nature and extent of sediment pollution of the Great Lakes system.  Based on these
findings, methods will be developed to evaluate both the impact of polluted sediments on the Great
Lakes and the technological capabilities of programs to remedy such pollution.

       This report describes progress made by the United States to fulfill its responsibilities under
Annex 14.   After a brief overview  of  U.S.  sediment activities, progress is described in three
general areas:  surveillance programs, technology programs, and long-term control measures.

Overview of U.S. Contaminated  Sediment Activities

       U.S. activities related  to  contaminated sediment are implemented under Sections  118(c),
Section 404, and Section  401 of the Clean Water Act (CWA)  and the GLWQA.

       Section  118(c)(3) of  the CWA  requires USEPA to  carry out  a 5-year  study  and
demonstration program for the control and removal of toxic pollutants from the Great Lakes.  The
CWA specifically designates five  AOCs for "priority consideration" in locating demonstration sites:
Saginaw Bay, Michigan;  Sheboygan Harbor, Wisconsin; Grand Calumet River, Indiana; Ashtabula
River, Ohio; and Buffalo River,  New York.

       It should be noted that both Annex 14 and Section 118(c)(3) of  the 1987 Amendments to
the CWA represent a new direction in contaminated sediment management.  Both the  Agreement
and  the  Act directly address the  problem of  contaminated sediments outside  the  context  of
navigational dredging and dredged material disposal. Concern is now focused on situations where
contaminated sediments,  if left  in  place, present  risks  to  humans and  the ecosystem through
contaminant mobility or  bioaccumulation.  (Annex  7 of  the GLWQA  deals further  with issues
related to navigational dredging.)

       Section  404  of the  CWA provides for  the  regulation  of  discharges of dredged  or  fill
material into all U.S. waters.  The U.S. Army Corps of Engineers  (USCOE), in cooperation with
the USEPA, administers  the Section  404  permit program. Michigan is the only Great Lake State
that has assumed the administration of the Section 404 permit program  for selected waters in the
State.  The USCOE retains jurisdiction of navigable waters and adjacent wetlands and  regulates
all U.S. waters in the absence of an approved State program.  The U.S.  Fish and Wildlife Service
(USFWS) and the National Marine Fisheries Service  (NMFS)  review and comment on  404  permit
applications and provide technical assistance to protect fish and wildlife resources and to mitigate
project impacts.

       Worst cases  of contaminated  sediments  are located in the  designated Areas of Concern
(AOCs).  Of the total 42 in the United States and Canada, 41  AOCs have contaminated sediments
that are impairing beneficial uses.  Preparation  of Remedial  Action Plans (RAPs) are under way
in all 30 U.S. AOCs and will address contaminated sediments.


COORDINATION OF RESEARCH AND OTHER STUDIES

       In FY 1988, GLNPO started work to improve its coordination procedures within  EPA and
with  other  Federal  Agencies and  the  Great  Lakes  States.   GLNPO established  interagency
agreements  related to  contaminated sediments  with several  other  government offices  and
institutions.  Within USEPA,  GLNPO has also established agreements for participation by other
EPA  programs and  offices in  Great  Lakes initiatives.   For  instance, GLNPO entered  into


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agreements with the Office of  Research  and Development to fund  Great Lakes work at the
Environmental Research Laboratory - Duluth, Minnesota, and its Large Lakes Research Station
(LLRS), Grosse He.  These two laboratories are contributing substantially to the  Green Bay/Fox
River Mass Balance Study, demonstration projects undertaking research on contaminated sediment,
and other GLNPO initiatives.

       Also in FY 1988,  GLNPO entered into an agreement  with  the Council  of Great Lakes
Governors to assist with implementation of the Great Lakes Toxic Substances Control Agreement,
signed by the Governors in 1986.  This Agreement pledges the States to treat the Lakes as a single
ecosystem despite political boundaries, acknowledges that toxic pollutants are  the foremost problem
to be addressed, and lays out goals for the States.  More recently, the Governors agreed to establish
a permanent fund for Great Lakes studies.  GLNPO plans  to continue work on all  of these efforts,
as well as initiate new  projects with State  organizations in FY 1989.

       During FY 1989, GLNPO established procedures for participating with EPA Headquarters
in development of the Agency  Operating Guidance for  water programs and participated with
regional water divisions in development of State water program guidance.   These two guidance
development  activities  are the  principal  methods  by  which  EPA  program priorities  are
communicated throughout the  Agency and to the States.  GLNPO plans to  expand its efforts in
this area to include participation in program guidance development for other EPA programs as
well.

       Overall, GLNPO has made important progress toward fulfilling obligations under both the
CWA and the GLWQA. All of these achievements have involved other organizations working in
the Great Lakes.  By working  cooperatively with the States and other  Federal Agencies, GLNPO
was able to ensure that significant progress toward achieving GLWQA goals was made during FY
1988. Much work remains to be done, however, and can be accomplished only through continued
cooperative efforts throughout the Great Lakes Basin within the United States and with Canada.
Future prospects focus primarily on control and abatement of toxic  pollution in the Great Lakes.


SURVEILLANCE  PROGRAMS

       The progress of surveillance  programs is discussed in  three categories:   classification of
sediment  quality, monitoring activities, and management  of contaminated sediments.

Classification of Sediment Quality

       Over  the  last several  years,  USEPA's Office of  Water has examined  ways to  develop
sediment  quality  criteria.  The following approaches  have been considered by USEPA in the
course of this criteria development effort:

       •   Sediment toxicity  tests  — safe sediment  concentration  of  specific chemicals are
           established by  a dose-response  relation in sediment spike toxicity tests.

       •   Apparent effects threshold (AET) -- field data on biological effects are compared with
           sediment concentrations  of individual  chemicals.  The  AET  is  defined as the
           concentration above which biological effects are always  observed.

       •   Equilibrium partitioning (EP) --  interstitial water concentrations are  equated to water
           quality criteria concentrations  for specific chemicals and used to calculate  numerical
           bulk sediment  criteria protective of aquatic life and its uses.

       •   Sediment quality triad  —  correspondence  between sediment chemistry, toxicity, and
           biological  effects  is used  to  determine sediment concentrations that discriminate
           conditions of minimal,  uncertain,  and major biological effects.


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       •  Tissue residue approach  -- safe  sediment concentrations  of specific chemicals are
          established by back-calculating from an  acceptable  tissue residue  to  the sediment
          concentration resulting in that residue.

       •  Reference approach -- frequency distributions of sediment chemical concentrations are
          established separately for reference  (i.e., background)  and  contaminated sites,  and
          compared with sediments of concern  on a statistical basis.

       •  Extraction (elutriate) test -- contaminant concentrations in  an elutriate  from a 4:1
          water/sediment mixture are compared with drinking or water quality criteria or various
          multiples thereof to protect  the water column  biota during dredged  material disposal
          operations.

       •  Bulk  sediment toxicity — the toxicities  of field-collected samples are determined by
          sediment bioassays.

All of these  approaches have some  history of application in other government programs.  For
example, the extraction test and reference approaches are being used in  dredged material permit
evaluations in many USEPA regions and the AET approach has been  extensively applied in USEPA
Region X.  Additional work  has been done by the  Puget Sound Program to develop and test the
sediment quality triad approach and AET method.

       The Office  of Water is working with  several Regions and States on the national sediment
criteria  effort,  which  may  include  chemical specific methods for  evaluating the  effects of
contaminated sediments (e.g.,  EP and AET) as well as non-chemical  specific methods (e.g.,
biological community structure,  and acute and chronic effects laboratory bioassays).  Most of the
methods  alluded to in  this  section will  be described  in a  Sediment  Classification  Methods
Compendium currently  under development  by EPA, information will  be presented  on  their
advantages, limitations,  and applications.

       USEPA Region V is working  with the  States on methods to assess sediments through a draft
In-Place  Pollutants  Control Initiative. In lieu of numerical sediment quality criteria derived  in a
manner consistent with that  used  for numerical water quality criteria,  the present approach to
classify contaminated sediment sites in the Great Lakes involves the  application of the  "Guidelines
for the Pollution Classification of Great Lakes Harbor Sediments" developed by USEPA Region V.
First  published  in  1968, these interim guidelines evolved from studies  of Great Lakes harbor
sediments started in 1967 by the Federal Water Pollution Control Administration. Those studies
established  three broad  categories  of sediment contamination based  on field  observations  and
professional judgment nonpolluted,  moderately polluted, and heavily polluted. Factors considered
included color, odor, particle  size distribution, presence of oil, and the condition of  the benthic
faunal community.  Natural breakpoints in the sediment contaminant level data  for samples from
over  100 different Great  Lakes  harbors  were  then used to establish pollutant  parameter
concentration ranges corresponding  to the observed conditions.  Supplementary interim guidelines
for 11 additional parameters were added in 1977, based on data from 260 samples collected at 34
harbors.  These  guidelines  are used to determine  if open lake disposal  of dredged sediments  is
appropriate.

       The Great Lakes Water  Quality Board of  the IJC, through its Dredging Subcommittee,
also published Dredged  Material Disposal Guidelines in 1982.  The guidelines are based on the c-
oncentrations of pollutants  in the sediments of depositional zones of the Great Lakes, rather than
on  the concentrations of pollutants  in  the harbor sediments.

       In addition,  USEPA's Office of Research and Development is  developing sediment bioassays
and measures of benthic community structure to evaluate benthic  ecosystem effects of specific
chemicals in  complex wastes  and contaminated sediments.


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       Some States have developed their own classification system.  The following describes each
State's approach to sediment classification:

       Illinois  has  developed  a  five-tier  classification system of stream sediment quality based
upon  standard deviations  for background  levels.   This  system  is  currently  used by  Illinois
monitoring programs to assess sediment quality.

       Indiana uses bulk analysis to evaluate sediment samples. In order to assess the test results,
Indiana has established  background levels for  each  substance of interest.  The background levels
were established using data collected over several years from uncontaminated sites. The test results
are compared  with established  background levels, with  USEPA  Guidelines  for the Pollution
Classification of Great Lakes  Harbor Sediments and with Indiana water quality standards. PCBs
are considered the contaminants of primary concern; 0.5-1.0 ppm total PCB,  depending on  the
sediment type, is considered the maximum acceptable concentration.  Sites with levels exceeding
this limit may require sediment removal.  Fish  tissue samples remain the primary  indicator of toxic
contamination, however.   If  fish tissue samples collected from  the  sediment site  do not  show
accumulation, it is unlikely that sediment will require removal.

       In  Michigan,  Minnesota,  and   New York the  choice  of  classification  criteria  is
site-dependent, although the  1977 USEPA  Guidelines  for the Pollution Classification of Great
Lakes Harbor Sediments are commonly used.  Recently, Minnesota  has also been using guidelines
set by Wisconsin.   Pennsylvania  conducts assessments  on a site-by-site  basis, as it  has no
standardized assessment criteria for contaminated sediments.

       New York  attempts to link the sediment classification to  actual use impairment within
specific water  bodies.   New York  State Department of Environmental  Conservation is currently
developing a technical guidance  document for  evaluation of water quality impacts during dredging
operations.

       Ohio uses criteria developed by Illinois to classify Ohio stream  sediments. Since the Illinois
criteria were developed for streams similar to those in Ohio, they are  more applicable than the
USEPA Great  Lakes Harbor  sediment guidelines.  Ohio does continue  to use  the USEPA Great
Lakes Harbor sediment guidelines  for harbor  areas (river  mouths), however.

       Wisconsin  has developed a three-tiered sediment assessment  scheme and  has established
sediment quality criteria. These criteria are based on background data from several sources.  The
background data for metals were collected from recent and 200-year-old  Lake Michigan sediments,
bluff material  from Lake  Michigan shorelines, and average  concentrations of  metals in surficial
sediments from all the  Great  Lakes.  Background levels for  organics were also  determined using
data  from surficial sediments from all the Great  Lakes.  Wisconsin has developed background
criteria for metals, total PCBs,  total tetrachlorodibenzodioxin (TCDD), total tetrachlorodibenzofuran
(TCDF), selected  pesticides, and oil and  grease.

Monitoring Activities

       The GLWQA, as amended  in 1987, sets  forth several monitoring and research programs.
Specifically, the Agreement requires the establishment of monitoring and research programs in
support of  the Great Lakes International Surveillance Plan at a level sufficient to identify:

        •   Temporal and spatial trends in concentration of persistent toxic substances

        •   Impact of persistent toxic substances on the health of humans and the  quality and health
           of living aquatic systems
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       •  Sources of input of persistent toxic substances

       •  Presence of previously unidentified persistent toxic substances.

       The  Agreement also stipulates that research  should be  intensified to determine  the
pathways, fate, and effects of toxic substances aimed at the protection of human health, fishery
resources, and  wildlife of the Great  Lakes Basin  ecosystem.  Research should  be  conducted to
determine:

       •  Significance of effects of persistent toxic substances on human health and aquatic  life

       •  Interactive effects of residues of toxic substances on aquatic life, wildlife, and human
          health

       •  Approaches  to calculate  acceptable  loading rates  for persistent  toxic substances,
          especially those which,  in part,  are naturally occurring.

       The  following  discussion of  U.S. progress  toward a comprehensive monitoring program
focuses on monitoring to determine the impact of contaminated sediments on  the Great  Lakes
system and on  monitoring to increase  our  understanding of the transfer of contaminants  to  and
from  bottom sediments.

Ambient Monitoring and Assessment  Activities

       Some States in the Great Lakes Basin  undertake sediment  monitoring as part of specific
remedial activities.  In particular,  Indiana  and Michigan have  identified contaminated sediment
sites near industrial discharge points requiring remedial action.  Michigan also has performed some
investigative  monitoring at three contaminated sediment study sites.

       GLNPO has conducted  harbor and  estuary sediment sampling to identify toxic hot spots
and to aid in the identification of areas that are contributing large amounts of toxics to  the Lakes.
Twenty-five harbors  on Lakes  Superior, Michigan, Erie,  and Ontario  were  sampled  for
conventional or priority pollutants  in  1981  and 1982, including  intensive sampling of the Buffalo
and Niagara  Rivers in 1981 and  the  Detroit  River in 1982.  The St. Lawrence  River and its
tributaries were sampled in  1984.

       GLNPO sampled 52 tributaries to the four  upper Great Lakes connecting channels during
1985.   The levels of contaminants in the sediments were compared against  guidelines  developed
by USEPA,  Ontario Ministry of the Environment, and the IJC.   Overall contamination at each
tributary to the connecting channels was evaluated  relative to the levels of metals, nutrients, total
PCBs, pesticides, and other organic compounds.  The evaluations allowed for the identification of
tributaries that  were substantial contributors of pollutants. In addition, over all comparisons were
made  among all of the connecting channels studied  to assist GLNPO in prioritizing remedial  action
needs.

       The binationai Coordinating Committee on the  Niagara River has developed an ambient
monitoring program evaluating  upstream versus downstream water quality and pollutant loadings.
The program presently measures 40 persistent toxic chemicals and has detection levels low enough
to evaluate the  potential exceedances  of chronic ambient water quality criteria.

       Future plans extend sampling to sediments  in the open waters of the Lakes to measure the
distribution, storage,  and fate of toxics in the ecosystem, beginning in Lake Michigan in 1991.
This sampling will provide a chronology of toxic inputs to the Lakes and will  support mass balance
models for Critical Pollutants. Sampling will also support development of Lakewide Management
Plans as required by the GLWQA. GLNPO coordinates this work with the development of national
sediment criteria and  sediment contaminant cycling studies conducted  by  USEPA's  Office of


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Research and Development laboratory at Duluth, Minnesota, and its Large Lakes Research Station
at Grosse  He, Michigan.

       USEPA also is working with  the States and local agencies on sediment monitoring during
the development of Remedial  Action Plans for the Areas of Concern by the IJC.

       The  Great Lakes States  are  also performing general area  sediment monitoring.  These
monitoring efforts are performed either in response to a specific problem or as part of the State's
routine basin monitoring programs.  Specific efforts  are described  in Table 4.

Activities  to Quantify the Transfer of Contaminants from Sediments

       In  addressing the issue of contaminated sediment management in  the Great Lakes,  the
Water Quality Board convened the Sediment Technical  Oversight Committee,  which is composed
of technical experts within the region.  The overall  objective of this Committee is  to  identify,
coordinate, and provide guidance on  contaminated sediment activities.  The Committee's research
plan includes the implementation of  the following  activities  over the next 5 years:

       •  Identification and detail of chemical specific and bulk sediment toxicity methods

       •  Development of benthic organism chronic toxicity, bioaccumulation, and carcinogenicity
          test methods

       •  Performance  of an  ecological assessment of  known sediment activity of metal ions in
          pore water and its toxicity.

       The  USEPA  Environmental  Research  Laboratory  at Duluth, Minnesota, is  involved in
monitoring efforts at sediment contamination remediation sites;  Recent studies at various sites
have  involved  sediment transport and deposition studies,  acute  and chronic  toxicity testing,
physical characterization,  chemical  analyses,  Ames  testing, and  carcinogenicity testing of  the
sediment.

       Contaminated sediment monitoring  is also an important element in the Green Bay  Mass
Balance Study.   This  Study,  coordinated by USEPA and Wisconsin  Department of  Natural
Resources, is intended  to develop and test a modeling framework on sources, transport,  and fate
of toxic compounds in the Green Bay area. The study is intended to support regulatory activities
within the study area and to serve as a pilot project  ror larger modeling studies.

       The  project  began  in  1987 with  the development  of  a monitoring plan  and  the
establishment of a quality  assurance  program for evaluating analytical and field methods to be
employed.  Field reconnaissance and sampling commenced the following year and will  continue
through 1989 to determine levels of  selected contaminants (i.e., those known to present  problems
in the Great Lakes and which also serve as surrogates  for larger classes of contaminants) in various
compartments (i.e., atmosphere,  water, sediment, biota) of the  Green Bay ecosystem. The model
will incorporate the following components:

       •  Comprehensive quantification of loads from all significant sources (e.g.,  atmosphere,
          tributaries, ground  water,  point, and nonpoint)

       •  Determination of the net rate of  exchange of contaminants  between environmental
          compartments (e.g., sediment, surface water, ground water, biota, and air)

       •  Net rate of  exchange with Lake Michigan.
                                            54

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                                          TABLE 4.  SUWARV OF STATE AMBIENT  UATER  AND  SEOINENT MONITORING PROGRAMS
Illinois

Stream sediment data are collected through two programs:  the Ambient Water Quality Monitoring Network (AWQMM) and the Intensive River Basin Survey Program.
The AUQMN provides background and trend information, as well  as information on current  conditions  in specific streams.  Intensive surveys are basin-specific,
and provide surveillance information for response to known or suspected water  quality problems.  Lake sediment data are collected through the State's ambient
lake monitoring program and intensive lake surveys.

Indiana

Indiana collects sediment quality data through its Toxics Monitoring Program. This program concentrates on analyzing fish tissue samples collected at the State's
21 CORE stations. Sediment samples are routinely collected at the CORE stations as well.   Intensive surveys have also been conducted on several  lakes, reservoirs
and streams in Indiana.  Through intensive surveys and special  studies  33  streams and 62 lakes and reservoirs have been studied in the past 3 years.

Michigan

Field investigations, including sampling and analyzing sediment  for historic and ongoing discharges,  may be conducted  when sediment contamination  is suspected
based on results of water quality monitoring programs.

Minnesota

Prior to 1980, sediment quality sampling was a component of routine water quality monitoring in Minnesota.   In  1973,  1976,  and  1979,  sediment samples were
collected at 19 fixed monitoring stations in the State.   This was discontinued after 1979 because of  the lack  of an established framework for data assessment.
Currently,  stream sediment quality data are collected through intensive stream surveys only.  The lake monitoring programs do not regularly include sediment
quality analysis.                      (

Men' York

Benthic macro invertebrate and fish community assessments, along with sediment samples  analyzed for PCBs, chlorinated pesticides, and priority pollutant metals,
are used in conjunction with water column data to describe overall water quality conditions.  Additionally, site  specific investigations to assess sediment condi-
tions have included sediment mapping, contaminant distribution and toxicity. bioavaliability, and erodibility testing.

Ohio

Ohio selects several streams each year for intensive surveys.  Surface water quality is  tested and fish and benthic populations are sampled at each site.  Fish
tissue and sediment testing are done less regularly.   Sediment tests are done when there is reason  to believe  that sediments may be contaminated.  Roughly one
third of the intensive survey sites throughout the State, or  60  sites,  conduct  sediment sampling each year.

Pennsylvania

When sediment contamination is suspected based on results of other  investigations, detailed analysis may be undertaken,  including sediment sampling  to determine
the extent and magnitude of the contamination.

Wisconsin

Contaminated sediments have been  identified as one of  six primary elements to  be evaluated by monitoring programs.   Monitoring  of  contaminated sediments  is
conducted under several programs, including basin assessments, special  projects,  Mississippi River monitoring, and specific response actions.

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       Analysis of field data, modeling, and interpretation are scheduled to begin in 1990. These
activities will be guided by several specific objectives:

       •  Usefulness in predicting concentrations of key contaminants  in fish to help determine
          cancer risks to human fish consumers

       •  Utility for USEPA and State in making regulatory decisions

       •  Applicability of the pilot study as a model for larger, lakewide studies.

       The  U.S.  Fish and Wildlife  Service also has been  involved in  general area sediment
monitoring.  The National Fisheries Center-Great Lakes has performed caged organism studies in
and  around  sites  with  contaminated  sediments  in order  to examine   biomagnification and
bioconcentration of  the  pollutants found in the sediments.   Clipped  wing  duck studies  at  a
confined disposal  facility (CDF)  suggest  that birds, when confined to a CDF having  aquatic
systems in contaminated ponds, can accumulate considerable body burdens of contaminants such
as PCBs. Other studies have focused on eagles because of their reduced reproduction in the Great
Lakes  area.   These studies  showed  that  eagles  may  be  indirectly accumulating sediment
contaminants through ingestion of prey organisms.

       The  National Oceanic and  Atmospheric Administration's Great  Lakes Environmental
Research Laboratory (GLERL) is continuing research important to the implementation of Annex
14. The research deals with measurement of the bioavailability and uptake of contaminants  from
sediments by  Pontoooreia  hovi and the incorporation of the results into  contaminant behavior
models.  A major  publication  provides a synthesis of 5  years of studies on the bioaccumulation
of PAH from sediments of £.  hovi.

       The GLERL HI-SED project made comparative studies of radionuclide inventories  between
1972 and 1982 in Lake Michigan and between 1976 and 1982 in Lake Erie.  These studies  show
the long-term  process  of  particle  associated tracers and  contaminants  focusing  on sediment
depositional basins.  A model has been developed to interpret distributions of chlorinated organic
compounds (e.g., PCBs and pesticides).

Management of Contaminated Sediments

       The United States and Canada are working  jointly to develop a standard approach for the
management  of contaminated sediments within the Great Lakes.  The first draft of the report  is
currently being reviewed by Federal, State, and  Provincial officials  in both countries.


TECHNOLOGY PROGRAMS

Remediation  Demonstration Program

       Under Section 118(cX3) of th« CWA as amended  by the Water  Quality  Act of  1987,
GLNPO will  conduct a 5-year study and demonstration project relating to the control and removal
of toxic pollutants from  bottom sediments.   The  geographic focus of  this study,  termed the
Assessment and Remediation of Contaminated Sediments Study (ARCS), will be in  several Great
Lakes  Areas  of Concern.  This program gives priority consideration to  conducting demonstration
projects  at five  Great Lakes locations:  Saginaw Bay,  Michigan; Sheboygan  Harbor,  Wisconsin;
Grand Calumet  River, Indiana; Ashtabula  River,  Ohio; and Buffalo  River, New York.  The
program will be carried out jointly with GLNPO and other Federal, State, and local agencies. The
final locations of  the demonstration sites will be determined by  matching technologies  and site
specific characteristics, including complementary activities by USEPA, States, and particularly by
the USCOE.  GLNPO has also entered  into an agreement with the Illinois Natural History Survey
for assistance in planning and designing  ARCS.


                                            56

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       An Activity Integration Committee (AIC) has been created for the ARCS program.  The
AIC will coordinate the ARCS program activities at the operational level.  This Committee will
be chaired by the chief of the Contaminated Sediments staff at GLNPO.  The AIC chair will also
be an ex officio member of, and report directly to, the management committee. The AIC will  be
responsible for the accomplishment of program tasks through  its  oversight of  the scientific and
technical Work Groups.

       Accomplishments  during  FY  1988  include  work on site  selection  criteria for  the
demonstration projects and work with USEPA's Office of Water on cleanup criteria for pollutants
in sediment.  Also in FY 1988, GLNPO entered into an interagency agreement  with the Army to
assist GLNPO  in the  development  of an evaluation  framework for  in-place contaminated
sediments, assessments of remedial strategies and associated technologies, and the assessment of the
overall effectiveness and benefits of various procedures  eliminating or reducing adverse impacts
resulting  from in-place contaminated  sediments.    The Chicago District of the USCOE  has
performed a study to  characterize Indiana Harbor sediments and  evaluate various disposal
alternatives.  The Chicago District  is now completing investigations on  a number of innovative
treatment technologies.  These include incineration, oxidation,  extraction, and solidification.  This
study will rank alternatives according to technological feasibility, and will include detailed cost
estimates.

Remediation Activities

       Remediation programs are carried out by Federal,  State, and local government organizations
throughout the  Great  Lakes  Basin, working  under  authorities granted  by  Federal  and State
environmental statutes.

       To date, USEPA has had limited success in mitigating sediment contamination problems
due  to a number of factors.  These include the lack of national guidelines for  determining what
levels of contaminated sediments cause problems, the problems and expense involved in dredging
and  disposal operations, and USEPA and USCOE limitations  for  management of contaminated
sediments. Virtually the only ongoing effort to remove contaminated sediments  in Region V is
the  USCOE dredging program.  This  program, however, is limited  to dredging  only where
necessary for navigation purposes.  As noted earlier, dredging for navigation purposes is addressed
in Annex 7.

       Another  potential  mechanism to remediate  contaminated sediment  problems  is  the
Superfund program.  However, sites with only contaminated sediment problems are not typically
found to pose risks to human health severe  enough for  the sites to be ranked very high on the
Hazard  Ranking System (HRS) or placed on the National Priorities List (NPL). For sites on the
NPL, sediments are not  always remediated along with on-site  media (soil, ground water) because
of the  lack of  SQC, the  difficulty  in  linking sediment contamination  to a single site, and
remediation/disposal difficulties and costs. Nevertheless, three contaminated sediment sites in the
Great Lakes Basin are slated for Superfund cleanup: Waukegan  Harbor,  Illinois; Fields Brook,
Ohio; and Sheboygan River, Wisconsin.

       In Region V, the thrust of the sediment work has been on the Great Lakes. Two USEPA
activities intended to remediate contaminated sediments in Great Lakes harbors and tributaries are
the development of  RAPs  for 30  Areas of Concern and the 5-year  demonstration program.
GLNPO  has provided technical support to all of the Great Lakes States in preparing the RAPs.
Since virtually all of the AOCs have contaminated sediment  problems, implementation of these
RAPs will be  a major step toward  remediating Great Lakes  sediments.  While the above two
activities  relate  solely  to  Great Lakes  harbors and tributaries, the current  In-Place Pollutant
Strategy  will emphasize  inland waterways.
                                            57

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                               TABLE 5.  STATE PROGRAMS FOR CLASSIFICATION AND DISPOSAL Of DREDGED  SEDINEHT
          APPLICABLE PROGRAMS
                                                                       CRITERIA
                                                                                                                        DISPOSAL  OPTIONS
Illinois

Issuance of an Illinois Section 401 permit for
a dredge project certifies that  the  dredging
activity  and  associated  disposal   actions
comply with Illinois water quality standards
and  laws.     Federal  404  pemits are  also
required for all dredge projects.
Sediment  quality   is   determined  through
particle size  analysis,  then  if necessary,
supernatant  or  modified elutriate testing.
The    preferred    method    of    sediment
classification is comparison of the elutriate
test  results  (based on  dredging technique,
disposal plans, and contaminants) to the water
quality standards  and effluent standards set
by State Code.
The  accepted means  for disposal  of  dredge
spoil   in   Illinois   are  Confied   Disposal
Facilities    (CDFs),    agricultural    land
nourishment,  beach  nourishment,  open  water
disposal, and bank disposal.  The  latter two
options  apply  only  to material  which  is  80
percent or more sand.
Indiana

Indiana  monitors dredged  sediment  disposal
through  Section  401  of the Clean Water  Act.
Federal  404 dredge and  till permits  are  also
required.
Sediment  quality analysis   is  required  if
tissues from fish in the area exceed U.S. Food
and Drug Administration (FDA) action levels.
The USEPA "Interim Guidelines for Evaluation
of Dredged Sediments" are used  as a general
guideline for evaluating bulk  sediment test
results, supplemented by Indiana  water quality
standards.  Test  results are  also compared to
background data compiled by  Indiana through
its monitoring programs.
Indiana water pollution control  laws prohibit
the disposal  in State  waters  of any matter
that   may  retard   the  growth   of   fish,
vegetation, or  other  animal  life.  Based  on
these  laws,  open water  disposal  of dredged
sediments is discouraged; however, open  water
disposal  is allowed  in certain instances  as
beach nourishment or rip rap.  Upland disposal
is  subject  to  solid  and   hazardous   waste
regulations.

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                                         TABLE 5.  STATE PROGRAMS FOR CLASSIFICATION AND DISPOSAL OF DREDGED SEDIMENT {CONTINUED)
                    APPLICABLE PROGRAMS
                                                                                 CRITERIA
                                                                                                                                  DISPOSAL OPTIONS
V/l
Michigan

Dredge  and  fill permits  are required under
Section 404 of the Clean Water Act,  and under
the  Michigan Submerged  Lands Act  of 1955.
Michigan maintains • Section 404  data base to
catalog information affecting permit  review.
Characterization data are stored by township
and  section, and include  factors  such as
contamination of  bottom sediments,  areas of
severe  coastal  erosion,   fish  consumption
advisories,   and/or    historic    discharge
information.  For each dredge and fill permit
application, a computer check determines which
characteristics  of  the  project   site  may
warrant special  attention.   Thus,   sediment
data are generated as a result of the permit
application process.

Minnesota

In Minnesota, dredging projects are  regulated
by  the  issuance of a  State Disposal  System
permit, in addition to federal 404  permits.
                                                               In cases where sediment analysis is required,
                                                               bulk  sediment  testing is performed for those
                                                               parameters  deemed likely to be present based
                                                               on historic data.
                                                              Secondary treatment, toxic effluent standards
                                                              and water quality standards are applicable to
                                                              each  individual  project.   Variances from the
                                                              standards   or   procedural  requirements  are
                                                              granted on  an  individual  basis.
In  most cases,  historic data  are  used to
determine whether the sediment is suitable for
open water disposal.  Permits for sites  that
require  frequent and  regular  dredging are
handled by the district  USCOE field  staff and
do not require State referral.
All hydraulic  dredging projects are usually
required  to  obtain a  state disposal system
permit  as there  is potential  for  carriage
water flow to  contaminate ground or surface
water.  Flow from confined disposal  facilities
is monitored.   If  the history  of the site
gives reason  to  suspect  contamination, and
there is  no  existing sediment data, testing
may be required.

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                               TABLE 5.  STATE PROGRAMS FOR CLASSIFICATION AND DISPOSAL Of DREDGED SEDIMENT (CONTINUED)
          APPLICABLE PROGRAMS
                  CRITERIA
                                                                                                                        DISPOSAL OPTIONS
New York

Section 401 permits are required for dredging
projects to ensure consistency  with New York
programs, laws, and regulations.  Federal 404
permits are also required.
Ohio

Issuance of a 401 permit  is  required for  all
dredging operations to ensure compliance with
all  Ohio programs,  laws,  and  regulations.
Federal 404 permits are also required.
There  are  no   set  criteria  to   classify
sediment.  Sediment are classified as  either
incidental  to  channel maintenance  or  those
which pertain  to water  use impairments  and
hazards posed by contaminated sediments.
If  contamination   is  suspected,   physical
characterization,   bulk   and/or   elutriate
analyses  are  required.    Sand  and  coarser
sediments are considered uncontaminated,  fine
sediments    require    chemical     analysis.
Parameters are determined by the site history,
using    EPA    guidelines    for    pollution
classification.  Bioassays are recommended to
be coordinated with EPA.
[No Information Available]
[No Information Available]
Pennsylvania

Issuance of a 401 Water Quality Certification
for  a   dredging  project   in   Pennsylvania
certifies  that  the  activity  complies  with
relevant water quality  standards.  Federal 404
permits are also required.
The USCOE  criteria are  used to  review the
degree   of   contamination   in  determining
appropriate disposal actions.
Nost  dredged  sediments  are  disposed  of on
upland sites and are subject to Pennsylvania's
solid   and  hazardous   waste  regulations.
Existing Pennsylvania  law allows  open  lake
disposal   depending   upon  the   degree  of
contamination.   Heavily contaminated dredged
spoils are  disposed  of  in confined disposal
facilities (CDFs).

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                               TABLE 5.  STATE PROGRAMS FOR CLASSIFICATION AND DISPOSAL OF DREDGED SEDIMENT (CONTINUED)
          APPLICABLE PROGRAMS
                                                                       CRITERIA
                                                                   DISPOSAL OPTIONS
Wisconsin

Wisconsin   has   codified   procedure*   for
assessment and criteria for in-water or beach
disposal of  dredged sediment*.   ThU  law  is
currently  being  redrafted   to  expand   and
clarify the  review  procedures.   Federal  404
per*its are also required.
Wisconsin   currently   applies   a   tiered
assessment scheme in evaluating dredge project
sites for regulatory, remedial, and Monitoring
activities.   The initial  assessment step  is
conducted   using   existing   and   readily
accessible  Wisconsin  data  or   information
submitted by the  applicant.

The second tier  is establishing sampling and
analysis   requirements.      Bulk  chemistry
analysis  is  performed on  the   samples   to
determine   potential    disposal    methods.
Background  criteria  are  used  to determine
suitability for open-water disposal  or beach
nourishment.   Open  water disposal  is  only
allowed by law if a beneficial use is  derived.

If the bulk chemistry criteria are exceeded,
the applicant may enter the third tier of the
assessment scheme--toxicity testing.
For  any project  where  upland  disposal   is
required or planned, assessment  requirements
are determined  under the  State solid waste
program review.  A new law has been proposed
to  define  the  requirements  for   in-water
confined disposal  facilities.

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       Table 6 lists State programs and projects, both  underway  and proposed, related  to the
remediation of sites with contaminated sediments.
                                             62

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                                     TABLE 6.  SUMMARY OF STATE PROGRAMS AND ACTIVITIES RELATED  TO CONTAMINATED SEDIMENTS
                     PROGRAM
                                                                                CURRENT PROJECTS
                                                                                                                                        PROPOSED PROJECTS
CP\
          Illinois

              The  Clean  Illinois program is  in place
          to fund the cleanup of contaminated botton
          sediments.
          Indiana

              A State bill  has been drafted for  a
          hazardous waste cleanup or "State Superfund"
          program.  The proposed law outlines a
          program that is meant to complement the
          USEPA Superfund program.
          Michigan

              The Michigan Environmental  Response Act
          (MERA) provides a method for identifying and
          assigning priority to sites of environmental
          concern within Michigan and conducting risk
          assessments.
     The Upper Waukegan Harbor  is currently
being investigated under  USEPA Superfund
authority and is the subject of litigation
and negotiation between USEPA and Outboard
Marine Corporation (OMC).  Negotiations
between EPA and OMC have  resulted in a
Consent Decree and recommended remedial
alternatives to clean the OMC/Uaukegan
Harbor site.  An estimated 1.100.000 pounds
of PCB are contained in 220.000 cubic yards
of sediment and soil.  The USCOE is
developing an Environmental Impact  Statement
(EIS) for dredging and disposal for the
Lower Harbor adjacent to  the area subject to
Superfund action.
     Sediment  data  for  the Grand Calumet
River/Indiana Harbor Canal  area have been
collected by the USCOE. Indiana Department
of Environmental Management  (IDEM),  and
USEPA.  Dredging of the Indiana Harbor
Canal, has been delayed due to concerns over
disposal methods for the PCB-contaminated
dredged sediments.
     Michigan DNR has  submitted nine RAPs  to
the 1JC which include remedial actions for
contaminated sediments.
      Once Superfund-related remedial
actions have been planned,  the Illinois
USEPA will assess other actions required to
satisfy the IJC requirements for RAP
development.
      Michigan DNR is responsible for
overseeing the development of one additional
RAP.

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                                     TABLE 6.  SUMMARY OF STATE PROGRAMS AND ACTIVITIES RELATED TO CONTAMINATED SEDIMENTS (CONTINUED)
                     PROGRAM
                                                                                CURRENT PROJECTS
                                                                                                                                        PROPOSED PROJECTS
o\
Minnesota

    Under the Minnesota Environmental
Response and Liability Act (MERLA) the
Minnesota Pollution Control Agency (MPCA)
has the authority to respond to the release
of hazardous substances to the environment.
HERLA ranks potential sites using the
Federal Hazard Ranking System.
Investigation at a potential site near any
surface water body must include sediment
quality analysis for contaminants of
concern.
     Sediment data  collected by MPCA show
the St. Louis Bay sediments to be polluted
with arsenic and chromium.  Some PAH
contamination also exists within the  bay.
Sediments near the Western Lake Sanitary
District outfall are contaminated with PCBs,
arsenic, cadmium, chromium, copper, mercury,
and lead.

     The St.  Louis  River  site  ranks on the
National Priority List and is  currently
being investigated for Federal Superfund
action.  The St. Louis River/Bay is also an
AOC.  Development of a RAP for this area is
in progress.
          New York

          (NO INFORMATION)
                                                         The State of New York has taken
                                                     remedial actions  involving sediments to
                                                     alleviate water quality problems.  Sediment
                                                     removal has been  used as part of lake
                                                     restoration programs, and demonstration
                                                     projects of alum  additions to reduce
                                                     phosphorus release from sediments have been
                                                     completed.

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                                     TABLE 6.  SUMMRY OF STATE PROGRAMS AND ACTIVITIES RELATED TO CONTAMINATED  SEDIMENTS  (CONTINUED)
                     PROGRAM
                                                                                 CURRENT PROJECTS
                                                                                                                                        PROPOSED PROJECTS
CTv
          Ohio

              A State ct  inup priority list was
          conceived to focus State attention on
          contaminated sites that were not addressed
          under Superfund.  The proposed list was to
          be designed especially to focus on sites
          with long-term environmental threats,  and
          therefore, do not rank high on the federal
          Hazard Ranking System.  Contaminated
          sediment sites fit this description.
     Four AOCs exist in Ohio.   All  four  are
characterized by contaminated sediments. The
development of the RAPs for at I four areas
is in the early stages.  One of four Ohio
AOCs is AshtabuIa Harbor, which contains
Fields Brook, a Superfund site.  A remedial
investigat ion/feasibility study has been
prepared.  The Fields Brook Record of
Decision proposes to incinerate the most
contaminated sediments and landfill those
remaining.  Rising costs and a number of
other complications may preclude efforts to
dredge the highly contaminated and toxic
sediments in the river navigation channel.
The river may be classified as a Superfund
site or as an extension of the Field Brook
Superfund site.

     A  recent lawsuit settlement  requires
Bethlehem Steel to cleanup a stretch of  the
Black River, impacted by his'torical coke
oven discharges, including phenolics and
PAHs.
          Pennsylvania

          Under the Hazardous Sites Clean Up Act (Act
          108) Pennsylvania Department of
          Environmental Resources has the authority to
          respond to the release of hazardous
          substances to the environment.
No current projects in the Great Lakes
System.
No proposed projects in the Great Lakes
System.

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                           TABLE 6.  SUMMARY OF STAIE PROGRAMS AND ACTIVITIES RELATED TO CONTAMINATED SEDIMENTS  (CONTINUED)
           PROGRAM
                                                                       CURRENT PROJECTS
                                                                                                                              PROPOSED PROJECTS
Wisconsin

    Under  its  Environmental  Repair Program,
Wisconsin has developed a State list and
ranking process similar to the NPL.  The
criteria for this ranking system makes it
unlikely that any contaminated sediment
sites will be targeted for action.
     The 1JC has identified four AOCs  in
Wisconsin:  1) the lower Fox River and Lower
Green Bay. 2) the Menominee River, 3)  the
Milwaukee Harbor Estuary, and A) the Lower
Sheboygan River and Harbor.  Contaminated
sediments are a problem at all four sites.
RAPs for att four are being developed by
Wisconsin.

     An initial  draft  has been prepared for
the Lower Fox River and Lower Green Bay.
The RAP for the Lower Green Bay/Lower  Fox
River was signed by the Governor of
Wisconsin as an amendment to Wisconsin's
Water Quality Management Plan.

     In 1985,  the  Lower  Sheboygan River and
Harbor AOC was designated as a USEPA
Superfund site.   A major source  of  PCB
contamination of fish and sediments has been
identified as a landfilled dike.   The
contaminated soil  from this dike was removed
under State orders.
      The potentially responsible party for
the PCB contamination of the Lower Sheboygan
River and Harbor will conduct the Remedial
Investigation and Feasibility Study under
the guidance of USEPA and the UDNR.
Implementation is scheduled to begin in 1989
after completion of the feasibility study.

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                       ANNEX 15:  AIRBORNE TOXIC SUBSTANCES
INTRODUCTION
       Although early studies  indicated that measurable  levels  of  phosphorus were contributed
to the  Great Lakes by air transport, giving rise in 1976 to the USEPA's  Atmospheric Deposition
Network, it has only  been  in the past decade that atmospheric deposition has been recognized as
a significant source of contaminants to the Lakes, and perhaps the only source of  some toxic
chemicals found in the Upper Great Lakes where  their presence is not attributable to either direct
discharges or land runoff.

       In  1981, the original Network  mission was expanded from collecting data  on airborne
phosphorus loadings to Lake Erie to monitoring the deposition of a variety of pollutants into all
the Great  Lakes.  Renamed the  Great  Lakes  Atmospheric Deposition (GLAD) Network at  this
time, the project  envisioned 36  U.S. monitoring  sites  representing industrial, agricultural,  and
urban  sources of airborne contaminants around the Great Lakes.

       The results of the GLAD Network and individual research projects in both  the United
States and Canada confirmed the atmosphere as a chief pathway of  certain toxic chemicals to the
Great Lakes. Recognizing the need for a fully coordinated, joint U.S. and Canadian program  with
compatible sampling and analytical protocols, two major workshops of experts  were convened to
assess the problem of atmospheric deposition and to assist in the design of an atmospheric research
and  monitoring program.

       The first workshop, held in 1985, was  sponsored by  GLNPO and  the  University of
Minnesota; the  second, in 1986, by the IJC.  Shortly thereafter, the  IJC Surveillance Work Group
established the Atmospheric Deposition  Task  Force  to design a joint atmospheric  research  and
monitoring network and  to  develop necessary protocols.

       In  1986, the Governors of the  Great Lakes  States signed  a Toxics Substances  Control
Agreement calling for cooperative action involving water discharge permits, accidental discharges,
monitoring and surveillance, information exchange, fish consumption advisories, and atmospheric
deposition.

       Based upon an increased knowledge and concern about atmospheric deposition, provisions
for addressing airborne toxic pollution were added to the Great Lakes Water Quality  Agreement
in 1987 (Annex 15). Annex 15 requires research, surveillance and monitoring, and implementation
of pollution control measures to  reduce atmospheric  deposition of  toxic pollutants to the Great
Lakes Basin ecosystem. The Annex also  requires the United States and Canada to report biennially
on progress in implementing the Annex. In response  to this and to  the amendments to the Clean
Water Act (CWA), the GLAD Network  effort was expanded in FY  1988 to include sampling for
airborne  toxic organics.

       With  regard to  regulatory  programs  under the  Clean Air  Act (CAA),  USEPA began
encouraging States to  assess the scope and severity of air  toxic exposures in 1986.  USEPA's  Air
Program  has provided States with  grants for compiling emission inventories  for certain source
categories, investigating capabilities to model  deposition patterns for  toxic pollutants,   and
developing permit review procedures that explicitly consider air toxic impacts on the Great Lakes.

       State  air programs  have made considerable progress  in reducing conventional pollutant
concentrations.  Control of  conventional air pollutants  has indirectly  resulted in substantial control
of many  air toxics. Attention has now  turned to the more explicit control of air toxics.  In FY
1988, USEPA Regions V and II were allocated $980,000 to support State air programs under CAA
Section 105, focusing on  the   issue of toxic deposition.   All eight  Great  Lakes States  are
coordinating emissions inventory procedures for air toxics and jointly developing permit guidelines


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to ensure that appropriate controls are placed on sources of air toxics.  There are currently 609
regulated facilities in the counties of the Great Lakes area  that are  in compliance with all CAA
requirements.  Of the 26 facilities that are  in violation,  7 are on compliance schedules.

       Also in 1988, USEPA published a decision to regulate municipal waste combusters (MWCs)
for dioxins, dibenzofurans,  heavy metals, and other organics, such as PCBs under the authority of
Section 111 of the CAA. The regulations will be based on the use of best demonstrated technology
considering cost and other impacts.  USEPA has issued interim operation guidance under the new
source review requirements of the CAA  that would effectively  require  emission limits for new
MWC permits, thus substantially reducing the  toxic components of  MWC emissions.  To  control
mercury emissions from other sources, USEPA has listed mercury  as a hazardous air pollutant
under Section 112 and has regulated mercury ore processing plants, chlor-alkali plants, and  sewage
sludge incinerators.   Other pollutants  regulated under  Section  112 include arsenic,  beryllium,
asbestos,  radionuclides, benzene, and vinyl  chloride.

       In  addition  to the  GLAD Network and CAA regulatory programs, GLNPO  coordinates
data-gathering projects to address atmospheric deposition through the developing Green Bay Mass
Balance Study and grant-funded urban toxic emissions inventories.


GREAT LAKES ATMOSPHERIC DEPOSITION NETWORK

       The GLAD  Network was originally established to determine atmospheric  loadings of
conventional  contaminants, evaluate annual trends, and assess  the  results of  various program
strategies.  In 1985, GLNPO enlisted the assistance of  technical experts to evaluate the  GLAD
Network.  The group concluded that:  1) the system was  not adequate to provide data  on airborne
loadings of trace organics, 2) sites were not  located  on the basis of USEPA siting criteria, 3) there
were potential problems in  GLNPO's quality assurance/quality control program, and 4) there was
a lack of coordination between Canada and the United States.

       To  remedy  these deficiencies, new objectives for the GLAD  Network were adopted,
focusing  on bioaccumulative pollutants found in  Great Lakes  fish.  These pollutants  include
metals, pesticides,  polynuclear aromatic hydrocarbons, and  PCBs. In addition, recommendations
were  made to design a monitoring  network that  would combine  deposition  measurement and
modeling to assess atmospheric deposition.

       In October of 1986, three of the International Joint Commission boards --  the  Science
Advisory  Board, the Great  Lakes  Water  Quality  Board, and the International  Air  Quality
Board -- hosted a major international workshop on the GLAD Network.   The purpose of the
workshop was to reach a consensus among  the  participants on the nature of atmospheric loadings
of 14 specific toxic  chemicals to the Great Lakes Basin.  The workshop findings demonstrated,
first,  the  lack of  knowledge on the  atmospheric  loadings of these chemicals, and  second, the
relative significance of these loadings compared  to other sources. -The resulting report estimated
that 90 percent of the PCB loadings to Lake Superior are from  the atmosphere.  It also estimated
that  Lakes Superior, Michigan, and Huron receive over 90 percent of their lead input from the
atmosphere.  The report concluded with recommendations related  to improving our ability  to
measure and predict atmospheric loadings.

       As  a result of these activities, two research and  monitoring  plans have been developed  to
address the deposition of air  toxics to the Great  Lakes.  In  1987, GLNPO completed  its proposed
modification of  the GLAD Network to  include toxic  organics.   This plan  calls  for the
establishment of five master  stations  across the Great  Lakes  to support necessary  research on
deposition  and exchange processes,  along with development of improved samplers.   In addition,
 12 routine GLAD Network stations are proposed,  which will include sampling for  toxic organics
using  currently available  sampling  equipment.   Each station is to  be  equipped  with wet
precipitation collectors, high-volume samplers for collecting  trace organics in the ambient air,


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snow gauges, wet/dry automatic precipitation collectors, high-volume samplers for collecting total
suspended particulate and total organic carbon measurement, meteorological towers  for collecting
routine data, and other equipment.

       Under a joint  grant to the Illinois State  Water Survey and  DePaul University, GLNPO
established  the first master station  and two  routine  stations on Green  Bay in 1988  to  begin
deployment of the planned Network and to support the ongoing Green Bay Mass Balance Study.
Each site is equipped with a 10-meter tower from which continuous measurements are taken on
wind speed  and direction, temperature, relative humidity, rainfall, and solar radiation.

       GLNPO plans to set up routine stations and initiate monitoring programs for Lakes Huron
and  Erie in FY 1989.  Master  and routine stations for  Lake  Superior are scheduled  for FY 1990,
and  for Lake  Ontario in 1991.

       The  Great Lake States will continue to participate with GLNPO in operating the monitoring
stations, and grants will be provided to universities for assistance  with the stations and laboratory
support for chemical analysis.  As required by the Water Quality Agreement, GLNPO will also
produce biennial  reports on the implementation  of this joint U.S. and Canadian air deposition
network. Meanwhile, GLNPO continues to participate  in planning discussions with Canadian and
U.S. experts to further refine  plans  for enhancing the GLAD Network to achieve  compatibility
and  concurrence with Canadian programs.

       The  second major research  plan, completed by the IJC Atmospheric Deposition Task  Force
in 1988, is  a  Plan for Assessing  Atmospheric Deposition  to the Great  Lakes.  The IJC Plan
submitted to the  Water Quality Board  with recommendation for inclusion in the  Great  Lakes
International Surveillance Plan, calls for two master stations to be established over a 2-year period,
followed by the phased establishment of routine stations as  research results become available.

       In December 1988, a committee was established  to review the  two plans, resolve remaining
differences, and  recommend   a  joint  U.S.  and  Canadian  research  and  monitoring  plan  on
atmospheric deposition. The joint plan should be completed by June 1989.  Currently, three ad
hoc  committees of  experts are detailing plans for quality assurance/quality control procedures,
analytical methods, sampler design, and siting criteria  to be used in  the deployment of the joint
network.


GREEN BAY  MASS BALANCE STUDY

       Traditionally, water quality management focused  on  control  of direct discharges  of
pollutants to surface waters.  Such point sources were the  easiest to identify,  characterize, and
control. In  many cases, however, their control did not solve  water quality problems.  Recognizing
that  pollutants are also introduced by contaminated air, soil, sediments, and. ground water, the
management approach  to Great Lakes  water quality had to  be reassessed.  This  reassessment led
to the initiation of a "mass balance" approach,  in  which the total contributions of pollutants from
all sources  are estimated and analyzed.
                                                                          *
       GLNPO, in conjunction with the Wisconsin Department of Natural Resources, the National
Oceanic and Atmospheric  Administration, and EPA's Office of Research and Development is
conducting a mass balance pilot study for toxics in a mid-sized ecosystem, prior to expanding  this
effort to whole-lake situations.  In Green Bay (the chosen site for study), a modeling framework
is  being developed and  tested  to  provide greater   understanding of the sources (including
atmospheric sources), transport, and  fate of toxic substances and  to ultimately guide and support
regulato'ry activity.  The models will be capable of alerting managers to the presence of currently
unidentified pollutant  sources, of describing the relative significance of the  sources, and  of
predicting the response of the  ecosystem to proposed regulatory actions involving a  single source
or a combination  of sources.


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AIR TOXICS EMISSION INVENTORIES

       In FY 1988, GLNPO also began work to fulfill Annex 15 requirements to inventory toxic
emissions in the Great Lakes Basin.  There are three major projects recently completed or ongoing
in the Great Lakes Basin  that contribute to this  effort.   The first is  the  Air Toxic Emission
Inventory for Southeast Chicago, the first phase of which attempted to estimate the emissions rates
of a wide variety of inorganic  and organic pollutants  in a  well-defined, highly industrialized
geographic area of the shores of Lake Michigan.  In the second phase, mathematical modeling will
relate emissions  rates to concentrations  at  ground level  and the  corresponding  health risks  to
exposed  humans.

       The second project is the Emissions  Inventory and Deposition  Modeling of Air Toxics in
the Lake Michigan Region, now underway.  Once air source data from the major metropolitan
areas  are collected, USEPA will attempt to model deposition of toxic pollutants to the Lake
Michigan watershed and directly to the Lake  to estimate total atmospheric deposition loadings from
near-field sources in the Lake Michigan airshed.

       The third  project,  the Great Lakes Air Toxics Transboundary  Project, focuses on sources
located  in a 50-kilometer-wide  corridor on either side of the shores of the Detroit River and
St. Clair River systems, including  the Detroit/Windsor and Port Huron/Sarnia urban/industrial
centers.  The project includes an emissions inventory, dispersion modeling, human risk assessment,
and deposition analysis of  pollutants of concern  in the watershed basin.

       These projects involve the cooperation of GLNPO, the  EPA Region V Air Program, and
local  governments.  Together, they should considerably increase  USEPA's understanding of the
significance of air deposition  to  the  water quality of  the  Great Lakes  and their  connecting
channels.

       Future efforts in the area of atmospheric deposition of toxic materials  include GLNPO's
plan to  work with USEPA's Air Program to complete an emission inventory  for air toxics to the
Great Lakes,  and to support initiatives  for State toxic  programs and for monitoring results.
Ultimately, if regulatory  or other  controls  are necessary to  meet the goals  of the Great Lakes
Water Quality Agreement, recommendations will be developed.
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            ANNEX 16: POLLUTION FROM CONTAMINATED GROUND WATER


INTRODUCTION

       Determining the magnitude, distribution, and impact of contaminated ground water of the
Great Lakes Basin is the subject of Annex 16.  In support of this overall goal, responsible State
and  Provincial environmental  agencies must  first identify  existing and potential  sources  of
contaminated ground water to the  Great Lakes.  To identify sources, each nation must map the
regional hydrogeologic  conditions in the  vicinity of significant contamination sources to determine
the probable and potential extent  of  pollution.  Next, a standard  approach  and procedures for
sampling and analysis of the contaminants in the ground water must be developed.  Implementation
of standard sampling and analysis programs will  enable  the Parties to quantify  the extent  of
contamination and  accurately  estimate contaminant  loadings to  the  Great  Lakes  to  support
development of Remedial Action Plans  (RAPs) and Lakewide Management Plans (LMPs).  The
Parties must report by December 31,  1988, and biennially thereafter, on progress  in controlling
sources of groundwater contamination and preventing  movement of polluted ground water to the
boundary waters of the Great Lakes.

       In this first  progress report, numerous  U.S. Agencies commented on activities conducted
in FY  1988 and,  in some cases beyond  this year,  in support of the  goals of  Annex  16.  Under
Federal statutory  authorities such as the Comprehensive Environmental Response, Compensation,
and Liabilities Act (CERCLA), the  Superfund Amendments and Reauthorization Act, the Resource
Conservation and Recovery Act (RCRA),  the  Hazardous  and  Solid Waste Amendments,  and the
Safe Drinking Water Act, or in conjunction with existing programs for monitoring and protecting
groundwater resources, these agencies have made  advances in protecting the Great Lakes from
contaminated ground water.

       Significant progress  has been  made  toward   controlling and remedying  uncontrolled
hazardous waste sites and toward ensuring that active  hazardous waste management facilities are
operated  in  accordance with  Federal  and State regulations.  States are developing  proposals for
wellhead  protection grants and have begun conducting pilot projects to demonstrate protection
strategies.   Much has  also been  accomplished in researching  the  significance  and  effects  of
groundwater   contributions   to  Great  Lakes contamination.    The  major  activities  and
accomplishments in these areas  are discussed in this section.


U.S. ENVIRONMENTAL PROTECTION AGENCY ACTIVITIES

Groundwater Protection Strategies

       In 1984,  USEPA initiated  a National  Groundwater  Protection Strategy.   This  strategy
consisted of four  principal elements:

       •   Strengthening the capacity  of State governments to protect groundwater  quality

       •   Addressing groundwater contamination sources of particular national concern

       •   Establishing a groundwater classification system to guide USEPA policies

       •   Coordinating the development and implementation of groundwater protection policies
          at the Federal, Regional, and State levels.

Since 1984,  various States, including those  in the Great Lakes Basin, have developed their own
State groundwater protection strategies that are tailored to  their existing regulatory  programs and
that  focus on  their specific  groundwater quality issues.  USEPA Regional  strategies  have been


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developed to promote and assist the States in  implementing their strategies and to bridge the gap
between the broadly focused national strategy and the very specific State strategies.

       The Region V Groundwater Strategy, adopted in  May of 1988, was developed as a vehicle
for unifying groundwater  initiatives underway  in the  Region.  The Strategy  highlights  those
groundwater objectives that require  more than  a single contaminant  source  perspective, and
provides a proactive method for achieving objectives given the  legislative and  fiscal constraints
of individual programs. The Strategy has three principal parts:  a set of groundwater goals, a set
of Regional groundwater  objectives and general  implementation steps necessary to  attain  those
objectives, and a process for conducting an annual review of Strategy-related activities.

       Geographic Information Systems (GIS) will be an important tool for implementation of the
Strategy.  During FY 1989,  Region V will  form a work  group to begin developing a GIS for the
Region with capabilities applicable to implementing RAPs in Areas of Concern (AOCs), managing
wellhead protection areas, monitoring and evaluating area-wide use of agricultural chemicals, and
assessing wetlands and other surface waters affected by groundwater contamination.

The Great Lakes National Program Office

       GLNPO dedicated resources this year to the development of strategies to accomplish each
of  the goals of Annex 16  and charted  a  5-year strategy to ensure completion of these  goals.
Recognizing that groundwater research strategies  are always evolving in this relatively early stage
of study, GLNPO committed substantial resources to train staff in using GIS to fulfill the Annex
16  requirement  to  inventory  and  map  hydrogeological conditions of the Great Lakes.   In
conjunction with this technical training, the Office is planning  strategies to  identify existing  and
potential  groundwater contamination sources.  GLNPO staff will  assume an important role in
establishing a Regional GIS for Region V  under  the Region's Groundwater Strategy.

       In addition, GLNPO submitted a series of proposals for site-specific exploration. GLNPO
will participate in a study in the Ashtabula, Ohio,  area to characterize pollutant sources  and
exposure pathways by implementing the Multimedia Environmental Assessment  Tracking System
(MEATS) in conjunction with a  standard  GIS.   The MEATS monitors environmental data in a
regulatory context and will  enable GLNPO to generate reports on compliance schedules and other
regulatory requirements for industries discharging pollutants  in  the Great Lakes Basin.

       GLNPO has outlined several goals for  the Ashtabula  project.  The project  will offer
program staff the opportunity to  gain expertise in GIS map production techniques and encourage
the development of standard GIS applications, programs, and models for environmental assessments
in  a geographic setting.   The  project  will also identify cross-media  issues  and  areas  where
regulatory actions are necessary.  Finally, the Ashtabula project  will increase coordination among
regulatory programs and  subsequently  integrate  planning efforts within existing  regulatory  and
organizational  frameworks.

        A second site-specific project with a significant groundwater component,  the Green  Bay
Mass Balance,  will include  compiling a comprehensive inventory of known  and potential sources
of groundwater contamination in  the  Green Bay Basin.   By using geophysical/hydrological
techniques  to determine the groundwater  flux on a continuous basis, GLNPO  will identify  the
sources, pathways, and fate of key indicator  toxic chemicals into and through the Green Bay. In
addition, staff  will analyze data derived  from  groundwater discharge  maps to define priority
groundwater areas. These activities will further the goal of improving permitting and enforcement
decisions  for   waste  sites  by  compiling maps  to reflect  hydrogeological   information  and
contamination  sources.

        To  support the Green Bay  Mass Balance and other important initiatives related  to  the
 GLWQA,  GLNPO has and continues to support important research  initiatives related  to  the
 significance of groundwater contamination for Great Lakes water quality. For example, the Office


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is presently funding a grant to the University of Wisconsin for research on groundwater intrusion
monitoring techniques. The results of this research will have important implications for the Green
Bay project.  The Green  Bay Mass Balance study plan includes a number of initiatives related to
estimating and measuring rates of groundwater intrusion; work in this area is expected to continue.

       GLNPO is also funding groundwater research to assist with RAPs.  Presently, GLNPO is
providing funds to the State of Indiana  for development of a RAP in the Grand Calumet River
AOC, where contaminated ground water may be an  important source of toxic pollutants.  At the
Grand Calumet  site,  the State and the  U.S. Geological Survey  (USGS) are collaborating on a
project to describe the hydrogeologic characteristics  underlying the region.  This effort will allow
scientists to predict how contaminants from the heavily industrialized region migrate from the site
and whether they are an important source of toxic pollution to the Indiana Harbor.

       In FY 1989, GLNPO continues to work with the Region V program divisions to assemble
and map the inventory of known and potential sources of groundwater contamination  in the Great
Lakes Basin.  During FY 1989, GLNPO will also develop  pilot CIS projects for wetlands in the
Great Lakes Basin, the Green Bay Mass Balance Study, and the Ashtabula RAP.

       USEPA  has  made considerable progress during FY 1988  toward addressing groundwater
contamination in the Great Lakes Basin. In support of Annex  16, paragraph (iv), the Agency's
hazardous waste programs  implemented under  RCRA  and under  CERCLA have continued to
address both active and inactive hazardous waste sites, one of the principal sources of contaminated
groundwater in the Great Lakes Basin and  throughout the United States.   Additionally,  USEPA
is now implementing a Wellhead Protection Program, as mandated by the 1986 amendments to the
Safe  Drinking  Water  Act,  and Groundwater  Protection Strategies are  being  developed   and
implemented  at the USEPA  Regional level and within the Great Lakes States.

       Under RCRA, USEPA and the States have continued to issue permits for active hazardous
waste treatment, storage, and  disposal facilities in  the Basin, and have begun to implement the
corrective action program mandated by the 1984 amendments to RCRA. This program will ensure
that all existing environmental contamination at active facilities is remedied as a condition  of State
or Federal permits.  In addition,  during FY 1988,  USEPA began promulgating regulations  that
restrict  certain  hazardous waste  from  land disposal.  This program,  together  with minimum
technology standards for  land  fills and surface impoundments, which became effective this year,
provide considerable protection against future groundwater contamination caused by placement of
hazardous waste on the land.  Also  in FY 1988, EPA began reviewing its present guidelines for
municipal and industrial solid waste disposal facilities. The Agency is now embarking on an effort
to develop and  promulgate more stringent guidelines for these  facilities.

       Under CERCLA,  USEPA regional  programs and State environmental agencies  have
continued to identify, characterize, and  address abandoned hazardous materials dumpsites in the
Great Lakes Basin.   In addition, States have taken initiatives to address their  own priorities for
cleanup.

       Specific accomplishments by  USEPA regional programs and GLNPO in these and other
areas  are presented in the following discussion.

Regional RCRA Programs

       In USEPA's  Region V (comprising six of the eight Great Lakes States),  there are nearly
1,000 companies that treat, store,  or  dispose of hazardous  waste. In  FY 1987, Region V  and the
States inspected more than  1,700 facilities and initiated more than  1,000 enforcement actions in
response  to violations.  During FY  1988, Region V and the States continued  to  issue operating
permits to active hazardous waste management facilities and to conduct an aggressive enforcement
and compliance monitoring program.  Future activities in  the Region and at the  State level  will
focus increasingly on the  problems of solid waste disposal and leaking underground storage tanks.


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       USEPA's Region II and Region III  offices, together with  the States  of  New  York and
Pennsylvania, have made similar progress toward implementing Great Lakes groundwater protection
programs under RCRA and RCRA's Hazardous and Solid Waste  Amendments (HSWA).  USEPA
estimates that nearly  26,000  RCRA  permittees and  permit applicants are located  within  the
counties of the Great Lakes Basin.  New program provisions implemented under HSWA will ensure
that these facilities are fully evaluated and that all existing contamination is remedied  as part of
the permit  issuance  process.

Regional CERCLA  Programs

       Similar progress has been made to address uncontrolled hazardous waste sites in the Great
Lakes Basin.  By  1988, USEPA's Region V had identified over 5,300 sites within its jurisdiction.
Presently, there are  228 Region V sites on the National Priorities List (NPL), more than any other
area of the country.  As of the end of September, 1988, Region V had completed preliminary
assessments at 4,730 sites and site  inspections at 1,310 sites.

       The Region conducts both long-term cleanup actions and emergency removal actions under
CERCLA.  In FY 1987, Region V  completed 8  removal actions at sites not listed on the NPL and
24 at  sites listed on  the  NPL.   Long-term  cleanups  have begun at nearly 150 sites  within
Region V.  These actions  may be conducted by the Region or  under Consent Decree with  the
responsible parties.

       USEPA Regions II  and III operate similar programs for cleanup of uncontrolled hazardous
waste  sites  that affect potential sources of groundwater  contamination in the  Great Lakes Basin.
In addition to the Federal programs, the States of Michigan, New York, Ohio, and Minnesota have
created their  own State Superfunds to address sites that are not eligible for  the Federal NPL,  but
are important State  cleanup priorities.


U.S. GEOLOGICAL SURVEY ACTIVITIES IN THE GREAT LAKES BASIN

       The USGS recently completed a 2-year study in cooperation with Canada on environmental
conditions  in  the Upper Great Lakes Connecting Channels (UGLCC).  This study  includes a
groundwater  component and  is part of an effort to study water quality  problems on  a  regional
basis  within  the  Great  Lakes Basin.   A similar study  was completed several years  ago on  the
Niagara  River in conjunction with the State  of  New  York.   Both  of these studies involved
characterizing  the  significance of nonpoint  sources  of pollution,  including  pollution from
contaminated ground  water.

       The objective  of  the groundwater component  of  the  USGS study  was  to  determine
groundwater   loadings into   the   UGLCC.   In  its preliminary  administrative  report,  USGS
recommends  greatly increasing extensive investigation into groundwater conditions in the Detroit
area.  The  development of a flow model would facilitate collection  of water quality information.
The USGS made  a preliminary finding that the deep injection of billions of gallons of hazardous
waste on the Canadian side of the connecting channels  is causing brines  to flow into  U.S. wells.
The  USGS also recommended that the  Port  Huron and St. Clair River areas  in Michigan be
investigated further, and has submitted a request to USEPA Region V for additional  funding to
continue research efforts on groundwater contamination in  the UGLCC.
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WELLHEAD PROTECTION ACTIVITIES

       The  1986 Amendments to the Safe Drinking Water Act (SOWA) established a new Wellhead
Protection  (WHP) Programs to protect ground waters that supply  wells  and  wellfields  that
contribute drinking water to public water supply systems. Under SDWA Section 1428, each State
must prepare a WHP Program and submit  it to EPA by June 19, 1989.  A comprehensive WHP
Program comprises several  distinct and essential elements.  At a minimum, each State's  WHP
Program must:

       •  specify roles and duties of agencies

       •  delineate  wellhead protection areas

       •  identify sources of contaminants

       •  describe management approaches

       •  describe contingency plans for well closures

       •  site new wells properly

       •  ensure public participation.

Of the eight Great Lakes States, Indiana, Ohio and New York are proposing to submit wellhead
protection programs  to USEPA by June 19, 1989.

       The State of Illinois has developed a sophisticated wellhead  protection approach. The State
Legislature recently passed the Illinois Ground Water Protection Act that requires the establishment
of setback zones around public water supply wells. These zones  are currently being delineated by
the  State according  to a  specified schedule and consistent with  the  particular hydrogeological
conditions of each area.  The Act also places restrictions on land use in relation to wellhead areas.

       The States of Minnesota, Wisconsin, Indiana, and Ohio have also initiated some preliminary
wellhead protection projects. Pilot protection programs are underway in Minnesota and Wisconsin.
The State of Indiana has funded a program for development activities on site-specific wellhead
protection projects,  and the State of Ohio  has commenced a  project to identify methods for
delineating wellhead protection areas  in two major hydrogeologic  regions of the State.

       The  State of Michigan has delegated authority for  wellhead  protection programs to both
the Michigan Department of Natural Resources and the State Department of Public Health.  These
agencies will collaborate to  develop a wellhead protection program  in the future.   A task  force
will work during FY 1989 to generate consensus regarding the State's wellhead protection program.
Michigan also has an extensive groundwater  contamination site  inventory  and  has  initiated a
number of groundwater cleanup activities under the State's Water Resources Commission Act of
1929 and the State Superfund Program.

       In Region II, New York State  has committed  to submitting a  wellhead protection program
for  the June 19,  1989, deadline as required  by SDWA.  This  program will explain  the  State's
approach to devising its program, including  the option to  phase-in various programs currently
under review as potential components of the overall program.

       Regardless of the program  strategy. New York  has decided to use existing regulations and
to increase enforcement capabilities.  Details on the specific strategy to  delineate wellhead areas
are  yet to  be finalized, however,  current thinking  favors the "fixed radius approach," (i.e., a
specified distance  around a  public water supply well).  The State will also address  the importance
of land use  issues  with respect to  groundwater protection programs.  As  land use remains a local


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issue, New  York  recognizes  that a  major part of the strategy will  focus  on  involving local
authorities in program development.

       In some areas of New York, wellhead protection activities are already underway, funded
by the Clean Water Act, Section 205(j).  For example, Suffolk County's water supplier is initiating
a wellhead protection program on its own, and EPA Region II is encouraging county officials to
participate.  If this program is successful, it may be extended to Nassau County. The program
uses existing regulations and strengthens  enforcement  provisions.  Officials are also distributing
educational  materials to  the public,  conducting audits, and establishing inventories of industrial
facilities.  In addition, Section 205(j) money has been  allocated  to three local planning agencies
(Herkimer-Oneida Regional Planning Board, Southern Tier West Regional Planning Board and the
Tug Hill Aquifer Commission) in upstate New York for mapping sources of contamination.
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           SPECIAL REPORT TO THE INTERNATIONAL JOINT COMMISSION
                             ON POINT SOURCE CONTROLS


INTRODUCTION

       Much progress has been made in  controlling point sources to  the  Great  Lakes system.
Direct discharges to the Great Lakes  system in the United States are regulated by nearly 3,675
discharge  permits for industry and municipal  sewage treatment  facilities, issued  as part of the
National Pollutant Discharge Elimination System (NPDES) under Section 402 of the Clean Water
Act (CWA). Through 1986, $7.9 billion in Federal and State grants had been invested in the Great
Lakes  Basin  for  municipal  sewage treatment  works.  In  1985,  more than 95 percent  of the
population in the Great Lakes States of USEPA's Region V (Illinois, Indiana, Michigan,  Minnesota,
Ohio, and Wisconsin) was served by municipal sewage treatment facilities and  99  percent of the
sanitary wastes in sewered areas  received at least  secondary treatment.

       Among the most significant achievements to date in the Great Lakes regarding point source
controls is the  reduction  of phosphorus discharges from point  sources.   Special  treatment for
phosphorus removal was provided  for 79 percent  of all sewage handled in sewered areas  during
1985, and 163 of 187 major municipal sewage  treatment facilities complied with the 1 milligram
per liter (1 mg/1)  effluent limit  for phosphorus set  by the GLWQA.  Advanced  waste water
treatment  was provided in 1985 by 15 percent  of  all treatment facilities, and 8 percent  provided
high-level  nitrogen  control.  The most recent data on phosphorus discharges from point sources
show that since 1972, the  United States has achieved a reduction  of phosphorus of  approximately
80 percent.

       In  other areas, the commitment to identify Point Source Impact Zones and reduce  their size
and effect is also an important aspect of attaining the GLWQA  objectives.  The  first report on
Point Source Impact Zones is  due September  30,  1989.  USEPA is currently  working  with the
Great Lakes States to establish consistent definitions and  methods of  reporting.

       Although  the GLWQA does not  expressly call for a report on point sources,  the  United
States considers it important to report  on activities and progress regarding  two point source areas:
activities related to  controlling stormwater impacts from both separate and combined  sewers and
efforts  directed  at  controlling  toxic chemicals  from  point  sources.   These efforts include
implementation of Section 304(1) of the CWA and State water quality-based control  programs such
as Michigan's Rule  1057.


COMBINED SEWER OVERFLOW STRATEGY

       Combined sewer overflows  (CSOs) are considered point sources, and must meet the permit
requirements of the  NPDES. In the process of  writing permits for CSOs, Regions and States must
conduct system-wide evaluations and set priorities by estimating such factors as flow,  frequency,
duration,  and pollutant loadings  to rank  publicly-owned treatment  works  (POTWs) collection
systems and CSO discharge points.  The permits must contain compliance dates as listed in Section
301 and Section 304 of the CWA  for those CSOs discharging toxic substances. Permits  must allow
for monitoring of CSOs to determine  whether facility modifications or  system  improvements are
necessary and to ensure that best management  practices are used at a particular facility.

       Other control measures that should be explored by municipalities  for controlling discharges
from  CSOs are improved operation  and maintenance, a system-wide  stormwater management
program, pretreatment program modifications, pollutant-specific limitations, compliance schedules,
flow minimization and hydraulic improvements, sewer ordinances, identification and elimination
of illegal discharges, local  limits program modifications, and construction of CSO controls within
the sewer  system  and/or new and modified wastewater treatment facilities.


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STORM WATER PERMITTING IN THE  ROUGE RIVER

       Under the terms of the Clean Water Act, storm water is considered a point source. Under
the 1987 amendments to the CWA, industries discharging storm water must apply for a permit and
must equip storm drains with BAT or BCT. Municipalities serving more than 100,000 people must
decrease discharges from  storm  drains to  the  maximum extent possible.  While the  other  sized
communities  are also affected, permitting  requirements are  phased with largest communities first
to comply.  Regulations on issuing stormwater permits as required by these provisions are expected
in 1990.

       Michigan's Rouge  River  Basin is an example of a recognized Area of Concern that could
benefit from  more restrictive stormwater permitting requirements.  The amendments to the CWA
gave the USEPA firm statutory  authority  to require permits for storm drains discharging to the
Rouge River, whereas regulations concerning such discharges  prior to these amendments  were
not specific  as  to the authority governing stormwater runoff.  The  Michigan Department of
Natural Resources (DNR) estimates  that pollutant loadings to the Rouge  River from point and
nonpoint source discharges were 473 million  pounds in 1987.  Although CSO and stormwater
runoff represent less than half of this amount, such discharges are most  likely to impair water
quality.  Stormwater runoff alone accounts for two-thirds of the lead discharged to  the Rouge
River, as well as conventional and nonconventional pollutants.

       State  officials are currently  identifying all industrial and municipal  storm  drains that
discharge pollutants to the Rouge River.  So far, 273 have been identified that need permits, but
officials suspect that there are many more that must be regulated and monitored.  Industrial permit
applicants  are  required to submit maps of onsite drainage, management  practices and control
measures,  and test data on various pollutants and other discharges.  Municipal  permit applicants
must  provide information on dischargers including source,  amount, and type of discharge.

       USEPA and Michigan DNR issued  a draft  remedial action plan  in June 1988 for the Rouge
River Basin and recommended a series of actions to address  the pollution problems associated with
discharges  from storm drains including eliminating illegal connections to storm drains, issuing
permit for stormwater discharge in  1990, reviewing and updating local stormwater management
programs,  and when necessary,  building retention basins to reduce discharges to the river. This
prototype plan will serve as a model for similar efforts in  the Great Lakes Basin.


STORMWATER REPORT TO CONGRESS

       USEPA is required by the amendments to the CWA to submit two  reports to Congress to
identify stormwater discharge sources, determine the nature and extent of pollution  from those
identified, and establish procedures and methods to  control such  discharges.  USEPA must
promulgate regulations, establishing application requirements for industrial and stormwater systems
serving large cities.  In addition, smaller cities, other jurisdictions, and commercial point sources
will be studied to assess stormwater discharge status.

        The reports to Congress will discuss the regulatory and environmental background of the
stormwater program with regard to  the NPDES,  CSOs, nonpoint source strategies, and  State and
local programs.  In addition, USEPA will  identify moratorium sources for stormwater discharges.


SECTION 304(1) OF THE CLEAN  WATER ACT

        The  CWA, as amended, provides  an accelerated timetable within which USEPA and the
 States are  required to assess and target impaired surface waters  for action to bring  these waters


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into  attainment  of applicable water  quality standards.   Section 304(1) imposes important new
statutory requirements on the ongoing national program for pollutant control by requiring States
to identify waters that are not expected to meet water quality standards after dischargers have met
current cleanup requirements. Section 304(1) requires increased activity in addressing known water
quality problems by requiring States to develop lists of impaired waters, identify point sources and
the quantity of pollutants they discharge that cause adverse impacts, and develop individual control
strategies  for each such point source.

       Regions  and  States  have  submitted preliminary  lists  of impaired waters  to  USEPA.
USEPA's  Water (Management) Divisions in Regions  II, III, and V (along with the Environmental
Sciences  Division  in  Region V) are  now reviewing lists  submitted by the Great Lakes States.
Individual control strategies must be designed to reduce discharges to listed waters and bring water
quality into compliance through final, enforceable NPDES permits and water quality standards  by
the statutory deadline.

       USEPA will assist States in routinely updating and refining procedures for implementing
point and nonpoint source controls by publishing criteria  and advisories on additional pollutants
of concern  (in addition  to  the CWA Section 307(a) toxic pollutants); providing supplemental
guidance on improved biological monitoring, assessment,  and evaluation techniques  for  complex
point  and nonpoint  source discharges; publishing national  technical guidance on  sampling,
modeling, and procedures for calculating total maximum  daily loads and waste load allocations;
and developing risk assessment/risk management procedures to define program  priorities for the
national program for  toxics control.


IMPLEMENTING WATER QUALITY-BASED POINT SOURCE EFFLUENT LIMITATIONS
FOR TOXIC SUBSTANCES

       Water Quality  Standards (WQSs) for lakes and streams set the maximum concentration for
substances that must be attained in ambient waters.  As noted in the previous section, they are an
essential basis for the  section  304(1) process addressing toxic substances.  To meet the requirements
of section 303(c)(2)(B) of the Clean Water Act,  each State must adopt numeric water quality
criteria for all section 307(a)  toxic pollutants for which EPA has published criteria under section
304(a) and the discharge  or the presence of which could reasonably be expected to interfere with
designated uses of the effected waters.  Although numeric criteria are to be  adopted, a State may
meet this  requirement by adopting a  narrative standard and a translator procedure to be used to
derive numeric criteria.  Either numeric or  narrative criteria must be  adopted  for any pollutant.
Criteria must be adopted for  protection of both human health and aquatic life. Also, criteria may
be adjusted on a site-specific basis to reflect changes in  water chemistry on the ability of local
species to  adapt. Standards are enforced through NPDES permits and permit  limits may be derived
based on either numeric  or narrative standards.   One means used to implement a narrative toxic
standard  is whole effluent toxicity testing.

       New York has adopted numerical WQS while Michigan has adopted narrative  standards.
New  York  was  immediately sued by  the  private  sector upon promulgation  of its  WQS,  but
prevailed  in court.  Michigan has not been sued, nor has Michigan had  to sue to enforce  its
authority  to impose water quality-based effluent limitation calculated according to Rule 10S7 in
its NPDES  permits.  Ohio,  Wisconsin,  and Minnesota have  adopted  or are in the process  of
adopting an approach similar to Rule 1057.   During its triennial review of  its WQS, Michigan is
now  contemplating revisions to  Rule SOS7  to allow it to derive enforceable  numerical ambient
WQC as required by the  1987 amendments to the CWA.

       The most controversial portion of Rule 1057 has been its regulation of carcinogens.  For
those substances causing  cancer in laboratory animals, humans, or both, Rule 1057 provides that
exposure to humans resulting from body contact, recreation, and fish consumption shall not result
in a  cancer risk  exceeding  one-in-one  hundred thousand (10  )for a 70 kg  adult  exposed


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continuously for a 70-year lifetime.  Michigan is the first state to propose an  acceptable cancer
risk threshold for its surface waters.  New York has adopted a  10~6design acceptable cancer risk
in deriving its  numerical WQS  for  carcinogens  (other than  those  for  which  Federal Drug
Administration action levels have been promulgated).  Both Michigan and New York calculate risk
on a chemical-by-chemical basis, while USEPA recommends adding the cancer risks of individual
carcinogens to estimate the aggregate risk.  Minnesota has adopted USEPA's approach.


PRETREATMENT

       Authorized by Section 307 of the CWA, the National  Pretreatment Program is designed to
regulate non-Uomestic wastewater contributions to POTWs. The General Pretreatment Regulations
(40 CFR 403) promulgated on June 26, 1978, established the administrative framework for the
program  and  identified the roles and responsibilities necessary  to  achieve the CWA goals.

       Since  1978, the General Pretreatment Regulations have  been the  focus of numerous legal
challenges  and  amendments.   The amendments  have expanded and clarified  the requirements
included  in the regulation. Most  recently  the regulations were  amended on October 17,  1988, to
incorporate changes recommended by the  Pretreatment Implementation Review Task Force.

       Concurrent with  USEPA  efforts  to develop  the  General  Pretreatment Regulations, the
Agency has worked toward the full promulgation of National Categorical Pretreatment Standards.
These standards establish technology-based control for specific industrial  categories known to
discharge significant pollutant quantities  to POTWs.  In addition  to these Federal standards and
requirements, POTWs are expected to develop  more stringent  or supplemental "local limits" as
necessary to ensure the integrity of the POTW treatment  works and its sludge disposal practices,
with NPDES-approved States exercising program oversight as "Approval Authorities."  The local
POTW programs act as "Control Authorities" in imposing Federal, State, and local standards and
requirements  on their contributing industries.

       In  the Great  Lakes States, a  total of  476  POTWs are  subject to these pretreatment
requirements.  (Of this total, 222 POTWs  have effluent flows greater  than 5 million gallons per
day.)  The  program approval rate  within the Great Lakes States has been better than the  national
average.  There are 33 approved pretreatment control  authorities in New York State  counties
containing  areas that drain into the Great Lakes area.  A total  of 466 facilities,  or 97.9 percent
of those  POTWs subject  to the new requirements  received  program approval  by  September 30,
1988.

       Efforts  are  currently underway  to delegate administration  of  the CWA Pretreatment
Program  to the States.  As of September 30, 1988, four Great Lakes States have received approval
for State Administration, and three other  States have  been  active in Pretreatment  Program
Implementation,  although program  administration  has not  yet  been  officially  delegated.
(Nationwide,  25 of the 39 NPDES  States and territories had received delegation of the Pretreatment
Program.)


NATIONAL MUNICIPAL POLICY

       The CWA required that by July 1,  1988, POTWs meet NPDES permit effluent limits based
on  secondary treatment or any more stringent limit necessary to meet  water  quality standards.
Because  of historic  problems with municipal compliance,   the Agency developed  the  National
Municipal  Policy (NMP)  in January 1984, which places renewed emphasis on improving municipal
compliance rates in order to protect the Nation's water quality.  The NMP establishes enforcement
priorities for facilities that are unlikely to meet  the July 1,  1988  deadline.
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       As of July 27,  1988, 87 percent of Region V's major POTWs  have met the  requirements
of the NMP.  Ninety percent of the Region's minor facilities are also in compliance, compared to
77 percent prior to NMP enactment. As a result, 95 percent of the  total sewage processed in  the
United States receives at least  secondary treatment. Voluntary compliance and  Federal and State
enforcement are responsible for achieving the compliance record. Of  the 13 percent of POTWs that
did not achieve compliance, most are on enforceable timetables leading to compliance or litigation.
USEPA Region V or the States have court actions pending against 62 large cities that have failed
to meet the NMP and have placed 29 city plants on court-ordered compliance  schedules.


DEMONSTRATION  PROJECTS

       Demonstration projects for addressing point sources of pollution on the  Great Lakes have
concentrated  on  controlling conventional pollutants and reducing eutrophication.  GLNPO  has
participated in evaluating  and demonstrating techniques for phosphorus  uptake  from sewage,
anaerobic oxidation phosphorus removal techniques, and in-line  storm  flow control devices.  Each
of these  has shown potential for  reducing discharges of phosphorus and other pollutants to  the
Lakes at a lower cost.

       In future years, Great Lakes programs for point sources will focus on controlling discharges
of toxic pollutants. During the next 2 years,  several important new programs for controlling point
source discharges of toxic pollutants will be developed and implemented under the CWA, including
programs under Section  304(1), discussed earlier.  In  FY 1989,  GLNPO will begin  developing a
process for addressing Point Source Impact Zones in the Great Lakes, as required by the GLWQA,
and will  continue to  work toward development of Lakewide Management Plans.  These programs
will require new  or improved  biological  and chemical monitoring techniques and  new regulatory
approaches that will  be the subjects of future Great Lakes demonstration projects.


MONITORING DATA FOR TOXIC LOADINGS FROM POINT  SOURCES

       Existing information on toxic pollutants of concern in  wastewater discharges within  the
Great Lakes system is still  too scant for accurate estimates of point source load contributions to
each of the Great Lakes.  Some permits require routine toxicity testing of effluents, involving tests
such as bioassays.  While these tests are carried out by the permittee, results are  shared with State
and Federal agencies. Surveys to assess compliance with permit  limitations are  also conducted by
regulatory agencies.

       Permittee self-monitoring data are stored in a computer  information  system known as  the
Permit Compliance  System.   The results  of  Federal  or  State  agency  compliance inspection
monitoring and select self-monitoring data are also contained in STORET,  USEPA's general water,
sediment, and biota quality data base.  Permittee and agency whole effluent toxicity test results
are summarized in the CETIS  data base.

       To analyze the  contributions of  persistent toxic  pollutants by point sources, GLNPO  has
supported the development of a  national data base of monitoring  data  from  Form 2c NPDES
permit applications.  In  addition, USEPA Region V and GLNPO have supported the  Michigan
DNR  with a  205(j)  grant  to update and expand  its  Critical Materials Register, a list of toxic
substances meriting State surveillance.  Each year, Michigan facilities are required  to report  the
production or use, discharge, and disposal in solid residuals of Critical Materials.  These data  are
compiled  in a  computer data base developed  under a Toxic  Substances Control Act grant to
Michigan from USEPA.  Total loadings of Great Lakes pollutants of concern can be compiled on
an individual facility, river, or lakewide basis.   GLNPO is using these loading estimates as part
of a larger effort to calculate  total loadings of  persistent toxicants  to the Great  Lakes from all
sources.
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