&EPA
              United States
              Environmental Protection
              Agency
              Region 5
              230 South Dearborn Street
              Chicago. Illinois 60604
May, 1983
5752E
Environmental
Management
             Valdas V. Adamkus, Regional Administrator
Attachment B

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         REGION V ENVIRONMENTAL MANAGEMENT REPORT
                      ATTACHMENT  B
                DETAILED PROBLEM ANALYSES
                    TABLE OF CONTENTS
MEDIUM






Air



Land



Water



Great Lakes
PAGE






  1



 54




 74



 91

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                 REGION V ENVIRONMENTAL MANAGEMENT REPORT

                               ATTACHMENT B

                                   AIR
Air Quality

The areas of highest concern to Region  V from the  standpoint  of  air
pollution include:

0  Ozone in the Chicago Region (NE Illinois,  NW Indiana,  and  SE  Wisconsin)
0  Ozone in Detroit (Michigan)
0  Ozone in Milwaukee (Wisconsin)
0  TSP in the Chicago Region (Chicago and NW  Indiana)
0  TSP in Detroit (Michigan)
0  TSP in Cleveland (Ohio)

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                                            -1
Analysis 1:  Chicago Region Ozone (NE Illinois,  NW Indiana,  and  SE  Wisconsin)

Because of the difficulty imposed by the transport of oxidant  precursors
from the Chicago and NW Indiana area to Milwaukee, it is  not a simple
matter to specify a problem area.  For this  analysis  emissions data  were
obtained for NE Illinois and NW Indiana while air quality data also  in-
cluded Kenosha and Racine Counties in Wisconsin.   The problem  area  is
represented in Figure A-9.  The population  subjected  to the  high ozone
levels of this area total  approximately eight million people.   Figure
A-10 summarizes the distribution of precursor sources in  this  area.
Also shown is the compliance status of each  source.   Note the  heavy
concentration of sources in NW Lake County,  Indiana and West Central
Cook County, Illinois.   From this figure,  it can  be seen  that  approxi-
mately 48% of the major sources in Illinois  are  not in final compliance;
whereas, only 12% of the Indiana major sources are also designated as
not being in final compliance.  But, there  is a  higher proportion of
major sources in Indiana than in Illinois  where  the compliance status is
unknown (35% in Indiana as compared to 14% in Illinois).   The  number of
days showing violations of the standards at  each  monitor  site  are demon-
strated in Figure A-ll.  In 1982 there were  a total of 13 ozone  site days
of violations (4 days in Cook, 1  day in Lake, 1  day in McHenry,  1 day
in Will, 3 days in Lake (IN), 2 days in Porter,  1  day in  Racine, zero days
in DuPage, Kane and Kenosha Counties).  Note that the number of  excursions,
because of the northward transport of precursors, are higher in  the
northern part of the problem area.  Figure  A-12  demonstrates the trend
in ambient ozone levels.  Though there seems to  be a  small decrease  in
the ambient levels, the ozone levels fluctuate too widely to be  able to
accurately determine the true trend.  In any case, the levels  are still
substantially above the standard.  Figure  A-13 shows  that total  precursor
source emissions have decreased in magnitude and that the mobile source
contribution to the loading is dropping.  Figure A-14 shows  expected
emission reductions along with a range of  control  requirements.   The
lower end of this range is based on air quality  data  solely  from Northeast
Illinois, and the upper end of the range is  based on  air  quality from
the entire area including Southeast Wisconsin.  The exact control percentage
needed to attain the standard is still uncertain because  USEPA and  Illinois
EPA (IEPA) disagree about procedures for estimating emission reduction
requirments.  The control  requirements shown on  this  figure  are  based
on the upper end of the ranges modeled by  IEPA but with certain  of  Illinois'
model adjustments removed.  Depending on how closely  the  control require-
ments shown here reflect actual emission reduction needs, it is  possible
that the Chicago, NW Indiana, and SE Wisconsin area may not  reach attainment
by 1987.

This analysis demonstrates that while precursor  levels are dropping, the
ozone problem may not yet be under control.   A major  factor  for  the  future
resolution of this problem is the high percentage of  sources,  especially
in Indiana, where the compliance status is unknown.

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                                               Figure A-9:  Chicago Problem Area for Ozone
WISCONSIN
ILLINOIS
State Boundaries

 Problem Area fo
 Emission and
 Monitoring Data
                                                                                    Extended Proble
                                                                                    Area for
                                                                                    Monitoring Data
                                                                                    Only
                                                                                             n
                                                                                            I

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Figure A-10:  Chicago Area .Major Hydrocarbon  Sources
                                          Q Source not in Final Compliance



                                             Source Compliance Status Unknown



                                             Source in Compliance

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                                                 *•'   .'$
c
      Jefferson
      County
  Wisconsin
                         Washington
                         County
Waukesha  Countv
              Walworth County
                                                  Figure A-ll:  19B1 Excursion nays for
                                                                Chicago Ozone
          KenoshaCpuntv\
                                                                                     State Boundaries
  Illirois
                 McHenry County
               Lake  County
  N

I
1
                       Kane County]
         (*)  Number  Represents
             Total Excursion  Days
                                                  Porter
                                                  C^yJ
                                                             Indiana

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                             FIG'.'P.g A-!?!
  0.35
  0.30
  0.25
  0.20
                        Ambient  Ozone  Levels
x 0.15
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UJ


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  0.05
  n.os
                 OZONE  TRENH FOR  CHICAGO/NW INDIANA/SE WISCONSIN

                      (Worst Case for Second High Values)
              National Ambient Air Quality  Standard
         1975
1976
                                 1977
                        1978
1070
                                                                     19«0

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                                          9
Analysis 2: Detroit Ozone

The Detroit Ozone problem is located in the tri-county area (Wayne,
Macomb, and Oakland Counties) depicted in Figure A-15 with an  affected
population of approximately four million.  But, because of the proximity
of this area to Ontario, Canada, the ozone problem in Detroit  may  also
adversely affect a substantial  number of people in the bordering Canadian
counties.  Figure A-16 locates  major precursor sources and their final
compliance status.  Note that of 144 major sources, only two have  been
designated as not being in final compliance (eight of these 144 sources
have an unknown compliance status).  Figure A-17 shows the 1981 monitor-
ing sites as well as the number of days that the ozone level was measured
as being over the U.S. standard.  In 1982 there were 4 days of ozone  vio-
lations in Wayne County and none in Macomb, and Oakland Counties.  Figure
Figure A-18 graphically depicts the ozone concentration trends for both
U.S. and Canadian data.  There  is a very strong indication of  a downward
trend with both the U.S. and Canadian Ozone levels approaching the U.S.
standard.  However, note that there is little evidence in  this figure of
the Canadian levels ever reaching the Canadian Ozone standard  of 0.08
ppm.  Figure A-19 exhibits the  source contribution for three selected
years.  This figure demonstrates that the greater contribution of  VOC is
now from stationary sources rather than mobile sources as  in the past.
As can be seen in Figure A-20,  attainment can be expected  in late  1985,
well before the 1987 deadline.

The ozone problem in Detroit is improving; however, ambient levels are
still above the National Standards.  Also of concern is that because of
possible U.S. influence the ozone levels in the neighboring Canadian
counties may not decrease to the Canadian levels.

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                           10
      MS:           OZONE
                                        •
          *
         Non-Attainment Area for Michigan
                                   Detroit
                                   Urbanized Area
does not meet
primary standard

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      FIGURE A-17:  CURRENT OZDNE MONITORING SITES
                    AND 19B1 EXCURSION DAYS
Livingston County
                                                                 Number  Represents  Total
                                                                 Excursion  Days  at  Honitorinq
                                                                 Site

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                                                  13
       0.35
           \
                         FIGURE A-13:


             OZONE TREND FOR DETROIT AREA (NACCH8,  OAKLAND.  AND WAYNE  COUNTIES
                  AND ADJACENT CANADIAN MONITORS)


                    (Worst Case for Second High Values)
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                                   U.S.  Ambient Ozone Levels
          Canadian Anbient
         \0zone Levels

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       0.10
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1981

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                                      16
Analysis 3: Milwaukee Ozone
The Milwaukee ozone problem area is shown  in  Figure  A-21.   The  base  area
is composed of four counties with Kensoha  and Racine Counties in  southern
Wisconsin being included for emissions  data only.  The  exposed  population
in these four counties totals to approximately one million  people.   The
air quality data for Kenosha and Racine Counties  are included with the
Chicago Ozone analysis.  Major ozone precursor sources  and  their  final
compliance status are shown in Figure A-22.   Note the heavy concentration
of sources within the City of Milwaukee.  In fact, 57% of the 56 sources
in the six county area are located in the  City.   Only 11% of these sources
are considered not in final compliance; however,  41  sources (73%) have
no known compliance status.  Monitor location and the number of days  in
1981  in which exceedances at each monitor  were noted are depicted in
Figure A-23.  In 1982 there were a total  of 10 site-days of violations in
the Milwaukee ozone problem area (5 days  in Milwaukee,  1 day in Ozaukee,
1  day in Washington and 3 days in Waukesha Counties).  Again, these  data
for Kenosha and Racine Counties were included in  the Chicago Area Ozone
analysis.  Figure A-24 shows that while there has been  an almost  continuous
decrease in ambient ozone levels, the most recent values are still substantially
above the standard.  The precursor source  contributions, depicted in
Figure A-25, shows that stationary sources comprise  an  increasing portion
of the total emissions.  Attainment is  expected in mid  1986, as is shown
in Figure A-26.  This is well before the  1987 deadline.

Ambient ozone levels are improving.  However, the proximity of  Chicago
and NW Indiana can affect the air quality  in  the  Milwaukee  area.

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                                                17
Wisconsin
Illinois
                                               Figure A-21:  Milwaukee Problem Area for Ozone

                      ..

                      Kane County]  Cook County
                                 DuPage
                                 County

                                                  Illinois
                                                            Lake
                                                            County^
Indiana
                                                                                  State  Boundarifi
                                                                              Problem Area for
                                                                              Emission and
                                                                              Monitoring Data
                  Extended Problem Are
                  for  Emission Data
                  Only
                                                                      Porter

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                                           18
          Figure A-22-'  Milwaukee Area Major Hydrocarbon  Sources
                         Washington County
               Waukesha County
                   O
•  Source  not  in  Final  Compliance

9  Source  Compliance  Status
   Unknown

O  Source  in Compliance
                       miles
$



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&
     Ozaukee County
Milwaukee
County
                                                                         Lake Michigan
                                           Kenosha County

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                 Figure  A-23:   1981  Excursion  Cays  for Milwaukee Czone
                             Washington County
                            O
                   Haukesha County
j) Number Indicates Number of
   Excursion Days
                        Ifi miles
             N
  Ozaukee County
Milwaukee
County
                                               Kenosha County
                                                                             Lake Michigan

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n.is;
                    FIGURE A-2A:
              D7.0NE TREND FOR HILWAWEE
              (Worst Case for Second  Hfqh  Values)
0.30
    1975
1976
                            1977
                                        1978
                                                    1979
                                               1980
                                                                            1391

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                                       23


Analysis 4:  Chicago Region TSP (NE Illinois and NW Indiana)

The Chicago participate problem area is sectioned into two parts, as is
shown in Figure A-27: one section includes the steel  area around Southern
Cook County, Illinois and Northwest Lake County, Indiana and the other
section includes Burns Harbor in Porter County, Indiana.  The Burns Harbor
section has only recently been designated as a primary nonattainment area.
Figure A-28 shows that the population exposed has decreased in the Illinois
portion of the problem areas but has stayed relatively constant in Lake
County, Indiana.  The major sources and the compliance status of these
sources are shown in Figure A-29.  Though the Illinois portion has a
higher percentage of sources not in final compliance  (73%) than Indiana
(41%), Indiana has the two largest sources of the area:   U.S. Steel  and
Inland Steel.  Figure A-30 indicates the monitor location and the viola-
tion status of each monitor.  The heaviest concentration of violating
monitors occur in the East Chicago and Gary area of the  problem area,
near the large steel facilities in the Chicago area.   The violating
monitors in Burns Harbor are all on site at the Bethlehem Steel  facility.
As is shown in Figure A-31, the average geometric mean of particulates in
the problem areas has stayed relatively constant and  above the primary
annual standard.  Also, note that while the maximum geometric mean is
decreasing the minimum mean is rising, suggesting that air quality may
be deteriorating in the cleaner areas.  The isopleths displayed in Figure
A-32 and A-33 show that the area exceeding the primary standards has
decreased primarily in the northwestern portion of the problem area.
However, there has been little decrease in the overall  extent of the
area exceeding the primary standard.  In fact, there  still  remain four
areas of particulate levels over 100 ug/m^.  These areas are located
around steel and agricultural  centers.  Figure A-34 shows that area
sources account for about 69% of the particulate emissions, mainly through
reentrainment of dust from transportation sources. However, over 75% of
the point source emissions are attributable to industrial processes
which generally contain the very fine inhalable particles that can enter
the lungs and cause respiratory problems.

The only solid evidence showing an improvement in the Chicago area parti-
culate problem is the decrease in the number of people exposed.   Other
evidence which also demonstrates improvement include  the decrease in the
size of the area exceeding 100 ug/m^.  However, there remain several  areas
with harmfully high ambient levels.  These areas seem to be associated
with the steel  industrial  areas, a significant source of unhealthy inhalable
particulates.

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                             24
FIGUPE A-27-   CHICABO/NW INDIANA TOTAL SUSPENDED OARTIHJLATE
              PROBLEM APEAS

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                                   25

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                                          2?
Chicago Problem Area-Major Sources

Sources not in Final Compliance

 1.  Carey Grain
 2.  U.S. Steel-South Works
 3.  Lakeside Slag
 4.  Valley Mold and Iron
 5.  Calumet Incinerator
 6.  Marblehead Lime
 7.  Republic Steel
 8.  Interlake Coke Plant
 9.  Interlake
10.  Continental  Grain-Elevator B
11.  Alburn-Earth II
12.  Ingersoll  Products
13.  Continental  Grain-Elevator C
14.  Indiana Grain Coop
15.  Ford Motor
16.  Bird and Son
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24.  NIPSCO-Mitchell
25.  Jones and Laugh!in
26.  Inland Steel
27.  Lehigh Portland
28.  U.S. Steel
29.  Bethlehem Steel

Sources in Compliance

 1.  Kirk Asphalt Corp
 2.  General  Refractory
 3.  H B Reed
 4.  Harbison Walker Ref.
 5.  U.S. Reduction
 6.  Blaw-Knox Foundry
 7.  Hammond  Lead
 8.  Amoco Refinery
 9.  Lever Brothers
10.  Bliss and  Laughlin
11.  Atlantic  Richfield
12.  Louisville Cement
13.  Heckett  Engineering
14.  Mississippi  Lime
15.  Cargil1,  Inc.
16.  Cinders,  Inc.
17.  Illinois  Slag  and Ballast
18.  Boise Cascade

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                                                     29

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                                       33
Analysis 5: Detroit TSP

Figure A-35 delineates the TSP nonattainment area in the Detroit indus-
trial area.  Figure A-36 demonstrates that the total number of persons
exposed to TSP levels exceeding the annual U.S. primary standard sharply
decreased in the early 1970's, and more slowly in the latter years.   The
adjacent Canadian population is also experiencing less exposure. Figure
A-37 depicts the major complying and noncomplying sources that are
located in the areas where the remaining violating monitors are sited.
As is shown by Figure A-38, the monitors that register violations of the
annual primary standard are located in an 18 square-mile area extending
from Dearborn to the Detroit River at River Rouge and from River Rouge
to southern Detroit.  No monitors in the area exceeded the alert level.
Two monitors in the City of Windsor, Ontario also showed violations  of
the U.S. standard.  Figure A-39 (which reflects all  monitors operating
in the target area in any given year) shows that the annual geometric
means have shown a general decrease in value.  However, the annual mean
dropped below the primary standard only in 1980 and 1981 when economic
decline has caused reduced industrial activity.  But, the magnitude  of
the impact of reduced industrial  activity on air quality has not been
quantified.  Isopleths of TSP concentrations in Figure A-40 show that
the eastern three-quarters of the primary nonattainment area as well  as
Southern Macomb County were above the primary standards in 1972.  In the
River Rouge-Southern Detroit area, TSP levels reached concentrations
above 150 ug/m3.  Isopleths in Figure A-41 show a sharp improvement  in
the air quality in 1981  with a third of the primary non-attainment area
below the secondary standard and only a small portion of the area above
the primary standard.  Yet, the TSP levels in the River Rouge-Southern
Detroit area are still at 100 ug/m^ and above.  Figure A-42 identifies
major categories contributing to the TSP problem.  It is important to
note that while industrial point sources contribute only 24 percent  of
the total  TSP, they are most dangerous to health because industrial
sources contain most of the very fine inhalable particles.  Figure
A-43 demonstrates TSP loadings for various wind directions at the 1981
violating monitoring sites (U.S.  side only).  Notice that at each site
the heaviest loadings occur in the directions of major noncomplying
sources.

In summary, a large improvement in TSP air quality has been made in  the
Detroit nonattainment area; however, there remains a persistent pocket
of high-level TSP in the Southern Detroit metropolitan area where 400,000
Americans  and Canadians are exposed to unhealthful levels of TSP.

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                                     39
Detroit Problem Area-Major Sources

Sources not in Final Compliance

 1.  Detroit Sewage Treatment Plant
 2.  GMC Cadillac Motor Plant
 3.  Great Lakes Steel-Zug Island
 4.  Great Lakes Steel-Ecorse
 5.  International Salt
 6.  Rouge Steel
 7.  Central Wayne County Sanitary Authority
 8.  Ford Motor
 9.  Detroit Coke Co.

Sources in Compliance

 1.  Industrial Smelting
 2.  Champion Spark Co.
 3.  Chrysler-Jefferson Assembly
 4.  IMC Foundry
 5.  Chrysler Corp.-Eldon Axle Plant
 6.  Chrysler-Lynch Road
 7.  Chrysler-Winfield
 8.  Bellevue Process
 9.  Chrysler-Hamtramck Plant
10.  Celeanese Coating
11.  Ford Motor
12.  Central Iron Foundry
13.  National Gypsum
14.  Metro Metal Process
15.  Detroit Housing Community
16.  Asphalt Products
17.  Asphalt Products
18.  Mercier Corp.
19.  Asphalt Products
20.  GMC-Fisher Body Plant
21.  Asphalt Products
22.  Ajax Materials
23.  Marblehead Lime
24.  Delray Steel Casting
25.  BASF Wyandotte-North Works
26.  Chem-Met Services
27.  BASF Wyandotte
28.  BASF Wyandotte-South Works
29.  Consolidated Lumber
30.  Ajax Material

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Analysis 6:  Cleveland TSP

The Cleveland TSP particulate problem area is  located in  the  Cities  of
Cleveland, Bratenahl,  Newburgh Heights,  Cuyahoga  Heights, and Brooklyn
Heights (see Figure A-44).  A smaller, more severe  area has been  located
along the Cuyahoga River Valley,  passing through  Central  Cleveland.
This area approximates the heavy  industrial  area  of Cleveland.   The
number of persons exposed to the  excessive particulate levels in  the
whole area are shown  in Figure A-45.   There has  been a sharp  drop in the
total exposure with the 1981 population  exposed  being about 25% of the
1972 population exposed.  Figure  A-46 shows the  major sources and their
compliance status.  Note that many of these sources and almost  all of
the noncomplying sources are in the Cuyahoga River  Valley.  The annual
primary standard violation status of  monitors  in  the area are shown  in
Figure A-47.  Note that most violating monitors  are located in  a  belt
extending from Cuyahoga Heights in the South to  Lake Erie in  the  North,
approximately the same area as the sites of the  steel  industries. Figure
A-48 states that while the annual  geometric mean  has shown a  steady
decline since 1972, it is still well  over the  primary standard.  By
comparing Figure A-49  to Figure A-50, the massive decrease in the size
of the area with TSP  levels over  the  annual  primary standard  is obvious.
However, Figure A-50  depicts two  areas of very high levels of over 100
ug/m3.  These two spots are located around steel  industry sources.   About
50% of the total TSP  emissions, as seen  in Figure A-51, are due to re-
entrainment of dust from transportation  sources.  The main source of
point source emissions is fuel combustion.

While Cleveland has experienced a tremendous improvement  in particulate
air quality, much of  the City of  Cleveland and nearby communities still
experience harmful ambient levels.  These levels  are significant  since
their likely sources,  steel processing and fuel  combustion, emit  large
amounts of the unhealthy inhalable particulates  and

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                                              49
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                                        50


CLEVELAND PARTICULATE PROBLEM AREA-MAJOR SOURCES


Sources not in Final Compliance

 1.   ALCOA
 2.   Boyas Excavating
 3.   Cleveland Trindidad Paving
 4.   Ford Motor Stamping Plant
 5.   Ford Motor Casting Plant
 6.   Ferro Corp
 7.   Jones and Laugh!in
 8.   Medical  Center
 9.   Republic St^el
10.   Republic Steel
11.   Republic Steel
12.   Wabash Alloy


Sources in Compliance

 1.   Metal Blast   (Shut Down)
 2.   Cleveland Municipal Light and Power   (Shut Down)
 3.   Cleveland Electric Illuminating-Hamilton
 4.   Independent Towel   (Changes to Gas)
 5.   Great Lakes
 6.   Bassachis Corp.
 7.   Cleveland Builders
 8.   Division Pumping Station    (Changes to Electric)
 9.   Forest City Foundary        (Shut Down)
10.   City of Cleveland Asphalt Plant   (Shut Down)
11.   Horvitz  Co.
12.   Reilly Tar and Chemical
13.   W. E. Plechaty
14.   Ferro Engineering
15.   S. E. A. Polishing and Buffing
16.   Apex International Alloy
17.   Bradley Metal
18.   Shell Sands
19.   Cuyahoga Smelting
20.   Harshaw Chemical
21.   Cuyahoga Lime
22.   Atlas Foundry  (Shut Down)
23.   Crucible Steel Casting     (Shut Down)
24.   Forest City Foundry
25.   Cleveland Electric Illuminating - Lake Shore
26.   Cleveland Electric Illuminating - Canal Road
27.   Cereal Food Processor

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                                   54


                 REGION  V  ENVIRONMENTAL MANAGEMENT  REPORT


                              ATTACHMENT   B
                                   LAND
PESTICIDES

Environmental Contamination Due to Pesticide Drift  and  Overspray

A significant number of environmental  incidents  have  occurred  in  Region  V  through
the careless application of pesticides.   Both private and  commercial  applicators
have been involved.  Most incidents are  attributable  to commercial  aerial  appli-
cators.  Crops, lakes, rivers and streams have been contaminated.   Resulting
damage has been illegal residues on crops,  significant  damage  to  beekeepers,
contaminated ground and drinking water,  fish kills  and  the destruction of  mon-
target vegetation.

State regulatory officials in Illinois,  Michigan and  Minnesota have analyzed
their enforcement programs and consider  drift and overspray as their primary
priority.  Wisconsin and Indiana officials  also  consider drift and  overspray  as
major issues.  In fact, Wisconsin Department of  Agriculture, Trade  and Consumer
Protection officals have amended the State's pesticide  statute to strengthen  the
drift and overspray provisions.

The state regulatory officials, as well  as  the pesticide training specialists,
are endeavoring to make pesticide users  more aware  of the  inherent  dangers of
drift by emphasizing equipment calibration.   Training sessions devoted exclu-
sively to calibration are conducted for  both aerial and ground applicators.
It is anticipated that increased emphasis will be placed on this  in the  future.

The extent of environmental contamination,  because  of drift,  is measured pri-
marily through the number of incidents that occur rather than  through a  con-
tinuous environmental monitoring program.  Environmental monitoring must be
emphasized to insure that pesticide residues are not  building  up  in the
environment and especially the rivers, lakes, streams,  ground  water, and
sediment.

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WMD/PS/ATT B-2          .             55    <


Environmental Contamination Due to Improper Handling, Storage and Runoff

Three of five states (Indiana, Michigan, and Minnesota) have experienced a
significant number of pesticide incidents relating to handling, storage and
runoff.  These incidents usually result in major, but localized health and/or
environmental problems.  For example, improper handling of containers while
loading trucks,or railroad box cars results in broken and leaking containers,
improper disposal, inhalation of toxic vapors, excessive chemical residues on
the handler, leaving containers in areas that are accessable to livestock
and small children.

Pesticide inspectors have found numerous violative products remaining in stor-
age and in the channels of trade.  Also, suspended and cancelled pesticides,
(for example, DOT, arsenic, 2,4,5-T) in leaking containers and broken bags
are improperly stored in old, decaying farm buildings.  Heavy rains have
washed the chemical into rivers, lakes and streams and in some instances
contaminated drinking water supplies.

The vast majority of fanners in Region V incorporate granular pesticides into
the soil for insect control as crops are planted.  Spray applications are
also applied at this same time to control weeds.   Heavy rainfall  following
application causes runoff of both the soil and the pesticide adhering to
soil particles.  Strong winds may also contribute to this problem.  The most,
significant and evident problem resulting from runoff is fish kill.  The
least apparent problem is a build up of illegal pesticide residues in crops
and non-target vegetation where the eroding soil/residues accumulate.  Vegeta-
tion may be consumed by dairy cattle, fish and wildlife, resulting in illegal
residues.  Accumulation of pesticides as a result of runoff can be toxic to
pheasants and other wildlife.  Bee colonies suffer because of runoff problems.
Highly intensive agriculture, continuous annual cropping, minor crop rotation
and a minimum of soil conservation through idle acres, contribute to this
problem.

State pesticide, natural resources and soil conservation officials are at odds
as to how this problem should be corrected.  Most feel stricter use regulations
are warranted.

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                                 56
WMD/PS/ATT B-3


Aldicarb Use and Contamination of Groundwater in the Central  Sands
Region of Wisconsin *

Aldicarb is the active ingredient found in Temik 15G and  Temik  10G,  systemic
carbamate pesticides manufactured and marketed by the Union  Carbide
Agricultural Products Company, Inc.   In 1980, 1981,  and 1982  aldicarb was
confirmed to be present in groundwater samples collected  in  Adams, Langlade,
Marathon, Portage, Barron, Waypaca and Waushara counties.   In some samples,
the amount of aldicarb detected exceeded 10 parts per billion (ppb), a  guide-
line based on assessments made by the National  Academy of Sciences,  and
accepted by the U.S. Environmental  Protection Agency (U.S.  EPA)  and  the
Wisconsin Department of Health and Social  Services as the threshold  action
level for public health purposes.  Based on this unofficial  state  standard,
the presence of aldicarb in drinking water at levels in excess  of  10 ppb  is
presumed to constitute a threat to public health.

Temik 15G contains 15% active ingredient by weight and has  been  used in
Wisconsin, primarily on potatoes, since 1975.  Perceived  benefits  of using
Temik over an alternative insecticide for the control of  potato  pests include
a wider spectrum of pest control and a greater persistence during  the growing
season.  Prior to a change in product labeling in 1982 which  reduced the
amount of aldicarb that can be applied to an acre of Wisconsin potatoes,  Temik
15G was labeled for the control of certain nematodes. This  provided another
advantage to growers.

As a granular pesticide formulation, Temik is incorporated into  the  soil.
This significantly reduces the potential for applicator exposure to  the
pesticide and the possibility of pesticide drift or overspray.   The  risk  to
birds and other wildlife is also minimized, when the granule is  soil incor-
porated.

In 1974, at the time of aldicarb product registration by  the U.S.  EPA,  it was
expected that, under normal conditions of use, aldicarb would fully  degrade
in the soil, and therefore, would not reach any potential  source of  drinking
water, such as subsurface water.  This has not been the case in  some areas of
Wisconsin.  Union Carbide first confirmed findings of aldicarb in  Wisconsin
groundwater in 1980.

Prior to the 1982 planting and growing season, the Wisconsin Department of
Agriculture, Trade and Consumer Protection ("DATCP") adopted a temporary
emergency rule to restrict the use of aldicarb in Wisconsin,  pursuant to
ss. 94.69 and 227.027, Stats.. Jhe rule was published on  March 12,  1982 with
a scheduled effective date of March 15.  The rule remained in effect until
July 13, 1982, when  it expired automatically.

The emergency rule established aldicarb-use moratoriums  in the recharge zones
of aquifers where aldicarb had been detected in potable water wells, at 1  ppb
or more, at any time prior to November, 1981.  Approximately 130 sections of
land, or 83,200 acres  (not all potato growing acres), were included  in  the


information taken from Environmental Impact Statement For Proposed  Rules
Relating to Special  Restrictions On The Use of Pesticides Containing Aldicarb,
Wisconsin Department of Agriculture, Trade and Consumer Protection,  December  1982.

-------
WMD/PS/ATT B-4                        57    -


moratorium areas.  Growers in the moratorium areas were prohibited by  the
emergency rule from using aldicarb in a 15% formulation in 1982.   All  users
in Wisconsin of the Temik 15G formulation were required to report  their
intended use of the pesticide to the DATCP at  least 15 days prior  to use,
regardless of the location of use in the state or the crop on which the
aldicarb was to be applied.

Under Wisconsin ss. 94.70 Stats., no person may apply a pesticide  in a
manner inconsistent with label directions.

1.  Aldicarb is designated as a restricted-use pesticide which may not be
    applied except by state-certified private  or commercial pesticide  appli-
    cators, or by other persons under the direct supervision of a  certified
    applicator.

2.  Aldicarb applications on potatoes in Wisconsin are to be made  4-6  weeks
    after planting, rather than at time of planting.   Directions for use on
    potatoes also require at least 50 days between crop treatment  with
    aldicarb and crop harvest.

3.  Aldicarb may not be applied to the same field more than once every
    2 years.  Fields treated with aldicarb in  1981 could not be treated with
    aldicarb in 1982.

4.  Application rates on Wisconsin potatoes are reduced to a maximum of
    2 Ibs. of active ingredient per acre (ai/A).

5.  The revised Wisconsin label includes a statement  of groundwater hazards
    associated with aldicarb use.

The 5 label changes were estimated by Union Carbide to reduce the  potential
for aldicarb reaching groundwater.  Postponing the date of application permits
soil temperatures to increase approximately 10 degrees, thus increasing the
activity of microorganisms.  This may promote  more rapid breakdown of  the  pro-
duct in the soil, before it leaches to groundwater.  A later application date
will also avoid 6-8 inches of water infiltration brought by early  rains, and
application made above the root system to an established plant will  increase
the amount of pesticide taken up into the plant, therefore reducing the amount
available to potentially migrate into groundwater.

Reducing the rate of application from 3 Ibs. ai/A to  2 Ibs. ai/A reduces the
amount of aldicarb available to reach groundwater.  Changing from  an annual
application to one application every other year reduces by 50% the amount  of
aldicarb applied to the soil. ~

Only certified applicators are able to apply Temik in Wisconsin because of its
restricted-use classification.  This, and the  addition of an environmental
hazard statement, help insure that applicators are aware of the product's
potential for leaching into groundwater.

-------
WMD/PS/ATT B-5                      58    ^


Simultaneous to the Temik 15G label  changes being made,  Temik  10G  was  regis-
tered for use on agricultural crops, including potatoes.  Union Carbide is  not
currently marketing the 10% formulation for agricultural use,  however.

Union Carbide stated during a November 3, 1981 meeting of the  state's  Pesticide
Advisory Council that the then proposed label  revisions  would  lessen the amount
of groundwater contamination (where samples showed aldicarb present at  50 ppb,
Union Carbide estimated a reduction in aldicarb levels to 9 ppb).   No  data  are
currently available to support the position that label changes alone will pre-
vent aldicarb from leaching to subsurface water.

To date, 1982 sampling has consisted of resampling, on a quarterly schedule,
those wells in which aldicarb was previously detected, and of  expanding
sampling to areas where aldicarb is used but which were not initially  consid-
ered "high risk."  Recent sampling efforts show the presence of aldicarb in
previously unsampled wells in Portage and Marathon counties.  Samples  taken
from Jefferson, Waukesha and Sauk counties showed no aldicarb  present.
Although research is under way, no trends in aldicarb behavior in  Wisconsin's
groundwater are apparent at this time.

Of the 505 different wells sampled by Wisconsin and Union Carbide  officials
in 1982, 93 wells sampled contained detectable levels of aldicarb. Thirty-four
of the 93 wells sampled contained detectable levels of aldicarb over 10 ppb at
one time or another.

Aldicarb continues to be detected in Wisconsin's groundwater,  and  use  in com-
pliance with product labeling has not yet been shown to prevent the pesticide
from leaching into groundwater.  Even if the 1982 label  changes are ultimately
successful in reducing new contamination, such that net additions  over  time
are kept within "acceptable" bounds, these additions may nevertheless  be
unacceptable in the short run when combined with high existing accumulations
from former years' applications under the prior label.  In areas where  signifi-
cant contamination has already occurred, localized use moratoriums may  be
necessary to prevent undue aggravation of existing problems, and to reduce  con-
tamination to "acceptable" levels.  The DATCP is therefore proposing an amend-
ment to Ch. Ag 29, Wisconsin Administrative Code, which would  place special
restrictions on aldicarb use in the state.

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                                    59
TOXICS

Manufacturing Sites of Toxic or Potentially Toxic (Hazardous) Substances

In order to determine where potential hot spots of toxic chemical  contam-
ination may be located, Region V has developed detailed maps indicating
the location of facilities which produce toxic or potentially toxic
substances.  The set of maps included here identifies manufacturers of
substances which were listed in the 1979 Chemical Activities Status
Report.  This information was generated by cross referencing with  the
1977 chemical inventory generated under the TSCA.  The substances  included
in the Chemical Activities Status Report include substances regulated or
being reviewed under the Clean Air Act, Clean Water Act, Federal  Insec-
ticide, Fungicide and Rodenticide Act, Resource Conservation and Recovery
Act, Safe Drinking Water Act, and the Toxic Substances Control  Act.
Manufacturers of potential carcinogens, substances found in the Great
Lakes Basin, and chemicals found in fish have also been determined.

This information provides a means to help identify facilities and  areas
manufacturing large numbers and quantities of toxic or potentially toxic
(hazardous) substances.  Such identification provides a logical means to
select sites for environmental assessments to determine if significant
quantities of toxic substances are being released to the environment.

The maps and computer printouts of manufacturing sites of these groups
of substances have been supplied to the environmental regulatory agency
within each State in Region V.  Due to a lack of resources, very little,
if any, monitoring for these substances was conducted by the end of 1982.
Because of the high potential for adverse health effects as a result of
exposure to these chemicals and because many of the sources are also
located near highly populated urban areas, it is imperative that these
potential hazards be evaluated.  The best method to evaluate these poten-
tial sources would be a multi-media approach, including ambient air and
water monitoring and investigating land disposal sites where wastes from
producing these toxic chemicals may have been illegally disposed.

Maps of the chemical production of substances listed in the Chemical
Activities Status Report cross-referenced to the 1977 TSCA inventory are
presented in the following pages for each State in Region V.  Those
counties having chemical production exceeding one billion pounds per
year have been shaded.  Only non-confidential information has been included
in these maps, so the absence of chemical information in some counties
or the numbers indicated in other counties do not necessarily reflect
all the chemical manufacturing information gathered under TSCA. The
data, therefore, must be viewed with these constraints.

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                                     60

WMD/TMB/ATT 8-2


PCB contaminated Harbors (Green Bay,  Ashtabula,  and Waukegan)

Several harbors in the Great Lakes  are  known  to  be contaminated with
PCBs.   Sediment samples showing PCB levels  in  excess  of  50 parts per
million (ppm), a level which EPA considers  as  significant contamination,
have been taken from the Fox River  at Green Bay, Wisconsin,  and harbors
located at Waukegan, Illinois;  Sheboygan and  Milwaukee,  Wisconsin; Grand
Calumet River and Indiana Harbor Canal,  Indiana; and  Ashtabula Harbor,
Ohio.   The most severe PCB problem  is PCB contamination  of Waukegan
Harbor at Waukegan,  Illinois.   This site contains the highest known
concentrations of uncontrolled  PCBs in  the  country.   PCBs in one drainage
ditch  leading to the Harbor have been detected at levels as  high as 25%.
The source of this contamination was  Outboard  Marine  Coporation, which
discharged PCB oils  into the drainage ditch.   This contamination has
resulted in an immediate threat to  Lake  Michigan water quality, where
unacceptably high concentrations of PCBs have  been found in  fish tissue.
Sport  fish from Lake Michigan,  including lake  trout and  coho salmon,
have been found to contain PCB  concentrations  ranging from 7 to 20 ppm
(FDA's action level  is 5 ppm).   Sale  of  these  species of fish in interstate
commerce has been restricted.

The Fox River, which empties into Green  Bay in Wisconsin, has been found
to be  contaminated with PCBs and mercury.   In  1977, a study  conducted
by the Wisconsin Department of  Natural Resources found PCBs  up to 16 ppm
in sediment samples  from this  river.  The highest levels were found
immediately downstream from the outfalls of paper companies  or the City
of Green Bay.  In November of 1982, samples from three birds, obtained
at Green Bay, Wisconsin, were  analyzed  for  polychlorinated dibenzofurans
(PCOFs), dioxins (PCDDs), and  PCBs.  The birds were a belted kingfisher
and two black-crowned night herons.  These  birds contained PCB levels
of 192 ppm, 86 ppm and 28 ppm.   PCDDs were  found in all  three birds at
levels of 37,188 and 88 parts  per trillion  (ppt).  PCDFs were found in
the kingfisher and one heron at levels  of 164  ppt and 8  ppt, respectively.

In Ohio, PCB contamination has  been found in  the Ashtabula Harbor and
in rivers leading to the Harbor. Sediment  samples from  the  Harbor have
revealed concentrations of PCBs ranging  from  5 to 70  ppm.  One small
tributary of the Ashtabula River, Fields Brook,  has PCB  concentrations
in the sediment ranging from 3  to 4 ppm.

A number of industries are located  in the drainage area  leading to the
Harbor, and waste water discharges  are  believed  responsible  for much
of the PCB contamination found.

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                                                 61
             MANUFACTURE OF TOXIC  AND  POTENTIALLY
             TOXIC  (HAZARDOUS)  SUBSTANCES
1LLI&03S
                                                  /-I      ^-r-t  13.1   f
'nxJuCtlon ;ou(ii!i<)o
No production or gn-
1,000 to IO.GCO
10.0CO to IOC :C
100,500 to i,;:3,c
l.coo,coo to  10,:
10.003,COT -.3
so.ow.oco 13  ioo,;.
loo.oco.ccD ts :CG,
$00,000,300 ;j Cnc
C-«cr One Billion

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MANUFACTURE  OF TOXIC AND  POTENTIALLY!
TOXIC  (HAZARDOUS)  SUBSTANCES
                                                      62
INDIANA
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                                                                     10,000 to ico.cc:
                                                                     loo.aoo to
                                                                     1.000.300
                                                                     io.oo3.oco to sc.::o.::i
                                                                     SQ.rOO.CCO to IC^I'V.IIJ
                                                                     loo.ooo.r.co to s:o,jc:.:"
                                                                     500,3C<3,500 to On.) sillio
                                                                     Over Cn« Sill ton

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                IT TO *vrtaic«i certs
        p>r
         Codl
         Ktnuf«turtd
63
                            SubtUfKit
                    County
                                   0«lo»)
IMd*!
    10 proouction or unltr !
    l.OCO to 10.KO
    10,000 !3 !!M.OOO
    loo.ooa -.0 ).:::. coo
    1.300.000 to 10. 300. COO
    io.ooo.:co ;: 5:.:.:c.:ci
    5o.K3.::o u ':;.:co.;:
    100,000 iC-CO *5 SCdCCOiC
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    Ovtr One 5»\lion
    lined
                                                                         MANUFACTURER  OF  TOXIC  AND  POTENTIALLY
                                                                         TOXIC  (HAZARDOUS)   SUBSTANCES
                                MICHIGAN

-------
MANUFACTURER OF TOXIC AND  POTENTIALLY
TOXIC  (HAZARDOUS) SUBSTANCES
MINNESOTA
                                                    'fon coun-iag* clii
                                                 Ho production 2r jn-^ef ' ,CCO :ouncs
                                                 1.000 15 10,COO

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                                65
MANUFACTURER OF TOXIC AND  POTENTIALLY
TOXIC  (HAZARDOUS) SUBSTANCES .
                                                          OHIO
1
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1

• ho production or
• i.xo :o ;o.::o
• lo.oco 13 10:.;-
• 1M.3CO to i .:::
l.QCO.OOO to 'G,
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• loo.;oo.coo t; ;
SOO.OOO.CM to Or
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                                            66
MANUFACTURER OF  TOXIC  AND POTENTIALLY
TOXIC (HAZARDOUS)  SUBSTANCES
WISCONSIN
                                                  Mrtt


                                                 Stand
                                                              "turner of Subiumces
                                                          Code *vzs*r for Poundage of SyO'Stancei
                                                          J»inuf*ctur»d p«r County (Cades list^a



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                                          67



                            Unregulated Toxic Substances


Overview

Increasingly, Region V is directing its attention in all program areas  toward
the identification, assessment, and control  of toxic substances  pollution.   This
progressive shift in program emphasis is a logical  outgrowth of  the Agency's
successes in addressing conventional  pollution problems; improved scientific
understanding of the nature and extent of toxic substances in the environment;
and, of course, the recent rapid growth in the number and volume of toxic  and
hazardous substances in the environment.  One by-product of these developments
and experiences is the growing awareness that toxic substances  in the air,
water,  and land media present a far more complicated set of pollution concerns
that any we have confronted to date.   Confounding this  situation is the fact
that the more scientists learn about toxic substances,  the more  regulatory
agencies realize that control  mechanisms applied at present are  inadequate.

The emerging problem of unregulated toxic substances has a number of dimensions.
First,  the information base necessary to develop an understanding of the nature
and extent of toxic substances problems is incomplete.   One element of  this  is
our information on the actual  and potential  sources of  toxic substances.   This
information should consist of qualitative and quantitative data  about chemical
production, importation, transportation, or use at  specific locations;  information
about types of industries, raw materials used, production processes, catalysts,
intermediates, products and by-products, point source discharges, and emissions;
and data on the location, number,  and contents of active and inactive disposal
sites.

Another critical  informational  element is data on the physical,  chemical,  and
toxicological properties of toxic substances.   This information  enables
scientists to gain insight into the movement,  fate, and effects  of toxic
substances in the environment.   It also provides a  basis for estimating the
potential  for exposure to chemical  substances.  And, most importantly,
characteristics information is  used to assess  the degree of hazard a chemical
substance poses to organisms,  and to  set priorities for regulating specific
toxic substances.

A final  element in our toxic substance information  base is the measurement of
the actual incidence and accumulation of specific chemical substances in the
environment.  Through research, monitoring,  and surveillance activities, informa-
tion is gained on new or previously undetected potentially toxic substances  in
the environment,  instances of detrimental  effects on human populations  and
natural  resources from toxic contamination,  and trends  in the environmental
concentration of specific toxic chemicals.

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                                      68
The second dimension of the emerging toxic  substances  problem is  the  complex
area of hazard and risk assessment.   The data in the information  base are used
in the assessment of the potential  hazard a substance  poses  to  humans and other
organisms.  An assessment is used to assist in deciding  which substances
should receive priority attention for regulation, monitoring, or  further
investigation.  In essence, hazard assessment is a continuous process that
involves the estimation of the potential  hazard of a toxic  substance  to an
organism.

The complementary exerise to hazard assessment is formal  risk assessment.
Risk assessment is a process of estimating  the probability  that exposure  to
a chemical at a particular level  will  cause an adverse effect in  humans,  other
living organisms, or important non-living environmental  components. Risk  assess-
ments should contain the following common elements:

    1.  definition and quantification of exposures;

    2.  characterization of the exposed  population in  quantitative terms;

    3.  chemical  and physical  properties  of the substance and its chemical
        reactivity in relation to exposure;

    4.  prudent quantitative mathematical  extrapolation  of  the  responses  from
        observed to estimated  exposure ranges within the observed biologic
        system; and

    5.  qualification of the estimated risks in light  of identifiable biological
        and toxicological differences that  may be present in the  exposed  human
        population.

The toxic substance assessment process sketched above  is a  highly complex
exercise for which no one definitive model  exists, nor is remotely likely
to be developed.   This very individualized  process is  undertaken  by many
regulatory agencies on a continual  basis  for the purpose of deciding  in
specific situations what the most appropriate control  or remedial measures are.
In view of the plethora of toxic  substances in the environment, it can readily
be seen from even this very general  outline of the purposes and elements  of  the
assessment process that our capacity to  deal with toxic  substances is severely
strained.

The third and final dimension  of  the unregulated toxic substances problem
is the regulatory and control  programs designed to manage toxic substances.
In this country there is an array of programs in all media  under  a variety of
environmental legislation designed at least in part  to address  toxic
substances from the time of their proposed  introduction  into commerce,

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through their...use,  to  the time  of  their  disposal  or discharge.   Federal  laws
addressing toxic  substances  in the environment  include  the TSCA, FIFRA,  CAA,
CWA, SDWA, RCRA,  and CERCLA.   In  practice, the  various  programs under  these
laws have been able to address toxic substances with  varying  degrees  of effec-
ti veness.

In the air medium, toxic air emissions  and their potential  health effects  are a
growing concern in  Region V due to the concentration of  potential  industrial
and hazardous waste  sources  and their  coincident proximity to  population  cen-
ters.  At present, toxic  air  pollutants  are regulated under  provisions of  the
CAA, in particular the National Emission Standards for Hazardous Air  Pollutants
(NESHAP).  Despite concern about the magnitude  of the health  and environmental
impacts of toxic  air pollutants  and   a  substantial   expenditure  of  effort  to
date, NESHAP regulations have  been  promulgated  for only  four  substances.   They
are vinyl chloride,  beryllium,  asbestos,  and mercury.  Lead  is  also  regulated
as a criteria  pollutant.   In addition, just three  other substances,  benzene,
radionuclides,  and  inorganic  arsenic,  have  been   designated   as  hazardous.
Thirty-seven chemicals are  on  a list  that  was  undergoing assessment  for  pos-
sible listing.   No  regulations for them  are proposed.  The  present  scope  of
Federal regulatory control over hazardous  air emission is  clearly very  limited.
As a  result  of  the complex  and  accordingly,  expensive  process  for  listing
toxic air pollutants, not to mention setting scientifically  and legally defen-
sible control standards,  the  efficacy  of the powers  under  the  CAA are  corre-
spondingly limited.

Furthermore, although it  is  known  that  controlling  particulates  and  volatile
organic compounds will  generally limit associated  toxic  emissions,  there  are
limits on the regulatory  agencies'  abilities to use  pollutional  surrogates  to
control toxic air emissions.

Additional air toxicants authorities, however, exist  at the state level.   State
agencies are developing  emission  inventories,  defining potential  problems  and
creating regualtory  programs.   A  current  initiative  is  an effort to  define  a
limited number of sites  and facilities  around the  Region  upon  which Federal  and
state resources  may  he focused.

In the water  medium,  toxic substances   under the  CWA are  controlled primarily
through wastewater effluent  limitations  derived from technology-based  evalua-
tions and water  quality  standards.  The  information  bases for  these  programs
are generated through the discharge permitting and compliance  process,  National
Effluent Guidelines  development, environmental   fate  pollutant monitoring,  and
research on  toxic pollutants.

The National  Pollutant Discharge Elimination System  (NPDES)  permit  program  gen-
erates limited  toxic data as well as information on  flow,  plant  configuration,
and effluent concentration.  Much of the information  on toxicants was generated
before 1977   and  is   now  being  updated for significant  critical facilities.

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                                     70
All plants (some 2,300 in USEPA Region V alone)  in some 30-35 industrial
categories are currently required to conduct limited chemical  evaluations  or
have evaluations conducted on their behalf for the 126 priority  pollutants
published by the USEPA.  In addition,  the industries are required  to provide
updated raw material, production, and  discharge  information.   The  states and

Region are requiring that a more select group of industries,  with  the highest
potential for the discharge of toxicants, conduct special  biological, chemical,
treatabil ity, and manufacturing process evaluations to aid in determining
limitations for toxicants and other parameters of concern.  This evaluation  and
limitation development process is designated to  balance human health and
environmental risks with treatability  and the economics of control.

Overall product use and environmental  fate data-gathering  are centralized  in
National  Effluent Guidelines and water quality criteria development.   Most
fate and risk studies have been within the purview of the  USEPA  Office of
Research and Developments' national  laboratories.  Unfortunately,  the data base  is
generally too fragmented to identify trends in large categories  of chemicals.

Limited environmental contaminant trends for a selected number of  toxicants,
particularly pesticides, have been developed for a number  of  locations in
Region V.  However, broad-scan analytical  capability for a large number
of other toxicants is just being implemented, particularly for fish  flesh  and
sediment surveys.  The fish flesh arid  wildlife contaminant trend monitoring
programs  have been largely limited to  sporadic reviews every  few years.
Most NPDES permit data are updated primarily through the permit  reissuance
process cycle of 3-5 years.  However,  the manufacturing information  available from
the TSCA inventory for identifying potential  toxic discharges  is becoming  outdated,
as most of it was gathered in 1977.  The most significant  new source of toxicant
production and release information is  expected to be the locally developed detailed
industrial inventories from implementation of the pretreatment regulations for
industries discharging to municipal  treatment plants and revised NPDES applications.
The municipalities and states are also now starting to evaluate  and  control  toxicants
which have and are contaminating municipal  sludge.  In some instances, contaminant
sludge has been used by home gardners  to raise vegetables  and can  have resulted  in
significant health problems.

The information utilized in the CWA toxicant comtrol programs  is usually
sufficient to perform first-cut analysis and problem identification.   How-
ever, information is not as yet available on product contaminants  and by-
products present in the wastewater.  This type of information requires
intensive and time-consuming reviews of target facilities.

Treatability and potential water impacts provide the technical  basis for
assessments.   These assessments are formalized and are uniform in  approach
at the national level, but are applied to only a limited number  of parameters.
Furthermore, the degree of control specified by  these assessments  is affected

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by industrial sector economics, successful  court challenges, and non-
uniform timing in implementation of controls.   National,  state,  and regional
formal assessment procedures for toxicants, other than guideline parameters,
are mostly in the initial  stage and are aimed  primarily at control  level
specification for industrial facilities.  The  assessment  process, due to
extensive delays in developing Best Available  Technology  Economically
Achievable (BAT) Effluent Guidelines,  has resulted in significant delays
in implementing toxicant controls.   Moreover,  many of the BAT development
efforts are focusing only on a limited number  of pollutants  of national
interest, primarily the heavy metals.   The development of toxicant  effluent
controls for other toxicants, therefore, must  be based on "best  professional
judgement" for each facility, a condition requiring extensive staff work.
Moreover, even where the criteria development  has resulted in a  strong
data base for toxicant control under water quality standards, the site
specific nature of the control again requires  intensive specialized
regulatory development.

The CWA authorities seem adequate to support the necessary toxicant control
programs.  However, the delays in implementing Best Available Technology
Currently Available (BAT)  requirements for toxic substances, the increasing
reliance on resource intensive BPJ  approaches  in a time of shrinking resources,
the need to undertake time-consuming site-specific criteria  modifications,
and the intensive water quality standard-setting process  limit the  scope and
effectiveness of the CWA tocicant control program.

In the water supply problem area, the  program  does not seek  to control toxicants
and their use in the environment, but  rather assures that the public does  not
consume toxic substances in its drinking water.  At present,  maximum contaminant
levels (MCL's) have been set for only  eight constituents  (i.e.,  heavy metals),
nitrate, flouride and six pesticides formulations, in addition to several  non-
toxicant contaminants.   Clearly, the regulatory  scope is  limited relative  to the
number and volume of potential toxic contaminants of groundwater and drinking
water.  In view of the complexity and  expense  associated  with toxic substances
control in groundwater and drinking water,  Region V is increasingly concerned
with the actual or potential  presence  of unregulated volatile synthetic organic
chemicals in drinking water, toxic  chemical  degradation of groundwater from
a variety of agricultural  and industrial  sources, contamination  from in-
place toxicants, and the adverse impacts  of toxic-contaminated municipal
sluoge.  Limited capacity  to sample and analyze, as well  as  the  lack of
scientifically sound risk  assessments, result  in insufficient knowledge
to address the full  extent of toxic substance  pollution problem  in  ground
water and drinking water.

In the hazardous, or land, media, which is  the focus of the  FIFRA program  and
the newer Agency programs  under TSCA,  RCRA, and  CERCLA, the  variety and extent
of the unregulated toxic substances problem is most evident.  Under  the Toxic
Substances Control  Act (TSCA), the  Region has  utilized the 1977  inventory  of
chemical  production to identify manufacturers  of various  categories for toxic

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chemical and  potential  problem areas  and  geographic  concentrations  of  major
chemical manufacturers.  Unfortunately, this  TSCA  inventory is  outdated  (1977
data), unsuitable  for  trend  analysis  (no  automatic  updating mechanism),  and
limited with  respect to manufacturer claims  of  confidentiabi li ty.   These  limi-
tations adversely affect the Region's  ability to base  inspectional  and  enforce-
ment priorities on timely,  scientific  information.

TSCA also provides for the  assessment  of chemicals  being  manufactured  which  are
considered to  have  potential  risks to  human  health  or the environment.  This
assessment is  conducted using two  methods.   First, manufacturers  are  required
to supply  toxicological  and  environmental  data  on  the  chemicals  produced.
Then, under the direction  of the Interagency  Testing Committee (ITC),  chemicals
are recommended  to  the  USEPA  for  regulatory   action.   Under  this  process,
chemicals are  assessed  on  the basis of production,  volume, environmental  re-
lease, and toxicological  data.  The ITC has established formalized  methods  for
the review of chemicals during manufacture.   However,  the  USEPA has experienced
difficulty in  responding promptly  to  the  ITC's recommended priority  chemical
lists due  to the  now familiar  problem of  time  consuming  scientific hazard
assessments.  In  this  often  times  arduous  process,   the  Agency must  evaluate
large amounts  of  toxicological  data  and,  before  restricting  a  chemical, must
establish the  degree  of  risk  and  the   impact of  possible  regulatory  actions.
The difficult and  resource-consumptive  assessment  requirements  under  the  TSCA,
while certainly  essential  from  the  persective  of scientific  soundness,  are
nonetheless extremely difficult to meet in a truly comprehensive  manner.   The
result is that  toxic  substances  in the environment are  not  regulated.   While
all chemical substances will  likely not require  restriction,  our limited  capa-
city to  identify  with  certainty  those substances  is an  emerging concern  in
Region V.  The states  have  only  limited  ability to complement federal assessment
efforts for  several  reasons:   formalized,  uniform testing  procedures are  at
best remotely possible due  to variations  in  state capabilities; state  program
support under the  TSCA  will   soon  cease; and  the extremely specialized nature
of some  of  the assessment  procedures   create  scale economics  and  efficiencies
realizable only in a national-level program.

In the  pesticides area, much of  the   above  discussion  concerning activities
under the TSCA  applies.  The  FIFRA controls  pesticide  manufacturing,  packaging
movement in commerce, disposal, and use by  requiring that  all  products  (approx-
imately 35,000)  be  registered.   Product  registration  is  a  detailed  process
requiring the submission of data which  addresses at a  minimum product  efficacy,
chemistry, environmental  fate,  toxicology,   residue  chemistry,  and ecological
effects.  Similar to TSCA, there have  been delays  in the  complicated  processes
of product  registration and  classification, although  recent efforts to  stream-
line the procedures have resulted  in fewer delays.  However,  these streamlined
procedures must  be  sufficiently  vigorous  to  prevent  the  introduction  of pro-
ducts which  pose  unreasonable risk of  injury to human health  and  the  environ-
ment.  Another  area of  concern  relative to unregulated pesticides  involves  the
need for  generally  available, adequate disposal  facilities and  techniques  for
pesticides containers and application wastes.   Simply  stated,  there is  a  grow-
ing concern  in  this  Region  of Heavy  pesiticides use about  the  proper disposal
of pesticides  in  accordance with the regulations.  This problem  is in  fact  one
aspect of the general hazardous materials  disposal  issue.

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                                         73
The real  issues concerning unregulated toxic substances  in  the  hazardous  waste
areas involve the long-term adequacy of environmentally-sound disposal  capacity;
the unregulated disposal  of hazardous wastes by  small-quantity  generators; the
proper listing and regulation of hazardous substances,  such as  dioxin;  the control
of hazardous wastes in recycling operations; and the  control  of hazardous wastes
in blended fuels for use in boilers or heat-recovery  units.  One other  major
concern involving unregulated toxic substances  relates  to the extent to which
the individual  Superfund sites will be cleaned-up.  This is commonly known as
the "how clean is clean" issue.

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                                    74


                 REGION V ENVIRONMENTAL  MANAGEMENT REPORT


                              ATTACHMENT  B


                                  WATER
TOXICS - SAUGET, ILLINOIS

Geographic Location and General Description

The Sauget Area consists of the City of East St. Louis, and the Villages of
Sauget and Cahokia.  As noted on the location map (Attachment 1), these
communities are all bounded by the Mississippi River on the west.  It is
generally known that this area is underlain with sand and that groundwater
flow  is toward the Mississippi River.  Groundwater within this area is not
used  for drinking water purposes.  Potable water in the area originates from
the Mississippi River, upstream of the Village of Sauget.

There are many large industries in this area, particularly within the Village
of Sauget.  The area contains several landfills which are now closed.  Since
the 1950's, several of these landfill sites received large quantities of various
chemical wastes.  Dead Creek is a small intermittent stream that flows through
the Sauget Area.  The Illinois EPA has documented that the creek bed sediments
of this waterway are highly contaminated from surface water discharges and the
probable dumping of chemical wastes.


Sauget Sewage Treatment Plant and Mississippi River Impact

The Sauget STP serves approximately 200 local residents plus the industrial
wastewater of several large industries including the Monsanto Krummrich Plant.
The STP is a physical-chemical plant described in Attachment 2.  The Sauget
plant treats approximately 8 million gallons a day of a wastewater that is
laden with organic chemicals.  The results of U.S. EPA sampling on March 2-3,
1982, revealed the influent and effluent to contain several organic chemical
compounds which are not removed, to any degree, by the STP.  The location of
the STP is identified in Attachment 4.

The environmental impact of the present STP discharge on the Mississippi
River is not well defined.' Organic chemicals, known for their persistent
and bioaccumulative characteristics, dilute down to below analytical levels
of detection due to the large dilution volume of the river.  In November 1982,
the U.S. EPA Water Division conducted a caged fish study in the Mississippi
River upstream and downstream of Sauget.  The intent of this study is to
define, under controlled conditions, any bioaccumulation of organic compounds
in the  study fish.  Also, some native fish are to be analyzed as a part of
this  study.  There is known to be some commercial fishing in the river, south
of Sauget.  The fish are generally sold in local markets for human consumption.
The results of this study are expected to be complete by mid-1983.

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                                      75
Groundwater Contamination

Contamination of the groundwater appears to be the result of the numerous
landfills  in the area.  A diagram showing these past dumpsites is described by
Attachment 4.  On March 3, 1982, U.S. EPA sampled several wells in the Sauget
Area.  The results are listed in Attachment 5.  Additionally, low levels of some
organic compounds were found in the groundwater, in particular, bis (2-ethyl
hexyl) phthalate.  Groundwater in the Sauget Area is not used as a drinking
water source, but is used by some residents as a supplemental water source for
watering their vegetable gardens.

Proposed Remedial Action

The Sauget STP effluent will be further treated by the American Bottoms
Regional Treatment Plant upon its completion in 1985-1986.  That treatment
facility will employ the use of powdered activated carbon to adsorb the organic
chemical wastes before discharging to the Mississippi River.  Waste Management
Division has evaluated and calculated MITRE scores on the inactive landfills
and dumpsites in the Sauget Area.  Due to the relatively low MITRE scores, to
date, only the Dead Creek area has received remedial  improvement measures.
This has consisted of enclosing the Dead Creek with chain link fence near a
residential area.

The construction and operation of a Regional Treatment Plant is a longer term
solution to an environmental problem that has been in existence for many years.
Alternative shorter term solutions could consist of reducing the quantity and
types of chemical wastes to the Sauget STP by implementing process controls
and modifications at the contributing industries.   Additionally, chemical wastes
from the contributing industries could be pretreated  on-site by the industry.
Neither alternative has received a favorable reception from the industries of
the Sauget Area.

Further groundwater studies are necessary to define the full extent of environ-
mental contamination caused by the landfills and dumpsites of the Sauget Area.
These studies are then condensed into a Remedial  Action Master Plan (RAMP)
which defines what remedial  actions are necessary  to  achieve a specified level
of cleanup and the probable cost of such actions.   Such remedial actions are
longer term in nature.   Short term immediate action should consist of  advising
the area residents of the limitations on the use of groundwater.  Active land-
fills in the area are regulated by State and Federal  law.   The deposition of
wastes in the landfills is restricted to prevent further degredation of the
groundwater.

-------
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-------
Attachment^?
        DATA TABULATION OF LABORATORY- RESULTS FOR> NON-METAL PERMIT PARAMETERS
                     LOCATION:   Sauget POTW
                  SURVEY DATE:   March 2-3,  1982
               (All Results in mg/1 Unless  Otherwise Noted)
CDO Sample Number 82CS01
Flow (Avg) MGD
pH(pH units) Field
Suspended Solids
Suspended Solids kg/day
BOD
BOD kg/day
Cyanide
Phenclics rag/1
Phenolics (kg/day)
Fluoride
Oil & Grease
Oil & Grease (kg/day)
SOI
\nSlv) f
-------
                      DATA TABULATION OF LADOR/TORY RESULTS FOR METALS
                          '  LOCATION: Saug£t POTW
                         SURVEY DATE: March 2-3, 1982
                   (All Results in ug/1 Unless Otherwise Noted)
 x',

L-C
CuO Sample Number
2"'; 4 ,6-trichlorphenol
iichlorophenol
"2,4-dichlorophenol
2-nitrophenol
itnitrophenol
phenol
b is (2-chloroethyl) ether
'^.2-dichlorober.zene
"isophorone
butyl benzyl phthalate
•Idrin
"alpha BHC
*beta-BHC and/or heptachlor
^gatntna-BHC
1 ,4-dichlorobenzene
naphthalene
•ois(2-ehtylhexyl)phthalate
di-n-butylphthalate
^-
-------
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-------
                                               Q A
                    DATA TABULATION  OF LABORATORY RESULTS
                      LOCATION:  JIrjaujad_ Wat!er_ Mo ni to ring { Sauget, Illinois
                      SURVEY  DATE:   March 3,  1~982
T ..e Number 82CX01
n »^ * *
5 •-"*"
I ,-nainun ug/1
1 ,.«enic
FT
I urium
I i^ron
1 'idoium
|.'irouiu«
,'obalt
toopcr
| Iron
1 lead
| v.sr.a£Tr.ese
r
! "ercurv*
1 Sickel .
Ssleniun
Silver
_:ln
ijindiutn
Sjlnc
i
s^tlnony
[^halluin
^-^TYlliuta
.^rcury**
SOI
<200
11
<100
10500
4.2
12
62
65
65000
570
1600
<0.2
<40
<2
<10
<20
<200
107000
<20
<10
<5
0.1
	
S02
410
<10
<100
11000
14
<10
70
<50
31000
97
1100
<0.2
<40
<2 •
<10
<20
<200
1
109000
<20
<10
<5
0.4
S03
390
<10
<100
8000
31
<10
82
<50
38000
74
1500
- . <0.2
<40
<2
<10
<20
<200
40000
<20
<10 •
<5
0.4
S04
<200
29
<100
1800
5.3
<10
95
<50
28000
9
5100
<0.2
1
<40
1
<2
<10
<20
<200
1900
<20
1
<10
<5
I ,
; 0.2
S05
940
<10
<100
140
<1
<10
<50
<50
530
11
460
<0.2
<40
<2
<10
<20
<200
260
1
<20
<10
<5
I 0.1
i
S06
1200
<10
<100
110
2.8
<10
<50
<50
250
10
80
<0.2
<40
<2
<10
<20
<200
350
! <20
<10
<5
<0.1
R09
<200
<10
<100
<100
<1
<10
<50
<50
<50
<5
<15
<0.2
<40
<2
<10
<20
<200
<10
<2C
<1C
<5
<0.1
       Analytical Laboratory Test   **CRL Laboratory Teat.  CRL mercury result is considerec
:r'dible because  analysis was performed within the required holding  tine.

-------
DATA TABULATION OF LABORATORY RESULTS
    LOCATION:  JSrjjuasLWa_t e r Monitor lag,  Sauget, Illinois
    SURVEY DATE:  March 3, 1982
I _!„ Nuaber 82CX01 507 |
I .,»il Aluminum ing/kg 750
f • Arsenic " 1.3
I • Bariun " 80
| • Boron " <10
if " Cadmium " 1.06
1 Chromium " 2.2
Cobalt " <5.0
Copper " 16'
| " Iron " 340
| " Lead " 45
j. " Managmese " 120
£*
P " Mercury " <0.02
S " Nickel " 6.5
| " Seleniun " <0.'2
I . " Silver " <1.0
I _ - Tin - <2.0
! _ " Vandiura " <20
1 > 	 " Zinc " 96
1 	 	 " -Antimony " <2.0
1
{ . 	 " Thallum " <1.0
i
[ . 	 " Beryllium " <0.5
1
S10 I
600
1.0
80
<10
1.64
<1.0
<5.0
24
360
20
630
<0.02
5.5
<0.2
<1.0
<2.0
<20
77
<2.0
<1.0
' <0.5
Sll
430
<1.0
80
<10
0.29
<1.0
<5.0
13
240
25
134
<0.02
4.0
<0.2
<1.0
<2.0
<20
130
<2.0
<1.0
<0.5
1
R12 |
<10
<1.0
<10
<10
<0.1
3.2
<5.0
<5.0
<5.0
<0.5
<1.0
<0.02
<4.0
<0.2
<1.0
<2.0
<20
<1.0
<2.0
<1.0
<0.5

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                                    83


TOXICS - WATER - DIOXINS IN MIDLAND, MICHIGAN


The Michigan Department of Natural  Resources (MONR)  and Region  V,  beginning
in 1981,  cooperated  in the  development  of  a  wastewat^r  characterization
study for the Dow Chemical Company  facility in  Midland, Michigan.  The  study
was to identify and quantify discharges of  contaminants with special  empha-
sis on toxic  substances.  The  data  obtained was to be  utilized, along  with
additional engineering  and  toxicological  analyses,  in the development  of
Dow's next NPDES permit.  A  preliminary report  was prepared in  March,  1983.
More than 40 toxic organic  chemicals were  identified  and quantified  in the
main process  wastewater  outfall,  most in  the  low  part per billion  range.
Discharge of toxic organic pollutants from  the  plant  is estimated  to  exceed
6 tons per year. More  than 30  organic  chemicals  were found in whole  fish
exposed to the main  outfall plume  at  levels ranging  from a few  parts  per
billion to over  1  part per million.  These chemicals   included  chlorinated
benzenes, phenols,  and pesticides.  A number of  dioxin  isomers were found in
the discharges and  the  caged fish. The most  toxic chlorinated dioxin  isomer,
2,3,7,8-tetrachlorodibenzo-p-dioxin, was  found  at a  level  of 50  parts  per
quadrillion in the main  process  effluent  and at 100  parts  per  trillion  in
whole fish exposed to the effluent.  The complete results  from the  fish  bio-
accumulation study are  not yet available.  The  remaining analyses will  be
completed this summer.

The Region continues to work  closely  with Michigan  to  study this  problem
and that  of  other  toxics  in  the  environment.  The cost  and complexity  of
analytical procedures and the need  to perfect analytical  methods for  sample
analysis in  the  sub-parts  per trillion   range  poses major  Regional   and
National problems.  This is a limiting factor to the number of  samples  that
can be analyzed. The development of a  study plans and associated  technical
protocols to perform credible  and  scientifically sound  studies is  impera-
tive.

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                                 84


*A1dicarb (Temik) Contamination  of  Ground  Water  in  Wisconsin


     Introduction
     Aldicarb is the active ingredient  found  in  Temik  15  G  and Temik  10
     G, systemic carbamante pesticides  manufactured  and marketed  by the
     Union Carbide Agricultural  Products,  Inc.  ("Union Carbide").

     In 1974, at the time of aldicarb product registration  by EPA,  it
     was expected that, under normal  conditions  of  use, aldicarb  would
     fully degrade in the soil,  and therefore, would not  reach any
     potential source of drinking water,  such as subsurface water.  How-
     ever, under normal use conditions, in certain  environmental  circum-
     stances, aldicarb residues  have leached  into the groundwater  before
     being fully degraded in the soil.   This  characteristic of aldicarb
     was discovered in Suffolk County,  New York  (Long Island) in  1979
     where high rates of aldicarb were  used on  potato fields.  Ground-
     water sampling for aldicarb residues  was then  initiated in other
     states where the pesticide  is used under similar conditions,
     Wisconsin being one of those states.

     In 1980, 1981 and 1982 aldicarb was  confirmed  to be  present  in ground
     water samples collected in  several Wisconsin counties  (See enclosure!).
     In some samples, the amount of aldicarb  detected exceeded 10 oa^ts  per
     billion (ppb), which is the drinking  water  guideline accepted  by  EPA,
     the Wisconsin Department of Health and Social  Services and the Wisconsin
     Department of Natural  Resources as the threshold action level  for  public
     health purposes.  Therefore, the presence  of aldicarb  in drinking  water
     at levels above 10 ppb is considered  a threat  to public health.

     Location and Severity of the Problem

     Although indications are that aldicarb applications  in Wisconsin  were
     made in compliance with pesticide  rules  and according  to product  label
     directions, aldicarb has leached through soil  and into the  groundwater
     in some areas of the state.  Union Carbide  first confirmed  findings  of
     aldicarb in Wisconsin ground water in 1980.  In 1981,  Union  Carbide,
     the University of Wisconsin, the Wisconsin  Department  of Natural  Re-
     sources, and the Portage County Community Human Services Department
     participated in extensive cooperative program  of well  water  sampling
     and analysis for aldicarb.

     Wisconsin water sampling sites were initially  selected based on  land
     use patterns and soil  and groundwater characteristics.  Sampling con-
     centrated on potable water wells  in those areas thought to  most  sus-
     cepitable to groundwater contamination by aldicarb.    "High  risk" sites

-------
                             85
chosen for sampling were those where:   aldicarb  was  used  the  two
preceding years; there is sandy,  acidic soil  with  little  organic
matter preset; the water table is close to the soil  surface;  and
irrigation is practiced.  Based largely on these criteria,  363
well water samples were collected and  analyzed from  10  counties
In 1981.  Of the 363 samples collected in 1981,  68 contained
detectable levels of aldicarb (over 1  ppb).   Of  these 68  samples,
51 contained aldicarb residues of 10 ppb or less,  13 contained
levels ranging from 11-30 ppb, and 4 contained levels greater than
30 ppb.  The highest level  of aldicarb in any one  sample  was  111
ppb.  In 1981, aldicarb residues  were  detected in  groundwater
in Portage, Adams, Barron,  Langlade, Marathon, Waupaca, and
Waushara counties.  No aldicarb was detected in  samples taken in
Juneau, Vilas, or Wood counties.

1982 sampling consisted of  resampling, on a quarterly schedule,
those wells in which aldicarb was previously detectd, and of
expanding sampling to areas where aldicarb is used but  which  were
not initially considered "high risk."   Recent sampling  efforts
showed the presence of aldicarb in previously unsampled wells
in Portage and Marathon counties.  Samples taken from Jefferson,
Waukesha and Sauk counties  showed no aldicarb present.  No  trends
in aldicarb behavior in Wisconsin's groundwater  are  apparent  at
this time from reared that  is underway.

Of the 505 different wells  sampled in  1981 and through  May, 1982,
93 wells sampled contained  detectable  levels of  aldicarb.  Thirty-
four of the 93 wells sampled contanied detectable  levels  of
aldicarb over 10 ppd at one time  or another.  The  analysis  of
samples collected between August  27 and September  27,  1982  by
DNR and the Portage County  Community Human Services  Department
shows that 27 different potable water wells in 5 counties (Adams,
Portage, Marathon, Langlade and Waushara) contain  aldicarb  at
levels above 10 ppb. (See enclosure 3).

Analysis and Discussion of  Problem  f

Characteristics, Uses, and  Effects of  Aldicarb (Temik)

Temik 15 G contains 15% aldicarb  by weight and has been used
in .Wisconsin, primarily on  potatoes, since 1975.  It is thought
that using Temik for the control  of potato pests rather than
alternative pesticides provided wider  spectrum of  pest  control
and greater persistence during the growing season.  Temik 10G
contains 10% aldicarb by weight and is registered  for  specific
uses in greenhouse and on outdoor nursery planting.   In 1982
agricultural uses were added to the Temik 10G registration  and
label.  As a granular pesticide formulations Temik is  incorporated
into the soil.  Temik is effective as  an insecticide because  it
inhibits the production of  acetylcholinesterase, an  enzyme  which

-------
                                 86
mediates neurological  transmission at  nerve/muscle  junctions
This effect has been observed in mammals  and  other  higher
species, as well as in insects.   Aldicarb has a  high  acute
toxicity and is both dermally and orally  toxic to humans.
Aldicarb is not known to be a carcinogen, mutagen,  or
teratogen.                                          j

Actions Already Taken to Minimize the  Potential  for Aldicarb
Contamination of Ground WateK

State Emppqency Rule

Prior to the 1982 planting and growing season, the  Wisconsin
Department of Agriculture, Trade and Consumer Protection
DATCP adopted a temporary emergency rule  to restrict  the  use
of aldicarb in Wisconsin.  The rule was published on  March  12,
1982 with a scheduled effective date of March 15.  The rule
remained in effect until July 13, 1982, when  it  expired auto-
matically.

Voli'ntarv Product Label Changes

In addition to the DATCP's action, Union  Carbide submitted  5
changes to the Temik labels to EPA on  March 11,  1982.   These
changes, approved by EPA on March 15,  1982, and  applicable
today, were designed to reduce the likelihood of aldicarb
contamination in groundwater by lessening the amount  of aldicarb
available for leaching, and include the following changes  for
use of Temik 15G in Wisconsin.  Under  s,  94.70,  States.,  no
person may apply a pesticide in a manner  inconsistent with  label
directions.

The 5 label changes were estimated by  Union Carbide to reduce  the
potential for aldicarb reaching groundwater.   Postponing  the  date
of application permits soil temperatures  to increases approximately
10 degrees, thus increasing the activity of microorganisms.  This
may promote more rapid breakdown of the product  in the soil,  before
it leaches to groundwater.  A later application  date  will  also
avoid 6-8 inches of water infiltration brought by early rains,  and
application made above the root system to an  established  plant
will increase the amount of pesticide  taken up into the plant,
therefore reducing the amount available to potentially migrate
into groundwater.

Reducing the rate of application reduces the amount of aldicarb
available to reach ground water.  Changing from an annual  ap-
plication to one application every other year reduces by  50%
the amount of aldicarb applied to the soil.

Only certified applicators are able to apply Temik in Wisconsin
because of its restricted-use classification.  This,  and the ad-
dition  of an environmental hazard statement,  help insure  that
applicators are aware  of the product's potential for leaching into
groundwater.

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                           *    8?

Union Carbide has stated to Wisconsin's Pesticide Advisory
Council that the label revisions would lessen the amount  of
ground water contamination.  However, no data are currently
available to support the position that label  changes alone
will prevent aldicarb from leaching to subsurface water.

Actions Under Consideration by EPA, State and Others

Proposed State Rule

It is the State of Wisconsin's position that  use of aldicarb in
compliance with product labeling, even the 1982 label  changes,
has not yet been shown to prevent the pesticide from leaching
into groundwater.  Even if the labelling changes are successful
in reducing new contamination, any additions  may be unacceptable
when combined with high existing accumlations from former years'
applications.  In areas where significant contamination has al-
ready occurred, localized use moratoriums may be necessary  to
prevent aggravation of existing problems, and to reduce contam-
ination to "acceptable" levels.  Therefore, the Department  of
Agriculture, Trade and Consumer Protection is in the process of
promulgating an amendment to Ch. Ag 29, Wisconsin Administrative
Code, which will place special restrictions on aldicarb use in
the State.  The rule is expected to be in effect for the  1983
growing season.

Central Sands Study

The Central Sands study is being completed by the Wisconsin
Department of Natural Resources and was funded by a 208
Water Quality Management grant.  It will provide further
documentation of the ground water problems in the Central
Sands Area and recommendations for potential  solutions.

EPA Review of Health Advisory Limits

At the request of Union Carbide, EPA Headquarters is currently
reviewing the SNARL (Suggested No Adverse Response Level) for
aldicarb to determine whether this drinking water health  advisory
limit should be changed based on new information.

Other Potential EPA Actions

Other actions which can be taken by EPA at this time are  limited.
If contamination from this source continues to occur at an  un-
acceptable level in spite of new states rules and label changes,
consideration could be given by EPA and the State to withdrawing
registration of the pesticide.  Since the environmental and eco-
nomic consequences of such an action have not been fully  evaluated,
an in-depth study would have to conducted before pesticide  cancella-
tion would occur.

-------
                                   •    i    88  .
 «  Enclosure 1:           •                            .
    -preliminary Draft of:
   Source:   Central  Sands Study, Wisconsin  Department
             of.Natural Resources  '         •
                             •\ '•-"-[ ^~ \ " . t  •  ^ /, Wausau
                   ^    '  "^" J_:---r^:::f^r-    fv'VVisconsin  ^"^-^T^i
                             *.  \':  V •••'-  •'•
                              !   y^x   v
                              I  i •*   i. _«V \      v

                                                      ^                  i'.'
                                                     ""          "
Figure 1. Map of the 10 countio of conTrjl Wnconiin and the appfoximatu boundaries of the Sand Plain (inicrpfttrd
             f»om numerous tour(.c»).

-------
"Enclosure, 2 :• '.'•-•' ~ -
i
Source:
• *
Environmental
"j~. . . •
SI: a cement
- . . . 'restrictions on the /Vise
'.*.'•"• . ' ".
* •
.• • .
.Wisconsin C)epa
:. Protection-.- '
' . *• * • "
rtment of
: i •
. , • '8.9 ';.

or. i-roposccl
o£ .pa stic id
Agriculture
•
. • '••••''•
' i i
rujo rela
30 PPB . • " :
•11 :
.1
0
• 0
• • • o
* .1
- .0
0
0
0
1 • - 4 ; :'..;.. ..
• * f\ »
- ° , -•
'0 ' '
. ,. o - -
.0 ' ' . '.
0-
.
• o • •
i 0 . ' .
0
0 . • • . -
Totals
358
                               295
46
                                   I3

                                  *.-

-------
 Enclosure  3:   ,   "  ;    •':.•-.      AlOOcMfVy    I—
. V Souf-_e: *  Environmental  Statement /  »' '  ^ x *   '*
   on proposed  rule  iclating  t-;               §£)
   special  restrictions  Svira,ar>. of 133 Wisconsin V,:ll Water
  .on the use of      Collected Between August 21 and September  7t  1982.
   Pesticides con-
   taining  aldicarb    '   Aldicarb detections  grouped by ppb  levels.
   Wisconsin Depart-    Repeat samplings shown as up, dovn, or even.
  'ment  of Agriculture           .                                   *
   Trade and Consumer Protection.  ' •                  ''        •
Number of Wells
County
Ad eras
". Barren

Juneau
Langlade
Karathon .
Portage
Vaupaca
Vaushara
Wood
Total
14
' 10
,_, •
5
8
35
34
9
10
- 8
Uew
1
4

1
2
27
22
7
5
5
Repeats
13
'6

•A
' 6
8
• * •
12
2 •
5
3
Number of Welle by
ppb Detect Level
0
11
7
**
5
5
7
21
7
8
8
J-10
2
2

0
2
11
6
2
1
0 .
11-30
1
. 0

0
0
•10
4
0
1
0
^30
0
0

0
1
7
3
0
0
0
Up
2
0
*
0
0
0
V2
1
2
0.
Repeats
Dovn
3
1

0
2
5
6
0
0
0
Even
8
5

4
4
' '3
4
1
3
3
                         133   74
59
"79    27
16    11
17
35

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                                       91
                        REGION V ENVIRONMENTAL MANAGEMENT REPORT
                                   ATTACHMENT B

Great Lakes Water Quality Board
Report to the International Joint Commission
              EXCERPTED FROM:

                            1982 Report on Great Lakes Water Quality
                            November 1982

                            Windsor, Ontario

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                                     92
                                Appendix

                           Areas of Concern


INTRODUCTION

DEFINITION
    An area of concern is  identified when an Agreement objective  or a
jurisdictional standard, criterion, or guideline has been exceeded.


PROCEDURE
    To identify,  evaluate,  and classify each area of concern from a technical
perspective,  all  available  environmental data - fish, sediment, and water  -
are used to provide as complete  a description as possible.   The  1978 Agreement
objectives, along with jurisdictional standards, criteria,  and guidelines,
provide the basis for review  and evaluation of these data.   To the extent
possible, the Board has established the human and environmental  significance
of the observed ecosystem  quality.  The Board has also established a
cause-effect relationship  between observed environmental  conditions and  the
sources of environmental insult.  This leads to a description of  regulatory
and remedial  measures which have been implemented in response to  the degraded
environmental conditions in each area of concern.

    Detailed information about present and proposed remedial programs  is then
evaluated, in order to decide whether environmental problems can  be solved and
beneficial uses restored.


DESCRIPTION OF  CONCERN
    In order to provide as  complete a description and evaluation  of all
potential areas of concern, the  following have been considered to the  extent
necessary and possible:

    1.   Compilation of surveillance and monitoring data  for fish and  other
         biota, sediment,  water  column, and air, in order to develop a
         description of present  and historical conditions.

    2.   Comparison of these  data with Agreement objectives and  jurisdictional
         values in order to establish and substantiate duration  and extent of
         any violations.   Values for sediment and fish are  given  in Tables 6
         and 7, respectively.  Agreement objectives and jurisdictional values
         for water are presented where appropriate in the discussion of
         specific areas below.

    3.   Discussion of potential and observed environmental and  human  health
         effects  and uses  affected.

    4.   Information about  biological community structure,  e.g.  types,
         relative abundance,  and absolute abundance of benthos and fish.
         Consideration of  how the community structure reflects and is  a
         consequence of observed ecosystem quality and anthropogenic inputs.
         Discussion about  the direction in which the community structure might
                                   - 75 -

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                                          93
                                        TABLE 6


                 GUIDELINES  FOR  CLASSIFICATION OF GREAT LAKES SEDIMENTS

                          (Concentrations  in  mg/kg  dry weight)

Volatile Solids
Chemical Oxygen Demand
Total Kjeldahl Nitrogen
Oil and Greese
Lead
Zinc
Mercury
Polychlorinated Biphenyl
Ammonia
Cyanide
Phosphorus
Iron
Nickel
Manganese
Arsenic
Cadmium
Chromium
Barium
Copper
U. S. EPA
NONPOLLUTED
< 50, 000
<40,000
<1,000
<1,000
<40
<90
<1
<1
<75
<0.10
<420
<17,000
<60
<300
<3
-
<25
<20
<25
MODERATELY
POLLUTED
50,000-80,000
40,000-80,000
1,000- 2,000
1,000- 2,000
40- 60
90- 200
-
1- 10
75- 200
0.10- 0.25
420- 650
17,000-25,000
20- 50
300- 500
3- 8
-
25- 75
20- 60
25- 50
HEAVILY
POLLUTED
>80,000
>80,000
>2,000
>2,000
>60
>200
>1
>10
>200
>0.25
>650
>25,000
>50
>500
>8
>6
>75
>60
>50
ONTARIO
M 0 E
60,000
50,000
2,000
1,500
50
100
0.3
0.05
100
0.1
1,000
10,000
25
-
8
1
25
-
25
Discussion of the applicability and limitations  of  these  guidelines  is  found  in the
report of the Dredging Subcommittee,  "Guidelines  and  Register  for Evaluation  of Great
Lakes Dredging Projects",  1982.  The  U.S.  EPA  guidelines  are from the report,
"Guidelines for Pollutional  Classification of  Great Lakes Harbor Sediments".
                                     - 76 -

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                                      TABLE 7
                        MAXIMUM CONTAMINANT LEVELS IN FISH
                       (Concentrations in mg/kg wet weight)
PARAMETER
Aldrin/Dieldrin
DDT and Metabolites
Endrin
Heptachlor/Heptachlor
Epoxide
Lindane
Mi rex
Polychlorinated
Biphenyls
Kepone
Mercury
Toxaphene
2,3,7, 8-TCDD
(Dioxin)
AGREEMENT
OBJECTIVE
(Edible portion)
0.3
l.oa
0.3
0.3
0.3
Substantially
Absent
O.la
-
0.5a
-
-
U.S. FDA
ACTION LEVEL
(Edible portion)'3
0.3
5.0
0.3
0.3
0.3
0.1
5.0
0.3
1.0
5.0
0.00005
CANADA HEALTH
PROTECTION GUIDELINE
(Edible portion)
-
5.0
-
_
-
O.la
2.0a
-
0.5
-
0.00002
a.  Whole fish
b.  Fillet with skin.

-------
         shift,  and why,  as  a  consequence  of changes  in ecosystem quality and
         in loadings.

    5.   Causes  of violations.   Specific point  source dischargers and/or
         nonpoint inputs  (including  land runoff and the atmosphere) are named
         along with the loadings of  substances  for which violations are
         observed.  If a  violation is  the  result, in  whole or in part, of a
         natural  phenomenon, this is noted.

    6.   Remedial or corrective  measures.  Controls presently in place are
         described. These are evaluated to determine their present ability to
         control  the release of  a particular substance, the correctability of
         the problem,  any modifications or additional measures required, and
         the probable  cost.  Observed  and/or projected changes in ecosystem
         quality are described.

    Consideration of the  above information provides a common basis for
selecting and evaluating  areas of concern.  This approach also establishes a
comparable depth and breadth to  the  data base required to substantiate a
concern.


EVALUATION OF  ENVIRONMENTAL INFORMATION
    Through consideration of the above information, the Water Quality Board
prioritized areas of concern into two  classes:

    1.   A Class "A" designation is  assigned to those areas exhibiting
         significant environmental degradation, where impairment of beneficial
         uses is severe.

    2.   A Class "B" desingation is  assigned to those areas exhibiting
         environmental  degradation,  where  uses  may be impaired.

    The Board employed a  set of  guidelines to evaluate, from a technical
perspective, available information for each area of concern, in order to
prioritize that  concern.  The  initial  questions asked were:

    1.   Are one or more  Agreement objectives or jurisdictional values
         violated?

    2.   Are values exceeded for a significant  number of parameters?  Which
         ones?

    3.   For each parameter, is  the  violation persistent over a number of
         repeat  observations?

    4.   How many samples were taken?   Over what period of time and what
         geographic area?

    5.   Is the  value  for each parameter exceeded by  a significant amount?

    6.   How old are the  data?   Are  such data still relevant?
                                   - 78 -

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                                     98
    A positive response to most of these  questions  would  suggest a Class  "A"
or a Class "B" classification.   A negative  response would  suggest that  no
further evaluation is required  at the  present  time.

    To further rank the relative severity of a  problem, additional questions
were considered:

    7.   Is a use impacted?  Which one or ones?

    8.   Is the violation related to current discharges or historic
         accumulation?

    9.   Are there any transboundary  implications?

    If the responses were positive,  then  a  Class  "A"  classification would  be
suggested.

    Through consideration of available technical  information,  and through
application of its professional  judgement to help identify where the most
severe problems exist, the Water Quality  Board  identified  and  reported  on  18
Class "A" and 21  Class "B" areas of concern in  its  1981 report.  These  39
areas of concern  are given in Table 8.


EVALUATION OF  REMEDIAL  PROGRAM   INFORMATION
    In this report, the Water Quality  Board has evaluated  specific information
about present and proposed remedial programs,  in  order  to  decide whether
environmental problems could be solved and  beneficial uses restored.  The
Board considered:

    1.   The nature of the environmental  problem.

    2.   The nature of the remedial programs in place or  planned.

    3.   The schedule to initiate or complete  these programs.

    4.   Factors  which would preclude  timely and  satisfactory  resolution  of
         the problem and restoration of uses,  including costs,  technical
         considerations, and further definition of  the  issue.

    5.   Expected date by which the problems would  be resolved and uses
         restored.

    Based on its  evaluation, the Board reached  one  of the  following
conclusions for each area of concern:

    1.   Remedial measures currently in operation will  resolve the identified
         environmental problems and restore beneficial  uses over the near  term
         (5 to 10 years).

    2.   Remedial measures currently in operation will  not resolve the
         identified problems and restore  uses  over  the  near term:
                                   - 79 -

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                                      97
                                   TABLE 8

                  CLASS  "A" AND CLASS "B" AREAS OF CONCERN
        CLASS "A"                                    CLASS  "B1
                             LAKE SUPERIOR BASIN

None                                         St. Louis River,  Minnesota
                                             Thunder Bay,  Ontario
                                             Nipigon Bay,  Ontario
                                             Jackfish Bay,  Ontario
                                             Peninsula Harbour,  Ontario

                             LAKE MICHIGAN BASIN

Fox River/Southern Green Bay,  Wisconsin      Manistique River, Michigan
Milwaukee Estuary, Wisconsin                 Menominee River,  Michigan-Wisconsin
Waukegan Harbor, Illinois                    Sheboygan, Wisconsin
Grand Calumet River and                      Muskegon, Michigan
  Indiana Harbor Canal, Indiana              White  Lake, Montague,  Michigan

                              LAKE HURON BASIN

St. Marys River, Michigan and Ontario        Spanish River Mouth,  Ontario
Saginaw River System and                     Penetang Bay  to Sturgeon Bay, Ontario
  Saginaw Bay, Michigan                      Collingwood,  Ontario

                               LAKE ERIE BASIN

St. Clair River, Ontario and Michigan        Clinton River,  Michigan
Detroit River, Michigan and Ontario          Wheatley Harbour, Ontario
Rouge River, Michigan
Raisin River, Michigan
Maumee River, Ohio
Black River, Ohio
Cuyahoga River (Cleveland), Ohio
Ashtabula River, Ohio

                             LAKE ONTARIO BASIN

Buffalo River, New York                      Eighteen Mile Creek,  New York
Niagara River, New York and Ontario          Rochester Embayment,  New York
Hamilton Harbour, Ontario                    Oswego River,  New York
                                             Toronto Waterfront, Ontario
                                             Port Hope, Ontario
                                             Bay of Quinte,  Ontario

                             ST. LAWRENCE RIVER

Cornwall, Ontario-Massena,  New York          None
                                - 80 -

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                                   1     98


         A.   However,  additional  programs and  measures  have  been  imposed,  and
              these will  be adequate  and timely.

         B.   Additional  programs  and measures  have  been imposed,  and
              environmental problems  will  eventually be  resolved and uses
              restored.   However,  there is a  long  lag time  between completion
              and operation of the remedial measures and the  response of the
              environmental system.

         C.   Even though all  reasonable remedial  measures  have  been or are
              being taken,  it  is doubtful  whether  the environmental  problems
              will be completely resolved and uses restored.

         D.   There are  apparently no firm programs  additionally planned that
              will resolve problems  and restore uses.

    3.   Insufficient information  has been received  or is available in order
         to make a reasonable  judgement as to whether control  measures are
         adequate, or to decide when  such measures may be required.

    Presented below is information describing the  environmental  quality,
discharges, and remedial  measures  for each Class  "A" area of  concern.  This
information has been updated and expanded from the material presented in
Appendix II of the Board's 1981 report.  Also presented  below is the Board's
evaluation of present and proposed remedial  programs, and conclusions about
whether and when environmental problems will  be solved and  beneficial uses
restored.

    The sources of information are given also below for each  area of concern;
the reader is referred to these for additional  details.   In general, the fish
data for U.S. areas of concern were obtained  from  records compiled by EPA's
Great Lakes National Program Office in Chicago. The sediment data for these
areas were drawn primarily from reports prepared  by the U.S.  Army Corps of
Engineers or by EPA; these reports are available  through EPA's Great Lakes
National Program Office.  The  U.S. water data are  from STORET.  The summaries
of environmental data for Canadian areas of concern were provided by the
Ontario Ministry of the Environment,  Toronto.  In  addition, several
jurisdictions have published special  reports  describing aspects  of these areas
in detail.

    Information about Class "B" areas of concern  is given in the Board's 1981
report.  The Board has also compiled available information about other areas
in the Great Lakes; this information is maintained at the Commission's Great
Lakes Regional Office.  These  other areas are also being kept under close
scrutiny and, where appropriate, the Board encourages the development of
information to establish the nature and extent of  uses impacted by discharges
or by conditions existing within these areas.
                                    - 81 -

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                                       99
FOX  RIVER  AND  SOUTHERN GREEN BAY, WISCONSIN

ENVIRONMENTAL  DATA
SEDIMENT

    The sediments of the lower Fox River and  the  navigation channel  leading
out into Green Bay were examined in  an intensive  1977  survey. , Sediments  in
the river were grossly polluted, with high  concentrations  of  volatile  solids,
chemical oxygen demand, total  Kjeldahl nitrogen,  oil and grease, mercury,
phosphorus,  lead, zinc, and ammonia.   The  sediments were also contaminated
with PCB in  excess of 10 mg/kg.  Pollutant  levels in sediments decrease away
from the river mouth; at the end of  the navigation  channel, about  16 km from
the river mouth,  sediments are classified  as  unpolluted.

    In the 1980 and 1981 sampling of  sediments  in the  lower Fox River, all
samples continued to show elevated levels  of  PCB  -  in  the  4 to 6 mg/kg range -
but down substantially from the greater than  10 mg/kg  levels  in 1977.  The
highest value was found at Highway 29 bridge  in the city of Green  Bay, 2.9 km
above the river's mouth.  DDT was also found  at this location in the sediments
and at another site closer to the bay itself.

FISH

    Fish collected both upstream and  at the mouth of the Fox  River in  1978 and
1979 were analyzed for more than 20 metals  and  organic  substances.   Levels of
PCB routinely exceed the U.S.  FDA action level  of 5.0  mg/kg;  the maximum
reported level is 90 mg/kg.  DDT and  mercury  levels were below the FDA action
level.  Traces of pentachlorobenzene, a-BHC,  HCB, nonachlor,  pyridine
carboxamide, tri-, tetra-, and pentachlorophenol, copper,  and chromium have
been reported.

    PCB levels exceed the 5.0 mg/kg FDA action  level in 18 of 30 fish  samples
collected from other tributaries to Green  Bay:  Duck Creek, Little Suamico
River, Oconto River, Peshtigo River,  Pensaukee  River,  Big  Suamico  River,  and
Red River.  Subsequent sediment sampling,  however,  showed  no  detectable
sources of PCB on these tributaries.   Investigations also  showed that  the fish
had migrated into the streams from the bay.

    Fish sampling in 1980 in the 11.7 km sector below  the  DePere Dam found 8
of the 9 samples  exceeding the PCB action  level.   PCB  levels  decreased above
the dam with only one sample exceeding the  action limit.   In  1981,  9 of the 11
fish samples on the lower Fox River exceeded  the  PCB action level.

WATER

    Five automatic monitoring stations are  located  in  the  64.4 km  (40.0 miles)
stretch of the lower Fox River between the  outlet of Lake  Winnebago and the
stream's mouth at Green Bay.   These  stations  have been  operational  since
1971.  They  are polled hourly by computers  providing electronically sensed
data on four or five parameters including  dissolved oxygen, pH, temperature,
and specific conductivity.  The data  are stored directly in the computer  for
later statistical comparison  and/or printed out on  the  teletype.   Stations can
be contacted manually at other times.


                                   - 82 -

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                                     jOO
    Additionally, since 1959 a monitoring station has  been  maintained near the
mouth in the DePere-Green Bay section where samples are collected  monthly for
a broader range of chemical  testing.   Fish, sediment,  and biological  sampling
is done routinely at the station too, but at less frequent  intervals.

    There is a series of dams in the  lower Fox River but negligible  storage
capacity below Lake Winnebago.  Tributary inflow to the Fox River  in  this
section is of little significance.  A stream flow gauging station  is  located
at Rapid Croche Dam, near the mid-point of the lower Fox River section,  and
its flow is considered applicable throughout the stream sector.  For  84  years
of stream flow records through the 1980 water year, the average  flow  was 117
cubic metres per second (4,163 cubic  feet per -second)  and the  most recent
determination of Q; 10 (minimum 7 days flow in 10 years) is 27 m-Vs  (950
ft3/s).

    Generally the worst stream conditions at the automatic  monitoring stations
have been found at Rapid Croche Dam.   For comparison,  data  at  that station for
the month of August are shown for 1972, 1980, and 1981.  The base  year,  1972,
was chosen because there was little advanced wastewater treatment  along  the
Fox River at that time and flow and temperatures were similar  to those in
1981.
                   RAPID  CROCHE DAM  - AUGUST MONITORING DATA
     Daily Ave. D.O. (mg/L)
     Daily Ave. D.O. (mg/L)
     Monthly D.O. (mg/L)
     Monthly Temp. (°F)
     Monthly pH
     Monthly Flow (ft3/s)
Max.
Min.
Ave.
Ave.
Ave.
Ave.
Min. Daily Fow (ftj/s)
 1972
 "2T4T
 0.00
 0.74
76.2
 7.82
2,334
1,335
 1980
 "OS
 6.63
 7.73
75.0
 9.10
3,804
1,598
 1981
 "97815
 4.43
 7.74
76.5
 8.50
2,046
1,556
         Change
980 to TSS1   1972 to l9~8T
    T7I2     "
   -2.20
    0.01
    1.5
   -0.6
 -1,758
    -42
7.34
4.43
7.00
0.3
0.68
-283
 221
    Total phosphorus analysis was conducted on the monthly samples  collected in
the Green Bay-DePere area.  For calendar years 1972,  1980, and 1981  the respective
total phosphorus averages were 0.20,  0.19,  and 0.14 mg/L.

    Ammonia can be detrimental to water quality in different ways.   In its
decomposition and stabilization, each part  of ammonia requires 4.44 parts of
oxygen for conversion to the end products of nitrates and  water and,  in so
doing, can remove sizeable amounts of the water's dissolved oxygen.   This
stabilization of the nitrogeneous materials does not start to take  place until
most of the carbonaceous material is  oxidized.  Extensive  mathematical
modelling of the lower Fox River from the outlet of Lake Winnebago  to the
DePere Dam - 64.4 km to 11.7 km from  the mouth - does not  show that a
significant problem exists or is likely.  Studies of the downstream portion
from the DePere Dam and in southern Green Bay are continuing.

    Ammonia is toxic at fairly low levels.   As the pH increase, the
ammonium/ammonia equilibrium is shifted further toward higher concentrations
of the latter.  Algal activity can contribute to pH increases.  Although no
toxic problems have been observed, it is believed there is a potential for
such near the mouth of the Fox River  and for some distance out into Green Bay.

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                                    oi
    Nitrogen and phosphorus are considered as key nutrients  in  the
eutrophication of a body of water.  Nitrogen as ammonium,  ammonia, and
nitrates is directly utilizable by aquatic plants and algae,  and  eutrophic
growths can result.  Both Lake Winnebago and southern Green  Bay have historic
eutrophication problems, and the additional  impacts from industrial  and
municipal discharges have not been determined with any certainty.

    Significant sources of ammonium discharges occur in the  Lower Fox River.
Monthly average effluent concentrations of ammonium from municipal
installations are about 15 mg/L at Appleton, 10 to 15 mg/L at Heart of the
Valley, and 35 to 55 mg/L at Green Bay.  Levels of 10 to 30  mg/L  at Ford
Howard Paper, Green Bay; 3 to 200 mg/L at Nicolet Paper, DePere;  and 5 to 40
mg/L at Consolidated Papers, Appleton make up the list of significant
industrial  discharges of ammonia to the Fox  River.


CAUSES AND REMEDIAL MEASURES
    The lower Fox River has the largest concentration of pulp and paper
facilities  in the Great Lakes Basin.   Sixteen mills discharge treated wastes
directly to the Fox River while five  other mills route all of their
wastewaters to local municipalities for treatment and subsequent  discharge  to
the same stream.  Over the past decade, the  industry has made significant
reductions  in their discharge of suspended solids and BOD as noted in the 1981
report of the Pulp and Paper Task Force to the Water Quality Board.

    Municipal discharges are the second most significant source of pollutants
on the lower Fox River.  Besides handling all domestic wastes from their
jurisdictions, the seven major municipal treatment systems treat the total
wastewater loads from 5 pulp and paper mills (some of the waste streams from
other mills provide their own treatment), and essentially all wastes from
other wet industries such as those involved in meat, milk, and  vegetable
processing.  All these municipalities provide phosphorus removal  and, with  the
exception of Appleton, which was under construction, were meeting the 1.0 mg/L
phosphorus  discharge requirement.  The 1981  average total  phosphorus discharge
for Appleton was 1.4 mg/L.  The flow-weighted average for the other 6
dischargers was 0.55 mg/L.

    A study to determine the phosphorus budget and dynamics  for Green Bay,  its
relation to phytoplankton growth, and how the phytoplankton  affects the oxygen
resources versus the effects from organic loading is underway by investigators
at Michigan Technological University, Houghton, Michigan.

    Dischargers must meet permit requirements and are required  to provide
detailed records of treatment plant performance.  For the 16 pulp and paper
mills, this means a daily record of treatment plant performance and stream
loadings.  The mills have increased production by about 50%  in  the past 10
years.  The population served by the  municipal treatment plants has at least
equalled the 7% county-wide gain shown in the 1970 and 1980  censuses and
totals an estimated 240,000 to 250,000 people.  The Wisconsin Department of
Natural Resources'  Lake Michigan District Office, Green Bay, has a team of
experienced professionals on operation and maintenance to ensure that
treatment plant performance continues at a high level.
                                     -  84  -

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                                    102   *


                       LOWER FOX RIVER POLLUTIONAL  LOADINGS
                                (Kilograms per day)

                                                        _ Percent  Chang
                          1972       1980       1981      1980  to  T98f   1972
Pulp and Paper
    BOD                 122,420     15,300     13,782           -9.9        -88.7
    Suspended Solids     97,500     16,775     15,223           -9.3        -84.4

Municipal
    BOD                  17,547      6,275   ~ -  5,436          -13.4        -69.0
    Suspended Solids     17,376      6,041      4,857          -19.6        -72.0

Combined
    BOD                 139,967     21,575     19,218          -10.9        -86.3
    Suspended Solids    114,876     22,816     20,080          -12.0        -82.5

    The 1981 records show that Consolidated Papers  at  Appleton and Appleton
Papers discharged average phosphorus concentrations of 3.8 and 1.1  mg/L
respectively.  These are above the Agreement goal  of 1.0 mg/L.,  Phosphorus in
these cases may be from excesses used in the wastewater treatment  process.

    Three of the pulp and paper mills on the lower  Fox River recycle  paper
that may contain PCBs:   Wisconsin Tissue,  Bergstrom Paper Company,  and Fort
Howard Paper Company.  High removal  of PCB with the treatment plant sludges is
likely, although an effluent sample  from the Fort Howard mill  was  found  to
contain 4.0 ug/L.  Paper recycling operations are  specifically exempted  by
state law from restrictions on the use of  PCB-containing materials.

    The Wisconsin Department of Natural  Resources  has  established  the total
maximum daily loadings  of BOD which  can be assimilated in the Fox  River  above
the DePere Dam and still maintain state water quality  standards for fish
protection.  These allowable loadings have been established for varying
conditions of river flow and temperature in three  separate reaches of the
river.  This assimilative capacity has been allocated, through the permit
process, to the various dischargers  in each reach.   The allocation for each
individual discharger is proportional to the quantity  of BOD which would be
allowed under the categorical effluent standards program.

    Wasteload allocations will be in effect on July 1, 1983' for most  of  the
lower Fox River and are under development  for the  point sources in the
DePere-Green Bay sector.  Waste load allocations,  including ammonia
restrictions, for the entire lower Fox River will  become effective January 1,
1985.  Facilities for treating BOD and suspended solids are essentially  in
full operation now.  The use of highly efficient wastewater treatment
technology has resulted in current discharges from  the pulp and paper mills to
be less than one-half the quantity permitted under  the categorical  treatment
standards.  (The combined permit averages  for BOD  and  suspended solids  -
35,646 and 51,113 kg/d, respectively - compares to  the 13,782 and  15,223 kg/d
actually discharged by  the pulp and paper  mills in  this stream section.)
Further reductions called for by waste load allocations are expected  to  be
achieved by reduced production and waste storage.   It  also appears that
substantial ammonia reductions could be attained by changing industrial
production methods.  This will likely be explored  in lieu of treatment.

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    Ammonia concentrations  in the effluents from facilities at Heart of the
 Valley and Appleton are probably in line with what would be expected for the
 type of  treatment and a municipal waste.  The Consolidated and the Fort Howard
 plants both have biological type treatment units which require nutrient
 additions, including ammonia.  High ammonium readings at Nicolet Paper are
 from problems  associated with an ammonia-based coating process.  The Green Bay
 Metro Plant receives high strength ammonium wastes from the Proctor and Gamble
 ammonium bisulfite  pulping operations at their Fox River Mill; and from the
 use of ammonia to neutralize wastes at the James River Paper Mill, formerly
 American Can Company.

    Consolidated Papers at Appleton will permanently discontinue operations by
 October  1, 1982.  Nicolet Paper's recent discharge permit gives them until
 July 1,  1984 to correct their ammonia problem.  Fort Howard Paper and the
 Green Bay metropolitan facility are in the DePere-Green Bay section of the
 lower Fox River which is under study and mathematical modelling.  This section
 is  tentatively scheduled to be subject to waste load allocations, including
 temperature/flow/ammonia requirements, if necessary, by January 1, 1985.

    Emphasis is also being  given to control of toxic materials released by the
 pulp and paper making processes.  As part of their reapplication for reissued
 WPDES permits, individual mills were required to analyze their effluents for
 the U.S. EPA list of priority pollutants.  They were also asked to assess
 their pulp and papermaking  processes to determine the potential sources of
 toxic contaminants in the wastewater.  Permit applications and other
 information sources were reviewed for deleterious concentrations of toxic
 pollutants.  Although specific limitations on toxic pollutants were not placed
 in  permits (ammonia limitations were, however, included in some cases), some
 mills are required to conduct additional monitoring, including bioassays, to
 more clearly define the presence of toxic substances in their effluents.  In
 addition, the Wisconsin Department of Natural Resources is initiating a trend
 monitoring program for selected toxic substances and a PCB "hot-spot"
 identification study on the river.  Inventory studies (e.g. Sullivan and
 Delfino's 1982 report, "A Select Inventory of Chemicals Used in Wisconsin's
 Lower Fox River Basin") are helpful in designing such monitoring programs.

ASSESSMENT

    A big improvement has been made in the water quality of the lower Fox
 River in the past 10 years, and all waste discharges are now essentially in
 compliance with their permit requirements.  When the waste!oad allocations are
 in  effect for  the DePere-Green Bay dischargers, tentatively scheduled for
 January  1, 1985, water quality standards should consistently be met with
 respect  to dissolved oxygen and suspended solids.  Reduced production and
 waste storage, rather than  treatment are expected to be the principal ways in
 meeting  waste load allocations during periods of low stream flows and high
 temperatures.

    Wisconsin has prohibited the use of dieldrin and DDT and the manufacture
 and most uses of PCB.  Point sources of these can be eliminated as they are
 identified but diffuse sources will persist in the environment for some time.
 The Wisconsin Department of Natural Resources is continuing an active program
 for the  identification and control of toxic substances.
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                                   |04
INFORMATION SOURCES
    For specific information regarding the lower Fox River and  Southern  Green
Bay, please refer to the following reports:

    1.   Sullivan, J.R. and Delfino,  J.J., "A Select Inventory  of  Chemicals
         Used in Wisconsin's Lower Fox River Basin."  University of Wisconsin
         Sea Grant Institute  WIS-SG-82-238, March 1982,  Madison,  WI.

    2.   Christiansen, R., "Wisconsin's Approach to Developing  Waste Load
         Allocations", J. Water Poll. Contr. Fed., Vol.  51,  No. 3,  March 1979,
         pp. 630-635.

    3.   "Waste Load Allocated Water Quality Related Effluent Limitations."
         Wisconsin Department of Natural Resources Regulations, Chapter  NR212,
         Wisconsin Administrative Code, Register, No.  309, September 1981.

    Additional specific information about the lower Fox  River and  southern
Green Bay can be obtained from the files and reports of  the Wisconsin
Department of Natural Resources, P.O. Box 7921,  Madison,  Wisconsin  53707.

    Five stations on the lower Fox River are automatically polled  hourly for
temperature, dissolved oxygen, pH, and conductance.  This information is
routinely summarized on a monthly basis for averages,  maxima, and  minima, as
well as stream flow.  The data may also be displayed graphically  by day, week,
month, or year.  Contact:  Bruce Fenske, Water Quality Evaluation  Section.

    The ambient monitoring station in the DePere-Green Bay section of the
lower Fox River is part of the statewide monitoring network and is sampled
monthly for chemical parameters and about annually for fish and benthos.  The
network has been operational since 1961 and data collected have been published
through 1980.  Contact:  Carol Tiegs, Water Quality Evaluation  Section.

    Mathematical modelling of the lower Fox River is under the  immediate
direction of Dale Patterson, Water Quality Evaluation Section.  He and Mike
Llewelyn, Water Quality Planning, with staff assistance  from the  Municipal  and
Industrial Wastewater Sections, generally guide wasteload allocations.

    Additional general information about both the lower Fox River and southern
Green Bay and the Milwaukee Estuary can also be obtained from the  Wisconsin
Department of Natural Resources.

    Municipal and industrial loading information was obtained from monthly
discharge monitoring reports submitted by the industries and the
municipalities.  The loadings are usually based on the arithmetic  average of
daily counts.  An annual summary of pulp and paper mill  discharges is made,
showing the daily averages by month and year, together with the average
discharges called for in the WPDES discharge permit.  Contacts:  Paul Didier,
Chief, Industrial Wastewater Section, and Chuck Ledin, Municipal  Wastewater
Section.

    Information about toxic substances  in fish was extracted from the annual
reports of the Coastal Zone Project.  A bibliography of toxic substances
reports published by the Wisconsin Department of Natural Resources has  also
been  prepared.  Contact:  Tom Sheffy.

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    The Department's Bureau of Water Quality  Management  has prepared a  list of
major research, survey,  and investigative activities  for the  period July  1,
1980 through June 30, 1982.  A bibliography of water  quality  reports published
by the Department has also been prepared.  Contact:   F.H. Schraufnagel.

    The U.S. Geological  Survey prepares an annual  report showing  daily  average
stream flows at principal  gauging stations, with  physical and chemical  data
also collected for streams and rivers in Wisconsin.


MILWAUKEE ESTUARY,  WISCONSIN

ENVIRONMENTAL DATA

SEDIMENT

    Surveys conducted in 1973 and in 1980 reveal  that the sediments in
Milwaukee Harbor are heavily polluted,  according  to EPA's "Guidelines".   The
sediments contain high  levels of oil and grease,  chemical oxygen  demand,  total
Kjeldahl nitrogen, total phosphorus, lead, zinc,  cadmium, and copper.   The
1980 surveys also showed portions of the estuary  to have PCB  levels in  excess
of 50 mg/kg.

    Further 1980 and 1981  sampling was  reported in the October  1981
Departmental publication to Coastal  Zone Management on the Toxic  Substances
Survey project.  This report indicated  that sediment  contamination in  the
Milwaukee River can be  divided into 3 reaches.  The first, between the  mouth
and Hampton Avenue, shows  an average PCB sediment level  of 9.60 mg/kg.  The
second, from Silver Spring Drive to County Highway C  below Grafton, shows an
average PCB level of 0.28  mg/kg.  A sediment  sample from Cedar  Creek,  which
flows into the Milwaukee River below County C,  showed a  PCB level of 0.73
mg/kg below the Cedarburg  sewage treatment plant.   In the third reach,  above
Grafton, PCB levels were below detection limits.

    Detectable levels of DDT (0.19 mg/kg average)  were confined to the reach
from the mouth to Silver Spring Drive.   Four  sediment samples from the  Woolen
Mills impoundment at West  Bend shows this area to  be  a low-level  source of
PCB, DDT, and chlordane.  Average values for  these residues were  0.28,  0.13,
and 0.04 mg/kg, respectively.  Dieldrin was not detected in any sample.

    The other two rivers draining the Milwaukee metropolitan  basin also
displayed measurable amounts of sediment contamination.   PCB  was  identified in
the Menomonee River sediment from Highway 100 downstream to its mouth.  Three
samples were taken in the  Kinnickinnic  River  between  Kinnickinnic Avenue  and
Jackson Park; elevated  levels of PCB were found in all three  with the  highest
nearest the mouth.  Chlordane (0.02 mg/kg) was found  at  Kinnickinnic Avenue.

FISH

    Fish collected in 1978 and 1979 surveys by the Wisconsin  Department of
Natural Resources were  found to be heavily contaminated  with  PCB; the  maximum
observed level is 88 mg/kg; the FDA action level  is 5.0  mg/kg.  DDT in some
fish exceeds the Agreement objective of 1.0 mg/kg; the maximum  observed level
is 2.98 mg/kg.  Also present in the fish at trace  levels or present but not
quantified are hexachlorobenzene, a- and y-BHC, cis-  and trans-chlordane,
dieldrin, trans-nonachlor, mercury,  copper, and chromium.

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                                106
    The 1981 Toxic Substances Survey report showed that  all  11  fish  samples
from the three rivers in 1980 exceeded the PCB action  level,  with a  range  of
8.6 to 88.0 mg/kg.  One sample from the Kinnickinnic  River exceeded  the
chlordane action level.  The 1981 extensive sampling  of  the Milwaukee River
fish revealed a PCB problem area extending from the mouth upstream to
Grafton.  Fifteen of the 23 samples in this area exceeded the PCB action  level
with a range of 5 to 49 mg/kg.  Fish from the  Kinnickinnic River in  1981
continued to show PCB values above acceptable  levels.

WATER

    Water samples collected in 1976 from Milwaukee Harbor exceed the Agreement
objectives for conductivity, ammonia, zinc, cadmium,  mercury, lead,  and
copper.  Note:  Little new water quality data  are available for the  Milwaukee
Harbor at this time.  The current harbor/estuary study is generating
considerable data, but it is mainly for design purposes, has not been
adequately analyzed to date, and toxics coverage probably is minimal.

    PCB (1.0 pg/L) was detected in the final  effluent to the Milwaukee River
at the Saukville sewage treatment plant.  Dieldrin (0.1  ng/L) and DDT (0.89
ug/L) were detected in the Butler storm sewer discharge  to the Menomonee  River
at 124th Street and Villard Avenue.  More intensive sampling is required  to
determine the exact sources of these microcontaminants.

    Dieldrin and DDT were also detected in the leachate  from the Woolen Mills
landfill at West Bend.  Two samples were taken, one of which showed  dieldrin
(0.07 ug/L) and both of which showed DDT (0.73 pg/L average).
    The Milwaukee Health Department has found that bacterial  counts increase
at area beaches as a result of combined sewer overflows after heavy rainfall.
Beaches are therefore subject to a two-day closure, as a precautionary
measure, whenever rainfall exceed 0.60 inches.  In 1981, South Shore Park was
closed 3 times for a total of 7 days, out of a 68-day swimming season.

CAUSES AND REMEDIAL  MEASURES

    The Milwaukee Estuary is heavily developed and highly industrialized.
However, the current water quality problems are primarily related to combined
sewer overflows and in-place pollutants.  The combined sewer effluents contain
significant amounts of heavy metals in addition to the normal oxygen -demanding
materials, oil, and nutrients.  In June 1981, the Milwaukee Metropolitan
Sewerage District obtained approval of a comprehensive Master Facilities Plan
for upgrading its facilities to meet federal and state clean water laws.  The
Milwaukee Water Pollution Abatement Program is estimated to cost 21.6 billion
in 1982 dollars.  Over 2300 million in work has already been completed or is
under contract.  Following are the court-ordered deadlines for completing the
initial plan elements:

    1.   July 1, 1982 for meeting treatment standards during dry weather
         periods.

    2.   July 1, 1983 for completion of relief sewers.
                                     -  89  -

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                                     107  •


    3.   July 1, 1986 for elimination of wet-weather bypassing in the
         separated sewer area.

    4.   July 1, 1993 for correction of the combined sewer overflow problem,
         if sufficient grant funds are available.  If they are not, minimum
         expenditures of 213 million (in 1976 dollars) per year until the
         combined sewer overflow project is completed.

    The current treatment facilities have highly efficient phosphorus removal
 systems and consistently meet secondary treatment requirements during dry
 weather periods.  The Milwaukee Metropolitan Sewerage District is presently
 developing a pretreatment control program to help reduce the industrial  impact
 on  sludge and on treatment plant effluent quality.

    A pretreatment standard for cadmium has been enacted by the Sewerage
 District.  As a result, pretreatment installed by one industry has reduced the
 cadmium content of Milwaukee's sludge product, Milorgam'te, to one-half of
 previous levels.  Standards have been developed, and are undergoing public
 review for zinc, nickel, copper, and lead.

    The primary rationale for these pretreatment standards is to reduce  the
 metals content in sludge and thus extend the site life for land applications.
 An  additional advantage of pretreatment is the removal of toxic and gross
 pollutants that would otherwise discharge to surface waters during periods of
 combined sewer overflows.  In accordance with Milwaukee's WPDES permit,  the
 Sanitary District must have an approved pretreatment program by July 1,  1983.

    Due to high levels of PCB found in fish native to the estuary and its
 tributaries, U.S. EPA conducted a special sediment survey in 1980.  The
 results showed that, overall, the contamination level in the inner harbor area
 was lower than expected.  Investigations under the Toxic Substances Control
 Act were conducted by U.S. EPA to identify the potential sources of the PCB
 "hot spots".

    The Milwaukee Metropolitan Sewerage Commission is conducting a
 comprehensive study of the harbor/estuary to establish the level of pollution
 abatement needed for the combined sewer overflows.  The study completion date
 is  scheduled for December 1984.  Pollution abatement for the combined sewer
 overflows is anticipated to rely on conveyance and storage facilities to
 intercept flows that would otherwise spill and store these flows until
 capacity is available at the treatment plants.  The results of the study will
 determine the amount of storage volume needed.  Additional planning efforts
 will then determine costs.  These costs, in addition to the provisions  of the
 court order Milwaukee is under, will determine 'the length of time required to
 complete the abatement works.  While the study is being conducted, overflows
 from the separated sewer area and treatment plant deficiencies are being
 corrected.

ASSESSMENT

    Some of the contaminants in the Milwaukee Harbor and lower parts of the
 Milwaukee, Kinnickinnic, and Menomonee Rivers are also found upstream.
 Indications are that diffuse sources or discontinued operations are or  were
 involved.   Wisconsin banned the use of dieldrin and DDT in the late 1960's
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                                  1 08

 and, effective July 1, 1977, with some exemptions,  prohibited the  manufacture
 and purchase for use of substances containing PCB.   Although the Wisconsin
 Department of Natural Resources continues to seek upstream sources to
 eliminate, these contaminants could persist in the  aquatic environment for
 some time.

    Also, with the correction of sewage overflows and treatment plant
 deficiencies, the Milwaukee Estuary problem will  continue as a major pollution
 problem until the combined sewer overflows in the metropolitan area can be
 addressed.  Complying with the court ordered clean-up of the combined sewer
 overflows and possibly the implementation of measures to mitigate  the in-place
 pollutants, should eliminate the area of concern.  This is a costly
 undertaking, and completing installation of the facilities in a reasonable
 amount of time, 10 to 12 years, will  rely on funding at the level  of 220
 million (1982 dollars) per year in local funds and  220 million (1982 dollars)
 per year in state aid from the newly created Combined Sewer Overflow Fund.

    The schedule to resolve the environmental problems should be nearly
 identical to the schedule to place the controls into operation, although some
 lag might be expected, depending on the specific  problem involved.  It should
 be noted that, although the final date for the combined sewer overflow problem
 correction is July 1, 1993, work is proceeding and the problem is  not 100
 percent uncorrected until that time.

INFORMATION SOURCES

    For specific information regarding the Milwaukee Estuary, please refer to
 the report, "Study Design for the Milwaukee Harbor Estuary Comprehensive Water
 Resources Planning Program," prepared by the Southeastern Wisconsin Regional
 Planning Commission (SEWRPC) in September 1981.

    The interests of the state of Wisconsin and its Department of Natural
 Resources, insofar as the court stipulation, agreements, and follow-up on
 progress is concerned, are handled by Jay Hochmuth, Special Assistant for
 Milwaukee Metropolitan Environmental  Affairs.

    General information sources are given at the end of the presentation for
 the lower Fox River and southern Green Bay.

WAUKEGAN  HARBOR,  ILLINOIS

ENVIRONMENTAL DATA

    Data obtained by U.S. EPA since October 1978 were subject to a protective
 order issued by the court at the request of Outboard Marine Corporation.  The
 order was lifted in mid-June 1981.  These data are now available from
 U.S. EPA, Region V, Chicago.

 SEDIMENT

    The sediments in Waukegan Harbor and the nearby North Ditch, a tributary
 to Lake Michigan, are grossly contaminated with PCB.  Levels up to 500,000 and
 380,000 mg/kg have been found in Slip No. 3 in the harbor and in North Ditch,
 respectively.


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                                      09
FISH

    PCB contaminant levels (whole fish) for samples of fish collected in the
harbor over a four year period are listed below:
Date of Collection
Number
of Samples
Average Coneentration
   of Total  PCB in
in Whole Fish (mg/kg)
   Number of Samples
   Exceeding 5 mg/kg
  U.S.  FDA Action Level
for Edible Portion of Fish
August 1978
May and July 1979
September 1980
July 1981
   9
   9
   7
   4
       18.9
       29.7
       77.4
        8.2
            6
            8
            5
            1
    A 1980 study demonstrated that uncontaminated fish exposed to  water from
Slip No. 3 for thirty days achieved PCB levels of 20 mg/kg.   After an 84-day
reacclimation period in open-lake water, the PCB levels did  not drop below 8
mg/kg.  The U.S. FDA action level for PCB in fish is 5.0 mg/kg.

WATER

    PCB levels in water in Waukegan Harbor range from 0.1 ng/L to  several  ug/L
in Slip No. 3.
CAUSES AND REMEDIAL  MEASURES

    The Outboard Marine Corporation (OMC) has an aluminum die-casting facility
located between Waukegan Harbor and the North Ditch,  a tributary to Lake
Michigan.  The facility had purchased 8.4 million pounds of PCB as hydraulic
fluids from Monsanto Company between 1959 and 1972,  and it is estimated that
an additional 1.5 million pounds were purchased between 1954 and 1959.   OMC
has estimated that as much as 15 to 20^ (1.5 to 2.0  million pounds) of  these
PCB may have been released to the environment.   A U.S. EPA consultant
estimated in a 1981 report that about 350,000 pounds  of PCB remain in the
harbor sediments and about 500,000 pounds remain the  North Ditch sediments.

    Initial  actions taken in 1976 by the U.S. EPA and the Illinois EPA  were
successful in substantially reducing the PCB load from the facility's
discharges.   However, the residual PCB contamination  of sediments and soils in
the harbor,  North Ditch, and the facility's property  continue to impact the
surrounding area.
    The U.S. EPA and the Illinois EPA
against Monsanto in 1980 for a remedy
scheduled for December 1982.
               filed suit against OMC in 1978 and
               to the PCB contamination.  Trial  is
                                       now
    Substantial engineering work on alternative mitigative measures has been
done by U.S. EPA in support of the lawsuit as well  as for potential government
clean up under the Comprehensive Environmental  Response, Compensation and
Liability Act (Superfund).
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                                119
    The warning signs against  consumption of fish caught in the harbor posted
by the Lake County Health Department  in 1980 remain in place.

    The U.S. Army Corps of Engineers  has a study underway to identify a
suitable disposal site for sediments  to be dredged from the federally
maintained portions of the harbor.  In the meantime, dredging  is only being
conducted outside of the breakwaters  in the entrance channel where accumulated
material is uncontaminated,  being  primarily littoral drift sand from Lake
Michigan.

    U.S. EPA, which has been pursuing remedies through the lawsuit as well  as
Superfund, has now decided to  concentrate on the lawsuit.  Consequently,  on
May 7, 1982, U.S. EPA withdrew its  application to the U.S. Army Corps of
Engineers, Chicago District, for the  dredge and fill permit under the
provision of Section 404 of the Clean Water Act of 1977.  The  Corps
acknowledged the withdrawal  of the  application and advised the Illinois EPA.
This action by U.S. EPA obviates the  need of the Illinois EPA to continue work
on the water quality certification, required by Section 401 of the Clean Water
Act; lacking an active application, no certification is necessary.

    The Illinois EPA also has  received an application for a permit to
construct retaining lagoons  and filter systems to receive the dredged
material.  A review had been completed and comments addressed to U.S. EPA on
the facilities.  At present the application lies dormant, since the Section
404 dredge and fill permit application was withdrawn.

ASSESSMENT

    Since resolution of this environmental problem is the subject of extensive
litigation involving several parties, remedial controls and reclamation
programs have not been specified as of this date.  Therefore,  assessment of
their adequacy is impossible.

INFORMATION SOURCES

    Information about environmental conditions in Waukegan Harbor and about
the status of remedial programs may be obtained from:

         Great Lakes National  Program Office
         U.S. Environmental  Protection Agency
         536 South Clark Street
         Chicago, Illinois  60605

         Illinois Environmental Protection Agency
         2200 Churchill Road
         Springfield, Illinois 62706

GRAND CALUMET  RIVER  AND INDIANA HARBOR  CANAL   INDIANA

ENVIRONMENTAL  DATA  -  RIVER AND  CANAL

SEDIMENT

    Sediment  surveys conducted from 1977  to  1980 confirm  that  all  sediments  in


                                   - 93 -

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                                  111
 Indiana Harbor Canal and the Grand Calumet River are heavily polluted for all
 conventional pollutants and heavy metals, and have high levels of organic
 chemicals associated with heavy industry.  The concentrations of pollutants
 are among the highest reported in the Great Lakes System.   Maximum observed
 concentrations for representative substances are:  oil and grease 175,000
 mg/kg  (17.51%), volatile solids 609,000 mg/kg (60.9%), iron 326,000 mg/kg
 (32.6%), chemical oxygen demand 415,700 mg/kg (41.57%), total phosphorus
 15,000 mg/kg, lead 15,000 mg/kg, zinc 13,000 mg/kg, chromium 2,000 mg/kg, and
 PCB 89.22 mg/kg.

 FISH AND MACROINVERTEBRATES

    Fish are observed in the area only occasionally.  In 1980, the Indiana
 Stream Pollution Control Board and U.S. EPA captured several fish from the
 Indiana Harbor Canal for contaminant analyses: carp (some with fins rotted
 off), a spotfin shiner, and a yellow perch.  Several organic substances were
 reported as present, including PCB, a-BHC, hexachlorobenzene,
 pentachloroanisole, cis-nonachlor, cis- and trans-chlordane, oxychlordane,
 p,p'-DDD, p,p'-DDE, and dieldrin.  Based on the total absence of fish in the
 Canal at other times that collections were attempted, and considering the
 small size and the condition of the fish that were collected, these fish were
 likely not indigenous to the area but were washed in during heavy flow periods.

    A macroinvertebrate sampling program was carried out in 1979.  When
 recovered, the sampler plates were covered with oily silt and sludge.  A few
 segments which appeared to be portions of oligochaetes were found on the
 plates, but no other organisms were present.

    A 1980 sampling program confirmed the presence of oligochaetes and an
 extremely small number of other macroinvertebrates.

 WATER

    Two water surveys conducted in 1978 showed that the Agreement objectives
 were exceeded for copper, iron, mercury, zinc, ammonia, phenol, and
 conductivity.  The maximum cyanide level was 87 ug/L, and the maximum observed
 PCB concentration was 17
    A water survey conducted by U.S. EPA in 1980 showed that the Agreement
objectives were exceeded for copper, lead, selenium, iron, zinc, ammonia, and
phenolics.  Indiana water quality standards were exceeded for ammonia,
cyanide, phenol, total phosphorus, chloride, fluoride, mercury, and oil and
grease.  The maximum cyanide level was 320 ug/L.

SURVEILLANCE DATA -  NEARSHORE  LAKE  MICHIGAN

    Outflow from the Grand Calumet River and Indiana Harbor Canal also has an
adverse environmental impact on the adjacent nearshore area of Lake Michigan.

WATER

    Based on intensive sampling by the Indiana Stream Pollution Control Board,
in cooperation with the Indiana Department of Natural Resources, in 1980 and
1981, elevated concentrations or violations were found for cadmium, phenol,

                                     - 94 -

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and ammonia in the nearshore area of Lake Michigan.   In addition,  phosphorus,
chloride, and sulphate concentrations appear to be increasing.

    The extent to which the Agreement objective for  cadmium (0.2 pg/L)  is
exceeded is not clear, since the analytical  detection  limit was  1.0 ug/L.
Ninety-one percent (540 out of 596} of the samples were less than  the
detection limit.  How many of these would have been  less than 0.2  ug/L  is
unknown.  The Indiana water quality standard for cadmium (10 ug/L)  was  not,
however, exceeded.

    Phosphorus concentrations appear to have increased slightly  from 1980 to
1981, but are well below the Indiana water quality standards of  0.30 mg/L
average and 0.40 mg/L maximum.  Chloride and sulphate  appear to  be  increasing
but do not exceed Indiana water quality standards (15  mg/L  monthly  average  and
20 mg/L daily maximum, and 26 mg/L monthly average and 50 mg/L  daily maximum,
respectively).

    Violations of bacteriological standards  for whole  body  contact  continue
periodically following rainfall.  The beach  at Hammond Lake Front  Park  remains
permanently closed, and the beach at Jerose  Park, in East Chicago,  was  closed
during 1981.  The four other beaches along the Lake  Michigan shoreline  in Lake
County, Indiana were open for the 1981 season.

FISH

    The 1981 annual fish flesh survey near Michigan  City, included  analysis  of
the anterior steak of lake trout, ranging from 22 to 32 inches  and  from 4
through 9 years of age.  Violative concentrations were found for PCB,  total
chlordane, total DDT, and dieldrin.  Pollutants not  detected were  heptachlor,
aldrin, p,p'-methoxychlor, o,p'-methoxychlor,  and endrin; Y-BHC  was detected
in only a few fish.  All other pollutants checked were below violative
concentrations, including mercury, pentachloroanisole, heptachlor  epoxide,  and
hexachlorobenzene.

REMEDIAL  MEASURES  AND ASSESSMENT

    The Grand Calumet River and Indiana Harbor Ship  Canal,  no more  than 13
miles in total length, predominantly consist of treated industrial  and
municipal wastewater and storm runoff with little, if  any,  "natural" flow.
Recognizing this, as well as other unnatural features  of these  waterways, the
Indiana Stream Pollution Control Board has designated  these waters  for  partial
body contact, limited aquatic life, and industrial water supply  use only.  The
Board has established water quality standards and effluent  limits  to obtain
these limited uses, as well as to protect the water  quality and  higher  uses  of
Lake Michigan.  It is doubtful that the river and harbor will ever meet some
Agreement objectives and that these waters will be suitable to  support  all
uses.

    The major industrial facilities discharging to this watershed  were  in
compliance with their permit requirements in 1980.  The permits  are being
reviewed by the Indiana Department of Health to determine whether  additional
requirements may be needed for control of toxic substances.
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    Sulphate and chloride Increases are caused by  wastewater treatment
techniques to reduce cyanide in steel  plant discharges and constitute  a
trade-off, presumably for the better.   These increases will  continue,
accelerated by cyanide reduction wastewater treatment techniques.   Whether  or
not such increases are a significant ecological  concern is unknown.

    Phenols originate from steel plant and oil refinery discharges  but,  while
exceeding the objective in some areas, do not cause  taste  problems  for Indiana
municipal water treatment plants.  U.S. Steel  and  the sole remaining refinery,
AMOCO, are meeting best practicable technology limits, and U.S.  Steel  is close
to meeting best available technology limits. Bother  steel  mills,  however,
discharge their phenolic wastewater to the East Chicago sewerage  system, which
passes through the treatment plant with little effective treatment.

    A special "sweep" of the area by U.S. EPA, Indiana, and local agency staff
identified a large number of industrial waste landfills in the  northwest
Indiana area.  Some of these have contaminated seepage and runoff to Indiana
Harbor and its tributaries.   As information becomes  available,  U.S. EPA  is
taking appropriate action under Section 311 of the Clean Water  Act  to  contain
these inputs.  Where needed, responsible parties are being taken  to state and
federal courts to ensure that the necessary abatement measures  are  taken.

    The East Chicago wastewater treatment facility was not in compliance with
its NPDES permit requirements in 1980, including requirements for phenol and
ammonia.  Some phenol violations will  persist in the receiving  water unless
the steel companies discharging into the East Chicago sewerage  system  provide
pretreatment.  However, existing violations do not affect Indiana water
treatment and should not affect Chicago.  Recent Indiana Stream Pollution
Control Board lake surveys show no concentrations  above detection limits (2.0
wg/L) outside Indiana waters.

    Ammonia violations occur primarily because the East Chicago wastewater
treatment facility receives  high ammonia-bearing wastewater from area  steel
mills.  An ammonia effluent  limitation has been imposed in the  facility's
NPDES permit which, if met,  should result in the elimination of violations  in
the nearshore area of Lake Michigan.  However, ammonia violations will persist
until East Chicago installs  and operates ammonia reduction facilities.  Their
progress in adding the necessary sewerage system improvements through
federal/state construction grants appears to be stymied.  No forecast  of when
the ammonia limitation will  be met can be made at  this time.

    Joint enforcement action by Illinois, Indiana, and U.S. EPA is  in  progress
against East Chicago concerning all its permit violations.  Several meetings
with all parties have been held to reach an agreement.  When finalized,  a
realistic abatement compliance schedule should result.

    The Gary Sanitary District was not in compliance with its permit
requirements in 1980.  New facilities are under construction.

    The Cities of Gary, Hammond, and East Chicago  have completed combined
sewer overflow studies.  These will be forwarded to  the state for review.

    In 1974, Indiana allocated dry weather waste loads for the  Grand Calumet
River and Indiana Harbor Canal.  Indiana water quality standards for  the area
have been changed since 1977.  The river flow has  been significantly reduced

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                                 114
since 1975, due to recycling of  cooling  water  by U.S. Steel.  Indiana plans to
update the 1974 waste  load allocations according to  the  following  strategy:

    1.   The 1983 waste load allocation  study  will be based on current state
         water quality standards.   New EPA  advanced  treatment review policy
         and effluent  guidelines for  industrial dischargers will be adopted in
         the study.

    2.   Projected effluent flows  for both  municipal and industrial
         dischargers will  be used.  The  progress of  the  U.S. Steel recycling
         plan will be  taken into account.

    3.   The 1983 study will include  a seasonal waste load allocation
         analysis, which was not considered in 1S74.

Toxic and conservative waste loads  will  be  evaluated and allocated for at
least phenol, cyanide, chloride, sulphate,  and phosphorus.

    While the Hammond  sewage treatment plant met its requirements, a faulty
sewer resulted in the  bypassing  of  combined municipal wastes and stormwater.
This resulted in extended beach  closings along the southern Lake Michigan
shoreline in 1980.  An emergency 38 million construction program was initiated
in the fall of 1980 and completed  in  May 1981.

    Periodic fecal coliform violations at some Lake  Michigan bathing beaches
are caused by combined sewer overflows to the  Grand  Calumet River.  While  dry
weather discharges have been and will continue to be eliminated, it is
doubtful that wet weather overflows will ever  be totally eliminated due  to the
expense and engineering difficulties  involved.  East Chicago may also
contribute by the discharge of inadequately treated  sewage which could be
eliminated by better operation and  plant improvements.   No remedial action is
comtemplated other than enforcement of NPDES limits  on wastewater  treatment
plant discharges.

    Whether contaminated sediments  in the Grand Calumet  River,  Indiana Harbor
Ship Canal, and Indiana Harbor are  a  sink,  or  a source for uptake  by aquatic
organisms, is unknown, even though  the sediments appear  to effectively remove
pollutants from the water column.   No remedial  action is planned at this time.

    The chlordane, PCB, DDT, and dieldrin in most lake trout (those greater
than 20 inches or more than 4 years old) caught in the Indiana waters of Lake
Michigan are apparently not attributable to municipal and industrial
discharges in the area.  These pollutants are  widespread throughout the  entire
lake.  Federal and/or  state remedial  measures  prohibiting or limiting the  use
and disposal of these  products has  already  been taken.   Until more is known of
the sources, uptake mechanisms,  and the  efficacy and the feasibility of  source
control (once determined), no remedial measures can  be proposed other than the
continued issuance of  fish advisoriei.

INFORMATION  SOURCES

    Additional information about environmental  conditions and  remedial
measures may be obtained from:
                                     - 97 -

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                                  115
         Indiana Stream Pollution Control  Board
         1330 West Michigan Street
         Indianapolis,  Indiana  46206

         Great Lakes National  Program  Office
         U.S. Environmental Protection Agency
         536 South Clark Street
         Chicago, Illinois  60605

ST,  MARYS  RIVER,  MICHIGAN AND  ONTARIO

ENVIRONMENTAL  DATA

SEDIMENT

    The Ontario Ministry of the Environment (MOE) carried out intensive
sediment analyses during 1973.  The  data  indicated  high  levels of iron, zinc,
phenol, cyanide, and oil exist in the  sediment along  the Canadian shore for a
distance of 5 km from the Algoma Slip  to  downstream from the Canadian locks.
Elevated levels of PCB  (as high as 300 tig/kg) were  found in 1974 along the
U.S. shore downstream from the locks.   The area of  contamination extended 2 km
from the locks with a maximum width  of 300 m.  High PCB  levels (as high as 120
ug/kg) also existed in  the Lake George channel downstream from the Sault Ste.
Marie, Ontario sewage treatment plant  and in Little Lake George.  Restrictions
have been placed by Ontario MOE on the disposal of  dredged materials.

FISH

    The 1982 Ontario Ministry of the Environment and  Ministry of Natural
Resources publication entitled, "Guide to Eating Ontario Sport Fish",
indicated that mercury, PCB, mi rex,  and DDT in boneless, skinless fillets of
dorsal muscle flesh of  fish from Lake  George are suitable for unrestricted
consumption for fish in size up to 26  inches.  Species such as northern pike
(>26 inches), lake trout (>22 inches), and walleye  (>18  inches) show elevated
levels of mercury and have consumption advisories.  The  Canada consumption
guideline for mercury is 0.5 mg/kg.

WATER

    Discharges from Algoma Steel Corp. Ltd. have contributed to elevated
levels of phenols, ammonia, and cyanide in the St.  Marys River.  Ontario MOE
monitored the river quality through  5  cruises during  1981.  Phenol levels
higher than the Agreement objective  (1 ug/D persisted along the Ontario
shoreline of the river  down to Little  Lake George.  Levels ranged from 100
ug/L at 300 m from the  Algoma outfall  to  5 ug/L at  Little Lake George (12 km
from the source).  Frequent equipment  breakdown in  the coke oven by-product
plant is largely responsible for the elevated levels  of  phenolic compounds in
the river.   Free cyanide levels exceeded  the provincial  objective (5 ug/L) for
a relatively small distance not exceeding 1 km from the  source.  Levels were
in the range of 10 to 120 ug/L.  Similarly, total ammonia levels (ranging from
0.2 to 1.2  mg/L) met the Agreement objective at 1 km.

    Bacterial contamination resulting  from sewer system  overflows along the
Sault Ste.  Marie, Ontario waterfront continues to restrict recreational use in
some areas.   The provincial fecal" coliform objective  (100 counts/100 mL) was
exceeded at 50% of the  stations located along the Sault  Ste. Marie

                                      - 98 -

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                                   116


 waterfront.  In the Lake George channel,  downstream from the  Sault Ste.  Marie
 sewage treatment plant, fecal coliform levels exceeded the  provincial
 objective at 50/° of the stations for a distance of 7 km.

 REMEDIAL MEASURES

     Algoma Steel Corp. Ltd. at Sault Ste.  Marie,  Ontario is not yet meeting
 Ontario MOE's effluent requirements  for suspended solids, oil,  grease,
 cyanide, zinc, phenols, solvent extractables, dissolved iron,  sulphite,  and
 ammonia.  On June 21, 1982, Ontario  MOE served the company  with a  Control
 Order which will require Algoma Steel  to  limit the discharge  of sulphides,
 cyanides, and ammonia, by September  30, 1985^ such that the effluent will  be
 non-toxic at the end of the prescribed mixing ^one.  The order also specifies
 that:

     1.   By September 30, 198G, Algoma must install the first phase of  a dual
          media filtration system designed  to reduce ether solubles from the
          existing 9,000 to 6,000 Ibs/d and to reduce total  suspended solids
          from 25,000 to 19,250 Ibs/d.

     2.   By December 31, 1987, Algoma  must install a biological treatment
          plant to treat phenols discharging from the steelworks, so as  to
          reduce the load to 50 Ibs/d or less.  A load of 50 Ibs/d  will
          eliminate the transboundary movement of phenols.

     3.   By September 30, 1988, Algoma must install the second phase of the
          dual media filtration system  and  further reduce ether solubles to
          3,000 Ibs/d or less and suspended solids to 13,500 Ibs/d  or less.

 The above program is based on the best available technology,  reducing  the
 concentration of all contaminants to levels that are either non-toxic  or as
 low as technically achievable.

     The installation of a primary clarifier by the Abitibi-Price Paper  Mill  in
 Sault Ste. Marie, Ontario should resolve  the existing suspended particulate
 problems associated with the plant.   This  clarifier is expected to be
 operational before the end of 1982.

     On May 20, 1982, an agreement was  signed among the federal, provincial,
 and municipal governments in Sault Ste. Marie, towards the  funding of  a second
 municipal sewage secondary treatment plant (4.2 MIGD), to serve the westerly
 section of Sault Ste. Marie, Ontario.   The first phase of this sewage
 treatment plant is expected to be completed and operational by 1985.

     Michigan dischargers to the St.  Marys  River are in substantial compliance
 with NPDES permit requirements.

ASSESSMENT

 WATER

     The effluent limitations contained in  the Control Order for Algoma  Steel
 Corporation will, when implemented,  prevent the problem of  transboundary
 pollution and will ensure that the Agreement objectives will  be met in  a
 relaively small distance downstream.


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    The increased municipal sewage treatment capacity resulting from the
provision of the new secondary plant is expected to ensure the protection  of
shoreline recreational  areas.

SEDIMENT

    The high contaminant levels in sediment are primarily a result of past
discharges from Algoma Steel and Abitibi-Price.  The Control  Orders are
expected to ensure that no further significant deposition of toxic or
otherwise objectionable substances will occur.  Dredging carried out as part
of the Great Lakes Power Development project in 1981 resulted in the removal
of some of the contaminated sediments.   Material was disposed of in a confined
area.  The problem does not appear to warrant any further direct remedial
action at this time.  Natural physical  and biochemical  processes are expected
to reduce the contaminant levels and lead to re-establishment of a healthy
benthic fauna community over the longer term.

FISH

    Since the problem of mercury levels in sport fish in the St. Marys River
is not of local origin, no remedial action is indicated.  The origin of the
problem, point surce inputs of mercury  to Lake superior associated with
chlor-alkali and pulp mill operations,  were eliminated in the early to
mid-1970's.  The remedial  programs cited above with regard to phenolics,
sulphides, cyanides, and ammonia will,  however, contribute to a healthier
sport fishery.

SUMMARY

    The transboundary phenolics problem is expected to be corrected by 1987.
The remedial programs scheduled for implementation over the period to 1988 are
expected to correct the local bacterial and other pollution problems
described.  Improvement of bottom sediment quality and recovery of the benthic
fauna will occur over the longer term through natural  recovery processes.

INFORMATION SOURCES

    Detailed environmental and remedial program information may be obtained
from two reports:

    1.   Hamdy, Y.S. and G. La Haye, 1982.  "Water Quality Conditions in  the
         St. Marys River 1966-1980."  Paper presented at XXV IAGLR Conf.,
         Sault Ste. Marie, Ont., May 4-6, 1982.

    2.   Hamdy, Y.S., J.D. Kinkead, and M. Griffiths, 1978.  "St.  Marys River
         Water Quality  Investigations 1973-74."  Ontario Ministry of the
         Environment, Water Resources Branch, Toronto,  52 pp.

    Information may also be obtained from:

              Ontario Ministry of the Environment
              135 St. Clair Avenue West
              Toronto,  Ontario  M4V IPS

    Information about the Michigan shoreline of the St. Marys River may be
obtained from:

                                   - 100  -

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              Michigan Department of Natural  Resources
              P.O. Box 30028
              Lansing, Michigan  48909

SAGINAW  RIVER  SYSTEM  AND  SAGINAW BAY,  MICHIGAN

ENVIRONMENTAL  DATA

SEDIMENT

    Sediments in the Saginaw River contain levels  of PCB  up  to  25.1  mg/kg.
Sediments in the Pine River contain levels of PBB  up to  77 mg/kg;  however,  PBB
has not been detected further downstream.   Chlorinated dioxins  have  not  been
detected  in sediments from the Tittabawassee  River.

FISH

    Samples of whole fish collected in the Saginaw River  in  1976 contained  8
to 12 mg/kg PCB, exceeding the Food and Drug  Administration  guideline  of 5.0
mg/kg for fillets.  Levels of hexachlorobenzene were 10  to 100  times greater
in these  fish, compared to levels in fish  from other Great Lakes tributaries.
High levels of PCB have been found in fish from the  Flint and Shiawassee
Rivers, tributaries to the Saginaw River.

    PCB was detected in the Saginaw fishery at the following levels  in 1980:
         Chinook Salmon
         Coho Salmon
         Channel Catfish
         Carp
    3.04 mg/kg
    2.28 mg/kg
    6.80 mg/kg
    9.47 mg/kg
    Fish samples taken in 1974 and 1976 from the Pine River,  another Saginaw
River tributary, contained PBB levels up to 2 mg/kg;  however,  fish  from
locations further downstream did not contain detectable  levels of PBB.   Of  ten
composite fish samples taken from the Pine River in  1981,  only three exceeded
the 0.1 mg/kg detection limit; PBB was detectable only in  rock bass.

    The chlorinated dioxin 2,3,7,8-TCDD was detected in  fish  from Saginaw Bay
at the following levels in 1980:
         Northern Pike
         White Sucker
         Carp
         Catfish
     4.0 ng/kg
Not detectable
    61.0 ng/kg
    50.0 ng/kg
Levels of dioxin in fish samples from the Saginaw River system have been
reported as high as 600 ng/kg; the U.S.  FDA guideline is 50 ng/kg.   A channel
catfish from the Tittabawassee River in  1978 contained 695 ng/kg of dioxin;
the highest level detected in fish samples taken from the Tittabawassee River
in 1980 was 142 ng/kg in a carp.  Tests  are currently underway to more fully
investigate the extent of dioxin contamination in fish from the Saginaw River
system.
                                     -  101  -

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                                        119


    Michigan has issued fish consumption bans for the  following  rivers,
because of contamination of fish by the substances noted:   South Branch  of  the
Shiawassee River (M-59 to Owosso)  - PCS; Chippewa River (downstream  from
Chippewa Road in Isabella County)  - PBB; Pine River {downstream  from St.
Louis) - PBB; Tittabawassee River (downstream from Midland)  -  PBB and TCDD;
Cass River (downstream from Bridgeport) - PCB; and Saginaw  River - PBB and
TCDD.

    A fish consumption advisory is also in effect for  Saginaw  Bay.   Carp,
catfish, muskellunge, salmon, and  trout should not be  eaten  by children  or  by
women who are pregnant, nursing, or expect to bear children; all  others  should
limit consumption to no more than  one  meal  per, week.   The advisory on
muskellunge, salmon, and trout also applies to the whole of  Lake Huron.

    Additional  discussion of area  biota, including contaminants  in herring
gull eggs, is contained in the report  of the Surveillance Work Group, "Great
Lakes Surveillance," prepared as an appendix to the 1981 report  of the Water
Quality Board.

WATER

    All 24 samples collected at the mouth of the Saginaw River during water
year 1980 exceeded the total dissolved solids objective of  200 mg/L.  The mean
concentration was 468 mg/L.

REMEDIAL  MEASURES

    Several wastewater treatment plants discharging to the  bay have  come into
compliance within the past year.  The  Bay City plant was in  compliance for  all
of 1981.  The West Bay plant has been  on line since December 1981 and has been
in compliance since April 1982.  The Flint plant is now in  compliance for all
parameters except ammonia and nitrates.

    The annual  total phosphorus loading from the Saginaw River to Saginaw Bay
decreased from 1,044 tonnes in 1974 to 409 tonnes in 1979.   The  1980 load
increased, however, to 472 tonnes.  The 1981 tributary load  cannot be
estimated with a high degree of confidence, due to the paucity of flow and
concentration data for that year.  Since the 1978 Water Quality Agreement
proposed target phosphorus load for Saginaw Bay is 440 tonnes  per year,  and
since the Saginaw River makes up approximately 90% of  the total  loading  to
the bay, it is apparent that the target load is being  approached.

    Programs to reduce phosphorus  loadings from point  source discharges  are
generally in place in Saginaw Bay  and  Saginaw River System.  It  is estimated
that more than  half of the loading decrease between 1974 and 1979 was due to
phosphorus removal  efforts by municipal treatment plants in  the  Saginaw  River
Basin and to the detergent phosphorus  ban in Michigan.  The  annual municipal
phosphorus load to Saginaw Bay decreased from an estimated  800 tonnes in 1974
(Upper Lakes Reference Group estimate) to 211 tonnes in 1979.  The annual
loads in 1980 and 1981 were 220 and 232 tonnes, respectively.  This  increase
in municipal  phosphorus load from  1979 to 1980 and 1981 is  due in part to an
increase in the number of facilities reported,  an increase  in  the total  flow
treated, and to poor performance by one or more of the municipal  facilities.
The point source component of the  phosphorus load to Saginaw Bay nonetheless
appears to have stabilized.
                                     - 102 -

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                                   120
     The rest of the  phosphorus  loading  decrease  from the Saginaw River to
 Saginaw Bay between  1974  and 1979  was due  to  reductions in  river flow.  The
 increase between 1979  and 1980  is  mainly due  to  increased tributary flow.

     The Saginaw Bay  ecosystem has  responded favorably to phosphorus load
.reductions  over the  last  decade.   The following  changes in  water quality
 indicators  have been observed to date.  Total phosphorus concentrations and
 secchi  depth measurements have  improved slightly, with an apparent lag in
 response to the reduction in loadings.  Trend analysis on spring and  fall
 chlorophyll a concentrations in Saginaw Bay shows a significant decline for
 the period  1974 to 1980.

     Changes in the phytoplankton in  Saginaw Bay  have been dramatic.   The peak
 blue-green  algal  concentration  in  inner Saginaw  Bay in the  fall of 1974 was
 1.29 mg-dry weight/L while in the  fall  of  1980 it was 0.027 rug-dry weight/L.
 In addition, two species  of nuisance-producing blue-green algae have  virtually
 disappeared from most  areas of  the bay.  The  number of days that the  odor of
 water (thought to be caused by  these algae) at the Saginaw-Midland water
 treatment plant,  the largest water intake  on  Saginaw Bay, exceeded the U.S.
 Public  Health Service  standard  has been reduced  from 56 in  1974 to 0  in 1980.

     Indicators of eutrophication in  the zooplankton community have also
 responded significantly to phosphorus reduction.  The extremely abundant
 crustacean, Bosmina  longirostris,  has decreased  almost 4-fold since 1974.
 Other indicators, sucTPas totaTrotifer concentration and predatory rotifer
 concentration, have  also  decreased.

     Eutrophication may be a natural  characteristic of Saginaw Bay; however,
 continuance of point-source control  programs  now in place will ensure minimum
 human contribution to  accelerating the eutrophication process.

     PCB contamination  in  the Saginaw River basin is the result of historical
 contamination of the sediments  and atmospheric deposition rather than current
 discharges.  PCB in  the intake  water of the Chevrolet Plant in Bay City has
 decreased from approximately 7  pg/L  in 1972 to less than 0.5 ug/L in  1980; PCB
 concentrations in the  discharge from this  facility have similarly decreased.
 PCB contamination exists  in the Shiawassee River at the Cast Forge site.
 Dredging of contaminated  sediments will be completed by October 1, 1982.  The
 plant site  was previously cleaned  up.

     PBB contamination  exists in the  Pine River but has not  been detected in
 Saginaw Bay.  The source, the Velsicol Chemical  site, has been capped, and an
 approved plan for controlling runoff is now in place.  There are on-going
 negotiations at the  state and federal level for  full resolution of the PBB
 problem.

     All industrial dischargers  on  the Saginaw River are in  compliance with
 permit limits.  Dow  Chemical  Company, Michigan Division, is adjudicating its
 new permit  but, it is, to date, submitting studies required by the permit.
 The new Dow permit placed increased  monitoring requirements on the company and
 limitations on nine  additional  non-conventional/toxic pollutants.  The permit
 requires a  detailed  wastewater  characterization  and a dioxin bio-uptake study.
                                      - 103 -

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                                    •"? 1
                                    fi J.
    Control measures proposed for implementation by Michigan are  directed at
providing necessary controls over chlorinated hydrocarbons;  however,
additional testing in Saginaw Bay will be necessary to determine  the  adequacy
of these control measures and the impacts, if any,  on Saginaw Bay of
contamination problems in tributaries to Saginaw Bay.

    Agricultural land management appears to contribute suspended  solids,
nutrients, pesticides, organic matter, and pathogenic organisms to Saginaw Bay
and the Saginaw River system.  These are detrimental to the  quality of the
water and the aquatic environment.

    Agricultural nonpoint source contributions occur as either a  direct or
indirect result of the tilling of soils, supplemental drainage measures,  or
the disposal  of plant and animal residues.  The pollutants are transported to
surface waters by wind,  erosion, water runoff, leaching through agricultural
tile systems, and by direct discharge.

    The Saginaw Monitoring and Evaluation Project in Huron and Tuscola
Counties, a program covering 72,000 acres and about 20% of the agricultural
drainage in the Saginaw Bay Basin,  has shown that the nutrient and suspended
solids loads  from agricultural nonpoint sources are measurable in the streams
and ditches which directly receive  agricultural runoff.  Coastal  areas and
tributary mouths on the  southeastern section of Saginaw Bay, areas which  are
most directly affected by the agricultural activities within this drainage
basin, are especially degraded locations in Saginaw Bay.

    Siltation is a problem throughout the Saginaw region,  resulting in fish
habitat degradation, the filling of surface drainage ways, and the filling of
the Saginaw Federal Navigation Channel.

    The dissolved oxygen level of the Saginaw River is particularly dependent
upon photosynthetic oxygen production and the benthic oxygen demand.   Both of
these characteristics are adversely affected by the nutrient and  suspended
solids loads  contributed by agricultural activities.  Loadings from wholly
agricultural  tributaries of the Saginaw River, i.e. Dutch Creek and
Cheboyganing  Creek, have been shown to cause dissolved oxygen sags to as  low
as 1.9 mg/L in 1976.

INFORMATION SOURCES

    Detailed  information about environmental conditions in Saginaw Bay may be
obtained from the following sources:

    1.   "Michigan Fishing Guide",  Lansing,  1982.

    2.   Letter from W.E. McCracken, Michigan Department of  Natural Resources,
         Lansing, to G.D. Haffner,  IJC, Windsor, June 8,  1981.

    3.   "1981 - Highlights of Water Quality and Pollution Control in
         Michigan", Michigan Department of Natural  Resources, Lansing.

    4.   "The Great Lakes Environmental Contaminants Survey.  Summary Report
         1972-1980."  Michigan Department of Natural Resources Publication No.
         3730-0038, Lansing, March  1982.

                                     - 104 -

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    5.   T.K. Rohrer, "2,3,7,8-Tetrachlorodibenzo(p)dioxin  Residues  in Fish
         from the Tittabawassee and Saginaw Rivers  and  Saginaw  Bay -  1980,"
         Michigan Department of Natural  Resources,  Lansing,  1982.

    6.   Bierman, V.J. Jr.,  D.M.  Dolan,  R.  Kasprzyk,  and J.L. Clark,   "A
         Retrospective Analysis of the Responses  of Saginaw Bay, Lake Huron,
         to Reductions in Phosphorus Loadings", U.S.  Environmental Protection
         Agency, Grosse lie, Michigan, 1982 (To be  published after internal
         U.S. EPA review).

    7.   Great Lakes Water Quality Board,  "1981 Report  on Great Lakes Water
         Quality.  Appendix:  Great Lakes  Surveillance," International Joint
         Commission, Windsor, Ontario.  November  1981.

    Information may also be obtained from:

         Michigan Department of Natural  Resources
         P.O. Box 30028
         Lansing, Michigan  48909

         Great Lakes National Program Office
         U.S. Environmental  Protection Agency
         536 South Clark Street
         Chicago, Illinois  60605


ST,  CLAIR RIVER,  ONTARIO  AND  MICHIGAN

ENVIRONMENTAL  DATA

SEDIMENT

    As a result of the elimination of point sources,  mercury levels  in
sediments  have declined significantly in the last decade;  however,
concentrations are still higher in some locations along the Canadian shore
than  the provim'cial guideline for open water disposal.  In 1977,  Ontario data
indicated  that the average mercury concentration  in the surficia'l  sediment was
3 mg/kg compared to an average level of 250 mg/kg in  1969.   During the  same
year, PCB  levels ranged from not detected to a maximum of  5.3 mg/kg, with an
average level of 0.3 mg/kg.   These high levels of PCB and  mercury  render  the
river sediments, especially in the vicinity of industrial  discharges, unsafe
for open water disposal.  Ontario Ministry of the Environment (MOE)  guidelines
for open water disposal for mercury and PCB are 0.3 and 0.05 mg/kg,
respectively.

    Most stations in 1977 contained concentrations of heavy metals in excess
of Ontario MOE's guidelines for open water disposal.   Fourteen  percent of the
stations exceeded the 50 mg/kg guideline for lead,  97% exceeded the  25 mg/kg
guideline  for chromium, 34% exceeded the 100 mg/kg guideline for zinc,  and
60% exceeded the 25 mg/kg guideline for copper.

    A marked improvement  in the biological  community  of the river sediment has
occurred over the last decade.  A resurgence of bottom-dwell ing life forms is
evident in the nearshore waters, as indicated by increased numbers and a
greater variety of taxa.

                                    - 105 -

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                                     123
 FISH

    Mercury concentrations in all species of fish from the St. Clair system
 have  declined  to  less than half of what they were in 1970.  The application of
 stringent controls on mercury losses from the Dow Chemical Company's
 chlor-alkali plant in Sarnia in 1S69 and the subsequent elimination of the
 mercury cell operation led to this decline.

    High levels of mercury in larger sizes of most fish species still
 necessitate restrictions on consumption.  In 1982, Ontario published a
 consumption advisory for gizzard shad >10 inches from the St. Clair River.
 Restricted consumption of the following sport fish from Lake St. Clair was
 also  advised due  to elevated mercury concentrations:  rock bass, pumpkinseed,
 and largemouth bass >6 inches; bluegill >8 inches; black crappie, smallmouth
 bass, yellow perch, and brown bullhead >10 inches; white bass and freshwater
 drum  >12 inches;  walleye >14 inches; channel catfish, northern pike, white
 sucker, and quillback carpsucker >18 inches; carp >22 inches; rnuskie >26
 inches; and sturgeon >40 inches.  Larger sizes of carp and channel  catfish
 also  contained elevated levels of PCB (exceeding the Canadian federal
 guideline of 2 mg/kg), necessitating consumption advisories.

    Michigan has  a fish consumption advisory in effect for muskellunge caught
 from  the St. Clair River, because of elevated mercury levels; the mean mercury
 concentration  in  1980 was 2.10 mg/kg.

    The incidence of fish tainting had declined significantly in recent years,
 although it is still occasionally reported in areas close to industrial
 sources.

 WATER

    In 1981, Ontario data indicated that levels of total phenols ranged from 1
 to 25 ug/L along  the Ontario shoreline of the St. Clair River.  The extent of
 the Agreement  objective (1 ng/L) violation was 15 km along the shore with a
 maximum width  of  50 m.

    During the same year, fecal coliform levels exceeded the provincial
 objective (100 counts/100 mL) along the Sarnia waterfront (Sarnia Bay) for a
 longitudinal distance of 300 m and a maximum width of 30 m.

    A recent survey of trace organics in industrial effluents indicated that,
 while there is no immediate threat to water supplies or fish, additional
 controls on the discharge of these compounds are warranted, for the long-term
 protection of  the river ecosystem.

REMEDIAL MEASURES

 ONTARIO

    Significant industries are concentrated on the Canadian side of the St.
 Clair River.   Shell, Petrosar, DuPont, Union Carbide, and Ethyl Canada are
 located at Corunna; Lambton Generating Station and CIL at Courtright; Suncor,
 Dow Chemical,  Polysar, Imperial Oil, and Esso Chemical at Sarnia.  Several
 industries in  the St. Clair area are not meeting Ontario MOE's effluent
 requirements for  conventional parameters on a consistent basis.

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    Phenols and BOD/COD loadings from Polysar exceed the  effluent
requirements.  A two-stage remedial  program has been required by Ontario MOE
to correct water pollution problems.   Stage 1 was completed on schedule, and
Stage 2 is scheduled for completion  in 1982 and will result in 85% of the
organics being directed to a biological  treatment plant.

    Two industries, Petrosar and Esso Chemical, periodically exceed
requirements for phenol in spite of  the  fact that both have effluent polishing
with activated carbon.  Neither contributes to the narrow band along the
Ontario shoreline where the ambient  objective for phenolic compounds is
exceeded, since the outfalls extend  into the-deeper channel where dilution is
achieved rapidly.

    Lead levels from Ethyl Canada continue to exceed discharge objectives in
spite of the installation of an inclined plate clarifier in 1981.  The unit
has been dismantled in an attempt to rectify shortcircuiting problems and
should return to service by late summer 1982.

    Since 1975, Ontario MOE has been investigating organic chemicals in
municipal and industrial effluents along the St. Clair River.  A report on the
1977-78 studies indicates that organics  are present in municipal and
industrial effluents.  In 1979 and 1980, Ontario MOE end Environment Canada
undertook a joint study to further characterize and quantify toxics in
industrial effluents in the St. Clair River area; the study reports are in the
final stages of completion.  It is anticipated that this joint study will
improve the data base on effluent characteristics both qualitatively and
quantitatively, with the result that Ontario MOE may impose further
requirements for toxic control  on the industries involved, to ensure that
water quality continues to improve in the St. Clair River.

    Additional surveillance work is  planned by Ontario MOE to refine the data
obtained in the above studies,  to assess trends, and to evaluate the benefit
of recent and impending improvements in effluent quality from several
industries.  At the same time the industries are being required, by way of
conditions on Certificates of Approval for new or modified discharges, to
monitor for specific toxic organic chemicals.  This will  permit Ontario MOE to
maintain an active data base of each outfall and monitor improvements achieved
by process modifications or control  techniques.

MICHIGAN

    Michigan industrial and municipal dischargers to the St. Clair River are
in substantial compliance with permit requirements.

ASSESSMENT

WATER

    Remedial action at Polysar Corporation in conjunction  with the extension
of the Township ditch and other outfalls will significantly reduce the  mixing
zones associated with phenolic compounds and generally lower contamination
concentrations within the river.  Regulatory controls and  discharge monitoring
results  indicate PCB input has been virtually eliminated.  Achievement  of
further controls on persistent and non-persistent toxic substances emissions

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                                    I 25
will follow from further definition of priority compounds,  identification  of
sources, and selection of appropriate control  technology.   It is  expected  that
this will proceed on a scheduled basis as the  results of additional  fish
contaminants analysis, discharge monitoring, and predictive modelling of
instream concentrations become available.

SEDIMENTS

    Improvements in contaminant levels and the zoobenthic  community  observed
over the last decade suggest that effluent controls  and natural  river
processes are contributing to system rehabilitation.   The  removal  of
contaminated sediment for confined disposal  as -part  of periodic  capital and
maintenance dredging projects carried out in the immediate  industrial  area
will result in further improvement.   No other  action  is warranted at this  time.

FISH

    The mercury levels in sport fish in Lake St. Clair are  now being resolved
through natural processes.  Scheduled abatement activity is expected to
totally eliminate the fish tainting problem.

SUMMARY

    The remedial action essential  to reducing  mercury levels in  fish was taken
in the early 1970's.  Levels have declined in  fish and should continue to  do
so, albeit at a reduced rate, as natural  physical and chemical  processes
reduce the availability of mercury in sediments. Similarly, the  major
controls necessary to the recovery of the benthic community along the Ontario
shoreline are in place and progress is being monitored.

    Remedial measures at Polysar,  when completed this year, should markedly
improve water quality in the Sarnia area.

    Correction of the bacterial contamination  problem in Sarnia  Bay  is being
sought in cooperation with the municipality.

INFORMATION  SOURCES

    Detailed information about environmental conditions in  the St. Clair River
may be obtained from the following reports:

    1.   Government of Ontario, 1982.  "Guide  to Eating Ontario  Sport Fish -
         Southern Ontario and Great Lakes,"  Toronto,  1982,  191 pp.

    2.   Ontario Ministry of the Environment,  Water  Resources Branch, Toronto,
         1977.  "St. Clair River Organics Study. Fish Toxicity  and  Tainting
         Evaluations for Selected Industrial Effluents."  Rept.  LTS  81-1,  21
         pp.

    3.   Hamdy, Y.S. and J.D. Kinkead, 1979,   "St. Clair River Organics
         Study.  Waste Dispersion."  Ontario Ministry of the Environment,
         Toronto.  27 pp.
                                    -  108 -

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                                   26
    4.   Ontario Ministry of the Environment,  Southwestern  Region,  1979.   "St.
         Clair River Organics Study.  Biological  Surveys.   1968  and 1977."
         90 pp.

    5.   Bouner, R.F. and 0. Meresz, 1981.   "St.  Clair River Organics  Study.
         Identification and Quantisation of Organic  Compounds."   Ontario
         Ministry of the Environment, Laboratory  Services  Branch Report,
         Toronto, 219 pp.

    6.   Ontario Ministry of the Environment,  Laboratory Services Branch,
         Toronto, 1981.  "St. Clair River Organics Study.   The Screening  of
         Industrial Effluents for Genotoxic Activity."  69  pp. plus appendices.

    7.   "Michigan Fishing Guide," Lansing, 1982.

    8.   "Great Lakes Environmental Contaminants  Survey,  Summary Report
         1972-1980," Michigan Department of Natural  Resources, Publication No.
         3730-0038, Lansing, March 1982.

    Additional information about remedial measures may be  obtained from:

         Ontario Ministry of the Environment
         Southwestern Region Office
         London, Ontario

         Michigan Department of Natural Resources
         P.O. Box 30028
         Lansing, Michigan  48909

DETROIT RIVER,  MICHIGAN  AND ONTARIO

ENVIRONMENTAL  DATA

SEDIMENT

    The Ontario Ministry of the Environment (MOE) conducted a survey of bottom
fauna, metals, and organic pollutants in the sediments of the Detroit River  in
1981  in preparation for a more intensive study in the future.  Levels in
excess of the Ontario guidelines for open-water disposal  of dredged materials
for PCB (0.05 mg/kg) and mercury (0.3 mg/kg) were found at 78%  and 34% of
the stations sampled, respectively.  The majority of exceedances were in
sediments along the U.S. shore in the vicinity of the Detroit sewage treatment
plant, Great Lakes Steel, and the Rouge River mouth, and would  necessitate
confined disposal of dredged materials.

    Improvements in distribution and numbers of the pollution-sensitive mayfly
have  occurred along both sides of the river since 1968.  However, a
significant portion of the U.S. shoreline in the  vicinity of and downstream
from  the Rouge River mouth still exhibits very high densities of tubificids
(sludgeworms).

    The Michigan Department of Natural Resources  (DNR) will conduct a
preliminary study of organic pollutants in the sediments of the  Detroit River
in 1982 in preparation for an intensive study in  the future.

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                                     127
    Conditions near the Detroit River mouth and in western Lake Erie suggest
that an overall reduction has occurred in organic and phosphorus waste
loadings into the area.

FISH

    The 1982 Ontario Ministries of Environment and Natural Resources
publication entitled, "Guide to Eating Ontario Sport Fish", indicated that
mercury levels in walleye (>16 inches) and rock bass (>6 inches) ranged from
0.5 to 1.0 mg/kg.  The Canadian federal guideline for fish consumption is 0.5
mg/kg.  Fish consumption advisories issued by Ontario for the above species
and sizes remained in effect.

    Michigan has issued an advisory against consumption of muskellunge from
the Detroit River as a result of a mean level of mercury contamination of 2.10
mg/kg.

WATER

    In water year 1980, 78 of 456 samples (17.1%) from the Detroit River
exceeded the fecal  coliform bacteria objective.  The mean phenol concentration
was 0.5 ug/L in 1980, compared to a mean of 0.93 ug/L in 1979.   Concentrations
exceeded Agreement objectives most often below the confluence with the Rouge
River.  Total iron concentrations exceeded the objective at every station on
the Detroit River on at least one date, but violations occurred more
frequently in the lower reaches.  The mean total iron concentration was
188 Mg/L.   The mean total dissolved solids concentration of 103 mg/L met the
Agreement objective, but samples collected at both the head and mouth ranges
in water year 1980 exceeded the objective.

    The Ecorse River, a tributary to the Detroit River, in the  past
contributed to fecal coliform and phenol  problems in the Detroit River, due
largely to combined sewer overflows.  In 1980, 15 of 18 samples exceeded the
Agreement objective for fecal coliform bacteria, with a maximum of 2.6 million
colonies/100 ml.   Phenol  concentrations reached 19 ug/L; the mean of 12
samples was 6 ug/L.   One 1980 sample showed a total  iron concentration of 620
pg/L,  compared to 630 ug/L in one sample in 1979.  Total dissolved solids
concentrations averaged 382 mg/L in 1980, with a maximum of 754 mg/L.
However, the communities of Lincoln Park, Taylor, and Dearborn  Heights on the
Ecorse River now have separate sewer systems, and Allen Park is under federal
court order to construct a separate system.

    The River Rouge is also a significant source of pollutants  to the Detroit
River.  This river is considered below, as a separate area of concern.

    Total  phosphorus loadings from the Detroit River into the western basin of
Lake Erie  have declined significantly over a 12-year period.  This improvement
is reflected by a decrease in phosphorus levels in the western  basin of Lake
Erie and a decline  in algal  densities at a municipal intake in  the basin.

    The 1981 Ontario data for bacterial levels along the Ontario shoreline
from Windsor to Amherstburg confirmed the restriction of the water use for
recreational swimming,  bathing,  and other activities along the  shoreline.
This restriction  is due to frequent violation of the provincial objective for


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fecal coliform (100 organisms/100 ml).  Bacterial  contamination in the Detroit
River does not, however, extend along the north shore of the western basin of
Lake Erie.

REMEDIAL  MEASURES

MICHIGAN

    The Detroit Wastewater Treatment Plant, long a major pollutant source to
the Detroit River, has fully met the standards for secondary treatment and
phosphorus removal, as ordered by the courts, since June 1981 for all dry
weather flows.  The plant meets the standards for oil and grease removal  for
all flows through plant.  The plant meets the standards for phenol removal for
all flows up to 805 million gallons per day, which includes peak dry weather
flows.  Results are tabulated below:

                 DETROIT WASTEWATER TREATMENT PLANT DISCHARGE

                        June 1980 - June 1981a    June 1981 - June 1982b

Flow     (average)               660 MGD                    684 MGD
         (maximum)               993 MGD                   1081 MGD
         (total)                 241 billion gallons        249 billion gallons

Total Suspended Solids
         (average)               52 mg/L                   24 mg/L
         (total)                50650 tons               (25000 tons)c

BOD5     (average)               37 mg/L                   17 mg/L
         (total)                35350 tons               (18000 tons)c

Phenol   (average)               46 mg/L                   19 mg/L

Total Phosphorus
         (average)               1.32 mg/L                 0.57 mg/L
         (total)                1259.5 tons               (590 tons)c

Fecal Coliforms
         (average)               110 MPN                   83 MPN

a.  Data obtained  from  "Final Fiscal Year Record", prepared by the Detroit
    Water  and  Sewerage  Department.

b.  Data obtained  from  "Monthly Operating Report", prepared by the Detroit
    Water  and  Sewerage  Department.

c.  Estimate.


    The  Detroit Wastewater Treatment  Plant,  probably  the main  source  of  phenol
to  the Detroit River  is  now  in compliance with  the phenol limits.  From
September  1980 to  May 1982,  the 30-day and  the  7-day  averages  for phenols
discharged  from the plant were 103.26, and  144.53  pounds, respectively.   The
limits are 400 to  800 pounds,  respectively.


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    The Ford Motor Company, also previously a major discharger of phenols,  is
now in compliance.

    Although preliminary examination of 1981 data indicates the phenol
objectives may be exceeded in the Detroit River,  those communities (Monroe,
Wyandotte, and Detroit-Southwest Plant) drawing water supply from the  Detroit
River no longer register problems with taste or odor.

    Several sites possibly contributing to surface water degradation  have  been
or are being cleaned up.  The BASF Wyandotte southworks are closed and  being
demolished.  The mercury cell room has been closed and is being torn  down.  A
previously owned BASF site in the City of Wyandotte has been cleaned  up and
capped.

    The Liquid Disposal  Incineration,  Incorporated site in Shelby Township  is
being cleaned up under Superfund emergency provisions.  The site  is on  the
interim national priority list to receive funds for remedial action.

    Urban surface runoff from the City of Detroit directly into the Detroit
River, combined sewer overflows in the Rouge River Basin, and combined  sewer
overflows from the City of Detroit result in elevated levels of bacteria in
the Detroit River and contribute to the total phosphorus load to  the  river  and
to the western basin of Lake Erie.  The Detroit Water and Sewerage Department
conducted a 25,000,000 facilities planning study addressing combined  sewer
overflows from the City of Detroit.  The study showed that, although  pollutant
loads to the river from this source could be reduced,  no significant
improvement in water quality would result from any of the abatement
alternatives identified to date.  Any load reductions and improvements  would
be masked by the direct surface runoff from the City of Detroit and by  the
combined sewer overflows in the Rouge River Basin.  There are no  plans  to
address direct land runoff into the river.  Combined sewer overflows  in the
Rouge River Basin are discussed below in a separate area of concern.   It
should be noted, however,  that over the past ten  years,  the City  of Detroit
has eliminated approximately 50% of its combined sewer overflows  through
in-system storage, and by preventing river inflow; also, as a result  of
improved plant operation,  this wastewater is receiving better treatment than
in the past.

    In its 1981 report,  the Water Quality Board reported that the estimated
annual phosphorus load from combined sewer overflows at Detroit was 110
tonnes.  The Board further reported that, when all municipal treatment  plants
in the Lake Erie Basin achieve an effluent limitation of 1.0 mg/L,  combined
sewer overflows at Detroit would constitute the third largest point source  of
phosphorus in the basin, in terms of annual  load.   Since combined sewer
overflows and direct land runoff contribute a sizeable loading of phosphorus,
control of these sources could afford a greater measure of protection  and
improvement to the water quality of the Detroit River and the western  basin of
Lake Erie.

    Monsanto Company in  1981 discharged 117 pounds per day of phosphate
phosphorus, an annual average concentration of 0.92 mg/L, which represents
98.8% removal of phosphorus from the process waste flow.  This is considered
to be best available treatment and no further remedial action is  proposed.
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                                   30
    The high contaminant levels in sediment are  primarily  a  result  of  past
discharges from industries along the U.S.  shore  of the  river.   The  regulatory
emphasis on hazardous waste disposal sites in the  Detroit  metropolitan area
ensure that no further significant deposition of toxic  substances will occur.
Natural physical  and biochemical  processes are expected to reduce the
contaminant levels and lead to re-establishment  of a healthy benthic  fauna
community.

ONTARIO

    While Ontario industrial  inputs do not in themselves result in  objective
exceedances or use impairment, described above,  there are  a  number  of  waste
treatment deficiences which are under active resolution or investigation with
the objective of reducing overall  waste loading.  As such, they should
contribute to the maintenance of water quality in  the Detroit River and
western Lake Erie once controls on major Michigan  inputs are complete.

    Ford Motor Company of Canada,  Chrysler Canada  Limited, Gulf and Western
Canada Limited, Hiram Walker and Sons Limited, Allied Chemical  Canada  Limited,
and Canada Salt Company Limited at Windsor and BASF Wyandotte Corporation at
Fighting Island are the industrial sources.  Except for Chrysler Canada
Limited and Ford Motor Company, all of these Ontario sources are in compliance
with Ontario MOE effluent requirements.

    Chrysler Canada Limited was not in compliance  with  Ontario MOE  loading
requirements for phosphorus.   The Company is planning to segregate  those waste
streams containing relatively high phosphorus concentrations for separate
treatment, designed specifically for phosphorus  removal.

    Ford Motor Company was marginally not in compliance with the loading
requirements for phenol and suspended solids. The reasons for this
non-compliance are being investigated.

    Shoreline bacterial contamination downstream of Windsor and at  Amherstburg
is being addressed through a number of municipal projects.  The City of
Windsor completed expansion of its Little River  plant in 1981 and is presently
expanding its Westerly wastewater treatment plant  to 163 x 10^ m^/d (36
MIGD).  Completion of this expansion is expected in late 1981.  Extension of
trunk and lateral sewers to areas presently serviced by septic tank systems
will continue as an ongoing program.

    A 220 million program to provide a sewage collection system, including
pumping stations and forcemains, is presently under construction in Sandwich
West Township, located immediately south of Windsor.  This provincially
financed system,  when completed in late 1981 or  early 1982,  will transfer
wastes to the West Windsor pollution control plant.  Completion of  this
project should improve water quality in the Detroit River immediately
downstream from Windsor.

    At Amherstburg, a proposal to expand the existing 4.5 x 10^ m^/d  (1.0
MIGD) primary type sewage treatment facility is  presently under review by
Ontario MOE for preliminary acceptance.  Also included in the proposed
expansion are pumping stations and modifications to chemical dosing


                                     -  113 -

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                                      Si
equipment.  Upon acceptance of the proposal,  final  design will  have to be
completed and funding secured by the municipality before construction begins.

    Recently completed and ongoing improvements to  the Windsor  area collection
systems and expansion of sewage treatment facilities at Windsor and
Amherstburg, coupled with the phased extension of sewer services into areas
presently serviced by septic tanks, will bring about steady improvement in
bacterial  levels along the Ontario shoreline,  and help ensure that the
provincial objectives for public health indicator bacteria will be met.

    The Windsor and the Amherstburg plants are currently discharging 97.2 x
    and 4.3 x 10^ m«Vd, respectively, with annual average phosphorus
concentrations of 1.0 and 1.9 mg/L, respectively.

    In addition to the above Canadian point sources, recent developments
concerning the possible future use of Fighting Island, located  in the Detroit
River, are also noted.  The island is in Canada and is owned by BASF Wyandotte
of Michigan.  It has been used for waste disposal since the 1920's.  The U.S.
EPA, Environment Canada, Ontario MOE, and Michigan  DNR are concerned about the
possible discharge of toxic substances in the  event that Fighting Island is
used as a treatment/containment facility for sewage sludge from the City of
Detroit.  Detroit proposed a pilot project for sewage sludge disposal on the
island; this proposal received provisional approval from Ontario MOE and is
now underway.  The process basically consists  of mixing sewage  sludge with the
settled materials from the abandoned treatment beds with the object of
determining the feasibility of employing waste material to support vegetation
to rehabilitate the island.  The pilot study is expected to require 2-3 years
for completion.

INFORMATION SOURCES

    Detailed information about environmental  conditions and remedial programs
may be obtained from the following reports:

    1.   Ontario Ministry of the Environment,  Southwestern Region and Water
         Resources Branch,  1981.  "An Assessment of the Bottom  Fauna and
         Sediments of the Western Basin of Lake Erie, 1979."  Ontario Ministry
         of the Environment, Toronto. 24 pp.

    2.   Ontario Ministry of the Environment,  Southwestern Region, London, and
         Water Resources Branch, Toronto.  Unpublished data on  1981 trace
         contaminants and macrozoobenthos survey of Detroit River sediments.

    3.   Letter communication from W.E.  McCracken,  Michigan Department of
         Natural  Resources, to G.D. Haffner,  International Joint Commission,
         Windsor,  June 8,  1981.

    4.   "1981 - Highlights of Water Quality and Pollution Control in
         Michigan",  Michigan Department of Natural  Resources, Publication
         Number 4833-9804,  Lansing.

    5.   "Great Lakes Environmental Contaminants Survey, Summary Report,
         1972-1980",  Lansing,  Michigan.
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      Information may also be obtained from:

         Ontario Ministry of the Environment
         Southwestern Region Office
         London, Ontario

         Ontario Ministry of the Environment
         Water Resources Branch
         135 St. Clair Avenue West.
         Toronto, Ontario  M4V 1P5

         Michigan Department of Natural Resources
         P.O. Box 30028
         Lansing, Michigan  48909

ROUGE RIVER,  MICHIGAN

ENVIRONMENTAL  DATA

 SEDIMENT

     No  recent data are available; historical data show severe degradation.

 WATER

     In  1980, fecal coliform concentrations exceeded the Agreement objective in
 11  of 12 samples, with a maximum of 60,000 colonies/100 mL.  Phenol
 concentrations exceeded  the Agreement objective., with a mean concentration of
 9  ug/L  and  a maximum of  24 ug/L.  Two samples were analyzed for total  iron in
 1980 with a mean concentration of 1,085 ug/L, compared to 6,700 ug/L in one
 sample  in 1979.  The mean total dissolved solids concentration was 295 mg/L in
 1980, and the maximum was 490 mg/L.

 FISH

     No  fish analyses have been performed.  It should be noted as anecdotal
 evidence of improved water conditions that two steel head were caught in the
 Rouge River in the spring of 1982.

REMEDIAL MEASURES

     Industrial dischargers to the Rouge Basin are in substantial compliance
 with permit requirements.

     The River Rouge is,  nonetheless, a significant source of pollutants to the
 Detroit River.  Combined sewer overflows are the major problem.  Twenty-five
 percent of  the total Rouge basin is drained by combined sewer networks.  The
 outfalls from these combined sewers are located in the lower portions of the
 branches of the  Rouge which are subject to low stream velocities.  Many
 pollutants  from  the-combined sewers settle out on the bottom and perpetuate
 polluted conditions for  days and weeks after the combined sewers overflow.

     Combined sewer overflow studies for communities in the basin,, upstream
 from Detroit, were undertaken.  The main study has been completed and other

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                                    I 33


 studies will be completed by fall of 1982.   More than $500  million  would be
 required to alleviate the effects of combined sewer overflow.   Based  on
 information available, and considering the  benefits to be  derived and the
 costs involved, the court has concluded that measures to correct combined
 sewer overflows in the Rouge River Basin are not warranted  at  this  time.

 INFORMATION  SOURCE

    Environmental information was provided  by W.E.  McCracken of the Michigan
 Department of Natural Resources in a letter to G.D. Haffner of the
 International Joint Commission, dated June  8,,1981.  Additional information
 about environmental  conditions and remedial  measures can be obtained  from:

         Michigan Department of Natural Resources
         P.O. Box 30028
         Lansing, Michigan  48909

RAISIN RIVER,  MICHIGAN

ENVIRONMENTAL  DATA

 SEDIMENT

    Sediments collected during 1975 and 1976 surveys from  Monroe Harbor and
 the approach to the Raisin River are heavily polluted with  volatile solids,
 oil and grease, and metals.  Chemical  oxygen demand is high.

 FISH

    Fish were collected from the Raisin River in 1978 and  1979.  PCB  levels
 were as high as 111 mg/kg, compared with the U.S. FDA action level  of 5.0
 mg/kg.  Also present were DDT, nonachlor,  tri-,  tetra-,  and heptadecane,
 naphthalene, methyl- and dimethyl naphthalene,  methylbiphenyl,  phenanthrene,
 fluoranthrene, pyrene, pyridine carboxamide, and mono- and  dichlorobiphenyl.

 WATER

    Water samples were collected in 1978.   Agreement objectives were  violated
 for cadmium, chromium, copper, iron, nickel, zinc,  dissolved oxygen,  specific
 conductivity, and fecal coliforms.  The Michigan standard  for  pH was  also
 violated.

REMEDIAL MEASURES

    All major dischargers to the Raisin River are in substantial compliance
 with their permits.   Existing water quality problems result to a great extent
 from contaminated sediments.  However, the  Michigan Department of Natural
 Resources received support from U.S. EPA to conduct process evaluations of
 several chemical and manufacturing facilities in the watershed, in  order to
 identify potential sources of toxic contaminants.  Three evaluations  were
 completed during Phase II of the study, and no problems were  identified.
 Phase III,  to be completed in October 1982,  will include evaluation of three
 more facilities in the Raisin River watershed.


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                                  134
INFORMATION SOURCE

     Additional  information about environmental conditions and remedial
 measures  can  be obtained from:

          Michigan Department of Natural Resources
          P.O. Box 30028
          Lansing, Michigan  48909

MAUMEE RIVER, OHIO

ENVIRONMENTAL DATA

 SEDIMENT

     Surveys conducted  in 1973 and 1975 reveal that the sediments in the lower
 Maumee  River  and Toledo Harbor are heavily polluted with volatile solids,
 chemical  oxygen demand, and metals.  Sediments in the outer bay are also
 polluted,  although less heavily so.

 FISH

     Fish  collected between 1976 and 1979 contain PCB up to 5.9 mg/kg;  the  U.S.
 FDA action  level is  5.0 mg/kg.  Also detected were DDT, hexachlorobenzene,
 chlordane,  nonachlor,  methylbiphenyl, methylbenzanthrene, pyridine
 carboxamide,  pentachloroanisole, heptadecane, and nonadecane.

 WATER

     Water collected  at the mouth of the Maumee River contains cadmium,  iron,
 manganese,  nickel, zinc, copper, and chromium in excess of the Agreement
 objectives  or Ohio EPA standards.  In addition, dissolved oxygen, specific
 conductivity, phosphorus, and fecal coliforms do not meet Agreement objectives.

CAUSES AND  REMEDIAL MEASURES

     The Maumee  River is the largest source of sediment and non-point
 phosphorus  loadings  to Lake Erie.  In recognition of this, a consortium of
 state,  local, and federal agencies has agreed to foster no-till and associated
 soil conservation practices in the Maumee River Basin.

     The U.S.  EPA has funded several large agricultural land management
 demonstration projects in the Maumee River basin, including:  The Black Creek
 watershed of  northeastern Indiana, Allen and Defiance Counties, Ohio and the
 Accelerated Conservation Tillage project (a nine-county program in
 northwestern  Ohio, specifically affecting three counties in the Maumee River
 basin).   Preliminary results are showing 30% to 90/o reductions in soil
 loss,  with  attendant phosphorus loss reductions, depending on the specific
 soils  and tillage practices being used.  In addition to encouraging
 conservation  tillage,  the Cooperative Extension Service of the University  of
 Ohio,  the Ohio  Department of Agriculture, and the Ohio Department of Natural
 Resources,  Division  of Soil and Water Conservation are promoting lower rates
 of application  of phosphate fertilizer in northwestern Ohio to more closely
 match  the crop  utilization rates.

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                                       135


     All of the large Ohio municipal treatment facilities in the Maumee River
estuary averaged below the 1.0 mg/L effluent phosphorus requirement during
1981.  All of these plants are at the  advanced secondary treatment levels
required to protect the dissolved oxygen requirements of the river.

     Combined sewer overflow problems  are currently under study at Toledo,
Perrysburg, and Oregon.  This problem  is also being evaluated by an outside
consultant under contract to U.S. EPA's Great Lakes National Program Office.
Remedial programs will be developed at the conclusions of these studies.
However, the funds to finance these proposals may not be readily available,
which may require the deferral of the  implementation.

     The industrial dischargers in the estuary are in compliance with the
NPDES permit requirements which were designed to meet the 1977 requirements
for the traditional sewage parameters  and also to meet the water quality
standards for toxicants (heavy metals, cyanides, and phenols).   A program to
control other toxic materials is being developed.

     Acute, static bioassay tests with fathead minnows were performed on the
effluents from the two petroleum refineries, Standard Oil Co. of Ohio and Sun
Oil Co., during 1982.  No acute toxicity was discovered.  Additional  remedial
measures may be required based on this review and the issuance of best
available treatment (BAT) requirements by U.S. EPA.  These BAT requirements
for the petroleum refineries are expected to be issued in 1982 with compliance
under the Clean Water Act being required by July 1, 1984.  However, the
implementation of any required control programs may take 3 to 4 years, with
final compliance in 1985 or 1986.

ASSESSMENT

WATER

     The combination of NPDES permits, the pretreatment program, and
enforcement practices should result in all  principal  dischargers meeting
Ohio's water quality standards.

     The water quality in the estuary may never meet the Agreement objectives
for Lake Erie because of the natural chemistry of the water in the drainage
basin and the existing land use patterns.  In addition, modifications of the
geometry of the estuary (installation  of bulkheads, loading docks, and deep
channel dredging) have changed the hydrology so as to slow the movement of
water through the estuary, resulting in a decrease in reaeration of the water
and the assimilative capacity of the streams.  The modified geometry promotes
sedimentation, requiring periodic dredging.

     The Maumee River estuary is also  profoundly affected by "lake effects"
through its location at the end of a relatively shallow lake.  During periods
of northeast winds, lake water is driven up the estuary for many miles, thus
preventing the normal  flow in the river.  The U.S. Gelological  Survey gauging
station on the Kaumee River is located 21 miles up river at Waterville in
order to be out of the area influenced by the "lake effects".

     The water entering the estuary from upstream of Waterville showed only
minor problems with violations of state water quality standards for lead,

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                                     133
cadmium, zinc, and mercury during the  period  October  1,  1978  through September
30, 1980.

SEDIMENT

     A portion of the high contaminant loads  in  the  sediment  can  be attributed
to past discharges of municipal  treatment plants  and  industries and from
agricultural practices.  The continued practice  of the  existing remedial
programs is expected to ensure that no further  significant  deposition  of
toxicants (heavy metals, cyanide, and  phenols)  will  occur.  The sediment
pollution from non-point sources is more  difficult to control  and  the  remedial
programs are voluntary.  Time and natural processes  are expected  to reduce  the
contaminant levels.  The U.S. Army Corps  of Engineers operates an  annual
dredging program for the navigation channel of  the Maumee  River in Toledo and
Maumee Bay.  Information from an assessment of  that activity  over  the  period
1976 to 1981 indicates that the sediment  is becoming less  contaminated with
time.  The material taken from the channel  northward  from  the Toledo Harbor
Light may be suitable for open lake disposal.  (Toledo  Harbor Assessment, in
preparation).

FISH

     The ban on PCB and natural  attrition will  in time  result in  the reduction
of this contaminant in fish.  A similar statement can be made for the
persistent pesticides and metabolites  (DDT, chlordane,  and nonachlor). The
other identified materials are hydrocarbons,  presumably from  petroleum
refining, coke manufacture, and other  petroleum oil  uses.   The major  sources
of these products have control measures in place  which  should minimize the
occurrence of these materials and allow natural  attrition  to  occur.  The  other
remedial programs discussed previously will also  contribute to a  healthier
fish population.

GENERAL

     The remedial programs in place for permit  sources  should decrease the
pollutant loads into the river so that the natural processes  of attrition
should  remove the contaminants from the sediments and fish over the  next  5  to
10 years.  The programs for non-point  pollution controls are  just under way,
but noticable improvements in sediment and phosphorus loadings should  be
realized within 5 years.

     It is unlikely that the water in  the estuary will  meet all  of the
Agreement objectives for Lake Erie.

INFORMATION SOURCE

     Additional information about environmental  conditions and the status of
remedial measures may be obtained from:

         Ohio Environmental Protection Agency
         P.O. Box 1049
         Columbus, Ohio  43216
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BLACK RIVER, OHIO

ENVIRONMENTAL  DATA

SEDIMENT

     A 1975 survey indicated that the lower Black River and Lorain  Harbor  are
heavily polluted with volatile solids, chemical  oxygen demand,  oil  and  grease,
nutrients, and metals.

FISH

     Fish caught at the mouth of the Black River in 1978 contained  PCB,  DDT,
methyl naphthalene, biphenylphenanthrene, flouranthrene, pyrene,  fluorene,
acenaphthalene, dibenzothioprene, pyridine carboxamide, terphenyl,
phenylnaphthalene, and pentachloroanisole.  Many of these substances  are of
industrial origin.  A maximum PCB level  of 12.6  mg/kg was recorded  in 1979,  in
excess of the FDA's action level of 5.0 mg/kg.

WATER

     Water samples collected during a 1978 survey contained concentrations of
phosphorus, ammonia, cadmium, copper, iron, lead, manganese, zinc,  mercury,
cyanide, conductivity, dissolved oxygen, and fecal coliforms which  violated
either the Agreement objectives or Ohio EPA standards.

CAUSES AiND REMEDIAL  MEASURES

     The observed pollution is attributed in part to past industrial
discharges.  Sediment sampling is currently under way to assess  the extent of
contamination with toxic organic substances.

     The lower Black River is affected by the discharge from the Elyria
municipal treatment plant, which has significant industrial inputs  of heavy
metals.  Elyria has applied for federal  grants to develop a pretreatment
program to address the industrial inputs and to  update its treatment plant.
Completion of construction is currently scheduled for 1985.

     Amherst's municipal treatment plant also contributes to the pollution of
the Lorain Harbor area.   This entity is currently operating under a consent
decree requiring it to meet interim effluent limits and to improve  its  plant
to meet advanced secondary limits by the end of  1986.

     U.S. Steel  will be initiating a remedial program to meet best  available
treatment and water quality standards.  These requirements will  be  included  in
the renewal permit to be issued this year which  will require compliance  by
July 1, 1984.

     An intensive survey of the lower reaches of the Black River from Elyria
to Lake Erie was conducted during tha summer of  1982.  These results, along
with the chemical/physical data collected by U.S. EPA, Eastern District  Office
will be used to assess the water use that can be achieved and to allocate  the
pollutant loads among the dischargers.  The data analysis and final report is
scheduled to be completed by September 1983.


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                                 138
     One hazardous material  site  in  Lorain  County, Chemical Recovery,  has been
cleaned up by the owners under a  consent  decree obtained  by the City of
Elyria.  A second site in Lorain  County,  Ford  Road Landfill,  is currently
being monitored and may be a candidate  for  clean-up, possibly with CERCLA
funds  ("Superfund").

ASSESSMENT

HATER

     NPDES permits, the pretreatment program  (Elyria), and enforcement (such
as the consent decree for Amherst)  should result  in the entities  involved
meeting Ohio's water quality standards.

     The natural  chemistry of the drainage  area end the current land use
patterns may preclude the river water from  attaining the  Agreement objectives
for Lake Erie.

SEDIMENT

     The reduction in pollution from point  source dischargers discussed above
should reduce significant deposition of additional pollutants.  Natural
physical and biochemical processes  are expected to, in time,  reduce the
contaminant levels.

FISH

     The elimination of sources of the contaminants found in  fish seems to  be
the only practical remedial  program  for ensuring  a healthy fish population.
The controls on dischargers  should  provide  a mechanism to eliminate the
contaminants.

GENERAL

     The remedial programs under  way should result in adequate controls of  the
discharges of wastewater into the river by  mid-1986.  There will  be a
residuals problem which will  require an additional 5 to 10 years  for natural
processes to correct.

INFORMATION SOURCE

     Additional  information  about environmental conditions and the status of
remedial measures may be obtained from:

         Ohio Environmental  Protection Agency
         P.O. Box 1049
         Columbus, Ohio  43216
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                                    1 39
CUYAHOGA  RIVER  (CLEVELAND), OHIO

ENVIRONMENTAL DATA

 SEDIMENT

      An extensive 1977  survey revealed that sediment from the Cuyahoga River
 is  polluted,  as is  the  majority of the sediment from the outer harbor.  Using
 EPA's "Guidelines for Pollutional Classification of Great Lakes Harbcr Sedi-
 ments", heavy contamination still exists for the metals arsenic,  cadmium,
 chromium, copper, magnesium, lead, and zinc.  The Guidelines are also exceeded
 for volatile  solids, chemical oxygen demand, total  Kjeldahl  nitrogen,  and  oil
 and grease.   Nonetheless, sediment quality is substantially  improved since
 1972.

      PCB levels in  both  river and harbor sediment samples exceeded 2.2 me/kg
 in  1977.

 FISH

      Because  of polluted conditions, the fish population remains severely
 depressed,  although carp, goldfish, and white sucker were actually caught  in
 the Cuyahoga  River  in 1980.  PCB levels in these fish ranged from 1.6 to 23.G
 mg/kg; the  FDA action level is 5.0 mg/kg.

 WATER

      Water  samples  collected at the river mouth in 1S78 exceeded the Agreement
 objectives  for dissolved oxygen, conductivity,  ammonia, mercury,  cadmium,
 copper, iron, manganese, zinc, and phenols.  The fecal  coliform level  exceeded
 the Ohio standard.

CAUSES AND REMEDIAL  MEASURES

      The Cuyahoga River  has been severely impacted by numerous municipal  and
 industrial  dischargers,  non-point urban runoff, and combined sewer overflows.

      The City of Akron  instituted a phosphate detergent ban  and is currently
 meeting the 1.0 mg/L phosphorus limitation in their discharge by adding
 polymers for  better solids removal.  The city is complying with an enforcement
 order that  requires them to upgrade and expand the treatment plant,  with a
 completion  date of  1986.  This upgrade will minimize the current problems  with
 combined sewer overflows and sewer system by-passes.

      The Northeast  Ohio  Regional Sewer District has three major wastewater
 treatment plants:   Easterly, Southerly, and Westerly.  There are construction
 programs under way  at all three facilities:

      1.  Easterly is currently meeting the phosphorus limitation, and the  rest
         of the construction is currently scheduled to be complete by 1983.

      2.  Southerly  is scheduled to have the phosphorus control facilities  in
         place by the end of 1982.  The rest of the construction is scheduled
         to be completed by 1985.
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     3.  Westerly is not meeting the phosphorus  limitation  and the schedule
         for needed facilities has slipped.   Facilities  are currently expected
         to be complete in 1983.

     In addition to the wastewater treatment plant expansions,  the District
has two large interceptor programs:

     1.  Cuyahoga Valley Interceptor is on schedule and  will  pick up the
         Summit County Macedonia plant in 1982.   The Phase  2 extensions to
         pick up Maple Heights and Cuyahoga  County S.D.#13  are scheduled for
         funding in September 1985,  with completion in 1989.

     2.  The Southwestern Interceptor slated to  serve Berea,  Brook Park,
         Middleburg Heights,  and NEORSD-Strongsville A is scheduled for
         funding by 1986, with completion in 1990.

     Wastewater treatment systems have been  installed at the major industrial
point sources in the estuary  to control conventional pollutants and
toxicants.   These facilities  are in compliance.   These facilities are being
reviewed to identify whether  additional controls are needed for other toxic
substances.

     The best available treatment guidelines for the iron and steel industries
have been issued.  The U.S. Clean Water Act  requires compliance by July 1,
1984.  The NPDES permits for  Republic Steel  and  for Jones and Laugh!in are
being reviewed to determine what additional  treatment may be required.

     The permits for the two  major che.nical  companies, du Pont, and Harshaw,
are also under review,  especially with respect to possible  toxic pollutants.

     Several hazardous waste  sites have been identified, closed, and/or
cleaned up.

     The Ohio Drum Reconditioning site was leased by L.  Gray Barrel & Drum
Company in November 1981.  There remains no  discharge from  this facility, the
marshy area having been diked.  Superfund money  is expected to be utilized for
clean-up of the PCB-contaminated marsh area.

     Approximately 3440,000  in Superfund emergency removal  monies have been
used to clean up the Chemical Mineral Reclamation site.   The final phase may
require an additional 5115,000.

     The Old Mill Creek site  clean-up is under way, with 400 of 1000 drums
removed.  Additional sites at Anaconda Avenue and Woodford Road Quarry are
under investigation.

     An intensive survey of the navigation channel of the Cuyahoga River  is
tentatively scheduled for 1985.  This survey will gather all the pertinent
information on biology, chemical and physical conditions of the water,
detailed information on dischargers and the altered geometry/hydrology of the
channel.  The survey will allow Ohio EPA to assess  the uses that are
attainable for the river and  develop wasteload allocations to enable those
uses to be achieved.
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                                  141
ASSESSMENT

 WATER

     Completion of the present remedial programs will  result in  improvement  in
 the  water  quality of the river.  However, achievement of high quality  water  is
 problematic  because of the extensive alteration of the stream geometry along
 with the intensive use as a navigation channel.

 SEDIMENT

     The improvement in water quality will result in less deposition of
 contaminants.  Enforcement actions, such as the Ohio Drum Reconditioning case
 in 1980 and  the identification of uncontrolled waste disposal  sites, will also
 reduce pollutants in the sediment.

 FISH

     The probability of the Cuyahoga River ever becoming a sport fishery is
 small.  However, with improved water quality and reduced pollutants  in the
 water and  sediments, fish may start to reappear.

 GENERAL

     There is inadequate information available to determine what water quality
 the  current  remedial programs will permit.  However, in light of the natural
 chemistry  of the drainage basin, the current intensive land use, and the
 greatly modified geometry of the navigation section of the river,  it is
 unlikely that the water quality in the river will ever meet the  Agreement
 objectives for Lake Erie.

INFORMATION SOURCE

     Additional information about environmental conditions and the status of
 remedial measures may be obtained from:

         Ohio Environmental Protection Agency
         P.O. Box 1049 -
         Columbus, Ohio  43216

ASHTABULA RIVER,  OHIO

ENVIRONMENTAL DATA

     Analyses of sediment, fish, and water samples collected from the  lower
 Ashtabula  River, the harbor area, the navigation channel, and the tributaries
 (Black Creek, Field's Brook, and Strong Brook) reveal  that this  heavily
 industrialized area has been and continues to be polluted.

 SEDIMENT
      Based on 1974 studies, Ashtabula Harbor was classified as polluted,
 because concentrations of volatile solids, total Kjeldahl  nitrogen,  chemical
 oxygen  demand, zinc, iron, manganese, chromium, and oil  and grease exceeded

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                                  143
     A group of major industries is located on Field's Brook,  a tributary to
the Ashtabula River in the navigable portion.   The industries  include Gulf and
Western Natural Resources Division, 01 in Corporation,  SCM Corporation,  Detrex
Chemical Corporation, General Tire and Rubber Company, and RMI, Inc.  The
discharge from these companies comprises the flow of the stream under low flow
conditions (the intake water is from Lake Erie).   All  of the companies have
installed treatment facilities to meet the 1977 requirements for the historic
sewage and toxic pollutants.  The treated wastewater could not achieve the
water quality standards for total dissolved solids,  and Ohio EPA eased the
standard for total dissolved solids from 1,500 to 3,500 mg/L for the brook
below the industries.

     01 in Corporation has closed its plant because the economics were no
longer favorable.   Detrex Corporation continues to operate its plant, for
limited production of hydrochloric acid and N-niethyl pyrrole.   The other
industries are being evaluated to see if additional  controls are needed,
especially to see if toxic pollutants are being discharged.

     The Detrex Chemical Company has an old dump  site  on its property.
Evidence shows that chlorinated organics are leaching  into the ground hater
and into Field's Brook.  Negotiations are under way with the company to
develop a program for clean up of the site.

     The contaminated sediment in Field's Brook is under study to determine
the best method of removal/containment.  A joint, cooperative  project with the
industry in the area is being discussed, with the option of using Superfund
monies as a back-up option.  Field's Brook is a priority site  on the Superfund
list; it is the only site where Superfund monies  are being considered for the
removal of contaminated sediment from a stream.

     The contaminated sediment in the navigation  channel of the Ashtabula
River will be dredged by the Corps of Engineers,  with  the material being
deposited at a secure disposal site.  An agreement among the various
governmental entities, the U.S. Army Corps of Engineers and the owners of the
preferred site is under active discussion.

     Hazardous waste sites were identified in the Ashtabula River drainage
basin:

     1.    Raser Tannery:  The company went into receivership  in 1980.  The
           site has been cleaned up with 233,000 of Superfund  money.

     2.    Poplar Oil/Laskins Waste Oil:  Superfund monies were used to remove
           some of the waste oils on an emergency basis.  A contractor has
           been selected and is currently av.aiting an award of £1.56 million
           to-clean up the site.

     Additional sites under review include Sitrex Chemical Co., Big D
Campground, North Kinesville Sanitary Landfill, New Lyme Township Sanitary
Landfill, and Detrex Chemical Co.
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                                    143  '


EPA's  "Guidelines for Pollutional Classification of Great Lakes Harbor
Sediments."

     An extensive 1979 study revealed the sediments in the navigation slip
near Strong Brook to be heavily polluted with zinc, lead, and oil  and grease.

     Sediments collected in Field's Brook in 1979 contained high levels of
chlorinated solvents, including hexachlorobenzene, polychlorinated butadienes,
ethanes, ethylenes, and benzenes, as well as benzo(a)pyrene and PCB.   These
are all U.S. EPA priority pollutants.  The sediments were also classified as
heavily polluted with mercury, arsenic, cadmium, chromium, copper, lead,  and
zinc,  all EPA priority pollutants.          ~ -

     Sediment samples collected in the navigation channel revealed
contamination with polychlorinated compounds, including 1,4-dichlorobenzene.
The metals arsenic, cadmium, and chromium were also present.

     A 1980 study in Field's Brook reconfirmed that the sediments  are heavily
polluted with mercury, arsenic, cadmium, chromium, lead,  and zinc.
Polychlorinated solvents present in the sediments included trichloroethylene;
1,1,2-trie Mo roe thane; tetrachloroethylene; 1,1,2,2-tetrachloroethane;
hexachlorobutadiene; plus others.  PCB is also present.

FTSH

     Fish collected from the Ashtabula River in 1976 contained a wide variety
of chlorinated organic chemicals, including several known to be toxic and/or
carcinogenic.  Compounds present include PCB, polychlorinated butadienes,
chlorinated propane, chlorinated prcpene, chlorinated styrenes, chlorinated
norborenes, and nexachlorobenzene.  No U.S. FDA action levels exist,  except
for PCB (5.0 mg/kg); the maximum PCB level measured was 7.2 mg/kg.

     A 1978 study confirmed these findings.  A 1979 study reported PCB
(maximum 45.3 mg/kg) and hexachlorobenzene as present. A 1980 study  again
confirmed hexachlorobenzene to be present.

WATER

     Water samples collected at the mouth of the harbor in 1978 exceeded
Agreement objectives for conductivity, mercury, cadmium,  copper, iron, and
fecal coliforms.

CAUSES AND  REMEDIAL  MEASURES

     The Ashtabula municipal wastewater treatment plant is probably the
principal source of the violations of the fecal coliform  objective due to a
lack of a chlorine contact tank.  Completion of construction of plant
improvements is scheduled for 1984.

     Acute, static bioassays were conducted for 24 and 48 hours on the
effluents in 1981, using daphnia as the test organism. The results showed
mortalities ranging from C% to 100%.   However, this species is sensitive
to total dissolved solids and it is suspected that the high salt content  of
the effluents caused most of the mortality.  Additional tests with other
organisms will be performed.
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                                    1 44
ASSESSMENT

WATER

     With respect to traditional  pollutants and toxicants,  the  improvement of
the municipal sewage treatment plant and the control  facilities  built by  the
industrial dischargers should result in improvements  to  the water quality.
The currently ongoing studies for other toxics must be completed and  decisions
made as to other controls required for industrial  dischargers before  any
assessment can be made as to overall improved water quality.

SEDIMENT

     Until the study of the removal  of the currently  contaminated sediments is
completed, it is not possible to  make any assessment  of  the effectiveness of
any remedial program to correct sediment pollution.

FISH

     If the water quality continues  to improve and if the contaminated
sediment is removed, the fish population in the area  should become healthier
and less contaminated.

GENERAL

     Significant progress has been achieved in the last  ten years in  improving
the water quality in the river basin.  In the early 1970's, Field's Brook was
a sterile watercourse because of  large discharges  of  chlorine in addition to
the chlorinated organic compounds and residues from the  titanium dioxide
refining processes.   In 1980, the major problems were corrected  and
pollution-tolerant fish have returned to the lower reaches  of Field's Brook
and the stream is meeting Ohio's  water quality standards.

     The upper reaches of the Ashtabula River are  relatively free of  pollution
except for infrequent iron, lead, and phenolic violations that  are suspected
to be from non-point sources.

     The estuary, despite the contaminated sediment,  is  an  important  spawning
area for many important Lake Erie fish.  Local sport  fishermen  and the U.S.
Coast Guard report salmonoid migrations and large  numbers of white bass in
this segment.

     The remaining problems are the  residuals problem and need  for additional
interpretation of the impact on human health, particularly  for  the
chlororganics, as well as continuing monitoring to assess the rate that
natural attrition is improving the water quality.

 INFORMATION  SOURCE

     Additional information about environmental conditions  and  the status of
remedial measures may be obtained from:

         Ohio Environmental Protection Agency
         P.O. Box 1049
         Columbus, Ohio  43216

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