.696
                                                            905K91001
                      U.S. ENVIRONMENTAL PROTECTION AGENCY

                GREAT LAKES POLLUTION PREVENTION ACTION PLAN



                                        April 12, 1991
         The United States is committed to ensuring a healthy Great Lakes ecosystem in which
         threatened species, such as the bald eagle, can successfully reproduce, and fish and
         wildlife are safe for consumption in unrestricted amounts. In order to achieve these
         environmental objectives, the levels of toxic substances found in the  Lakes must be
         reduced significantly.

         The United States Environmental  Protection Agency (EPA) and the Great Lakes States
         will implement an ambitious effort to reduce the levels of toxic substances found in tfie-
         Great Lakes Basin by promoting pollution prevention activities to significantly reduce
         or eliminate the use and/or release of toxic substances at the source, with a  special
         focus on reducing or eliminating persistent bioaccumulative toxic substances. Pollution
         prevention activities will complement current Great Lakes efforts to reduce toxics, such
         as placing stringent permit limits on generators of toxics and remediating contaminated
         sediments.

         In 1987, as part of the  Great Lakes Water Quality Agreement, the United States and
         Canada committed to strengthening efforts to achieve the goal of virtually eliminating
         the release of persistent toxic substances into the Great Lakes Basin environment.  This
         Pollution Prevention Action Plan  for the Great Lakes marks a concerted effort to turn
         this goal into a reality.

         Further, with  the adoption of the  national EPA Pollution  Prevention Strategy  and
         passage by Congress of the Pollution Prevention Act of 1990, EPA is firmly committed
         to promoting pollution prevention in every aspect of the Agency's operations.   The
         Pollution Prevention Act of 1990 declares as national policy that pollution prevention
         is the preferred approach to environmental protection: reducing or eliminating pollution
         through, for instance, changes in  production processes and/or by reducing reliance on
         environmentally harmful materials. When preventing pollution is not feasible, recycling
         in an environmentally safe manner is the next preferred option, followed by treatment.

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  Disposal or other release into the environment should be the management option of last
  resort, and should only be done in an environmentally protective manner.
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  EPA places a high priority on incorporating this hierarchy of options into all Agency
  activities  and on encouraging all sectors of society - including government, industry,
  agriculture, transportation, educational  institutions and  individual consumers - to
  incorporate pollution prevention into  their environmental decision-making  as well.
  Industry,  in particular, is increasingly aware that reevaluating products and processes
  for environmental reasons can lead to improvements that pay off competitively in lower
  costs and higher quality.  A commitment to pollution prevention is a commitment to
'  innovation - and innovation is the kef to a competitive ,U.S. economy.

  This Action  Plan  for  the Great Lakes highlights how  EPA will incorporate, in
  partnership with the States, pollution prevention into overall efforts to reduce the use
  and release of toxic substances in the Great Lakes Basin. These activities are designed
 ;to complement  efforts/already underway at the State and Federal levels.  The Great
  Lakes States have laid much of the groundwork for promoting pollution prevention by
  pursuing  a  wide range of innovative programs.   These include technical assistance
  efforts, demonstration projects, research programs, recognition of success through-
  awards., education efforts, training'initiatives, and facility planning requirements. Some
  States are also currently exploring ideas such as multi-media .permitting, incorporating
  pollution  prevention efforts  into enforcement activities, linking permit fees to toxic
•  generation rates, and addressing barriers to pollution prevention found in regulations.
  EPA will continue  to coordinate  closely with the States, provide funding for State
  pollution  prevention activities, and target efforts under this Action Plan to complement
  and enhance State initiatives throughout the Great Lakes Basin.

  This Action  Plan  has  two  distinct components.   First  it includes new initiatives
  designed  to promote innovative pollution prevention practices throughout the Basin.
  Second, it involves reorienting and refocusing existing activities, such as enforcement
 .actions,'to ensure  that pollution prevention  is  an integral  part  of government's
  environmental protection efforts. This Action Plan also builds upon the national EPA
  Pollution Prevention Strategy. The focus of the national strategy is reducing on-going
  generation  of toxic pollution  in any  form (air  emissions,  wasiewater discharges,
  hazardous waste, runoff, or fugitive releases)  through reduction  in the  use of toxic
  substances, process changes,, product changes, etc.   In  this Action Plan,  EPA, in
  partnership with the Stales and municipalities,  will:

  •   ».  Target, for  pollution prevention efforts,  particular pollutants, geographic
        areas and/or sources on the basis of their risk reduction potential, among
        other  factors.   Targeted pollutants will  include  substances of concern as

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       identified in Lakewide Management Plans (LaMPs)1  and in the Great Lakes
       Water Quality Initiative (GLWQI)2 as well as many  of the toxic substances
       identified in EPA's nationwide 33/50 Program (formerly called the Industrial
       Toxics Project).3  Pollution prevention efforts will also be targeted in select
       geographic areas including Northwest Indiana, the Niagara River, and Milwau-
       kee, Wisconsin in order to  concentrate a critical  mass of resources to achieve
       demonstrable environmental benefit.

       Set interim goals, on the  way to virtual elimination, for the reduction in
       releases  of targeted toxic substances  and  measure  progress.   Specific
       pollution prevention goals for persistent toxics will be  developed as part of the
       LaMP processes.  In addition, consistent with the goals of the 33/50 Program,
       this effort will focus on achieving 33 percent aggregate reduction of releases into
       all media of the 17 targeted 33/50 Program contaminants by the  end of 1992,
       with 50 percent aggregate reduction by the end of 1995.  These reductions will
       be measured using the Toxic Release Inventory (TRI), with 1988 as a baseline
       year.

       Focus governmental institutions and programs, and private sector efforts;
       on meeting these goals. This plan details several ways in which this focus will
       be achieved.

       Continue to integrate pollution prevention into existing regulatory and  non-
       regulatory efforts. Pollution prevention is being integrated into efforts such as
   1  Lakewide Management Plans (LaMPs) are multi-media plans being designed to restore beneficial
uses in ike open waters of the Great Lakes by reducing loadings of critical pollutants, such as persistent
toxic substances,  into the Lakes.  The development and implementation of a LaMP for each lake is
required under the Great Lakes Water Quality Agreement, as amended.  EPA is currently developing
LaMPs/or Lakes Michigan and Ontario. LaMP development for Lakes Erie, Huron, and Superior will
follow.

   2  The Great Lakes Water Quality Initiative (GLWQI) is an effort by EPA, the Great Lakes States,
and Indian tribes to establish uniform water quality criteria and related guidance for the Great Lakes
Basin.

   3  The 33150 Program (formerly called the Industrial Toxics Project) is an important element of
the national EPA Pollution Prevention Strategy.   Through this project, EPA  has targeted specific
chemicals that are reported and tracked in the  Toxic Release Inventory and will seek voluntary
reductions from the major industrial emitters.

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      the GLWQI, LaMPs, Remedial Action  Plans4, enforcement actions,  and the
      permitting process.

•     Ensure effective stakeholder involvement in all facets of this effort. This will
      be done through technology transfer workshops, demonstration projects and
      public outreach efforts.   Stakeholders for Great Lakes pollution prevention
      efforts include industry, agriculture, Federal, State, tribal, and local governments,
      public interest groups, and individual consumers.

Success with each of these elements  is critical to achieve the objective of reducing
and/or eliminating discharges of toxic substances into the Great Lakes.
TARGET POLLUTANTS, GEOGRAPHIC AREAS AND SOURCES

As  noted earlier,  EPA believes that  pollution prevention must be central  to the
Agency's environmental mission. For this reason, one of the primary objectives of the
national  Pollution  Prevention  Strategy  is  to incorporate fundamental pollution
prevention concepts into the broad array of Agency environmental activities.  At th>
same time, EPA believes it is important to establish specific objectives and time frames
to demonstrate success in critical areas. This plan details several targeted efforts for
the Great Lakes Basin. Specific pollutants, sectors, geographic areas and sources  have
been targeted.                   ...

Nationally, EPA has selected, through its 33/50 Program, 17 high priority pollutants as
the  focus of EPA's efforts for this voluntary pollution prevention  initiative;-' Hiese
chemicals were selected according to two basic criteria:  risk to human health and the
environment, taking into account health and environmental effects data, potential for
total exposure over time as well as potential for exposures to multiple toxic substances,
and opportunity for prevention. In 1991, EPA will focus initial toxic reduction efforts
in the Great Lakes on the 17 chemicals identified under the 33/50 Program.

Regionally,  specific pollutants  and  specific pollutant sources  will be  targeted for
pollution prevention efforts in each Lake through the LaMP process. Urilike the 33/50
Program which focuses on industrial  generators, all sources of preventable pollution
   4  Remedial Action Plans (RAPs) specify how contamination in specific Areas of Concern will be
remediated or cleaned up. Pollution prevention will protect current investment in cleanup activities by
ensuring that future releases of pollutants will not recontaminate an area. Whereas EPA has lead
responsibility for the development of LaMPs, states have the lead responsibility for the development and
implementation of RAPs.

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will be examined.  For each LaMP, the impact of agricultural and urban non-point
sources, industrial  sources  and municipal sources  will be  evaluated,   From the
evaluations, the LaMPs will establish load reduction strategies for each Lake.

Both the  Lake Michigan and Lake Ontario  LaMPs have  already targeted specific
pollutants for priority attention and consider persistent toxic substances candidates for
pollution prevention efforts.

In addition, EPA is using the Lake Michigan LaMP to target - for pollution prevention
efforts - substances that are currently  discharged, but are not yet  documented  as
impairing beneficial uses, Specifically:

•     By June 1991, EPA through the Lake Michigan LaMP process, will
      develop, for public review and comment, a draft list of candidate critical
      pollutants  of concern specifically for  Lake  Michigan,  containing
      information on their sources and making suggestions for pollution preven-
      tion activities (including recommendations for fast track actions). These
      activities will be closely coordinated with ongoing pollution prevention
      activities in the Great Lakes Basin.

•     By September 1991, EPA will develop the final list  of these pollutants
      and suggestions for appropriate pollution prevention activities (including
      recommended fast track actions) to address these pollutants.

In addition  to targeting  by pollutants and source, several geographically focussed
initiatives are underway for pollution  prevention such as the Agency's  efforts  in
Northwest Indiana and in the Niagara area. EPA. will also support the local initiative
underway in Milwaukee. These are described in more detail elsewhere in this Plan.
SET REDUCTION GOALS AND MEASURE PROGRESS

EPA believes that it is important to set performance goals in order to focus effort and
measure  progress.  Since it is  important to have specific  goals, the Great Lakes
pollution prevention effort will be guided by lake-specific, multi-media reduction goals
set through the LaMPs and the national 33/50 Program goals.

The  LaMPs will establish goals for reducing  generation  of  specifically targeted
pollutants.  Pollution prevention goals in the LaMPs  will target loadings from all
sources of pollution, including  non-point, non-industrial  sources that represent an
important part of the overall pollution problem for each of the Lakes.

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As noted earlier, the 33/50 Program establishes two goals:  first, 33 percent reduction
of TRI releases of targeted contaminants by the end of 1992; with 50 percent reduction
by the end of 1995. These goals are aggregate goals and are not intended to apply to
individual facilities, which may achieve reductions either above or below the aggregate
goals.

EPA will  take the lead in working  to  improve the  ability  to  measure pollution
prevention success.  Unlike the overall environmental protection strategy for the Great
Lakes Basin which  measures success in terms of concentrations of pollutants in fish
and wildlife, reductions  in  overall pollutant loadings into  the Lakes, and protec-
tion/restoration of critical habitats,  this Pollution Prevention Action Plan is tightly
focused on reducing the on-going releases of pollutants.  Thus its primary and most
direct measure of success is tied to reductions in the amount of pollutants released into
any media.  EPA will track progress toward the pollution prevention goals using the
TRI data base as the initial benchmark against which to measure reductions, while also
working to establish environmental indicators to measure progress in restoring the
overall health and well-being of the Great Lakes ecosystem.  Specifically, EPA will:

Measure Reductions              ,.-•;'«'•'    "                                  .  "--
•     Use TRI, with 1988 data as a baseline year, as a benchmark against which to
      measure reductions in releases.  Under the Pollution  Prevention Act of 1990
      generators  are required,  as part of  the  TRI  report,  to provide information
      regarding toxic chemical  source reduction and recycling.

•     Explore using other information  sources as interim indicators of progress.

Establish Environmental Indicators
•     Develop ecosystem  objectives  for  Lake  Michigan by  September  1991.
      Ecosystem objectives  for Lake Ontario were proposed  in May  1990 and are
      pending approval by Environment Canada, EPA, New York,  and Ontario. Draft
      Lake Ontario ecosystem indicators  will  be ready for public  comment by
      September 1991.

•     Continue annual collection and  analysis of persistent  toxic substances in fish
      from each of the Great Lakes. Sampling will be completed by September 1991.

•     Conduct exploratory toxicant monitoring by September 1991 in Lakes Michigan
      and Ontario to obtain preliminary estimates of toxic  substances in the water
      column.

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      Identify what data will be needed to assess ecosystem responses to reductions
      in pollution levels; these data will be collected as part of a revised and integrated
      Great Lakes long-term monitoring program by September 1991.
FOCUS INSTITUTIONS:     THE GREAT LAKES POLLUTION
                              PREVENTION CHALLENGE

This Action Plan will focus governmental institutions and programs and private sector
efforts on achieving these reduction  goals.  In addition to a cleaner environment,
cleaner  production is  being  recognized  as the key  to international  competitive
advantage.  It is important that industries in the Great Lakes Basin are seen as leaders
in the field of clean production, for the benefit of both the Great Lakes environment
and the  region's economic base. Participating in the Great Lakes Pollution Prevention
Challenge is one way of establishing that leadership.

The Great Lakes States, in cooperation with EPA, will issue the Great Lakes Pollution
Prevention Challenge to all sectors of society through outreach activities, such as
mailings, newsletters, and briefings. The States and EPA will challenge these sectors
to use prevention techniques to achieve reductions in generation of toxics; to develop
new technologies, tools and techniques to prevent pollution; and to begin to establish
informatio» and supplier networks necessary to make pollution prevention widespread.

Specifically to launch this effort, the States and EPA will challenge:

            industrial  generators in the Great Lakes Basin to incorporate pollution
            prevention as the preferred strategy for meeting environmental goals;

            agricultural generators to incorporate  pollution prevention into fanning
            practices (e.g., organizing  collection programs for  unwanted/canceled
            pesticides);

            colleges and universities in the region to incorporate pollution prevention
            into their engineering, business, and related curricula;

            Federal and  State governments to promote incorporation of pollution
            prevention concepts into environmental decision-making;

            cities, counties and towns to develop  programs that facilitate pollution
            prevention choices for the community  (e.g. prevent toxic contamination
            of urban stormwater,  and/or promote energy conservation);

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            environmental groups to promote pollution prevention to their member-
            ships and through their activities; and,

            individual consumers to incorporate pollution prevention into their day-to-
            day decisions, including, but certainly not limited to, minimizing use of
            household toxic substances and generation of household hazardous waste.

In July 1991, EPA and the States will conduct outreach to encourage participation in
the Challenge. The States will develop a regional award program for the Great Lakes
Pollution Prevention Challenge, modeled after the Baldridge award for quality. Like
the Baldridge award, this award program will have tightly-defined criteria and will be
designed in conjunction with industry and research organizations. The most innovative
and/or successful projects  will be  selected  for Great Lakes Pollution Prevention
Challenge Awards. At the time that the Challenge Awards are announced, there will
also  be  public  recognition  of  all businesses,  farms,  communities,  universities,
environmental groups and individuals that have come forward and agreed to meet the
Great Lakes Pollution Prevention Challenge.

As part of this Challenge, the States and EPA will convene a working  group to
examine incentives and disincentives to pollution prevention, especially in the legal  and
regulatory systems.  This working  group will include participation  from industry,
communities, and environmental groups, at  a minimum.   The working group will
evaluate  the  extent to which increased regulatory flexibility can help to promote
prevention.  Such an evaluation would  include, but not be limited to, incentives for
experimental processes and technologies, and incentives to go beyond environmental
regulatory requirements.

In addition, this  Challenge will  provide  the framework  for the four major  new
EPA/State initiatives  (Automobile Industry, Lake Superior, Urban Non-Point Source
Pollution, and the International Pollution Prevention  Symposium),  as well as other
initiatives that will be developed in the future.
WEAVE   PREVENTION  INTO  THE  FABRIC  OF  ENVIRONMENTAL
PROGRAMS

It is important to fully integrate pollution prevention into all environmental programs
so that  reductions in one media are  not  offset by increases in others.  Pollution
prevention activities have been included in environmental programs for many years.
Now, however, the increasing emphasis on pollution prevention as the cornerstone of

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environmental protection efforts is driving environmental program managers to reassess
their programs to ensure that pollution prevention is an integral part of all efforts. A
key component  of this Action Plan is  ensuring  that the  countless opportunities to
promote pollution prevention are being fully utilized throughout EPA and State
programs.  Specifically, in 1991:

•     The  States and EPA will continue to place a high priority on the Great Lakes
      Water Quality Initiative in order to establish consistent Great Lakes States Water
      Quality standards and  implementation procedures.  Compliance  with such
      standards  will provide an opportunity to adopt prevention technologies.

      The timeline for the GLWQI, as established in the Great Lakes Critical Programs
      Act of 1990, is as follows:

            by  June 30, 1992, EPA will publish final water quality guidance
            for  the Great Lakes system in the Federal Register; and

            within two years after the  final  guidance is published, the Great
            Lakes States will adopt water quality standards, anti-degradation
            policies, and implementation procedures within the Great  Lakes
            system which are consistent with that guidance.

9     EPA recognizes that training is needed to help institutionalize prevention as the
      strategy of choice in all environmental decision-making and protection activities.
      EPA is developing specialized courses designed for government employees and
      industry.  In  addition, EPA will  develop pollution  prevention training for its
      permit writers, using a cross-media, ecosystem focus. This training will consider
      cross-media impacts and options for promoting pollution prevention in the EPA
      permitting process.

•     EPA will  incorporate pollution prevention into stepped-up enforcement efforts
      for the Northwest Indiana area, the Niagara River, and other  areas throughout
      the Great Lakes Basin, as appropriate.  In Northwest Indiana, for example, EPA
      is actively negotiating to incorporate pollution prevention commitments  into
      consent agreements.  In the  Niagara  River, all industrial sources of toxic
      substances will  be closely examined  to ensure that pollution prevention is
      considered for implementation and incorporation into enforcement actions.

*     EPA and the States will incorporate pollution prevention,  as appropriate, into the
      Remedial  Action Plans (RAPs)  for Areas of Concern in the  Great Lakes.
      Pollution prevention activities will ensure that a remediated area will not become

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recontaminated by on-going pollution generation.  EPA  and the States will
provide pollution prevention training for Regional RAP coordinators and RAP
stakeholders.

EPA, in cooperation with  other  Federal  agencies,  will promote pollution
prevention in the agricultural sector in order to reduce non-point source loadings
into  the Great Lakes. Programs to promote conservation tillage and to assess
overall  farm practices are already in operation  and will be enhanced.   In
addition, EPA is  producing  technical assistance materials  for farmers to  help
them reduce surface and groundwater contamination from agricultural practices.
These materials will stress that good environmental practices also make good
economic sense.  Some of these materials are currently available,  while others
will  be released during the year. This project will be completed by September
1992.

EPA will work with local governments to incorporate pollution prevention into
their programs and responsibilities in two different ways.

First, EPA will work with Rochester, Minnesota  to pilot a household battery"
recycling project.  Batteries  are a source of air toxic emissions if incinerated
with the general municipal solid waste stream. Community outreach and educa-
tion material will  be prepared. EPA and the community will prepare a "lessons
learned" report to summarize program implementation and results, particularly
the procedures to establish the  recycling program, and the environmental and
economic benefits that are realized.

Second, EPA and Wisconsin will support the Greater Milwaukee Area Toxic
Minimization Task force  in its effort to  develop and implement an overall
strategy to promote pollution prevention in the region, including programs for
education and outreach.  This task force  is composed of members of city
government, industry, universities, business, environmental groups,  and the local
sewerage district.

EPA will support  Wisconsin's effort to develop a statewide pollution prevention
strategy  and integrate  pollution prevention into all environmental quality
programs.   The strategy will focus on specific actions that individuals and
industries across the state can take to improve waste management.  It will foster
technology transfer,  innovative approaches and financial assistance for waste
reduction particularly among small  and medium-sized businesses.  Primary
emphasis will be directed at facilities that generate toxic  pollutants, use tox-
ic/hazardous substances and/or generate hazardous waste.  The program will

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promote pollution prevention as the best way of complying with new toxic air
and water quality regulations.

In  order to  involve  labor and management fully in cooperative pollution
prevention activities within industry's environmental programs, EPA will support
the work of the Great Lakes Strategy Board (convened by the Council of Great
Lakes Governors) which is charged with identifying and reporting on the "best
labor/management practices" that foster pollution prevention.

To promote adoption of pollution prevention practices by industry, agriculture,
and the public, EPA and the Great Lakes States will sponsor over 25 technology
transfer conferences or workshops this year.  In addition, EPA and the States
will disseminate  pollution prevention information  through activities such as
EPA's Pollution Prevention Information Clearinghouse, an electronic database.

EPA has initiated the Pulp and Paper Regulatory Ouster.  Hie purpose  of this
cluster is to develop an integrated regulatory framework in which all relevant
regulations affecting the pulp and paper industry, such as revised effluent guide-
lines and Gean Air Act regulations, are considered together to ensure maximum-
policy consistency and optimal environmental results. In addition to examining
regulations in an integrated fashion, the purpose of the cluster is to raise cross-
media  issues  and to  consider pollution prevention and  other  non-traditional
approaches to environmental management.

EPA is launching four major new initiatives with the Great Lakes States.  These
initiatives were chosen because, together, they address the broad spectrum of
pollution prevention opportunities available in the Basin.

First, in a public/private initiative, EPA and the States will work in conjunction
with Chrysler, Ford  and General  Motors  to  promote voluntary pollution
prevention  of persistent  toxics that negatively impact the Great  Lakes in a
significant  way.  These automobile companies recognize  the  importance of
protecting the Great Lakes ecosystem and acknowledge  the  goal of reducing
discharges of persistent toxics that significantly impact the Great Lakes.

•     These automobile  companies will participate with EPA, the States, and
      other appropriate  parties in a  basin-wide  effort  to determine  which
      persistent  toxics are of greatest concern to the Great Lakes ecosystem.
      Once priority persistent toxics have been identified, these companies will
      evaluate which of those materials are in use in their operations.
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•     These automobile companies will identify their past efforts to reduce the
      use and generation of these toxics; establish priorities among the materials
      of concern for additional in-house pollution prevention efforts; .and work
      with their suppliers  to promote pollution prevention efforts for persistent
      toxics.

•     Further, these companies will participate in technology transfer forums to
      share non-proprietary information on pollution prevention techniques and
      success stories; and participate in similar forums to share information
      about their efforts to establish pollution prevention thinking and actions
      within their companies.

•     In addition, these automobile companies commit to continue exploring
      new pollution prevention opportunities within their facilities for waste
      streams of concern  to their companies.

As the second major initiative, EPA, in partnership with Minnesota, Wisconsin,
and Michigan, will work cooperatively on pollution prevention efforts on Lake
Superior.   Lake Superior has not  experienced  the intensive  development^
urbanization and pollution characteristic of the lower Lakes and has remained
relatively pristine. It is the head of the Great Lakes System and does not receive
pollution from the other Lakes.

Although  it is the largest  of the Great Lakes, Lake  Superior is also the most
vulnerable to pollution from toxic substances, since toxics tend to remain longer
in Lake Superior and once degradation does occur, it takes a longer time for the
Lake to recover.

The U.S. believes that focusing attention on the Lake Superior Basin will build
upon the considerable interest within the Great Lakes community for cleaning
up Areas of Concern and protecting the rest of this valuable resource from
degradation.  Public interest  also supports the International Joint Commission's
call  for strong  measures  designed to protect  the Lake.  In support of the
initiatives, EPA and the Lake Superior States are committed to:

      Reducing the quantity of persistent toxic substances entering the Lake by
      building  upon  and  accelerating  existing  environmental  protection
      programs such as RAPs within the Lake Superior Basin; and preserving
      the high quality waters of the Lake by developing and reaching agreement
      on  common anti-degradation procedures and  programs with the Great
      Lakes jurisdictions.

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•     Developing an inventory of basin wide impairments and a consensus on
      Lake Superior "critical11 pollutants using a consultative process involving
      stakeholders.

•     Establishing an improved international air toxic monitoring network in the
      Lake Superior Basin and conducting modeling to identify major local and
      distant source areas impacting the  Lake.  This is needed because Lake
      Superior is particularly vulnerable to atmospheric deposition of toxic
      substances due to its large surface  area and slow rate of sedimentation.
      The monitoring network and modeling will enable the U.S. and the Great
      Lakes jurisdictions to identify the pathways and sources of persistent toxic
      substances entering Lake Superior and to design pollution prevention
      techniques for their elimination.  In addition, this information will support
      development  of the Lakewide Management Plan.

•     Reviewing and strengthen existing environmental criteria for water and air
      programs  and their implementation to ensure that they are adequate to
      protect the Lake.

•     Supporting Minnesota's and Wisconsin's efforts in working with the St.
      Louis River RAP citizen committees and private sector in developing a
      multi-media pollution prevention approach to eliminate or reduce major
      sources of discharge to the western end of Lake Superior.

•     Supporting Minnesota's Lake Superior Project which  will consist of a
      multi-media  inspection/compliance initiative  with  an emphasis  on
      pollution prevention. This project  is geographically focused within the
      Lake Superior basin and includes the service area of the Western Lake
      Superior Sanitary District,  home to most  of the  major industries in
      Minnesota's portion of the Lake Superior basin.

As the third major initiative, EPA and  New York will launch pilot programs in
pollution prevention for urban non-point sources.  In order to focus on the
prevention of urban non-point source discharges in the small quantity generator
and household hazardous waste areas,  EPA will support New York's efforts to
conduct three pollution prevention projects.  Specifically:

•     New York will conduct an intensive consumer education campaign on
      household hazardous waste use, disposal and reduction in conjunction
      with county and municipal governments (Monroe County/Rochester, Erie
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            County/Buffalo,  Niagara County/Niagara  Falls and Jefferson  Coun-
            ty/Watertown).

      •     In addition, within these communities fact sheets will be developed to
            inform the public of the potential dangers of lawn chemicals and to assist
            them in making responsible lawn maintenance choices.

      •     New York will  also work with smaller  towns in these counties to help
            identify non-point pollution sources. New York will develop guidance
            documents to help local officials discern the origin of non-point source
            discharges as well as to outline  potential local courses of action which
            may be implemented in order to ensure the reduction of such discharges.

      As the fourth major initiative, EPA and Environment Canada will co-sponsor an
      International Pollution Prevention Symposium  in conjunction with the Interna-
      tional Joint Commission meeting in the fall of 1991 to highlight the advances
      made in pollution  prevention under this  Action Plan  and through Canadian
      activities, and to establish the agenda for future pollution prevention efforts. -
ENSURE STAKEHOLDER INVOLVEMENT

EPA believes that a broad-based public commitment to pollution prevention is essential
to ensuring the long-term health of the Great Lakes ecosystem. To this end, EPA will
look to the Great Lakes stakeholders: States, tribes, regional organizations,  industry,
trade associations, academia, environmental groups and interested citizens to 'spread
the word' and to enlist support for its initiatives.  Specifically:

•     EPA will compile TRI information regarding releases of targeted toxic chemicals
      by key industries into the Great Lakes Basin. This information will be  available
      to the public in September 1991.

•     EPA will work to enlist stakeholder support as part of on-going LaMP efforts.
      By September 1991, EPA will convene the  Lake Michigan Lakewide Advisory
      Council,  which will include government and public representatives; to provide
      input into the development of the  Lake Michigan LaMP.  For Lake Ontario, the
      existing planning  process  under  the  Lake  Ontario Toxics Management Plan
      actively solicits input from all stakeholders and keeps  them  informed of its
      progress.
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      EPA will support the Council of Great Lakes Governors in its efforts to enhance
      the involvement  in pollution prevention by  all stakeholders, including State
      agencies,  environmental groups  and the private  sector.   The Council will
      coordinate with existing pollution prevention networks throughout the region to
      disseminate information about the full range of pollution prevention initiatives,
      from local public education campaigns to industry-specific technology transfer
      efforts.

      The International Pollution Prevention Symposium, discussed above, will present
      an opportunity to share information regarding pollution prevention activities with
      stakeholders in the Great Lakes Basin and to solicit input  into ongoing and
      future activities.

      Finally, EPA, working with the States, will recognize  the contributions  of
      participants  of the Great Lakes Pollution Prevention Challenge at the September
      1991 International Pollution Prevention Symposium.
CONCLUSION

Achieving environmental quality in an industrial society is an immense challenge and
the improvements in the quality of the Great Lakes over the last 20 years are a credit
to all citizens of the Basin.  The time has come now to expand our focus to include
preventing pollution at the source.  This Great Lakes Pollution Prevention Action Plan
outlines the  "next steps" that EPA will be taking, in full cooperation and partnership
with the Great Lakes States, with industry and agriculture, and with all citizens of the
Basin, to create a better environment and to ensure the viability of long-term economic
development in the region.  EPA is proud to launch this initiative and looks forward
to making these cooperative efforts of the Great Lakes Basin a model for the world on
how to achieve both the highest level of environmental protection and  a prospering
economy.
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