00403
1 Su"' OOOR88002
I September 20, 1988
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| SUMMARY REVIEWS OF REMEDIAL ACTION PLANS
_ INCLUDING COMMENTS OF INDIVIDUAL REVIEWERS
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GREEN BAY 1
RIVER RAISIN 37
MANISTIQUE RIVER 95
TORCH LAKE 117
WHITE LAKE H7
DEER LAKE 167
MUSKEGON LAKE 193
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September 20, 1988
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SUMMARY REVIEWS OF REMEDIAL ACTION PLANS
INCLUDING COMMENTS OF INDIVIDUAL REVIEWERS
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GREEN BAY 1
I RIVER RAISIN 37
MANISTIQUE RIVER 95
TORCH LAKE 117
I WHITE LAKE 147
DEER LAKE 167
I MUSKEGON LAKE 193
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I U.S. Environmental Protection Agency
dLNPO Library Collsction (PL-1ZJ)
77 West Jackson Boulevaid,
. Chicag"."- 60604-3590
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May 11, 1988
HATER QUALITY PROGRAMS COMMITTEE
CO-ORDINATED REVIEN
of the
REMEDIAL ACTION PLAN
for
LOWER GREEN BAY
Preface:
This Remedial Action Plan (RAP) was prepared under the guidelines
prescribed by the Nater Quality Board (WQB) before the signing of the Accord
of 1987 which amended the GLNQA of 1978. Therefore, this review assesses the
adequacy of this RAP against the original WQB guidelines. The WQB guidelines
were amended somewhat as they were Incorporated into the Accord, and these
changes in structure will be recognised 1n the final statement regarding the
way in which this RAP fits into the three phases of the new RAP guidelines in
the amended Agreement.
Participation:
This coordinated review brings together the individual reviews of various
members of the WQPC committees, so as to provide a wide range of expertise in
reviewing the various technical details of the RAP.
Reviews (attached) were received from the following:
Surveillance Work Group
Point Source Sub-Committee
G.R. Lowry U.S. FWS
G. Sherbin Can. DOE
V.O. Saulys U.S. EPA
Non Point Source Sub-Committee J. Bredin Mich. DNR
J. Nowland Can. Agr.
G. Wall Can. Agr.
D. Persaud Ont. MOE
0. Reinert U.S. EPA
Sediment Sub-Committee
Toxics Sub-Committee
Science Advisory Board
A.M. Beeton U.S. NOAA
J. Vallentyne
Great Lakes Fishery Commission C. Fetterolf GLFC
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STAGE 1: WHEN A DEFINITION OF THE PROBLEM HAS BEEN COMPLETED UNDER
SUBPARAGRAPHS 4(a)(1) and (11).
1. Are the goals and objectives clear and concise? I
Most of the reviewers agreed that the goals and objectives are clear
and concise 1n a descriptive sense. For point sources, however, there
remains the need for quantifiable goals 1n terms of both loadings and I
concentrations. The descriptive, ecosystem type goals are appropriate from a
user point of view, but with few quantifiable objectives 1t will be very «
difficult to measure progress.
2. Are the goals and objectives consistent with the specific goals of the I
1978 GLHQA?
The GLWQA specific goals (Specific Objectives) are not addressed
directly. Most of the RAP objectives are consistent with Agreement
objectives. The target concentration of phosphorus, however, 1s ten to
fifteen times as high as that recommended for Lake Michigan. Historically, m
Lower Green Bay always has been somewhat eutrophic. The phosphorus
concentration target will return the lower bay to the conditions of the
1940s which 1s a reasonable objective.
3. Is the Information base sufficient to adequately define the problems
and Identify the causes?
The problems have been Identified in a descriptive way, from the point
of view of the user. This reflects the high level of public participation 1n _
developing the RAP. Specific problems are Identified but not quantified 1n
many cases. For example, contaminated sediment 1s Identified as the source
for most of the PCBs but the current concentration of toxics 1n the sediment
is not reported. Rather, the fact that there 1s a fish consumption advisory
1n effect due to higher than acceptable levels of PCB, 1s used to define the
problem, and contaminated sediments are identified as the most important
cause. Many Areas of Concern share this difficulty regarding appropriate M
objectives and remedial actions for contaminated sediments.
The sub-section on Land Disposal Areas should be renamed "Known or
Potential Sources of Ground Water Contamination". There are many sources of
ground water contamination besides landfills. Also, limiting the inventory
of known or potential ground water contamination sites of concern, to those
within 1/4 mile of the Lower Fox River or Lower Green Bay, may be
Inappropriate.
The lack of detailed characterization of the major industrial point
sources and the current level of remedial action are serious weaknesses of
the RAP.
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STAGE II: HHEN REMEDIAL AND REGULATORY MEASURES ARE SELECTED UNDER
SUBPARAGRAPHS 4(a)(111), (1v), (v), and (vD.
4. Are the Identified remedial actions sufficient to resolve the problems
and restore beneficial uses?
The "Key Actions" 1n the RAP are a mixture of remediation and
Investigation. In some cases the timing and technology of the remedial action
1s dependent on the outcome of some of the projected studies.
From a point source perspective, no clear connection or linkage 1s made
between point sources and beneficial use Impairment. While not stated
explicitly, 1t 1s assumed that the water quality standards and effluent
setting procedures will be consistent with the Specific Objectives of the
GLWQA.
5. Are these actions consistent with the stated goals of the RAP?
Yes! The "Key Actions" relate directly to the "Goals and Objectives" of
the RAP.
6. What beneficial uses, 1f any, will not be restored? Does the RAP Indicate
why?
The RAP acknowledges that a return to a "pristine" environment 1s not
feasible. Many of the natural marshes have been destroyed. The RAP does
propose to achieve the flshable, swlmable, drinkable uses. The new population
of fish 1n the bay will be a more deslreable assortment of species, from a
human user point of view, but It would be very difficult to document the
restoration of all of the original species. Permanent loss of some marshland
habitat will have a lasting Impact on the fishery.
7. Is the Identified schedule for Implementation of the remedial actions
reasonable?
Target dates are given for many of the "Key Actions" and these appear to
be realistic. In many cases, however, the "Key Action" 1s not a remedial
action, but rather a study or data gathering activity. The "Action
Recommendations" detailed within the "Key Actions" do identify specific
remedial actions.
8. Have the jurisdictions and agencies responsible for Implementing and
regulating remedial measures been Identified?
In many cases a number of agencies are Identified as sharing
responsibility for a remedial action. A shared responsibility often results in
no responsibility. A shared activity needs to be broken out Into pieces that
can be undertaken by Individual agencies or "work shared" under a formal
multi-agency agreement. We understand that specific agency responsibility
currently 1s being negotiated.
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9. Have studies necessary to complete the RAP been Identified and have
schedules for their completion been established?
Yes! Many ongoing and new studies are required by the RAP. In most cases m
a time target has been stated.
10. Is the proposed monitoring and surveillance program sufficient to
document Improvements as a result of the remedial action Implemented and
confirm the restoration of beneficial uses?
Yes! The monitoring and surveillance program 1n the Plan should be I
sufficient to document Improvements as a result of the remedial actions
Implemented and confirm the restoration of beneficial uses.
11. Has there been adequate and appropriate consultation with the public?
This clearly 1s the strongest aspect of this RAP. The public has been |
Invited to participate 1n the development of the RAP from the very beginning.
Due to this active Involvement, there has developed a very strong public «
support for the proposed remedial actions.
STAGE III: HHEN MONITORING INDICATES THAT BENEFICIAL USES HAVE BEEN RESTORED
UNDER SUBPARAGRAPHS 4(a)(v11) and (v111).
Stage III requirements await Implementation of the RAP.
SUMMARY OF PROS AND CONS
PJPQS:
The RAP 1s well written and logical 1n Its format. Consultation with the
public has been exemplary, with formal and Informal forums to discuss every
phase of the RAP development. The various "stakeholders" also have been
Involved.
The goals and objectives have been developed from an ecosystem
perspective and the Key Actions are related directly to the Goals.
Agencies responsible for remedial actions have been Identified and I
associated costs have been estimated. Agency specific responsibilities are
being negotiated.
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Cons:
One of the major weaknesses of the RAP 1s the qualitative rather than
quantitative nature of many objectives. This win make It very difficult to
monitor the Implementation of the remedial measures and especially the
response of the system.
Responsibility for 'Remedial Actions' 1s assigned to a group of agencies
Instead of targeting Individual agencies for specific tasks. This weakness 1s
being addressed at the present time.
Significant groundwater contamination from sources other than "Land
Disposal Areas within 1/4 mile of the river or bay" have been overlooked.
There 1s a lack of detailed characterization of point source effluents
and an evaluation of current remedial measures.
OVERALL RATING
The Lower Green Bay Remedial Action Plan Is a very good attempt to
combine significant public involvement and an ecosystem approach 1n developing
a working document. It 1s well done as far as 1t goes, but 1t lacks
quantification and currently does not charge specific agencies with specific
tasks.
H1th reference to the six categories of the WQB guidelines, this RAP,
generally, 1s 1n category 4. That 1s:
4. Causative factors known and RAP developed, but remedial measures not
fully implemented.
However, it 1s recognised that for the toxic substances Issue -
particularly contaminated sediments, the RAP is still being developed. Also,
specific agency commitment has not been Identified. Therefore, 1t must be
placed in the third category also. That is:
3. Causative factors known, but RAP not developed and remedial measures not
fully implemented.
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POSITION NITHIN THE NEW THREE STAGE PROTOCOL
Stage 1 requirements have been met, but the precision of the objectives
could be Improved with some additional quantification.
Stage 2 requirements have been partially met, but the RAP needs better
data on the evaluation of remedial measures 1n place, and could benefit from a
better means to measure progress toward the objectives. Also, there needs to
be specific agency responsibility for each remedial action required, as well
as a timetable for achievement.
Stage 3 requirements await the results of the RAP.
RECOMMENDATIONS
The authors of the RAP are to be congratulated on the very significant
work, accomplished to-date and encouraged to continue the process 1n order to
remedy the deficiencies noted.
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United States Department of the Interior
FISH AND WILDLIFE SERVICE
P«OBRAL BULONO, POUT 8NHJJNO
WIN CmeS, M**80TA 88111
FWS/AE-ES
APR 6 1988
Dr. E. T. Wagner
Chairman, Surveillance Work Group
International Joint Commission
P.O. Box 32869
Detroit, Michigan 48232-2869
Dear Dr. Wagner:
We provide these comments, as requested, through our participation on
the Surveillance Work Group. The Lower Green Bay Remedial Action Plan
(Plan) was prepared under the protocol prescribed by the Water Quality
Board before the signing of the accord of 1987 which amended the Great
Lakes Water Quality Agreement of 1978. Accordingly, this Plan was
reviewed relative to the original Water Quality Board review process.
We believe the goals and objectives of the Plan are clear and concise.
They are consistent with elements of the Desired Future State of the Fox
River/Lower Green Bay system identified early in the plan development
process and are generally consistent with the policy as well as general
and specific objectives of the 1978 Great Lakes Water Quality Agreement.
The Plan has taken an ecosystem approach in determining remedial action
needs, thus, the goals are directed toward ecosystem rehabilitation.
The Plan states that its goals describe "...a rehabilitated ecosystem
that is a compromise between full restoration and continuing
degeneration" and that "...the goal of rehabilitation Is to halt any
further degradation and actually reverse the process to regain a more
desirable environment." We believe that the Plan's approach is
realistic and that fish and wildlife resource concerns have been
adequately incorporated into its goals and objectives.
An extensive Information base was available from which to define
problems and general causes; however, no individual entity(ies) can be
identified as responsible or targeted to accomplish remedial action.
Pollution problems have developed in the Fox River/Lover Green Bay over
a long period of time. They can be related by category to general point
source and nonpolnt source origins. Municipal and industrial vastevater
discharges, surface water runoff from agricultural and urban/industrial
areas, and abandoned landfills have all contributed over time. The long
term nature of deposition and discharges has, in itself, caused a major
problem of in-place contaminated sediments and hypereutrophlcaelon of
the bay. Wetland habitat losses due to filling and development have
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Dr. E. T. Wagner z
further contributed to the degradation of aquatic resources. These
primary factors and other contributory influences are identified and
discussed within the plan, and fully considered in developing plan _
recommendations,
The remedial actions Included in the Plan were developed to respond to
the Plan goals and have done so consistently. If these actions are
carried out, we believe that beneficial uses can be restored. Relative
to our principal Interest in fish and wildlife resources, with reduction
of toxic chemical availability from sediments, reduced phosphorus and
sediment loads, virtual elimination of toxicity of wastewater
discharges* wetland protection and habitat management* and fisheries
management to achieve balance and diversity of species and populations
It would be possible for a healthy ecosystem to be restored. The
monitoring and surveillance program in the Plan should bs sufficient to
document improvements as a result of the remedial actions implemented
and confirm the restoration of beneficial uses.
No studies are necessary to finalize the Flan, as such. There are,
however* a number of studies Included ss a first step in carrying out tm
various remedial actions. Included are feasibility/engineering studies
for removal of phosphorus and algae from Fox River waters* and to
determine the best approach to reduce availability of in-place _
contaminants; studies to evaluate sediments to determine mass*
concentration* and transport into the Fox River and from the Fox River
into Green Bay; feasibility studies for wetland management actions; and
a study to evaluate the importance of carp in the ecosystem and
effectiveness of harvesting or management options. |
All of the studies and remedial actions have been assigned a target year M
for completion. That level of scheduling should be sufficient for the
types of actions Included. The schedule for implementation of the Plan
Is generally reasonable-provided-adequate funding Is obtained.
Completion of some actions .will be dependent on the results of related
outside efforts such as the U.S. Environmental Protection Agency's Green
Bay Mass Balance Study or State administrative actions to establish
requirements for dredged material disposal and water quality standards
for toxic substances. I
Budget estimates have been included and responsible
agencies/Jurisdictions have been Identified for each remedial action.
For most actions, multiple agencies* organizations* and/or the public
would be involved In Implementation. As In development of the Plan* .
there will have to be cooperation and commitment at all governmental
levels plus Interested citizens and organizations to obtain/provide £
funding and staff support to carry out the remedial actions. There is
no existing source of funding nor single juris diction /agency capable of
implementing the Plan. An Implementation Committee is being organized
by the Wisconsin Department of Natural Resources (Department) to
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Dr. E. T. Wagner
Initiate action on the Plan. Thia coonittaa will function until a
formal Coordination Council is approved and organized. If the level of
commitment shown in development of the Plan continues with
implementation, the Plan can be successful.
Consultation with the public has been excellent. The Department made a
concerted effort from the initiation of the Plan to seek public
participation. Three technical advisory committees and a citizens
advisory committee were established to provide input to the Plan.
Through efforts of the Department and these committees* public
information meetings and hearings were conducted, questionnaires were
distributed widely to obtain input* a newsletter was sent out
periodically, presentations on the Plan were made to schools and
organizations as well as at local events where displays or Information
tables could be set up.
The U.S. Fish and Wildlife Service through its Green Bay Ecological
Services Field Office actively participated in two of the technical
advisory committees and the citizens advisory committee. Through that
effort, our Interests and concerns were well addressed and fully
considered, We support the Plan and expect to be involved in its
Implementation.
Sincerely
cct John Bartig, 1JC, Windsor
John Gannon, NFC-Great Lakes, Ann Arbor
Green Bay Field Office
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Environment
Canada
Environmental
Protection
Enwormement
Canada
Protection de
renwomement
25 St. Clalr Avenue East
7th Floor
Toronto, Ontario
M4T 1M2
Telephone: (416) 973-1085
OUM>
1165-36/C71-10
February 23, 1988
Dr. A.R. LeFeuvre
Water Quality Programs Committee
Great Lakes Water Quality Board
International Joint Commission
c/o NWRI
867 Lakeshore Road
P.O. Box 5050
Burlington, Ontario
L7R 4A6
"fet^lr: \0
Re: Review of Lower Green Bay RAP
Attached are my comments on the Lower Green Bay RAP. The review
was completed according to the Protocol for Review of RAP's with a
focus upon point source Issues. The problem definition under Stage 1
1s clearly stated. The goal appears to be to Initially achieve
non-degradation with a long term goal of rehabilitation. Stage 2
requires some further data collection in the RAP document as well as in
the Toxic Substances Management document.as well as IB the Toxic-
Suks4at>ctis- Mdiia-gemtifil flocumefft. Stage 3 has been addressed through the
Identification of key actions and schedule in the main RAP document.
From a point source perspective some further work (Stage 2) may be
required to determine acceptable levels from point source discharges
before any remedial measures are Initiated.
Yours truly,
G. Sherbin
Manager
Pollution Abatement Division
Environmental Protection
Ontario Region
Conservation & Protection
IO/kp-0063
attached
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REVIEW OF LOWER GREEN BAY RAP
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1. In terms of the goals and objectives of the RAP, there 1s a r\eed
for a more positive statement In goals 5 and 6 (pages IV.5 and
IV.6) on the Identification and control of point sources and the
necessity for determining acceptable levels for contaminants.
2. Mention 1s made of Impairment of water quality and decline of the
fish population (page II.5) and some statements are made as to the
degree of Impairment (page II.6) but from a point source
perspective no clear connection or linkage 1s made between point
sources and beneficial use Impairment. Although pulp and paper
mills, agricultural activities and urbanization are cited as
contaminant sources what 1s the amount of all toxic substances
entering the system from point sources?
3. A study designed for estimating the loading of toxic substances to
the Lower Fox River from Point Sources 1s discussed in the Toxic
Substances Management report. Such a study is important in the
Implementation of the Key Action items.
4. A clearer indication 1s necessary as to what remedial measures are
in place to control point source discharges of contaminants and
whether these mitigative measures have been evaluated. Chapter VI
contains Key Action recommendations but makes no statement on the
effectiveness of current controls.
5. The report identifies point source dischargers but has not
characterized each in great detail. Goals and Objectives for
restoration appear to be adequate. Remedial and regulatory
measures are addressed from a point source perspective. The
problem assessment will be stronger once the study design for
estimating loadings 1s completed.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
DATE: 2 5 APR 1988
SUBJECT: Review of the Green Bay Remedial Actior
Vacys J. Saulys, Chief
FROM: Remedial Programs Staff,
an
TO:
Griff Sherbin
Canadian Point Source Coordinator
I have reviewed the Green Bay Remedial Action Plan (RAP) as submitted by
the State of Wisconsin to the International Joint Commission and provide
the following comments.
1) Ground - Water Contamination.
There are many other sources of ground-water contamination in addition to
abandoned landfills referenced in the RAP. The Wisconsin DNR Lake
Michigan District Office has compiled a list of "known or potential
sources of ground-water contamination in the five counties surrounding
Green Bay which include over sixteen categories of such sources
(attached). The list of known or potential sources of ground-water
contamination is available from the WDNR and should be included in the
RAP.
The RAP only references known or potential ground-water contamination
sites within 1/4 miles of the lower Fox River and lower Green Bay. Sites
located on the tributaries to the river and bay need to be evaluated.
Inhomogeneity of geologic materials and areas of fill adjacent to the
River and Bay and the ability of ditches and sewers to intercept ground-
water flow and thus "short circuit" the generally long travel times in
ground water, render the 1/4 mile distance meaningless in terms of
potential for impact.
The RAP lists 16 landfills of concern. The Wisconsin Environmental
Repair Fund Lists 333 Waste Sites in the lower Fox River Basin. I am
not able to ascertain whether or not the Comprehensive Environmental
Response and Liability Act Information System (CERCLIS) or the Hazardous
Waste Data Management System (HWDMS) databases were searched. Our review
of the Cerclis Inventory yielded the following additional 10 potential
sources.
Better Brite Plating Inc. (Chrome) DePere
Better Brite Plating Inc. (Zinc) DePere
Brown County Landfill (East) DePere
Brown County Landfill (West) Hobart
DINY Robert and Brothers Property Greenleaf
Fort Howard Paper Co. Sludge Site Greenbay
PA FOAM 13204 (REV. 3-76)
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H&R Paper Greenbay
Northwest Engineering Co. Inc. Greenbay
Texaco Inc. Texaco USA Division Greenbay
Valley Engraving Company Greenbay
Based on the above discussions I feel that relevant available data has
not been appropriately incorporated into the RAP. The State of Wisconsin
needs to reassess the RAP submission based on these comments and consider
amending the plan accordingly.
2) Regulatory and Legal Framework
The RAP does not provide a clear discussion on the implementation of the
key action items from a regulatory and legal framework. The RAP
identifies who has the responsibility to act regarding key actions but
references to local, State or Federal laws are omitted. Compliance and
enforcement issues which are critical to the longterm implementation of
the RAP are not discussed.
The RAP proposes the creation of a Coordinating Council to facilitate
plan implementation. The establishment of such a Council is strongly
encouraged, but many of the proposed action items can be implemented
immediately through existing local, State and Federal regulatory
authorities. Implementation of key components of the plan do not require
the creation of the Council (Examples: investigation and clean up of
contaminated land fills-RCRA and SARA, development of water quality
standards to include toxics in the Bay and River with subsequent issuance
of NPDES permits with toxic limits).
3) Point Source Inventory
In the AOC Drainage Basin permitted dischargers to surface waters include
120 industries and 66 municipal treatment plants. The RAP focuses on the
major permitted facilities as significant sources of toxics and
nutrients. The RAP does not include an inventory of all the permitted
dischargers including the minor facilities. Such an inventory, which
could be presented as an Appendix, should list the facility name,
location, flow manufacturing process and waste treatment process.
The plan as submitted needs to be amended to include the above mentioned
deficiencies. Issues regarding the dredging and disposal of sediments on
Kidney Island and the existing confined disposal facility need to be
discussed in the RAP since they remain unresolved. Implications for the
RAP need to be addressed regarding the outcome of the proposed dredge
spoil disposal site and potential for leakage from the existing confined
disposal site.
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1) Known or Potential Sources of Ground-Water Contamination:
Toxic Spills
Waste Water Lagoons
Sludge Application Sites
Septic Waste Areas
Active Landfillls
Abandoned Landfills
Airports
Municipal Wells
Other than Municipal Wells
Special Well Casing areas
Pesticide Storage and Handling Areas
Salvage Yards
Pesticide Mixing Areas
Gravel Pits
Salt Sheds
Ground-Water Contamination Sites
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wffi
STATE OF MICHIGAN
'URAL RESOURCES COMMISSION
THOMAS J ANDERSON
(>RL£N£ J f LUMARTY
RRY KAMMER
STEWART MYERS
vio 0 OLSON JAMES J 8LANCHARO, Governor
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DEPARTMENT OF NATURAL RESOURCES
STEVENS T MASON BUILDING
BOX 30028
LANSING Ml 48909
CORDON E GUYEP Director
February 4, 1988
TO: John F. McDonald, Secretary, Nonpoint Source Subcommittee
International Joint Commission
FROM: Jim Bredin, Michigan Department of Natural Resources
SUBJECT: Review of Lower Green Bay (Fox River) Remedial Action Plan
I have reviewed the Lower Green Bay (Fox River) Remedial Action Plan and
have the following comments:
General Comments;
The plan does not clearly identify the degree of impairment and the
geographic extent of the impairment (specifically for the Fox River
portion of the planning area).
Existing remedial mesures have not been clearly identified and
evaluated.
The Executive Summary does not discuss problems, causes or sources.
Watershed characteristics, water uses and land uses were discussed
in general, not in detail.
Description of enviornmental conditions is discussed generally and
detailed information is not included in the plan.
Goals and objectives have been discussed thoroughly in the report.
Remedial action descriptions are discussed at great length, however,
no detail is included regarding specifics of the programs.
Bibliography does not include all references identified the report.
Nonpoint Source Comments;
The plan includes general descriptions of the nonpoint source
problems relating to the use impairment.
Nonpoint source remedial actions are included., in the .Plan - focusing
on intensive watershed management projects. No detailed-description-
of the intensive watershed management projects was included. -
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John F. McDonald
Page 2
February 5, 1988
The Plan contains general descriptions and information for all aspects of
the remedial action plan. Because of my personal knowledge of the area,
I am familiar with some of the documents that were used as references for
the Plan. I question the need to restate or to even include all of the
numerous reference documents as part of the Plan, however, it would be
appropriate to more thoroughly document which reference materials were
used to develop the plan and where these documents may be obtained.
I feel this Plan would be a good example for the Nonpoint Source Subcom-
mittee to discuss regarding the degree of detail the Subcommittee would
like to see in the remedial action plans. The Lower Green Bay Plan
presents general information regarding the environmental conditions and
the extent of the problems, and focuses on objectives of the planning
effort and remedial actions. This may be appropriate for the Lower Green
Bay area 'because of the extensive documentation that is available for the
planning area. A Subcommittee discussion regarding this issue would
assist me and other Subcommittee members in reviewing future remedial
action plans.
If you have any questions regarding my comments, feel free to contact me
at 517-335-4110.
cc: Bruce Baker, WDNR
D. Rlemens, MDNR
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L.ind Resource Research Centre
Centre d e recherche s u r 1 e s t e r r e s
Central Expf-r ir.ent a 1 Farm
Fermt? cxperimentale cent rale
Ottawa, Canada K1A OC6
Tel: (613) 995-5011
February 1, 1988
Mr. Johr. F. McDonald
Seer e t a. r y
International Joint Commission
Great Lakes Water Quality Board
Nonpoint Source Sub-Conmittee
100 Ouellette Ave.,
8th Floor,
Windsor, Ontario
K9A 6T3
Dear Mr. McDonald:
Re: Review of Recommended Plan for the Lever Green Bay and Lower Fox
LiiL^I Area of Concern - Remedial Action Plan
It is not cJe^r to me just how far this Remedial Action Plan (RAP) is
supposed to go. The "Protocol for Review" indicates that plans are
supposed to be submitted in 3 stages. I am going to assume that this is
Sta£e 1 ar,d Stage 2, though I haven't seen anything that identifies
The RA? is very wordy and repetitious. It seerrs that each section is an
expansion of that preceding it, and a lot of repetitive material becomes
frustrating to read. Apart from this, I would have to say that it is
well written from the standpoint of choice of words and clarity of
language.
According to the "Protocol for Review - Stage 1", the RAP should be
assessed as follows:
Are the goals and objectives clear and precise? Are they consistent
with the general and specific gcals of the GLWQA?
I think that they have satisfied this requirement, though the goals
of the GLWQA do not seem to be mentioned. They say that the RAP is in
response to problems identified by the IJC, and this may be sufficient.
Have the environmental problems of the Areas of Concern been
adequately described, including identifying beneficial uses impaired,
the degree of impairment and the geographic extent of such impairment?
Canada
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Again, I think that I would have to cay that this has b-ven done,
but there is a lack of quantification in the "Recommended Plan".
Adequate data seem to appear in the "Technical Advisory Co,:., i 11 ce" (TAG)
reports that accompany the Recommended Plan. Saying that the bay
like pea soup during part of the surfer" is very descriptive for t
citizer.s panel, bi:t does not provide a base line against w*ich to
measure any improvements. Similarly, toxics are referred to
qualitatively, with no reference to measured levels in fish, for example
- just that they are unfit for human consumption - the reader has to '
refer to the TAG report for information regardirg the levels that have
been found. The description of the geographic extent vas also
qualitative, but this I found to be satisfactory.
Have the causes of the use impairment been identified, including a
description of all known sources of pollutants involved and an (
evaluation of other possible sources? j
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- Here too, the reader must go to the TAG reports. It looks as though
the data base is fairly good for P, although poor for some industries.
For toxics it is, of course, very difficult to identify or quantify
sources.
The Stage 1 work seems to have been done as thoroughly as is reasonable
to expect and the reports, as a package, are very well done.
Stage 2 - seems to be generally weaker, but I'm uncertain if completion
of Stage 2 has really been reached in this document.
Have remedial measures in place been evaluated?
In a general fashion t\ey have, but not entirely. Remedial measures
in place seem to consist only of P control at the discharge from certain
municipal sources. As I understand it, industrial sources have no P
control at all because of a court decision in 1978. The "Key Action"
for P indicates that they are going to further evaluate point sources,
establish P standards and allocate loads. By Stage 2 this should have
been done. For non-point sources there does not appear to have been any
evaluation of existing measures.
Have alternative additional remedial measures to restore beneficial uses
been evaluated?
- No.
Have additional remedial measures to restore beneficial uses been
identified including a schedule for implementation? What beneficial uses
(if any) will not be restored? Does the RAP indicate why?
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There arc lots of st fitemc-pts about conducting feasibility studies,
and va^ue refeiences to possibilities that might be considered after
further studies have been done, but very little concrete about
additional remedial measures. The schedules for irr.plerr c-nt at i on all r-eer
to indicate that they are dependent or. the results of the feasibility
studies. No rr.ention is made of beneficial uses not being restored, but
it is evident from reading the report that it is unlikely that rrany of
their ultimate restoration objectives will be met in the forseeable
future. For so^ie reason they nave t^.ken an odd approach to priorities
or. control of bacterial discharges, rar-King them low, vhile stating t nat
restoration of swimming is an important beneficial use. 'They have also
devoted considerable space to a discussion of atmospheric deposition as
a contribution to pollution, which seems completely out of place as they
can have little or no effect on it, and compared with the other sources
in the basin, it is clearly of negligible proportions.
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Has the surveillance and moni'torir:g program to track effectiveness of
remedial actions and confirmation of beneficial uses been adequately
desc r ibed?
- There is a "Key Action" to monitor the effectiveness of the RAP which
lacks detail, but generally seems to cover the major concerns.
Have the persons or agencies responsible for implementation been
identified? Have the beneficiaries or organizations impacted by the RAP
beer, identified? Has there been adequate ar.d appropriate consultation
with the public?
- This seems to have been done more than adequately.
In su.~j7.3ry, I would say that these reports c.re a mountain of paper that
tends to skirt around the real issues. It is evident that they are only
half-heartedly thinking of implementing stronger controls on municipal
plants and industries. By hiding behind feasibility studies and further
evaluations, they seem to be delaying doing anything substantive for a
long time. It appears that the Area of Concern is a real mess at the
moment, and that full restoration of desirable beneficial uses is
probably j u - t a dream.
I will return the reports in a few days when some other staff here have
had a chance to look at them.
Yours sincerely,
John L. Nowland
A/Director
Land Resource Research Centre
JLN/lh
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,
Lower Green Bay
Remedial Action Plan
Stage I
- Goals and objectives are clear and as precise as could be expected.
- Environmental problems are well described. Use impairment and for the
most part, degree of impairment have been adequately reported. The
geographic extent of impairment is sufficiently documented to procede
with plan implementation.
- The major causes of use impairment have been identified. Some potential
sources of pollutants (such as abandoned landfills) have been located
and will be evaluated In the future.
State II
- In place remedial measures such as phosphorus control at wastewater
treatment plants have been evaluated.
- Plan effectively considers and evaluates alternative remedial measures.
- Implementation schedule has been presented. Beneficial use not to be
restored is drinking water quality due to uncertainty with respect to
toxic chemicals.
- An adequate surveillance and monitoring program have been proposed.
- The agencies responsible for implementation have been identified and
costs estimated. Public consultation has been a strong component in
plan development.
Sate III
- Plan has not reached the implementation stage.
General Comments
Good remedial action plan with public Involvement included
throughout the process. Alternative solutions to issues have been presented
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with discussions of advantages and disadvantages. An attempt has been made
to calculate costs for different solutions. Agencies responsible for
Implementation have been identified and a schedule presented.
B A coordinating structure for implementation of the plan has been
H presented that is innovative.
I was particularly Impressed by the overall strategy of the plan
development. [Citizens Advisory Committee (CAC) through Technical Advisory
Committees through Action Plan through Implementation Plan].
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Gregory J. Wall, Ph.D.
Research Scientist
Land Resource Research Center
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Ontano
Ministry
of the
Environment
Ministere
de
I'Environnement
135 ivtnot SI Out
Bureau 100
Toronto (Onuno)
M4V1PS
135 Si OairAv«nu«Wist
Suit* 100
Toronto, Onuno
M4V1PS
323-5808
January 28, 1988
A.R. LeFeuvre Ph.D.
Water Quality Program Committee
International Joint Commission
Great Lakes Water Quality Board
100 Ouellette Avenue
8th Floor
Windsor, Ontario
N9A 6T3
Re; Review of Lower Green Bay RAP
Dear Dr. LeFeuvre:
Attached are comments on the above RAP report. The review has been
guided largely by the IJC review protocol and although the focus was on
the contaminated sediment portions of the report (specific comments),
comments of a general nature are also provided on other sections of the
report that have a bearing on sediment-related issues.
According to the stage I requirement of the protocol for review, the
RAP report has not adequately addressed the environmental problems
associated with sediment in the Area of Concern, especially beneficial
use impairment, degree of impairment and the geographical extent of
impairment. In this regard, the sediment problems alluded to on the
last paragraph, of page III.3 and first paragraph of page III.4 of the-
main report, appears to be perceived ones.
Based on the supporting evidence (or the lack of it) the report at best
have identified few real problems (eg. contaminated fish and
eutrophication)and a number of potential problems. The recommended
actions in the main report would help to confirm some of these but in
relation to sediments, future actions must include a clear definition
of the problems and their significance. In this regard, the RAP team
will find the IJC sediment subcommittee publication - "Guidance on
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Assessment and Remediation of Contaminated Sediment Problems In the
Great Lakes" helpful.
If you have any questions related to the attached comments, please give
me a call.
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ABS/88-1-20098-01C.1
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Review of the Lower Green Bay RAP
General Comments
There 1s some overlap with regards to remedial options and additional
studies for items covered under the various "key actions" in the main
report. Each key action has identified future studies and option
related activities and associated costs. In some instances these costs
may inadvertently result in double firtriple accounting. For example
some of the controls and studies being suggested for phosphorus may
also be used to address other forms of contaminants. For Instance
action taken with regards to "In-Water Management" of phosphorus (p.
VI.25 of main report) may also be effective in reducing the levels of
toxic substances in sediment.
In order to maximize the benefits of research and cleanup moneys, the
RAP team may wish to group relevant subject areas under a common
heading for study and remedial action, e.g. under "high priority" on
page VI-4 it may be possible to approach the AOC under-:
1. Source Control - (point and non-point) - Nutrients, Sediment,
organic and inorganic contaminants, BOD wastes, bacteria and
toxicity and,
2. In-sit^Jconcerns_- nutrients, organic and inorganic contaminants.
Such an approach will not only assist in maximizing financial benefits
but will also aid in determining the stringency of the clean-up action
required and where necessary determine disposal options. For example,
"in water management" of phosphorus may require removal of sediment, but
if that sediment is also contaminated with PCB, it may require more
stringent controls during removal and disposal than would perhaps be
the case if phosphorus was the only concern.
Further evaluation will be required to determine acceptable levels for
various contaminants from point source discharges. Before measures are
taken to set standards for discharges, knowledge of the allowable
levels that would be required to prevent build up in sediments would be
needed. Contaminant reduction in effluents to non-toxic levels may not
guarantee that build up in sediments will not occur or continue to
occur. Controls that would achieve the most stringent of several
requirements (eg. institution of some form of Best Available Technology,)
may be required.
The other suggestion of a general nature is that all "remedial" type
activities related to sediment be handled under a single program eg.
a sediment management program. Such program must embrace the "cradle
to grave concept" covering cleanup to ultimate disposal. Work in this
regard will address Issues related to inplace pollutants cleanup and
routine maintenance dredging operations. Here as above, the basis for
grouping similar subject areas is to maximize the benefits of research
and monitoring $.
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Specific Comments
The specific comments from this review relate mainly to Key Action 14
(page VI.44) of the main report dealing with contaminated sediments.
This section of the report does not provide any convincing evidence of
a good grasp of the sediment problems being alluded to 1n Section III.
This apparent lack of evidence Is amplified by the absence supporting
technical references in the text. This deficiency 1s especially
critical in Section III.
Although the report claims that pulp and paper mills are major
discharges to the Fox River system; there does not appear to have been
any significant effort to characterize the effluent and monitor
sediments for compounds that may be present in such effluents. The
entire thrust of Key Action #4 1s based on a perceived notion that
removal of sediment with levels of PCB over 0.05 ug/g (in conjunction
with reductions 1n effluent toxicity and measures to reduce sediment
inputs to the system) may be the ultimate solution to existing
"problems". It should also be pointed out that one of the drawbacks in
using PCB as the primary guidance parameter is that an area may have
low levels of PCB but other contaminants may be present in undesirable
levels and would therefore be missed.
Although, as the report suggests, the sediment may be contaminated,
there should be a solid scientific basis for arriving at such
conclusion. Without the scientific basis, the claims that PCB from
sediment may be responsible for the undesirable levels in fish can only
be treated as hypothetical. If the sources are other than sediment,
the problem may persist after sediment cleanup is effected.
The report also relies on fish as the sole monitoring medium on which
to gauge problems. While fish is undoubtedly the most important
barometer of problems in the aquatic environment other media cannot be
overlooked under the "ecosystem approach". Sediment, water and benthic"
organisms provide the other dimensions in this regard. It is Important
that reliance is not placed entirely on fish because fish may not show
declines in certain contaminants (after cleanup is effected) as rapidly
as the other media might. The effectiveness of cleanup action must
therefore be gauged by the medium that responds the earliest.
The report has made som£ positive recommendations (page VI. 44) on
future work related to contaminated sediments. Part of this work
entails data gathering which must include a good biological component.
Consideration should be given to monitoring sediment and associated
biota since a good baseline does not appear to exist.
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The information collected should be geared towards providing a good
baseline against which future results can be compared. The Information
should also be used to define the geographical extent of the problem
and the degree of contamination (eg. contamination above some action
level)and areas devoid of benthic life as a result of contamination
(hot spots). The significance and degree of contamination can also be
assessed through laboratory sediment bioassays.
The efforts associated with dredging under Key Action #4 could perhaps
be broadened to include management of all sediment (navigational
dredging, inplace pollutants, etc.). Alternate disposal or treatment
options can then be investigated on a pilot or full scale basis as the
situation warrants. This Information will be useful for all
contaminated sediment remedial action once the problems and their
significance have been defined.
The report makes a good attempt at identifying potential problems.
The additional studies being proposed to substantiate.these and a
proper focusing of the various efforts (eg. combining phosphorus
investigations with sediment and suspended sediment studies) will
provide the RAP team with a more realistic approach to achieving the
various goals or uses being contemplated.
In this regard work should also be carried out to ensure that the
anticipated uses do not conflict with each other ie. will additional
boating introduce the need for marinas and related facilities and
concomitant sediment and water quality problems?
ABS/88-1/20098-01C.1
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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4 AM?2 3 WASHINGTON. D.C. 20460
V^lfa*^
MEMORANDUM
February 12, 1988 OFFICE OF
POLICY. PLANNING AND EVALUATION
TO: John Hartig, Physical Administrative Officer
International Joint Commission
FROM: Donn J. Viviani,"
Toxic Substances
r
Chairman ., -' N ' *""*
Committee ^
Thanks for the opportunity to review the RAP's for the
sites in Michigan.
Dave Pasco reviewed
are attached. Jim Smith
comments directly to you.
the Manistique River RAP and his comments
reviewed Torch Lake and should have sent
I had Dr. Joe Reinert of my staff review
Green Bay in depth and the others in less detail and his comments
are also attached.
Attachments (2)
c?7
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ATTACHMENT
RAP Review - Joe Reinert
e p.3. Some of the pesticides listed in group C (e.g. toxaphene,
DDT) have well-documented adverse reproductive effects. It
seems that these compounds would better fit in group A, based
both on this similarity of effect as well as the similarity
in physicochemical properties and methods of analysis.
0 In the table on p. 66, U.S. Food and Drug Administration (FDA)
and Wisconsin Division of Health standards for acceptable
respidue levels in fish are given for a number of contaminants.
For at least some of the pesticides on the list, the value
given is the same as the FDA action level. It is my understanding
that FDA sets pesticide action levels in fish only on the basis
of nononcogenic chronic effects. The action level therefore may
or may not correspond to an acceptable lifetime cancer risk.
This needs to be kept in mind when discussing carcinogens, e.g.,
on p. 69.
0 The above comments holds for the other RAP's which address toxics
?osing chronic problems. The White River RAP uses the FDA action
evel as a goal, without acknowledging the fact that this goal may m
correspond to a particular lifetime cancer risk.
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U.S. DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
ENVIRONMENTAL RESEARCH LABORATORIES . . .
Great Lakes Environmental Research Laborator
2205 Commonwealth Blvd.
Ann Arbor, Michigan 48105-1593
Jan. 25, 1988
R/E/GL
Dr. A.R. LeFeuvre
IJC, GLWQB
Water Quality Programs Committee
100 Ouellette Ave., 8th Fl.
Windsor, Ontario, Canada N9A 6T3
Dear Dr. LeFeuvre:
NO.
PATE
To
InlMs [ C
""'-'y--
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I have reviewed the Lower Green Bay RAP as per your request of December 15,
1987. Some of my comments are of a more generic nature in that SAB is
attempting to decide as to how they can be most useful in review of the RAPS.
Kindest regards.
Sincerely,
Alfred H. Beeton
Director, GLERL
Enc.
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Review of Lower Green Bay RAP by A.M. Bee ton
Pl
I was pleased to see good committee structure with evidence of citizen
involvement in the RAP.
It would be useful to evaluate how effective the questionnaires were as well as
the response to public hearings.
II The Setting
This section is of questionable use in that it presents too little information
to be of much value. Gives a paragraph on seiches, but little on the impact of
loss of wetlands, for example.
The "institutional setting" section should be strengthened in that it leads one
to conclude that the problems are minimal.
Ill Problems
The problems are addressed in general terms, but treatment is adequate.
IV Goals and Objectives
The presentations seem consistent with the Water Quality Agreement.
The walleye objective may be questioned as to whether there would be or is a
need for reduced harvest, since Great Lakes walleye are known to migrate great
distances.
The geographical extent of impairment Is not clear.
A reduction in the carp population should occur naturally if the goals and
objectives are attained for the other species.
The desired total phosphorus seems high relative to the Water Quality
Agreement.
PCBs in fish - objective based on fillets and not whole fish - how compatible
is this with FDA standards?
Meed to define the nixing zone.
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V Strategy
The 16 key actions are commendable, but are they realistic, e.g., how will they
virtually eliminate toxicity caused by nonpoint and atmospheric sources?
VI Recommendations Section
Table VI.2 has a mixture of enforcement, jurisdictlonal, advisory groups,
research groups, etc. All do not have responsibility for a clean bay.
How are priorities on p. VI.13 related to table VI.4?
p. VI.145 The proposed research agenda does not reflect an ecosystem approach,
and most of the recommended actions could better be dealt with in such a
holistic approach.
Seems to be some incompatibility between "Monitoring #15" (p. VI.135 et al) and
Research #16," e.g., monitor trophic status is high priority in #15 and low in
Not a clear delineation between monitoring and research; perhaps they should be
combined.
VII Implementation
Not clear as to who is to do what.
Nutrient and Eutrophtcatton Management Report
Bibliography is disappointing as it is very limited in scope and some basic
papers are not included.
Phosphorus is a major concern, yet no figure of P concentrations bay wide.
Dealing with broad taxonomic categories of algae (p. 37) provide little useful
information - papers are available dealing with species occurrence and
distribution as well as trophic significance.
Trophic gradients occur on a west-east axis as well as north-south (Fig. 4, p.
36). This is important in view of the counter clockwise circulation and the
flow of the Fox River water along the eastern shore.
Is it wise to establish "mean trophic gradients" on the basis of data from so
few stations in a "region"
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Biota and Habitat Management Report
'This report la heavily oriented to fish and some birds. The ecosystem approach
is lacking. Where are the other components of a healthy ecosystem not
mentionedI
A limited bibliography may have contributed to the above. The Committee needs
to upgrade its knowledge of the available literature.
No reference is made to the Corps of Engineers dredging and disposed study
which resulted in establishment of spoil disposal islands in southern Green
Bay.
Toxic Substances Management Report
This report is seriously lacking in its consideration of the physical and
chemical factors which are of great importance in the availability, fate, and
transport of toxic substances.
What is the possible relationship of birds affected with toxics in the northern
bay to conditions in the southern bay.
32.
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REVIEW OF GREEN BAY REMEDIAL ACTION PLAN J U V"* v\< ^
PREPARED FOR THE SCIENCE ADVISORY BOARD
This review was assigned by the Science Advisory Board to Dr. A.M. Beeton and Dr.
J.R. Vallentyne. The Plan was accompanied by supporting reports on nutrient and
eutrophication, biota and habitat, and toxic substances and institutional and
socio-ecomonic consensus. The comments below are set forth in the IJC Water Quality
Board's draft Protocol for Review dated December 10, 1987, and the IJC Science
Advisory Board's Guidelines for Review of Remedial Action Plans dated February 4,
1988.
Q. Are the goals and objectives clear and precise? Are they consistent with the
general and specific goals of the Great Lakes Water Quality Agreement?
A. Yes, although the section on strategy could profit from a more penetrating analysis
of human behavioral obstacles to achieving the other goals. A reduction of the
carp population should occur naturally if the goals are attained for other species.
The walleye objective may be questioned as to whether there would be a need for
reduced harvest since Great Lakes walleye are known to migrate considerable
distances.
Q. Have the environmental problems in the Areas of Concern been adequately
described, including identifying beneficial uses impaired, the degree of impairment
and the geographic extent of such impairment?
A. Yes.
Q. Have the causes of the use impairment been identified, including a description of
all known sources of pollutants involved and an evaluation of other possible sources?
A. Yes.
Q. Have remedial measures in place been evaluated?
A. Yes.
Q. Have alternative additional remedial measures to restore beneficial uses been
evaluated?
A. Yes.
Q. Have additional remedial measures to restore beneficial uses been identified,
including a schedule for implementation? What beneficial uses (if any) will not be
restored? Does the RAPs indicate why?
A. Yes. For each key action the Plan identifies priorities (high, moderate and low)
and probable costs thereof. The high cost of actions pertaining to contaminated
sediments ($409 million) is noteworthy.
Q. Has the surveillance and monitoring program to track effectiveness of remedial
actions and confirmation of beneficial uses been adequately described?
A. Yes.
Q. Have the persons or agencies responsible for implementation been identified?
Have the beneficiaries or organizations impacted by the RAPs been identified?
Has there been adequate and appropriate consultation with the public?
A. Yes to all; however Table VI.2 has a mixture of enforcement, jurisdictional,
advisory and research groups. All do not have equal responsibility for a clean bay.
...over
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Stage 3
0- Have all identified remedial meausures to restore beneficial uses been
implemented according to the schedule in R.A.P.? If not, why?
A. No, too early to comment.
Q. Do surveillance and monitoring data confirm restoration of beneficial uses? If not,
why?
A. No, too early to comment.
SAB Questions
Q. Does the Plan embody an ecosystems approach?
A. The Plan recognizes the ecosystems approach but falls short in application in that
it focuses on the aquatic ecosystem more than on the drainage basin as an
ecosystem; also, human health considerations have not been comprehensively
addressed.
Q. Have effects been adequately linked to contributing causes and examined in terms
of societal factors?
A. Effects have been linked to direct contributing causes but have not been
exhaustively examined in terms of societal factors.
Q. Are the remedial actions adequate to sustain the beneficial uses indefinitely?
A. The answer to this question is not clear. The Plan needs to interface more
intimately and directly with educational and recycling systems on land.
Q. Have nongovernmental responsibilities for implementing remedial actions been
identified, e.g. communication and education systems, industries, citizen groups
and individuals?
A. Yes, to a limited extent; however, it is doubtful whether the limited educational
actions will have any significant effect on the interests and motivation of people in
the community.
Q. Do studies necessary to complete the RAP comprise a balanced information system
of societal, technological and ecological elements?
A. Somewhat. The main emphasis of the Plan is on the technological and ecological
aspects of the pollution problems. Water pollution can be viewed as the sign of a
deeper problem; the removal of the sign may not be equivalent to removal of the
problem.
Q. Is there provision for periodic public review and updating of RAPs by the
jurisdictions? v
A. Yes. The Coordinating Council concept and proposed budget are well thought out.
Representation on the Council from Boards of Education would be desirable.
The Remedial Action Plan for Lower Green Bay is generally well done, making
extensive use of available data, and involving extensive planning and public
participation. It is clearly the best of the first seven plans reviewed by the Science
Advisory Board. By incorporating the full sense of an ecosystems approach this Plan
could move into a clear position of leadership, setting the standard for other Remediel
Action Plans in the basin.
Docu. 5077S
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ESTABLISHED BV CONVENTION BETWEEN CANADA AND THE UNITED STATES TO IMPROVE AND PERPETUATE FISHERY RESOURCES
April 19, 1988
l.J.c
R.O. WINDER
APR 2 01988
Dir*.
Secty WQ8.
Secty SA8_
Head SS
A.O
LO
Fife.
Mr. M. P. Bratzel, Jr., Secretary
Water Quality Board
Great ]>v«=« Regional Office
International Joint Commission
100 Oullette Avenue
Windsor, Ontario, Canada N9A 6T3
Dear Marty:
Please advise the International Joint Commission's*Water"- Quality .Board"that "
the Great Lakes Fishery Commission's Habitat Advisory-'Board: (HAB) :noted, > atrits 13
April meeting, the excellent reviews~of the remedial action, plans {RAPs) -for: the
Lower Green Bay, the River Raisin, and the Deer Take areas of concern1 by the.U.S.
Fish and Wildlife Service. The Board also considered the comments of the Ontario
Ministry of Natural Resources made through HAB member, Dr. Douglas Dodge, and noted
that GLFC Commissioner Regier was a member of the Deer Lake RAP review team for the
IJC/Science Advisory Board. The Habitat Advisory Board will notify the GLFC that
there was adequate review by fishery interests of the Lower Green Bay, River
Raisin, and Deer Lake RAPs. The Board awaits the judgement of the Water Quality
Board on the overall adequacy of" the RAPs as blueprints and schedules for resolving
the problems of the areas of concern. ....-...,
Further, the HAB members have initiated a survey to assess the adequacy of the
fishery involvement with the RAP process. Preliminary results suggest that there
has been extremely variable involvement to date. Perhaps the more 'in-depth
responses expected later this month from our Lake Committee liaisons will be more -
encouraging to report to the Fishery Commission. -j"
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Carlos M. Fetterolf , Jr.
Executive Secretary
cc: HAB members
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Mr. M.P. Bratsel, Jr., Secretary I
Page 2
April 19, 1988
toxics problems which will ensure that abnormalities due to food chain accumu-
lations do not occur in aquatic birds and animals, and that fish fron the Great
lakes, including the areas of concern, can be consumed confidently by fishermen and Q
the general public without reference to public health advisories.
If there are ways the HAB can work cooperatively with the WQB toward our
shared objectives and goals, please let HAB Go-Chairmen Bill Pearce (NYSDEC) and
Doug Dodge (CM4R), or me knew.
Sincerely,
. -, -., *j.
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May 11, 1988
HATER QUALITY PROGRAMS COMMITTEE
COORDINATED REVIEW
of the
REMEDIAL ACTION PLAN
for
RIVER RAISIN, MICHIGAN
PREFACE
This Remedial Action Plan (RAP) was prepared under the protocol prescribed
by the Water Quality Board before the signing of the 1987 Accord that amended
the 1978 Great Lakes Water Quality Agreement. Therefore, this review assesses
the adequacy of this RAP against the original Board protocol. That protocol
was however, amended somewhat 1n response to new requirements 1n Annex 2 of
the modified Agreement. These changes (primarily how the RAP relates to the
3-stage submission process) will be recognized in the final statement, below.
PARTICIPATION
This coordinated review brings together the individual comments of the
various reviewers. These reviewers provided a wide range of expertise in
considering the various technical details of the RAP.
Reviews (attached) were received from:
Great Lakes Fisheries Commission C. Fetterolf Jr.
IJC Sediment Subcommittee D. Persaud
T.B. Reynoldson
IJC Toxics Substances Committee R.L. Collin
IJC Surveillance Work Group G. Lowry
D. Rathke
J. Letterhos
J.H. Leach
L.A. Fay
V. Saulys
Point Source Subcommittee S. Humphrey
Nonpoint Source Subcommittee M.T. Llewelyn
G. Wall
Science Advisory Board K. Bauer et. al.
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1. Are the goals and objectives clear and precise?
In Section 4.1, the MDNR states:
"The goal of the RAP 1s to compile and analyze existing data which
can be used to develop a plan for the restoration of Impaired uses 1n
the Area of Concern to 1) determine data deficiencies and recommend
data additional Investigations that will help define the problems and
sources, 2) recommend remedial actions that will lead to restoration
of Impaired uses 1n the Area of Concern."
In the rest of the Section, however, numerous other Impairments are noted
Including acute and chronic toxic effects, power plant entrapment, Impacts on
drinking water, metal contamination.
The RAP could be enhanced by developing wider and more comprehensive goals
and objectives. Since there are Impaired uses associated with the freshwater
fishery, it 1s most likely that other problems also exist relating to areas
such as, wildlife, benthos and other aquatic biota other than fish. Further
goals relating to water and sediment toxicity and bioaccumulatlon should also
be investigated.
A more organized presentation would facilitate a better understanding of
the problems, objectives and goals of the RAP. The Inclusion of wider goals
and objectives would also allow for the development of more comprehensive
remedial actions.
2. Are they consistent with the goals of the Great Lakes Hater Quality
Agreement?
There is no mention of the GLWQA and no comparison made of existing water
quality to any standards or objectives. The RAP's objective, for example, 1s
to reduce PCB concentrations in fish to less than 2.0 ug.g~^ whereas Annex 1
of the GLWQA is no more than 0.1 ug/g~'. Water quality data given also
shows that concentrations of copper and zinc exceed GLWQA objectives at some
stations.
The data were not evaluated relative to any water quality criteria and
exceedances of the GLWQA are not recognized. Consequently it is not clear
whether or not remediation will be consistent with GLWQA goals.
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3. Is the Information base sufficient to adequately define the problems and
Identify the causes?
There appears to be some Inconsistencies 1n the presentation of
Information on sources. Poor organization and presentation make 1t difficult
to determine exactly what Information 1s available and whether or not 1t 1s
sufficient to adequately define and Identify the problem. Some of the
confusion 1n presentation could be alleviated by a clear statement of Impaired
uses and a plan development that focused on these uses. In general, the
cause-and-effect relationships are not well defined.
For example, 1t 1s not clear 1f the CSOs are 1n the Area of Concern; they
are never mentioned until Chapter 10. Paper plants are Identified as a source
of PCBs but the plants themselves are not Identified as paper plants until
near the end of the report. No effort 1s made to explain why the Monroe WHIP
has diverted Its discharge from River Raisin to Plum Creek or to speculate on
effects of the diversion on water quality 1n the Area of Concern.
As another example, Section 5 Includes a description of point and nonpolnt
sources of a number of pollutants. Table 21 summarizes a number of organic
and Inorganic pollutants from nonpoint sources scored by the Michigan SAS.
However, the summary to Section 5 covers only PCBs and indicates that they are
not a serious problem in municipal and industrial effluents. Table 26, which
is a summary of PCBs in or adjacent to landfills in the Area of Concern,
indicates a distinct lack of available data. On the other hand, Table 27 and
28 provide substantial lists of contamination and potential sources from the
Port on Monroe landfill sites.
One source of information which appears unused to identify problems and is
repeatedly mentioned by the reviewers is the US-EPA (LLRS) studies carried out
in the River Raisin. The PCB mass balance undertaken by US EPA (1987)
indicated the presence of "unaccounted for" sources of PCBs 1n the River
Raisin, yet there is no suggestion of what further studies might account for
this. For example, no PCB measurements have been conducted at any of Union
Camp's 7 outfalls discharging into the Area of Concern. And though not
described as a point source, stormwater and CSOs have been known to contribute
PCBs to the Area of Concern (Marsalek and Ng, 1987). An inventory of SN and
CSO outfalls and measurements for priority pollutants would help to clarify if
these are a source. There is an obvious need to quantify source loadings of
PCBs and certain metals.
No information on permit limits or data on compliance and compliance
monitoring is provided although It 1s undoubtedly available. It is unclear
whether or not Improvements to the Monroe WWTP are completed or still in
progress. Will limits for metals and monitoring for toxics be included 1n
future NPDES permits? Why are Ford and Union Camp operating under expired
permits? This Information is important and should be explained 1n the text.
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The Plan also falls to discuss 1n detail possible sources of heavy metals
me nan aiso iaiii 10 uisiuss in oeiaii pussioie sources or neavy me id IS m
and other Identified contaminants. The origins of heavy metals, such as urban
runoff, might vary from that of PCBs, and should be addressed separately and
1n detail.
The RAP states that the sediments are heavily contaminated yet there 1s
little discussion on River Raisin and Plum Creek. The discussion focuses only
around chemistry, there 1s no discussion on biological significance from a
toxldty or bloaccumulatlon perspective. The brief mention on uptake by clams |
and on degradation of benthos should also be discussed from a contaminated
sediment perspective. If biological data are not available this should be «
clearly stated.
4. Are the Identified remedial actions sufficient to resolve the problems and
restore beneficial uses?
No remedial actions are Identified. There 1s a good description 1n
Chapter 8 of remedial measures already 1n place but no evaluation of their
effectiveness.
5. Are these actions consistent with the stated goals of the RAP?
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The development of appropriate remedial actions must stem from an
organized and concise definition of problems and goals. Nlthout this type of
clear statement at the beginning, there can be no clear follow through to the
Identification of remedial actions and Implementation timetables. An expanded
and more thorough Identification of problems and goals could assist 1n
determining and evaluating the remedial actions necessary to restore the River
Raisin's Impaired uses, and to del 1st River Raisin as an Area of Concern.
6. Hhat beneficial uses, 1f any, will not be restored? Does the RAP Indicate
why?
Because the RAP does not Identify specific remedial actions, It follows
that 1t cannot specify 1f there will be any beneficial uses which cannot be
restored.
7. Have studies necessary to complete the RAP been Identified and have
schedules for their completion been established?
Some studies have been Identified, however no schedules for Implementation
have been presented. More detailed study plans are needed however. Including g
site designations, objectives, sampling schedules, and parameter lists. In
particular, attention could be directed towards determining the unknown _
sources of toxic substances.
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8. Is the Identified schedule for Implementation of the remedial actions
reasonable?
No remedial actions or schedule for Implementation have been Identified.
9. Have the jurisdictions and agencies responsible for Implementing and
regulating remedial measures been Identified?
No.
10. Have work plans and resource commitments been made?
The five or six major historical point sources have been Identified, but
there Is no explicit mention of which jurisdictions or agencies might be
responsible for site clean-up or remediation.
Michigan has existing programs and authority to Implement a number of
remedial actions, and although they are mentioned generally as coming under
the Initiatives of Act 307 "Proposed Priority List for Fiscal Year 1988,"
commitments and time schedules are not made clear.
11. Is the proposed monitoring and surveillance program sufficient to
document Improvements as a result of the remedial actions Implemented and
to confirm the restoration of beneficial uses?
There Is no description of a monitoring and surveillance program.
12. Has there been adequate and appropriate consultation with the public?
Two public meetings were held but there is no explicit mention of which
interest groups or Individuals might be regarded as stakeholders. It is not
clear from the report what effect public participation has had on the content
or direction of the Plan. Inclusion of a summary of comments from the public
would have been useful, as would have an outline of future plans for public
involvement as the Plan develops.
SCIENCE ADVISORY BOARD REVIEW GUIDELINES
The Science Advisory Board guidelines for review of RAPs are appended.
The points are valid but, because they were raised after the RAPs were
submitted, they were not explicitly considered in this review. However, they
should be considered in future updated versions.
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SUMMARY OF PROS AND CONS
Pros
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The River Raisin RAP represents an enormous amount of work on the part of I
the MDNR. It 1s a good technical document providing a platform for assessing
the need for future studies and decision making. It 1s a step towards meeting
the requirements of the GLWQA.
Cons _
1. Imprecise definition of goals and objectives.
The development of appropriate remedial actions stems from an organized
and concise statement defining problems and goals. Without this type of clear
statement at the beginning, 1t follows that there can be no Identification of
remedial actions or timetables for Implementation.
An expanded and more thorough "problems and goals" Identification could
assist 1n determining and evaluating the remedial actions necessary to restore
the Impaired uses and to dellst River Raisin as an Area of Concern. I
2. No discussion of biological/ecosystem effects.
Several reviewers pointed out the need to more precisely define the
biological effects of toxic substances 1n the River Raisin. Since there are _
Impaired uses associated with the freshwater fishery, It 1s most likely that
other problems also exist relating to areas such as, wildlife, benthos and
other aquatic biota other than fish. The RAP does not present any
environmentally based goals or criteria for water, sediment, or biota, which
are necessary 1n order to Identify contaminants of concern. Without these I
criteria, neither the extent of contamination nor the effectiveness of
proposed remedial action can be evaluated.
3. No surveillance and monitoring program. _
Without a monitoring program, effectiveness of remedial programs cannot be
assessed and beneficial use restoration cannot be confirmed.
4. Poor presentation.
Overall, the presentation of the RAP document does not do justice to what I
appears to have been major efforts to remedy a serious and complex problem.
In some cases, Information could be more clearly related to the problem
definition or remedial action recommendations. Many of the maps are
Indecipherable; their scale and their relationship to each other 1s not
clear. Much of the raw data could be presented 1n appendices.
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OVERALL RATING
In 1985 the Water Quality Board presented a six step description of the
RAP development and Implementation process. According to those steps, the
River Raisin RAP 1s at Category 2: "Causative factors are unknown and an
Investigative program 1s underway to Identify causes".
The MDNR makes the statement that "This RAP 1s Intended as a technical
management document providing a platform for future analyses and decision
making. It 1s not a detailed review and synthesis of data and/or Information
on the Area of Concern." This statement appears to be Inconsistent with the
spirit of the Water Quality Board's 1985 Report.
POSITION WITH NEW THREE-PHASE PROTOCOL
In relationship to the 3 step submission process In the new GLWQA, the
River Raisin RAP does not completely satisfy the requirements of Stage I. The
problems are not clearly and precisely stated and, as a result, the
cause-and-effect relationships are not well defined. No remedial actions are
Identified; Instead, the Plan consists largely of a data Inventory and a
proposed series of continued studies.
RECOMMENDATIONS
It 1s recommended that revisions be made 1n the River Raisin RAP 1n order
to satisfy the requirements of State I 1n the 1987 Agreement. This would
Include a more precise definition of goals and problems, Including
establishing cause-and-effect relationships.
The Water Quality Board views the RAP process as Iterative, where RAPs are
updated and Improved based on a better understanding of the problems and their
causes and the development of new technologies to remedy problems. The
challenge of RAPs 1s to make them focused and specific enough to demonstrate
and verify progress. RAPs are Intended to identify when specific remedial
actions will be taken to resolve the problems and who 1s responsible for
taking those actions. If remedial actions cannot be identified and additional
studies are needed, the RAP should Identify when the studies will be
initiated, when they will be completed, and when this new information will be
used to Identify remedial actions.
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VJ
mmissioir
ESTABLISHED BY CONVENTION BETWEEN CANADA AND THE UNITED STATES TO IMPROVE AND PERPETUATE FISHERY RESOURCES
April 19, 1988
i.J.c
R.O. WINDSOR
APR 2 01988 |
Dir.
Secty WQ8.
Secty SA8_
Head SS
A.O.
LCX
Fite.
Mr. M. P. Bratzel, Jr., Secretary
Water Quality Board
Great Lakes Regional Office
International Joint Commission
100 Oullette Avenue
Windsor, Ontario, Canada N9A 6T3
Dear Marty:
Please advise the International Joint Commission's Water Quality Board that
the Great Lakes Fishery Commission's Habitat Advisory Board (HAB) noted, at its 13
April meeting, the excellent reviews of the remedial action plans (RAPs) for the
lower Green Bay, the River Raisin, and the Deer Lake areas of concern by the U.S.
Fish and Wildlife Service. The Board also considered the comments of the Ontario
Ministry of Natural Resources made through HAB member, Dr. Douglas Dodge, and noted
that GLFC Commissioner Regier was a member of the Deer Lake RAP review team for the
IJC/Science Advisory Board. The Habitat Advisory Board will notify the GLFC that
there was adequate review by fishery interests of the Lower Green Bay, River
Raisin, and Deer Lake RAPs. The Board awaits the judgement of the Water Quality
Board-on the-overall adequacy of -the RAPs as blueprints^ and schedules- for resolving
the problems of the areas of concern.
Further, the HAB members have initiated a survey to assess the adequacy of the
fishery involvement with the RAP process. Preliminary results suggest that there
has been extremely variable involvement to date. Perhaps the more in-depth
responses expected later this month from our Lake Committee liaisons will be more
encouraging to report to the Fishery Commission.
The Habitat Advisory Board now has a team in place to review the RAPs, but we
hope that the Water Quality Board can release them in a more steady flow rather
than in batches of seven. The team will use the excellent reviews by the Fish and
Wildlife Service as an example, and encourages other reviewers to do the same.
It is clear from the plans reviewed to date that toxics should be treated as
an ecosystem problem, rather than simply a water quality problem. The Habitat
Advisory Board encourages the Water Quality Board to consider solutions to the
Page 1 of 2
1451 Green Road Ann Arbor, Michigan 48105-2898 Telephone (313) 662-3209 / FTS-378-2077
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Mr. M.P. Bratzel, Jr., Secretary
Page 2
April 19, 1988
toxics problems which will ensure that abnormalities due to food chain accumu-
lations do not occur in aquatic birds and animals, and that fish from the Great
Lakes, including the areas of concern, can be consumed confidently by fishermen and
the general public without reference to public health advisories.
If there are ways the HAB can work cooperatively with the WQB toward our
shared objectives and goals, please let HAS Oo-Chairmen Bill Pearce (NYSDEQ and
Doug Dodge (CfUR), or me know.
Sincerely,
Carlos M. Fetterolf, Jr.
Executive Secretary
cc: HAB members
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of the de
Eruirorii n-.nt I'Envi.
S. :>!.<' B.- >. '50
To.vt ;> Of. i . To-. .-lO-1
M-4, Ifj V4.' l?j
32 J-492-1
February 11, 19C8
Mr. VV.A. Stegglcs
V;^.Lor Quality Programs Conrc j ttf«
GrcaL I, ah s Water Quality Bo-nrd
InLei nat io-.;^ 1 Joitit Co»>-.. i ssi'.^n
100 Ou-jlletLo Ave.« 8th Flooi:
Windsor, Ontario
N9A 61 3
Dear Mr. Stegglos:
The IJC Sediment Subcois.J'U tLc;o h?s review. -1 tlie
sections of this R/.P with respect to the signif ic< -ice of
contaminated sediments and the proposod actions based on
the extent of the defined problem. We were hoping for a
much broader discussion of the significance of
contaminated sediments in the Area of Concern,
especially given the extensive work carried out in this
area by the Large Lake Research Station of EPA at Grosse
Isle.
Our coiwnents are attached. Should you have
any questions regarding the comments, please give me a
call.
DP/vf
Attachmc-n t
00785F
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RAISIN RIVfiR RWSDIAL ACTION
i) n?rinilio!: oC Problem (Ch vter f>)
This section states tlv.1: the s^ltnents, arc honvily
cont-Hr.i imted, yet the entire section comprises four
paragraph?, on the R:. T>u?
clir.ouyuiori- fijciii. .^:; oaly ar'-jun-l c u o ,vi i s t r y, thcie is no
discussion on biological sign i f icance in this part
either from a toxicity or b i o-i ecu r. Mint ion perspert i vo.
There is a brief irention in the next section on up tike
by clans, and in ch-Tplor 10, a section on d-^rcidat ton of
benthos. This sho'ilil be discusser? f von -a contaminated
sediment perspective. This section could be improper!! l>/
iricorp-.'fatin'jj mapi en-l it eh<_".ild be- clearly state"! where
biological data ere not available.
it) Pollut**:t LoiHciings c;nd T»:c*nspO) t Kechanis.n
(Chapter 6)
The use of a mass balance approach gives a general
indication of the relative significance of sources but
provides little informotxon on the significance of those
sources and the biological fate of contaminants. Based
on the mass balance model alone, it is evident that
there is an important unquantified source of PCS, yet
the conclusion appears to be that sediment resuspension
is not the origin. Given the problems associated with
estimating resuspension we find this a little
surprising. This should be cause for suspecting
sediments and requiring further investigation. We
reiterate that the discussion does not address in the
slightest, non-physical, non-chemical transport
mechanisms, which are the ultimate concern.
iii) Remedial Action Steps (Chapter 10)
The table in this chapter identifies contaminated"
sediments (four times) as a source of impairments. Thif
suggest that sediments at._- a major concern despite the
lack oC adequate dis'-ussion and documentation in the
previous suctions o' the report. Rayo-l on the earlier
discussion, the need is no;: well docunontcd, and the
only reference in this chapter is a brief paragraph (on
p!50) stating that accumulation occurs, but there is no
evidence for this in the previous sections. The
remedial actions described consist of one paragraph on
p!51. This is far too brief to make any assessment. A
d^ta ' led et
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1 (">'\.ef orient G~>u%p'neT)ent
%' of Oroda du Canada MEMORANDUM NOTE DE SERVICE
ro >; D . F'ersaud
A _.' (Chairman, Sediment S u b c o m in i t tee
T.B.Reynoldson ~ \~ ^OL^FILE v
,^.. Research Scientist
r l 0 M
DC Lakes Research Branch, NVs'RI .. _ .
.
Re: Raisin River Remedial Action Plan ;
I examined four parts of the RAP with respect to the
significance of contaminated sediments and the proposed
actions based on the extent of the defined problem. I
regret to say that I wus disappointed by this pJan. I wr.
hoping for a much broader discussion of the significance of
con tr.;:i nnted sediments in an Area of Concer:-, especially
Driven the extensive work carried, out in this aiea by the
Lar^c- Lake Research Station of EPA at Grosse Isle.
The four parts of the plan I examined were: Cb.5. Definition
of Problem; Ch?. PoJlutant loadings and Transport
Nechan i srns , ^ n-> : Ch ] 0 Rer.i.-d ; D 1 A ct i on ? t epr- .
i) Definition of Problem.
Just about the first statement in this section states that
the sediments are heavily contaminated, yet the entire
section omprises four paragraphs on the Raisin R. and two
on Plu:n (Jk . The discussion focuses only around chemistry,
theie is no discussion on biological signific .nee in this
part either from a toxicity or bioaccumulation perspective.
There is a brief mention in the next section clam uptake,
and in chapter 10 a section on degradation of benthos, why
is that not discussed fron a contaminated sediment
perspective. There need to be naps in this part and if
biological data is not available it should be stated.
ii) Pollutant Loadings and Transport Mechanisms
The mass balance approach used while it gives a general
indication of the relative significance of sources provides
little information on the significance of those sources and
the biological fate of contaminants. Even using the nass
balance model it is evident that there is an important
unquantified source of PCB, yet the conclusion appears to be
that sediment resuspension is not the origin. Given the
problems associated with estimating resuspension I find this
a little surprising. I would have thought that this should
be cause for suspecting sediments and requiring further
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investigation. I would also again reiterate that the
discussion does not address in the slightest non physical
non chemical transport mechanisms, which are the ultimate
concern.
111) R o medial A c t, i o n Steps
The table in this chapter identifies contaminated sediments
four times as a source of impairments, this suggest again
that sediments are a major concern despite the lack of
adequate discussion and documentation in the previous parts
of the plan. It is evident that the plan is going to
address sediments. Based on the earlier discussion the need
is not i-'eJl documented (although T do not doubt it), ar.d th«
only reference in this chapter is a brief paragraph, on
pi 50, stating that, accumulation occurs, where is the
evidence for this in the previous sections. The remedi I
actions described consist of one paragraph on p!51. This is
far too brief to make any assessment. A detailed study plan
is required with site designations, objectives, sa.i'plirig
schedules, parameter lists etc outlined. The ni^pping should
include chemistry, physics and biology so a? to provide the
information required to assess the significance of sediment
contamination, trends in contamination and provide
i ;;f orr.a t i on
a:: \. i o: i e . ^ .
to determine the
remove
e t
t u e t <
I hope this is of some assistance
Trefor B. Reynoldscn
cc.M. Zarull
'
IJ.C.
R.O. WINDSOR
FEB- 31933
K.Ql.
I1O1.
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New York State Department of Environmental Conservation
50 Wolf Road, Albany, New York 12233-
Thomas C. Jorling
Commissioner
February 11, 1988
Dr. Donn Viviani
Regulatory Analysis Branch, PM-223
U.S. EPA
401 M Street, S.W.
Washington, D.C. 20460
Dear Donn,
Enclosed is ny review of the River Raisin RAP. Hope it will be
helpful.
Sincerely,
Robert L. Collin
RLC/vr
Enclosure
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REVIEW OF RIVER RAISIN RAP
Overall, the River Raisin RAP is poorly presented and does not do
_ justice to what I am sure are major state efforts to remedy a serious and
complex problem. Although there is much descriptive material on problems
in the area of concern, the only comprehensive presentation of the state's
views as to what the River Raisin's problems are is in a table near the end
I of the report in the chapter titled "Remedial Action Steps". This table is
^ not discussed and appears to bear little relation to the rest of the plan.
* The lack of any comprehensive statement under "Definition of the Problem"
leaves this reviewer confused about the state's view of the problems in the
River Raisin.
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_ There is no apparent plan for remediation. Actions are recommended
* but this falls far short of a state commitment for remediation. When
I programs are not in place or funds are lacking, recommended actions are
appropriate. However, for a number of recommendations the state has
| programs and authority to implement the recommendations with minimal
_ expenditures. In such cases, the RAP should lay out commitments with a
time schedule.
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There is no description of a program to monitor the success of
| remediation.
The report contains extensive material that is not clearly relevant to
the report. Soil maps and tables of soil type are an example. This
detailed information is just dropped into the report and is not integrated
into the problem definition or remedial action recommendations.
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The quality of the figures, particularly the maps, is generally poor.
More specific conments grouped under the IJC-W3PC review criteria
follow.
Are the goals and objectives clear and precise? Are they consistent
with the general and specific goals of the Great Lakes Water Quality
Agreement?
In Section 4.1, the primary objective of the RAP is stated as "to
address the PCS contamination of water/ sediments and biota". The
secondary objective is stated "to point out the need for erosion
control...". In the rest of the Chapter, however, numerous other
impairments are noted including acute and chronic toxicity effects,
power plant entrainment, impacts on drinking water, metal
contamination, etc. It is not apparent that these problems are
entirely connected either with PCBs or erosion.
A clear and concise statement of the current problems, as contrasted
with a discussion of data and findings, is lacking. The use of
different wording for the statement of RAP objectives in Chapters 4
and 8 adds to the murkiness of the presentation. The objective
regarding erosion control appears to be weak and suggests there will
be little in the RAP that will commit the jurisdiction to action in
this area. Indeed, in Section 8.0 where goals are again stated, there
is no mention of erosion control.
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_ In Chapter 4 there is no mention of the Great Lakes Water Quality
Agreement and no comparison is made of water chemistry and any
fl standards or objectives. Consequently, it is not clear whether or not
the remediation will be consistent with Agreement goals. Water
g quality data show that mean concentrations of copper and zinc exceed
. GLWQA objectives at some stations.
I Have the environmental problems in the Areas of Concern been
adequately described, including identifying beneficial uses impaired,
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the degree of impairment, and the geographic extent of such
impairment?
The description of the environmental problems seems adequate.
However, a clear relation between the data and impairment of
| beneficial uses is not always apparent. A listing of beneficial uses
mm for the waters in the AOC with a concise statement relating each to
the data and concluding with a yes, nor, or maybe statement would
urprove the presentation. An attempt at this has been made in Table
31 near the end of the report. The position of this table in Chapter
m 10 and the lack of discussion or tie-in to other parts of the plan
suggest that it was put in as an afterthought with no particular
purpose in mind.
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Have the causes of the use impairment been identified, including a
description of all known sources of pollutants involved and an
evaluation of other possible sources?
Chapter 5, Sources of Pollution (PCBs), summarizes information on the
sources of PCBs but also contains other extraneous information (e.g.
final effluent limits which do not mention PCBs, descriptions of
wastewater treatment, and a description of Act 307) which makes a
clear understanding difficult. There is no discussion of sediment
sources in this Chapter, although an objective of the Plan is to
"point out the need for erosion control". Some of the confusion in
the presentation could be alleviated by a clear statement of ijnpaired
uses and a plan development that focused on these uses.
Have remedial measures in place been evaluated?
There is a good description of remedial measures that are in place but
no specific evaluation is presented.
Have alternative additional remedial measures to restore beneficial
uses been evaluated?
There is no discussion of alternatives.
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future remedial action, maybe a monitoring plan was deemed
superfluous.
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Have the persons or agencies responsible for implementation been
" identified? Have the beneficiaries or organizations impacted by the
RAP been identified. Has there been adequate opportunity for
consultation with the public?
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It is not clear from the report what agencies or individuals are
responsible for the recommended remedial measures. Two public
meetings have been held but it is not apparent what effect the public
comment has had on the Plan. Apparently there has been no public
participation in the RAP presentation outside of these meetings.
Inclusion of a responsiveness summary to comments from the public
' would have been useful.
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Have the persons or agencies responsible for implementation been
identified? Have the beneficiaries or organizations impacted by the
RAP been identified. Has there been adequate opportunity for
consultation with the public?
It is not clear from the report what agencies or individuals are
responsible for the recotmended remedial measures. TVro public
meetings have been held but it is not apparent what effect the public
conroent has had on the Plan. Apparently there has been no public
participation in the PAP presentation outside of these meetings.
Inclusion of a responsiveness sunmary to comments from the public
would have been useful.
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United States Department of the Interior
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FISH AND WILDLIFE SERVICE '" "'Lr *""* T°:
Federal Building, Fort Stiellmg
Twin Cities. Minnesota 55111
FWS/AE-ES
FEB 1 7 1988
Dr. E. T. Wagner
Chairman, Surveillance Work Group
International Joint Commission
P.O. Box 32869
Detroit, Michigan 48232-2859
Dear Dr. Wagner:
We provide these comments, as requested, through our participation on the
Surveillance Work Group. The Remedial Action Plan (Plan) for the River Raisin
Area of Concern was reviewed using the three stage review process in the 1987
Amendments to the Great Lakes Water Quality Agreement, Annex 2, 4(d)(i)-(iii).
We have determined that the Plan only partially satisfies Stage 1 of the
review: Adequacy of Problem Definition. The Plan fails to satisfy Stage 2:
Identification of Remedial and Regulatory Measures; and Stage 3: Restoration
of Beneficial Uses. Pursuant to the review process, we concur with the
Category 2 designation made in the Plan for the River Raisin. This designation
Indicates that the causative factors are unknown and an Investigative program
is underway to identify causes. To its credit, the Plan does recommend
numerous studies and remedial investigations which will help to more fully
Identify problems within the Area of Concern. Specific problem areas with the
Plan are discussed as follows:
1. The Plan does not specify the goals and objectives related to the
protection of ecosystem components such as fish and wildlife. The
only criterion utilized in the document for a clean-up goal is the
Food and Drug Administration's 2 parts per million (ppa)-wet weight
polychlorinated biphenyl. (PCB) concentration-in fish fillets, used to
designate a fish consumption advisory. This criterion is at best a
human health criterion, based on national exposures from average
national fish consumption with little or no relationship to the health
or well-being of the rest of the environment. As such, it is
inappropriate to evaluate the effectiveness of proposed remedial
actions solely by this criterion.
Specific numerical criteria for terrestrial biota and soils as well as
water, sediment and aquatic biota should be identified for
contaminants of concern. In the case of PCBs, the International Joint
Commission objective for total PCBs in whole fish is 0.1 ppm-wet
weight to protect birds and magmaIs which consume fish. Likewise, the
Service suggests an objective for total PCBs in sediments (instream
and terrestrial soils) of <0.05 ppm-dry weight to protect fish and
wildlife via direct exposure and food chain bioaccumulation. We
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Dr. B. T. Wagner 2 I
further suggest an objective for total PCBs In water of <1.0 ng/1
part* per trUlioa (ppt) to protect fish and wildlife. PCB criteria B
for other specific biota may also be warranted. Heavy metals (cooper,
chromium, sloe) and other identified contaminants of concern (residual
chlorine, ammonia) also require the setting of ecologically-based
criteria. These criteria are essential prerequisites to the |
development of remedial actioris regardless of the authority of the
action. These criteria are needed'to establish the framework from m
which to determine the extent of remedial actions required. In their
absence, the full extent of impaired use identification cannot be
determined nor can the effectiveness of remedial actions be evaluated. m
2, The suoaary of impaired uaea (Table 31) fails Co adequately address
the likely impaired uses of the biota other than fish consumption and
degraded fish and benthlc populations* The Raisin River/PI urn Creek
estuary was once a highly productive wetland complex that supported a
great diversity of fish and wildlife species. Although ouch reduced
In size, the delta still contains sizable vegetated and open water
wetlands which are habitat for wildlife species. Based on the known
contamination within the basin, we suspect there are significant
Impaired uses concerning wildlife, Including the potential for added _
mortality to birds and other wildlife, and the potential for a human
consumption advisory on waterfowl in this area. The Plan should *
outline a program to collect and analyze wildlife samples In order to
quantify the presence and degree of wildlife impairment. Earthworms, tt
woodcock, Juvenile and adult waterfowl, mink, moskrat and turtles are
species suitable for evaluation relative to both human consumption,
foodchalns and wildlife health. These evaluations should be initiated SB
at all suitable areas within the Area of Concern including identified |
hazardous waste sites. The evaluations will need to be continued
throughout the life of the Plan to monitor restoration of Impaired .
wildlife uses.
The Plan should also contain the results of the fish tumor survey that
was conducted by Dr. A.E. HcCubbin, Roswell Park Memorial Institute,
Buffalo, New York. This investigation in the Area of Concern, was
under contract from the U.S. Environmental Protection Agency, Large
Lakes Research Station, Grosse He, Michigan. The outcome of this
work may warrant the inclusion of fish tumors or other deformities aa
an indication of Impaired uses.
3. The geographic extent of the Area of Concern is not well defined nor
documented within the Plan. The Influence of the Detroit Edison power
plant cooling water withdrawals from the River Raisin and discharge to
Plum Creek, coupled with the recent relocation of the Monroe -
Vastewater Treatment Plant outfall from the River Raisin to Plum Creek
suggests that the Area of Concern, and its associated impaired uses,
nay extend well past the boundaries established in the Plan to Include
LaPlaisance Bay in Lake Erie. It is not clear to what extent Plus
Creek is included in the Area of Concern.
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Dr. E. T. Wagner 3
A. The Plan does not discuss likely Impacts to the Lake Erie ecosytea
from contaminant input (ruiso loading) froo the Area of Concern. An
cstinatc should be cade or contaminant Input, including nutrients,
into the nearshore Lake Erie vatera. Important areas within Lake Brie
and in the vicinity of the Area of Concern should be outlined, such as
known and historic fish spawning areas, waterfowl staging and
wintering areas, and colonial bird breeding sites. The Plan does not
discuss vnether nearshore fish samples yere taken In Lake Erie and the
role these saaples played in issuing fish consumption advisories for
carp and catfish in the Area of Concern. Additionally, there is no
indication whether there are other studies of impaired uses.
5. The Plan minimizes the contribution of point sourcee of PCBs within
nd upstream of the Area of Concern (principally National Pollutant
Discharge Elimination Systen discharges), but no information on permit
limits and no data on compliance or compliance monitoring is provided
to substantiate this assertion. The Plan fails to discuss to any
large degree the sources of heavy metals and other Identified
contaminants to the Area of Concern. The origins of the various
identified heavy metals may indeed differ froo PCBs, and should be
addressed separately and in detail. Information on the monitoring and
compliance records for permitted discharge levels of heavy metals and
other identified contaminants is not presented.
6. The Plan does not provide a tentative tinetable for the recommended
actions, or an estimate of the costs involved. The majority of the
recommendations Involve additional studies to determine types and
extent of contamination at several Industrial waste landfill sites :
within the Area of Concern. This effort will require the completion
of work plans, remedial Investigations and feasibility studies in
advance of any remedial actions. A timetable for completion and
estimates of costs should be made for these preliminary studies.
7. It is our belief that this Plan will need to be consistent In its
ultimate recommendations with the Detroit River and..Wauaee Blver .
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8. ** The Appendices to the Plan should "contain'the'raw'data tableV^or
contaminant concentrations in water, sediments/soils, ."and biota
collected in the Area of Concern, as well as the monitoring and "' --'' '-
compliance records for permitted point source discharges. ' ".'.' .'" "I'l":"-
9. The-Plan should also contain information on the other natural'resource \. -' ." V
. " planning efforts that have occurred Including the management--plan V> *' ^-'S""
r", being developed for the River Raisin under the Federal funding for -V~./. »il.r.:r-j
..:-;. fisheries-restoration. ..-j .,,; .-..,.' v .-.--/;,--.;.".'».,::.-:.--:';» " _-';'-"-'. Vw.-Z.i
»- ; -. :<- -.,^
. -- c!->r---^'i
...::\ ;H- /.!.
;,..-«%. ; ^ . r -> .'» t -. "" V*?/-
-f . ' ' \»
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Dr. E. T. Wagner 4
10. The few remedial actions recommended in Che Plan center on the
continued dredging of contaminated harbor sediments by the Corps of
Engineers, and the updating and monitoring of National Pollutant
Discharge Elimination System permits by the State of Michigan. While
these are necessary actions, they cannot be considered sufficient to
satisfy Stage 2 of the review protocol. Continued sampling of fish
for the public health advisory determination is also insufficient to
satisfy the requirements of Stage 3. Likewise, contamination of
wildlife and potential for consumption advisories on wildlife needs
definitive work.
The Plan has two major shortcomings regarding Stage 1 of the review protocol.
First, the Plan fails to evaluate impaired uses for species other than fish and
benthos which is insufficient, considering the ecosystem approach. Other
potentially impaired uses need to be evaluated, and monitored throughout Plan
Implementation until restoration is complete. Secondly, the Plan does not
present any environmentally-based goals and criteria for water, sediment, and
biota for the identified contaminants of concern. Without these criteria,
neither the extent of contamination nor the effectiveness of proposed remedial
actions can be evaluated.
The completion of the studies and remedial Investigations recommended by the
Plan and an expanded evaluation of Impaired uses should eventually satisfy
Stage 1 of the review protocol: Adequacy of Problem Definition. Information
derived from these studies will enable the design of a comprehensive set of
remedial action alternatives and initiate Stages 2 and 3 of the review:
Identification of Remedial and Regulatory Measures, and Restoration of
Beneficial Uses. The Plan, at this time, has only partially satisfied Stage 1
and does not satisfy Stage 2 or 3 requirements.
We appreciate the opportunity to provide comments on this important document,
and would be glad to discuss any of the above comments with you. Please feel
free to contact Dave Best at our East Lansing ES Field Office, 517/337-6650.
Sincerely,
Actinf
Regional Director
, IJC, Windsor
NFC-Great Lakes, Ann Arbor
ES Field Office
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V'' -
INTENTIONAL JOINT COMMISSION
GREAT LAKES WATER QUALITY BOARD
SURVEILLANCE WORK GROUP
Lake Erie Task Force
100 Ouellette Avenue, 8th Floor
Windsor, Ontario, Canada N9A 6T3
or P.O. Box 32869, Detroit, Michigan 48232-2869
File # 2610-7-2 February 15, 1988
Mr. E. T. Wagner
Chairman
Surveillance Work Group
Environment Canada - Ontario Region
P.O. Box 5050
Burlington, Ontario L7R 4A6
Dear Mr. Wagner:
Three members of the Lake Erie Task Force have reviewed the River Raisin
RAP as requested. I have enclosed their letters of response for your
consideration. In general, all three reviews considered the Raisin River RAP
to be Inadequate as a final remedial action plan document.
I have also examined the document and found it not to conform with the
proposed requirements for a RAP. At best, I considered it to be a poorly
organized compilation of the existing data. By no means should this document
be considered to be a RAP. No remedial actions were ^identified, instead the
document consisted of a data inventory and a proposed series of continued
studies. Even the proposed studies were poorly defined with no"time schedule
assigned to the continued Investigations. One would have thought that after a
two year, three million dollar intensive study by U.S.- EPA - LLRS on the
River Raisin AOC, that a more reasonable RAT and continuation study plan couTd
have been developed.
If you have any questions or require additional information, please feel
free to contact me.
Since
-.'_- David E. Rathke, Chairman
Lake Erie Task Force
DER . . ,
Enclosures: As stated
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^*">t« of Ohio Environmental Protection Agency
v,. J. Box 1049. 1800 WaterMark Dr.
Columbus. Ohio 43266-0149
Richard F. Celeste
Governor
February 8. 1988
Dr. David Rathke
International Joint Commission
Great Lakes Regional Office
P.O. Box 32869
Detroit, Michigan 48232-2869
Dear Dave:
RE: Review of River Raisin RAP
I have reviewed the River Raisin RAP and my comments are attached. The review
protocol outlined by the IJC was followed as closely as possible. Although we
were asked to review the report for all three stages. It only met the
requirements of the first stage and only partially those of the second. It
has not reached the third stage at all.
The objectives stated 1n the RAP are fine for the first stage, basically
Identifying the environmental problems and pointing out deficiencies 1n the
data base. However, they cannot be considered goals for a RAP as defined by
the IJC guidelines. Please feel free to call me 1f you have questions on my
comments .
Sincerely,
Julie Letterhos
DIVISION WATER QUALITY MONITORING AND ASSESSMENT
JL/maf
0549S
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Comments on the River Raisin RAP
1. Although 1t appears that sufficient Information 1s Included to make an
accurate assessment of the environmental problems 1n the area, the format
and organization of the report make 1t difficult to achieve a clear
picture of exactly why the River Raisin 1s an area of concern. One needs
to read the entire report In order to determine all the Impaired uses and
probable sources.
2. The goals and objectives are not clearly stated but can be determined when
reading the entire report. The goals that are stated appear to be
consistent with the general goals of the Mater Quality Agreement, but
there 1s no reference to meeting the specific goals of the Water Quality
Agreement. Shouldn't some reference be made to the goals of the Clean
Water Act - such as Hshable. swlmmable?
3. In the Executive Summary, problems 1n the area of the concern have been
Identified as PCB contamination 1n fish, PCB and heavy metal contamination
of sediments and sediment Input from upstream of the AOC. However, In the
text of the report, additional problems are also Identified such as a
biological community Impaired by toxic discharge from the Monroe WWTP,
entrapment and Impingement of fish at the power plant, navigational
Impairment and elevated concentrations of conventional pollutants.
4. Geographic extent of the area of concern Is described 1n the text, but a
good map 1s needed.
5. No reference 1s ever made to the microbiological conditions of the AOC or
1f 1t 1s suitable for primary contact recreation. Is the beach at Sterling
State Park always suitable for swimming?
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6. The major pollutants of concern were Identified as residual chlorine,
copper, zinc, chromium and PCB. The sources and possible sources of these
were all presented. Are there CSO's 1n the area of concern? They are
never mentioned until Chapter 10. Paper plants are Identified as a source
of PCB's, but the plants themselves are not Identified as paper plants
until near the end of the report.
7. Remedial actions 1n place have been described and additional sampling to
further define ambient conditions 1n the lower river have been presented.
8. Two public meetings were held and 1t was Indicated that the public
provided a valuable historical perspective. What future plans are there
for public Involvement as the plan progresses?
9. It 1s unclear whether or not the Improvements to the Monroe WWTP are
completed or still 1n progress. Will limits for metals and monitoring for
toxics be Included 1n future NPDES permits? f
10. A number of additional remedial measures to restore beneficial uses have
been Identified. Some of these will occur under existing programs such as
further Investigations of the Industrial landfills and disposal sites
addressed under Act 307. For the remaining activities there 1s no
Implementation schedule or Identification of parties responsible for the
Implementation.
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Comments on the River Raisin RAP (cont'd)
11. No surveillance and monitoring program to track effectiveness of remedial
actions and confirmation of restoration of beneficial uses has been
described.
12. Overall, the draft RAP contains alot of pertinent Information, but much of
this Information should be presented 1n an Appendix. Chapter 3 devotes
too much space to the entire river basin rather than focusing on the area
of concern. It should focus on background environmental conditions that
emphasize Impaired uses and characteristics that have led to the site
being considered an area of concern. The same comments can apply to
Chapter 5. A tighter format would present a much more useable report.
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Ministry 01
Natural
Resources
Ontario
Your file:
Our file:
1988 01 25
Dr. David E. Rathke
Lake Erie Task Force
International Joint Commission
100 Ouellette Ave., 8th Floor
Windsor, Ontario
N9A 6T3
Dear Dave :
SUBJECT: Review of River Raisin RAP
I attach my review of the above. I'm not sure that I
reviewed this from a surveillance perspective.
Somewhere I lost my perspective entirely.
Sincerely
Leach
Research Scientist
Fisheries Research
R.R. 2
Wheatley, Ontario
NOP 2PO
(5190 825-4171)
Attach
JHL/fc
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Review of RAP for River Raisin, October 27, 1987
I have attempted to review the River Raisin RAP along the
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guidelines suggested by the Protocol for Review of RAPs for
Areas of Concern (dated 87-12-10). Specifically, I have tried
to respond to the questions listed under stages 1 and 2 of the
review process as follows:
Stage I (adequacy of problem definition)
(a) Are the goals and objectives clear and precise?
Are they consistent with the general and specific goals
of the Great Lakes WQB?
Very brief statements of goals and objectives appear on
Pages 6 and 146. They are general and do little more than
state that the objectives of the plan are to determine data
deficiencies and recommend remedial actions that will lead to
restoration of impaired uses. The brevity and lack of
informaton in the objective statement would indicate that the
general and specific objectives of the 1978 GLWQA were not
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considered in its formulation. The only persistent toxic
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substances mentioned in the RAP objective are PCBs although
many of those listed in Annex t of the Agreement are included
in the RAP as major pollutants of concern. Furthermore, the
RAP objective is to reduce PCB concentrations in fish from the
AOC to less that 2.0 ;ug g whereas the Agreement (Annex 1)
objective is no more than 0.1 ug g
(b) Have the environmental problems in the AOC.-.been.-.^ r-r.'.'ir.-
adequately described, including identifyingebenef iciali ?.
uses impaired, the degree of impairment and = the-p*.irc«~ ,
geographic extent of such impairment? ce-rs.r~~hl<; *~*-*
Section 4 contains a considerable amount of information
on environmental problems. A summary of the impaired uses
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(such as expressed in Table 31) included near the beginning of
this section would have been useful. The degree and
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geographic extent (particularly in Lake Erie) of impairment
| does not appear to be well documented. Do the EPA reports
from the 1983-84 research effort by the Large Lakes Research
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Station contain additional information pertinent to this
section?
(c) Have the causes of the use impairment been identified,
including a description of all known sources of
pollutants involved and an evaluation of other possible
sources.
* Section 5 includes a description of point and non-point
sources of a number of pollutants. Table 21 summarizes a
number of organic and inorganic pollutants from non-point
P " sources scored by the Michigan SAS. However, the summary to
(L section 5 covers only PCBs and indicates that they are not a
serious problem in municipal and industrial effluents. Table
126, which is a summary of PCBs in or adjacent to landfills in
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the AOC, indicates a distinct lack of data. On the other
hand Tables 27 and 28 provide substantial lists of
_ contaminantion and potential sources from the Port of Monroe
* landfill sites. There appears to be inconsistencies in
presentation of information in this section. No effort is
made to explain why the Monroe WWTP has diverted its discharge
from River Raisin to Plum Creek or to speculate on effects of
the diverson on water quality in the AOC ." .The EPA- (LLRS) .. -^v
study indicated that the WWTP effluent was; ±oxio.to cu-.tu n:3; ;
Ceriodaphnia and fathead minnows. Is there.^additional :.--. fc-r:.--:
information in the EPA reports that should be included in this
section?
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Stage 2 (identification of remedial and regulatory measures)
'-, (a) Have remedial measures in place been evaluated?
Completed remedial actions and remedial actions in
progress are listed in section 7. Very little evaluation of
the actions is included in the discusson.
(b) Have alternative additional remedial measures to
restore beneficial uses been evaluated?
No
(c) (d) (e)
Some of the information pertaining to the remaining
questions in Stage 2 is included in section 10, Remedial
Action Steps. This section outlines studies that are
~~\ considered necessary to provide information required for
implementation of remedial actions. Some of the studies are
effluent monitoring programs. Remedial actions are
recommended for specific sources of pollutants but schedules
* - *
for implementation are not included. Surveillance and
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monitoring programs to track effectiveness of remedial actions
and confirmation- of beneficial uses have not been adequately
described. Persons or agencies responsible for implementation
have not been specifically identified. The main impaired use
being addressed is the warm water fishery yet there is no
indication in the RAP that the AOC supported a fishery.
Section 3 refers to sport fisheries upstream of-the-AOC. ^
In general, I found that the RAP cpntainsia large amount ;;
of information which is not well organized. -Parts of the
report are repetitive. The RAP recommends more studies and
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mentoring before remedial actions are taken. My review of
( I the report was hasty but it appears to me that sufficient
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M 'information exists in this document and the EPA reports (LLRS)
to permit the agencies to proceed with the drafting of
I implementation schedules for remedial actions.
As an aside, I think the report would benefit from
B rewriting with a view to brevity and improving organization
M and clarity. Some of the figures are cluttered and some of
the raw data tables could be eliminated, reduced or placed in
ft the appendix. Many references cited in the text are not
included in the reference list. In my view^Appendix 3-1
I adds little to this report.
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December 29, 1987
To: The Authors of the River Raisin Remedial Action Plan (RAP)
From: Laura A. Fay (Center for Lake Erie Area Research)
Subject: REVIEW OF RIVER RAISIN RAP
According to the protocol for review of the RAPs for Areas of Concern, I
feel that the River Raisin RAP 1s 1n need of some revision. Although there 1s
good Information 1n the PLAN, 1t 1s not presented 1n a concise manner for the
reader. The environmental problems were not made apparent, primarily due to
the lack of Information on sediment contaminants and little or no discussion
on the degree of Impairment to the system, I feel that the environmental
setting of the AOC needs to have additional Information to provide adequate
coverage (pg 7-34). Please add at least one paragraph on all the Industrial
effluents within the AOC. For those Industries Involved with PCBs more
detailed Information would be beneficial.
The primary objective of addressing PCBs In water, sediments and biota
appears not to be well covered due to the poor organization of PCB
Information. All PCB Information should be Included 1n this report.
Mason Run concentrations for PCBs Indicated levels as high as 499.7 ng/L
during the 1983-1984 study yet the report recommends additional collection of
samples. Don't we know enough to make positive suggestions for Improvement?
I have Included some specific comments regarding the text, figures and
tables below. If I can be of further assistance please let me know.
p. 4 Simplify Figure 2. Eliminate some water depths and possibly
latitude and longitude lines. " " *
p. 35 If PCBs are of primary concern then fish and water concentrations
should be the first Issue presented. Currently PCBs 1n fish are 1n
section 4.1.2 and PCBs 1n water 1s 1n section 4.2.1 (p. 47) and
PCBs fn sediments" (p. 99). r suggest ttrat~you add a= map- depicting
water and sediment PCB concentrations to highlight the problem
spots.
p. 38-40 Show a map Indicating station locations (I.e. stations 7 and 45).
p. 46 Elaborate on how pollutants of concern were determined. Add a
table of data showing concentrations of all metals. I am surprised
that vanadium levels are not high considering the size of the
Monroe Power Plant.
p. SO Include table listing IJC water quality objectives for In, Cu, Cr.
Also Include FDA guidelines. '
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p. 58-61 This 1s old sediment data (1976). Where is Information from the
U.S. EPA 1983-1984 study (Clarkson College)?
p. 62 Change Rathbun et al to Fay et al.
p. 65 Again, why is no mention made of the 1983-1984 metals study?
Sediment data was collected for metals and organics.
p. 71 Point and nonpoint sources are not obvious (Figure 20b).
p. 74 In Figure 21 please Indicate the relative volume of flow using
thickness of arrows. Also Include location of dams and dikes.
p. 88-91 Figures 25, 26, 27, 28, 29 and 30 are of dubious quality.
Orientation (I.e. North) should be consistent and maps need to be
more legible.
p. 96 Why do the less than values fluctuate between different dates of
analysis. For example Selenium varies from .03 to .008?
p. 104 Figure 32 needs to be redrafted. Indicate north in a conspicuous
place 1n all figures.
p. 108 Figure 35 delete and use base map from Figure 23.
p. 110-112 There are too many maps in this report and not many of them are
comprehendable. Combine the three maps on these pages. Also
simplify Figure 2.
p. 123 Figure 40 1s not applicable. Delete it or revise it for freshwater
'estuaries', (delete upper salinity layer* and bottom salinity
layer).
p. 141 Why.are Ford and Union Camp operating under expired NPDES permits?
This 1s Important and should be explained 1n text.
p. 142 Show new location of WWTP outfall to Plum Creek in a figure.
p. 142 Reference figure for new dike in Plum Creek. Since the lagoons
were built in 1983 to improve the water quality then data should
have already been collected to demonstrate their effectiveness as
stipulated 1n Protocol for Review of RAPs. ;;i .
p. 142 Section 7.1.4. Provide table of data deraonstratlng-.reduction 1n ;-;...
fish Impingement at Power Plant since installation-bf^Fish Bypass. " 1J
p. 142 Nine remedial actions are currently 1n progY-ss butipage-r!43'0l a« lion*.
mentions only seven. List all nine. ' ,......:.. . .\ ..
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p. 144 It may not be cost effective to collect water samples for priority
pollutants (especially PCBs). Suggest sticking with sediment and
fish analysis or possibly Cladophora. Sediment and water data
should already be available from LLRS for 1983-1984.
p. 146 Text implies that the only impaired use of River Raisin is the
fishery! If this true?
p. 148 Explain SAS screening score of 848.
p. 151 Item c. Sediment mapping was conducted in 1983-1984 by U.S. EPA
and MDNR. Where is this data?
p. 152 10.2.3. High PCBs have been found in Mason Run during the
1983-1984 study. What other source could it be other than Union
Corp? If multiple sources are suspected then more than the
effluent should be tested.
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UNITED SERIES HWIROWEMmL PROTECTION AGENCY
GREAT LAKES MVnOftL PROGRAM OFFICE
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EftTE: April 25, 1988
SUBJECT: Review of River Raisin Remedial /
Action Plan - October 27, 1987 Version ^-/7
* FRCM: Vacys Saulys, U.S. Point Source Coordinator 7^2^*
«TO: Griff Sherbin, Canadian Point
Source Coordinator
I have completed my review of the Raisin River Area of Concern (ADC)
Remedial Action Plan (RAP) and have the following conments:
In general, the RAP is well written and organized. It addresses most of
the significant issues, and provides good sunmaries of all relevant data
which is available. As is indicated in the attachment concerning ground-
water aspects of the plan, more detail, and more discussion of specific
contaminants, their concentrations, and transport is needed.
Although some remedial steps have been taken, the complexity and
magnitude of the pollution problems have prevented quick fix solutions.
The RAP presented is therefore more a Remedial Investigation Plan than
a Remedial Action Plan. The RAP needs specific information concerning
financial and resource commitments made to performing future
investigation and remedial actions, as well as the costs of various
alternatives and proposed schedules for these activities.
An example of this is the waste disposal problem at the Ford Motor
Company - Monroe Stamping Plant. The sludge lagoons at this site contain
listed hazardous wastes, which are regulated under RCRA and Michigan's
Act 64. The RAP mentions this problem, and indicates that a consultant
(Neyer, Tiseo, and Hindo, LTD) was hired to evaluate the feasibility of
combining the sludge from all existing disposal areas into a single
permanent disposal area on site. No details of this alternative are
given. Without more detailed information, the success of this proposal
is questionable. Since the Ford Motor Company site is not presently a
RCRA licenced disposal facility, the company and the proposed disposal
site would have to meet applicable RCRA requirements before the plan
could be considered feasible.
The RAP contains many typographical and format errors which must be
corrected. Many of the figures were difficult or impossible to read.
Several citations are incomplete or inappropriate.
A list of these problems is also attached.
Attachments
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GENERAL COMMENTS
River Raisin Remedial Action Plan
In order to understand the relative importance of all waste cxaitributions
within the Area of Concern, it is necessary to inventory all sources and
attempt to evaluate their emulative effect. Normally this would be
perceived as a difficult task, however the State of Michigan has the
tools to achieve this. The Michigan Resource Inventory Program,
operating out of the Land and Water Management Division has the
capability to perform evaluations of multiple sites impacts on a basin-
wide, or a smaller scale. Digital inventories of natural features,
hydrologic features, land use, and base maps are complete or partially
complete for Monroe, Lenawee, Washtenaw and Jackson counties.
Furthermore, some Act 307 site locations, all NPDES outfall locations,
and some ground water information, ambient water quality information are
computer readable as well. Use of Michigan Geographic Information
Systems (MIRIS/GLIS) to organize all information in the River Raisin
basin would allow comprehensive, unequivocal determinations of inputs
from various sources both basin-^wide and in down-river areas.
MIRIS and GLIS have been used in the Draft Clinton River RAP effectively
for integration of various data. Also, use of these systems for map
generation would improve legibility of the graphics in this RAP.
Specific Conments
p. 25 Section 3.4.3 Waste Disposal
It would be best to evaluate direct and indirect dischargers separately
from solid waste disposal areas and other known or potential sources of
ground water contamination. Numerous known or potential sources of
ground water contamination in addition to the six solid waste landfills
listed in this section are found in the Raisin Basin and in down-river
areas. An inventory of fifty such sites within the River Raisin drainage
basin have been selected from the Comprehensive Environmental Response
and Liability Act Information System (CERCLIS) and listed in an
Attachment. An inventory of waste generation, transport, storage and
disposal facilities in the Hazardous Waste Data Management System (HWOVE)
database would yield a list of other potential sources of ground-water
contamination. Have all these sites been considered as sources of water
quality impairments?
Die US Geological Survey estimates that ground water makes up
approximately 10% of river flow in southeastern Michigan. Ine magnitude
of toxic loading to the River Raisin based upon ground water quality
information and ground-water discharge rates needs to be estimated.
p. 46 Section 4.1.6 Toxic Impacts on Human Health - What levels of
contamination have been measured? What are the impacts on surface water
quality?
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p. 89 Section 5.3.1.1 - Chemistry analyses for ground water should be
presented and coipared to U.S. EPA Anfcient Water Quality Criteria (ftWQC),
Michigan Water Quality Criteria (WQC) and Great Lakes Water Quality
Agreement (GLWQA) Specific Objectives. Estimates of ground-water
discharge and toxic loading to the River Raisin need to be made.
p. 101 KB Contamination - The "evidence of further ground-^water
contamination11 should be presented.
p. 106 Section 5.3.3 Ford Motor Company Monroe Stamping Plant - Ground
water quality data should be presented and compared to USEPA BWQC, GLWQA
Specific Objectives, and Michigan WQC.
The degree of confinement and of the hydraulic connection with surface
water of all described landfills in the area needs to be evaluated? Is
the Detroit Edison Fly Ash Disposal Area a clay-lined facility? What is
the likelihood that the large volume of KB contaminated sediments placed
here (1,326,963 cubic yards) are truly confined.
p. 119-120 Table 27 - This table should highlight that the levels of
metals in ground water are greatly in excess of various criteria:
mercury levels are in excess of three orders of magnitude greater than
acute ?MQC and 3500 times the Maximum Contaminant Level (MCL) for
drinking water; lead levels are 20 times the MCL. Also the high
concentrations of solvents in ground water here, cause concern that
cosolvent effects and the possible existence of Non-Agueous Phase Liquids
(NAPL) cause a significant increase in KB mobility.
p. 148-150 Section IQ.l.l - Ground-^water assessments at area landfills
need to consider the following:
Estimates of ground-^water discharge rates and amounts.
Cosolvent enhancements to KB transport.
Presence of NftPL and possible enhancements to KB transport.
Possible macronolecular transport of PCBs.
p. 158 10.3.3 Detroit Edison - Ground-water discharge from this and other
area landfills should be measured directly as wells as estimated based
from hydrogeologic characteristics.
p. 153 Section 10.3 Non-Point Source Remedial Actions - A schedule for
remedial activities at area landfills needs to be included. What is the
likelihood that proposed remedial actions will be completed? What
alternative sources of funding for completion of these activities have
been considered?
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ATTACHMENT
Consolidate Packaging Corp.
Darling Road Landfill
Detroit Edison Dredge
Ford Motor Company
Heckett Engineering landfill
Jessie Oil Company
Monroe City Landfill
Monroe Stone Plant (SIA)
Monroe Works
Port of Monroe Landfill
Salco Industrial Services
Simons Sanitary landfill
Zieman and Grames Road Dump Site
City of Adrian Salt Storage
Adrian WWTP
Amoco Station Deerfield Village
Anderson Development Company
Brubaker Clarence Farm
Buckeye Products Corporation
Dura Corporation
Estech Gen Chem Corp. Riga
Fatco Prod.
Kewaunee Scientific
Lenawee Co. Rd. Ccmn. Main St.
Lenawee Disposal Service Co.
MOOT
Medina Township Dump
Michigan Mineral
Michigan Prod. Dairy Co.
Palmira Twp. Fertilizer Spill
Pawson Road Paint Solvents
Railroad Avenue Plating Co.
Raisin Township Landfill #1
Raisin Township Landfill t2
Stauffer Chemical Co.
Sunoco Station Clinton
SWS Silicones Corp.
Tecumseh City Dump
Wibbeler Landfill
Astro Manufacturing
Chelsea Sanitary landfill
Detroit Abrasives Company
Diversified Dimensional Deburring
Ford Motor Company Saline Plant
Hoover Universal Inc. Plastics Mach.
Manchester Dump
Mobil Station Chelsea
Sycor Corp.
Gurmley Bartlett landfill
Napoleon City Landfill
Village laundromat
Div.
City
Monroe
Milan
Monroe
Monroe
Monroe
Dundee
Monroe
Monroe
Monroe
Monroe
Monroe
Dundee
Milan
Adrian
Adrian
Deerfield
Adrian
Blissfield
Adrian
Adrian
Riga
Qnsted
Adrian
Adrian
Adrian
Adrian
Canandaigua
Adrian
Adrian
Adrian
Cnsted
Adrian
Raisin Twp.
Raisin Twp.
Weston
Clinton
Adrian
Tecumseh
Cnsted
Chelsea
Chelsea
Chelsea
Chelsea
Saline
Manchester
Manchester
Chelsea
Manchester
Brooklyn
Napoleon
Brooklyn
County
Monroe
Monroe
Monroe
Monroe
Monroe
Monroe
Monroe
Monroe
Monroe
Monroe
Monroe
Monroe
Monroe
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Lenawee
Washtenaw
Washtenaw
Washtenaw
Washtenaw
Washtenaw
Washtenaw
Washtenaw
Washtenaw
Washtenaw
Jackson
Jackson
Jackson
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TYPOGRAPHICAL PROBLEMS
Raisin River Remedial Action Plan
Section Comments
1. Executive Summary
Cn page 1, paragraph 3, the text should be changed as
indicated below:
".. .Port of Monroe Landfill, [at] which a remedial..."
3. Environmental Setting
3.2.3 Hydrology
The citation "...Cole 1978 as cited in Rathburn 1985..."
should be changed such that the original reference is
listed in the bibliography. If the original source was
not actually checked, it should not be cited.
The abbreviations MDNR and MWRC (Michigan Department of
Natural Resources and Michigan Water Resources Commission)
should be defined before the citation since they will not be
obvious to all readers.
3.4.1.2 Water Supply
On page 24, paragraph 2, township is misspelled
11... rechlorinated in Bedford township..."
4. Problem Definition
4.1.3 Actute Toxicity Impacts
Monroe WWIP - wording is awkward:
".. .The report concluded that chlorine appeared to be
responsible for the acute..."
try
.. .stated that chlorine was the probable cause of...
A similar awkward statement occurs in the description of
the Ford Motor Co. outfall in the same section.
4.1.4 Chronic Toxicity Impacts
More awkward phrases were found here :
"A definite correlation appeared to exist between..."
try
There appeared to be a correlation of copper and
zinc concentrations with the zooplankton EC50...
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5.0 Sources of Pollution
5.2.1 City of Monroe WWTP
Cn page 67 the citation Bednarz, Johnson and Buda (1985)
was not found in the reference list. As in the comments for
section 3.2.3, the citations for Thompson and Irvin (1980)
and for Boersen and McGarry (1984) should either be listed
independently in the bibliography, or omitted if these
sources were not actually consulted.
On page 69, 2nd paragraph, should read
11 The permit schedule of compliance requires the permitted
[facility] to discontinue..."
5.3 Non-Point Sources
Cn page 79, 2nd paragraph, one of the "inmediatells should
be removed (... "immediately address immediate human
health concerns...")
Table 22 Record of Wastes Accepted - Port of Monroe
The following errors were found:
Page 84 Jan 11, 1956 "...194 rail cards..."
Page 85 June 6, 1961 - The meaning of the sentence which
follows this heading is unclear.
Figure 30 - page 95 - This figure is iirpossible to read.
Figure 38 - page 112 - This figure is unsatisfactory.
Page 116 - last line - ... [s]paucity of data...
6.0 Pollutant Loadings and Transport Mechanisms
Sixth sentence - ...undert jstandings...
Figure 45 - This figure is impossible to read.
7.0 Remedial Actions
7.1.3 Waste Containment
Questions about the dike should at least be followed by
question marks, and preferably listed with arabic numbering.
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7.1.4 Page 144 - 1975 to Present
Correct to read :
'"Die removal of sediments for the purpose of navigation can
also be considered £Q be. "
10.0 Remedial action Steps
10.3.4 Consolidated Packaging Corporation
Section A. "Die phrase ".. .what are the contaminants that are
present and at what concentrations..." is very awXward.
seven lagoons, and their concentrations.
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I try .. .to determine what oontaminants are present in the
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1 ll.l'l -t»»»t»t
f'.I'M 11
I 'iv
C.vi.vi.1
25 St. Clair Avenue East
7th Floor
Toronto, Ontario
M4T 1M2
cv'-»
CXx '»
Telephone: (416) 973-1085
1165-36/C71-10
16 February 1988
W.A. Steggles
Water Quality Programmes Committee
International Joint Commission
100 Ouellette Ave,, 8th Floor
Windsor, Ontario, Canada N9A 6T3
Dear Sir:
Re: Review on Rivrfr Raisin RAP
As per your request, the above-noted RAP has been reviewed by
staff of this office:
1) from a point-source perspective; and,
2) for all three stages identified in the IJC's RAP Review
Protocol.
In general, the RAP is incomplete.
substantive comments is attached.
Sincerely,
A summary of more
G. Sherbin, Manager
Pollution Abatement Division
(SH)
IBM cwiwn* My*
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Rte/or Kaisin RAP Review Out File: 1 1 65- 36/C7 1-1 0
S. Humphrey Date: 16 February 1908
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requested, the River Raisin RAP has been reviewed:
1. from a point-source perspective
2. for all three stages identified in the IJC's RAP Review Protocol
Goals and Objectives?
fe goals and objectives of the RAP are clearly defined. It is understood
at the intent is to restore water quality and designated uses to the River
»isin by 1) addressing PCB contamination of water, sediments and biota; and,
emphasising need for erosion control (non-point source issue).
t
es Impaired?
It is clearly stated that the primary impaired use of the River Raisin is
fat of the warmwater fishery (ie fish consumption advisory for PCB's,
pecially in carp).
int Sources Identified?
The RAP demonstrates a good understanding of the contributions to the problem
tiginating from some, but not all, point-sources in the AOC. This being the
se, the RAP cannot be deemed complete. The RAP team must identify all
sources of contaminants to the AOC before starting to implement remedial
asures.
PCB mass loading- study undertaken by USEPA {1987) indicates the presence
"unaccounted-for" sources of PCB's in the River Raisin. Other possible
urces not identified in the RAP:
to date, no PCB measurements have been conducted at any of Union Camp's 1
outfalls discharging into the AOC. The effluent from this industry must
be monitored for PCBs.
though not considered a point-source, stormwater and combined sewer
overflows have been known to contribute PCB's to AOC's (Marsalek and Ng,
1987). Perhaps an inventory of SW and.CSO outfalls, and measurements
for priority pollutants (incl. PCB's) will help to identify/eliminate
this as a source.
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»medial Measures?
n page 148, the RAP refers the reader to Figure 27, which supposedly lists
use impairments, causative pollutants, and pollutant sources". Figure 27, ipflj
y copy of the RAP, is a location map of the Port of Monroe. I believe the P
ext should refer the reader to Table 31.
here seems to more "studies" than "actions" listed under this section. In
he case of point-sources, the RAP tends to call for "remedial investigations
nd data analysis", after which "feasibility studies to determine the best
uited remedial actions" will be completed. Under the IJC's Protocol for
eview of RAPs, a completed RAP must define the actions and the timetables to
estoce all identified beneficial uses in AOC's.
that Uses Can't Be Restored?
'he RAP has not identified any "uses which cannot be restored", likely
:he RAP team has not completed all necessary studies'.
Surveillance/Monitoring Programme?
4ot as yet identified.
Agencies Responsible for Implementation Identified?
tot as yet identified.
Restoration of Beneficial Uses?
Not as yet identified.
fZ
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'
.'"-V.-! Sl;Uc of \\ i.^oiiMn \ DciPAPl \'.:1 ^1 OF NATURAL
International Joint Cc:.r..r.isric:
IOC Ouollec-te Av^., 8uh Floor
P.O. Box 32669
Detroit, Michigan 48232-2863
Vhis letter is to trans.". Lt iry co:rn;eni:s on the Hiv.
Kor; edirJ Action Plan.. I have limited my co:~~.or>ts
ele~-.'.nts of the plan v;hirh pertain to nonpar! nt so irce
pc?lurion. Due to ?,n in-state neeting, I \;ill not be able to
a i r e no. the n:\lr i.ic 3t.i r/'i of ~h:o I-onpoint Source r~ur co.vr it -.ee . If
c 0 3 - .' '> t':-9± 54 .
C-" ^r:^1 ".o: ~ent
In orier to faciiitatf ho\ J j the- g-i.;i :.:« I
tl: ~i. ." i_Jc.n::ing process, I s~.:^gest removing rvjor. of t^?- bac>.vix;; ~d
tt c'.i.ical .iata fro:^ the :>Hii report and inclining it ' n
t --'_hr. ic;;l app:-- indices .
Th:: t-xpcu^ivc^ s\:w;raf:ry do^.-3 re D c"^ a good job of s .;-.?-. -;r i:7 ir ^ th^
r^. . e. dial c-i^uions v.'hich are rsccr, .r^'-.Td
jr.n "no ^oint source" in this ol^-in inclvce:" lc;n Jf i 11 s . I
I- . l " L ti J. .11 11 <-) ._ J j_: 1 L. t. 'J ^* ^_ ^ t^ ^ i: o 1 ] , ^ . j _L '.x ' 1 _L J O r L
d .> not", agree with this definition. Landfills
C° 7 '- -. - --^ ~r a ^ '->.> " '--," r_ cr /-> -^ >. ^^ ^ 1 - r. ^ 7- tc
ITc'cle 3, p. 17. - This inform at ion shoulc bo prefer. ;<-
v_., j~ -: r :j 1"; ^- _d , rath&r than th.3 counties to refieco the ^ c
conLr.1 buLing area to the Piver I:en sin.
4.1.1 - V7hat specific levels of turbidity and phosphorus ?re
beirig referred to?
4.1.3 - Are Tore recent dara available?
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4.1.C - '."h.-:r is the depth of the drinking vatar ..;>11 <~?
4.2.1 V.'nar are tr.a currently applicable wat.^r ci.?.]ity
s~_\: -":;. dr-T What is ri-i^nt by "infrc-.j
r--,r;:- -; -u ^e .-, - v;.itrT rju'-i]it.v standard
not aaaress i;roan run.oi* vmcn couj.a ;"-e a n-ijor
source of hoa^v netals in the sed irir-n.ts.
tavgf.-tir:c rr-ripoint source controls in cgr icv:ltur?.I are?~ .
rolr-.tivcj c^rtribut:on is arjricul rural no; point ?ourc-: poll
r.a};iri? M\:at sp?:cific pollutants and
1 believe r.he plan doe^s an adequate job of addressing the PCB
sources and rcredia] actions but falls short in te^ nss of
no ipoLnt s-o^vces tror urban and rur^l c';ro?,s.
1r,:.nh you for the c/rortunity to rcivicv: the River R?isir. vle-n.
/ ' N /
yich^cl I;/ Il-?.-;elyn, Chief
:To:;poJ :.r. £:.;. r;-t. and L^.na Kanagev. nl-
E-.r-c-au ci U.'/-r.r Ro.jovrces I'lanac.o^-int
-2-
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February 11, 1988
RAISIN RIVER REMEDIAL ACTION PLAN
Comments by
G.J. Wall
Canadian Chair, Nonpoint Source Subcommittee
Stage 1. o Goals appear clear and precise. Consistent with the Great Lakes
Water Quality Agreement.
o Beneficial use Impairment has been described but the degree and
extent of this Impairment are not well known.
o Sources of all the PCBs have not yet been determined to allow a
cost effective targeted remedial program.
Stage 2. o Existing remedial measures (e.g. landfill dike or waste water
treatment diversion) have not been evaluated for effectiveness.
o Alternative remedial measure options are not presented for
evaluation.
o No Implementation schedule presented but this would be difficult
to do until further site assessment 1s completed.
o Surveillance and monitoring programs to track remedial action
effectiveness are not well documented.
o Agencies responsible for action are not always Identified.
Limited public participation apparent.
Stage 3. o Remedial measures have not yet been implemented nor have the
sources been Identified and quantified.
o No evidence for restoration of the beneficial uses.
Comments: Generally a good effort to address a rather complex problem.
Given the main objective of the RAP is to reduce PCB Inputs,
there remains the need to quantify the relative significance of
the PCB inputs and the relative costs to rehabilitate.
jj Available remedial dollars could then be tarageted to specific
sources on a cost benefit basis.
cc: J.H. Hartig
R.E. White
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AMS010.DOC
KUB/ms
2/12/1988
MEMORANDUM REPORT
REVIEW OF RIVER RAISIN REMEDIAL ACTION PLAN
FOR SCIENCE ADVISORY BOARD, INTERNATIONAL JOINT COMMISSION
FEBRUARY 24, 1988
INTRODUCTION
The Science Advisory Board of the International Joint Commission has asked
that remedial action plans prepared for areas of concern within the Great
Lakes basin be reviewed by teams of Board members. Review of the remdial
action plan for the River Raisin was assigned to a team consisting of A. M.
Armour. L. K. Caldwell, D. A. Chant, and R. A. Liroff. K. W. Bauer was asked
to coordinate the team review and draft a memorandum report for Board review
at the meeting of the Board scheduled to be held in Erie, Pennyslvania,
February 24-26, 1988.
SUMMARY OF PLAN
The remedial action plan for the River Raisin was prepared by the Michigan
Department of Natara-F Resources-with the assistance of the Science" Application"
International Corporation. The plan is documented in a 177-page report
entitled "Remedial Action Plan for River Raisin Area of Concern" dated October
27, 1987.
The lower River Raisin was identified by the International Joint Commission as
one of 42 areas of concern in the Great Lakes basin. *The River Raisin area is
located In the southeastern portion of Michigan's lower peninsula in Monroe
County.
The overall purposes of the remedial action plan are given as the compilation
and analysis of existing data for use in the development of a plan for the
restoration of impaired uses, and the determination of data deficiencies and
additional investigations required to help define the problems and sources.
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The plan contains descriptions of the environmental setting, Including general
data on drainage, topography, hydrology, soils, runoff, erosion, and land and
water uses In the area; Identifies Impaired uses and specific concerns,
including eutrophlcatlon Impacts on biota, acute toxlclty Impacts on aquatic
life, chronic toxiclty impacts on aquatic life, physical impacts on human
health, toxic impacts on human health, and impacts on navigation; identifies
the major pollutants of concern; and identifies the sources of the major
pollutants.
The problems identified include high total phosphorus concentrations
associated with high sedinent loadings from upstream areas; contamination of
sediments and water column by heavy metals and polychlorinated biphenol;
contamination of fish tissues by polychlorinated biphenol and the need to
issue a fish contamination by and consumption advisory; acute toxlcity impacts
on aquatic life, primarily from chlorine and elevated levels of oil and
grease; and chronic toxicity impacts on aquatic life. With respect to the
latter, the data indicated no special locational trends, with copper and zinc
being the suspected pollutants involved, although chlorine, un-ionized
ammonia, pesticides, and other metals were also present. Evidence was found
of some pollution by toxic substances of the aquifer providing drinking water
to a portion of the area, and navigation was found to be impacted by the
_excessive sedimentation with required removal by dredging of the shipping
channel. The plan identifies an enormous fish kill taking place at the
Detroit Edison electric power generation plant with up to 31 million fish
being killed per year. The fish contaroinaton and consumption advisory is
identified as the primary use impaired, and the plan is specifically designed
to address this impaired use.
Sources of pollution identified included the direct discharge of industrial
process waste and cooling waters; leachate from waste lagoons, stockpiles,
storage sites, and landfills; the lower 2.6 miles of the River Raisin itself;
and upstream agricultural nonpoint sources of pollution. The plan attempts to
quantify pollutant loadings and identifies the transport mechanisms and
probable fate of the principal pollutants.
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The plan Identifies completed remedial actions, including permits issued under
the National Pollutant Discharge Elimination System, limiting the discharge of
polychlorinated biphenol and certain toxic metals, ammonia, and chlorine; the
construction of improved sewage treatment works by the City of Monroe; the
construction of a waste containment dike by the Port of Monroe Authority; and
an effort Co reduce the enormous fish kill continuing to take place at the
Detroit Edison plant.
The plan identifies nine remedial actions currently in progress. Eight of
these deal with site assessments and remedial investigations relating to
landfills and industrial sites.
Proposed remedial actions include the continued removal of sediments by
dredging for navigation purposes; the abatement of agricultural erosion in
upstream watersheds; a fish contaminant monitoring program; a water quality
monitoring program; and some special fish sampling.
REVIEW COMMENTS
The review comments provided below reflect the collective judgments of the
team asked to review the River Raisin remedial action plan. The comments are
organized by the Protocol questions set forth in the International Joint
Commission Water"Quality" Board's draft Protocol for" Review dated December"10,
1987, and the International Joint-Commission Science Advisory Board's
Guidelines for Review of Remedial Action Plans dated February 4, 1988.
Q. Are the goals and objectives clear and precise? Are they consistent
with the general and specific goals of the Great Lakes Water Quality
Agreement?
A. Yes. Although there nay be some problems with terminology and
although the objectives of the plan may be too narrowly drawn, the
plan clearly identifies the purpose of the remedial action plan
process as providing a systemwide approach to environmental
management that will ultimately lead to the successful rehabilitation
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of the Great Lakes. The plan also recognizes that this approach
requires an integration of available data on environmental
conditions, socioeconomic influences, and political institutional
frameworks. The plan itself, however, focuses on resolution of the
immediate problems impairing water uses in the area of concern. This
narrowly limits the plan to addressing heavy metal and
polychlorinated biphenol contamination of the sediments, water
column, and fish tissue in the area and to the control of excessive
sedimentation from sources outside the area. There is no indication
in the plan as to whether other problems now exist, nor is there any
attempt made to project or forecast probable future conditions,
potential problems, and recommend actions which would avoid such
problems.
Q. Have the environmental problems in the Areas of Concern been
adequately described, including identifying beneficial uses impaired,
the degree of impairment and the geographic extent of such
impairment?
A. Yes.
Q. Rave- the causes of the use impairment been identified, including, a-
description of all known sources of pollutants involved and an
evaluation of other possible sources?
A. Probably not. The known sources of polychlorinated biphenol within
the drainage area tributary to the estuary appear to account for less
than one-half of the total loadings on the estuary. Yet, the report
does not quantify urban nonpoint source loadings which may, along
with atmospheric loadings, account for much, if not all, of the
unaccounted for portion of the total loadings. If urban nonpoint
loadings are indeed found to constitute a significant source of
polychlorinated biphenol, effective remedial actions could be
recommended.
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Stage 2
Q. Have remedial measures in place been evaluated?
A. Yes.
Q. Have alternative additional remedial measures to restore beneficial
uses been evaluated?
A. Yes; but the evaluation appears to'be largely non-quantitative.
Q. Have additional remedial measures to restore beneficial uses been
identified, including a schedule for implementation? What beneficial
uses (if any) will not be restored? Does the R.A.P. indicate why?
»
A. Yes. The plan recognizes that despite annual dredging of the
navigation channel sediment concentrations of toxic substances are
not decreasing. The plan suggests further investigations to
determine the unknown sources, including the preparation of sediment
contamination naps to identify concentrations of polluted sediments.
The plan is, however, silent on the need to establish sediment
quality standards for the further assessment of the extent and
magnitude of-Che problems Ir^ som«= cases, such-as tbft issuance and
enforcement of National Pollutant Discharge Elimination System
permits, the implementing agencies are implicitly but clearly
identified. For other actions, such as the contaminant sediment
mapping, the implementing agency is not clearly identified.
Q. Has the surveillance and monitoring program to track effectiveness of
remedial actions and confirmation of beneficial uses been adequately
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described?
A. No. Although the plan does envision a continuing surveillance
program, the program is described only generally; and such specifics
s the implementing agencies; the type, frequency, and location of
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the sampling activities; Che funding; and importantly, the reporting
process are not clearly specified.
Q. Have the persons or agencies responsible for implementation been
identified? Have the beneficiaries or organizations impacted by the
R.A.P. been identified? Has there been adequate and appropriate
consultation with the public?
A. Not clearly. Consultation with the public appears to have been
limited to the conduct of two public meetings attended by about 50
persons.
Stage 3
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A. No. It is too early in the process to expect meaningful monitoring
of the results of the remedial actions. .
(a) Does the plan embody an ecosystems approach?
Q. Have all identified remedial measures to restore beneficial uses been
implemented according to the schedule in the R.A.P.? If not, why?
A. No. Some of the measures have been implemented. Some are being
implemented, and some are recommended to be implemented. The plan,
however, does not contain a specific time schedule for
implementation.
Q. Do-surveillance- and monitoring- data confirnr restoration of beneficial
uses? If not, why?
A. The plan recognizes the ecosystems approach but falls short in actual
application.
(b) Have effects been adequately linked to contributing causes and
examined in terns of societal factors?
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A. Effects have been linked to directly contributing causes but have not
been examined in terms of societal factors.
(c) Are the remedial actions adequate to sustain the beneficial uses
indefinitely?
A. This question is not answered in the plan. It is doubtful that the
question can be answered by any plan however well done. A better
effort to answer this .question could have been made if the plan had
entailed projections and forecasts- of probable future, as well as
analyses of existing, conditions. .
(d) Have nongovernmental responsibilities for implementing remedial
actions been identified, e.g. communication and education systems,
industries, citizen groups and individuals?
A. Yes; to a limited extent.
(e) Do studies necessary to complete the RAP comprise a balanced
information system of societal, technological and ecological
elements?
A. No. The emphasis in the plan is on the technological aspects of the
problem. Some attention is given to the ecological aspects and very
little or none to the societal.
(f) Is there provision for periodic public review and updating of RAPs by
the jurisdictions?
A. No.
SUMMARY AND CONCLUSIONS
The remedial action plan for the River Raisin is generally well done, making
effective and efficient use of available data. The remedial actions
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recommended are practical and would appear to represent sound Incremental
steps to Che eventual abatement of the toxic substances pollution problem
existing in the River Raisin estuary. Shortcomings of the plan include an
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apparent failure to account for all pollutant loadings on the estuary with no
considertion at all of urban nonpoint source loadings; a failure to attempt Co
project or forecast: probable future conditions, potential problems, and
recommended actions which would avoid such problems; a failure to recognize
Che need Co esablish sediment quality standards as a basis for further
assessment of Che extent, magnitude, and sources of the sediment contamination
problem; and an apparently minimal public participation program. The plan
lacks a full disclosure cf institutional issues pertinent to the problems and
their resolution. 1C does not always clearly identify implementing agencies
and does noC contain a time schedule for implementation.
A major disappointment in the plan is the failure to recommend further means
for reducing Che enormous fish cill taking place at the Detroit Edison
electric power generation plant. While improvements made in 1982 have
apparently reduced this fish killby about half, it appears that tens of
millions of fish are sCill being killed each year by Che cooling water intake
for Che plane.
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May 25, 1988
WATER QUALITY PROGRAMS COMMITTEE
COORDINATED REVIEW
of the
REMEDIAL ACTION PLAN
for
MANISTIQUE RIVER
Preface:
This Remedial Action Plan (RAP) was prepared under the guidelines
prescribed by the Water Quality Board (WQB), which is consistent with Annex 2
(Section 4) of the 1987 Agreement. This review assesses the adequacy of the
Manlstique River RAP against the original Water Quality Board guidelines.
These guidelines are structured according to the new three stage review
protocol, for the purpose of this review.
Participation:
This summary brings together the individual reviews of various members of
WQB committees, the Science Advisory Board, and the Great Lakes Fishery
Commission, so as to provide a wide range of expertise in reviewing the
various technical details of the RAP. Reviews (attached) were received from
the following:
Surveillance Work Group R. Rossmann, University of Michigan
M. Moriarty, U.S. Fish & Wildlife Service
Toxics Committee D. Pascoe, Environment Canada
Point Source Coordinators L. Sarazin, Environment Canada
V. Saulys, U.S. EPA
Sediment Subcommittee D. Persaud, Ontario MOE
Science Advisory Board L. Caldwell, Indiana University
STAGE 1: WHEN A DEFINITION OF THE PROBLEM HAS BEEN COMPLETED UNDER
SUBPARAGRAPHS 4(a)(i) and (ii).
1. Are the goals and objectives clear and precise?
Only one substantial goal is identified in the RAP (i.e. to reduce PCB
concentrations in carp fillets below 2 ppm). Specific numerical goals for
water, sediment (instream sediment and terrestrial soils), and biota should be
identified for contaminants of concern to protect ecosystem health.
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2. Are the goals and objectives consistent with the general and specific
goals of the GLHQA? |
No. Goals consistent with the GLWQA are missing. The RAP provides a good
torlcal review of the Area of Concern. Hoi
discussed 1n the context of GLWQA objectives.
historical review of the Area of Concern. However, these data are not " I
3. Is the Information base sufficient to adequately define the problems and |
Identify the causes?
No. There seems to be other Impaired uses within the Area of Concern. As I
outlined 1n the 1987 GLNQA these Include: degradation of fish and wildlife
populations (Annex 2: l,c,111); degradation of benthos (1,c,v1); restrictions
on dredging activities (1,c,vii); and degradation of aesthetics (1,c,x1).
Impaired uses within the Area of Concern should be evaluated relative to these I
categories and discussed accordingly 1n the RAP.
While 1t 1s clear from the RAP that Man1st1que Paper Co. operations 1n the I
past resulted 1n PCB contamination of the harbor, the Information 1s
Inadequate to exclude other sources. Other sources of PCBs are possible, but
not Identified (including the lagoon which received de-inking waste).
STAGE II: WHEN REMEDIAL AND REGULATORY MEASURES ARE SELECTED UNDER
SUBPARAGRAPHS 4(a)(111), (1v), (v), and (vi).
4. Are the Identified remedial actions sufficient to resolve the problems
and restore beneficial uses?
No. Remedial actions are not identified. Investigations lack specific
details to properly define the cause of the problems (i.e. PCBs in Manistique
River fishes, impacted benthos, and impacts on PCB contamination of Lake
Michigan fishes).
5. Are the remedial actions consistent with the goals of the RAP?
No. The goals are too limited and not specific enough to determine I
whether or not historical remedial actions will achieve the stated goals. No m
new remedial actions are identified. Studies are proposed.
6. What beneficial uses, if any, will not be restored? Does the RAP
indicate why?
No impaired beneficial uses will be restored given the actions
recommended in this RAP. Only Investigations are proposed. _
7. Is the Identified schedule for Implementation of remedial actions
reasonable?
No specific remedial actions are identified.
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8. Have the jurisdictions and agencies responsible for Implementing and
regulating remedial measures been Identified?
No specific remedial actions are Identified.
9. Have studies necessary to complete the RAP been Identified and have
schedules for their completion been established?
A number of studies have been Identified 1n the RAP. If fully completed,
these studies would go a long way towards providing the Information necessary
to be able to Identify remedial actions. Schedules for initiation and
completion of identified studies are not presented.
10. Have work plans and resource commitments been made?
The majority of the studies are proposed and lack, resource commitments.
11. Is the monitoring and surveillance program sufficient to document
Improvements as a result of the remedial actions Implemented and confirm
the restoration of beneficial uses?
No monitoring and surveillance program Is identified.
12. Has there been adequate and appropriate consultation with the public?
Two public meetings were held (62 people attended the two meetings). The
level of public participation makes it difficult to judge the adequacy of the
consultation process. This could be a result of: 1) poor notification of the
public, or 2) lack of Interest from the public.
STAGE III: WHEN MONITORING INDICATES THAT BENEFICIAL USES HAVE BEEN RESTORED
UNDER SUBPARAGRAPHS 4(a)(vii) and (viii).
Stage III requirements await completion and implementation of the RAP.
SUMMARY:
The Manistique River RAP states that the ongoing studies are necessary.
Sufficient data exist to show that there are problems with contaminated
sediments. Greater emphasis must be placed on remediation, in contrast to
further study to identify the problem.
The major causative factors are obvious (i.e. historical discharges from
the deinking operations and the resulting sediment contamination). The
relative contribution from active sources of PCBs is unknown.
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While further study 1s advantageous, there 1s an evident need to
remediate contaminated sediments. Therefore, the Man1st1que River Area of
Concern 1s 1n Category 3 (causative factors known, but RAP not developed and
remedial measures not fully Implemented). Further, the Man1st1que River RAP
does not satisfy the requirements of Stage I 1n the 1987 GLWQA (because
further study 1s proposed).
The Hater Quality Board views the RAP process as Iterative, where RAPs
are updated and Improved based on a better understanding of the problems and
their causes and the development of new technologies to remedy the problems.
The challenge of RAPs 1s to make them focused and specific enough to
demonstrate progress. RAPs are Intended to Identify when specific remedial
actions will be taken to resolve the problems and who 1s responsible for
Implementing those actions. If remedial actions cannot be Identified and
additional studies are needed, the RAP should Identify when the studies will
be Initiated, when they will be completed, and when this new Information will
be used to Identify remedial actions.
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P.O. WINDSOR
GREAT LAKES RESEARCH DIVISION APR 2 7 1988
Oir
2200 BOMSTEEL BLVD ^»rty WOR
\NN ARBOR. MICHIGAN 48109
in-ti-ro «lprty SAB
A f 1 T *" 1 QQQ HP^n ^j
April O, 19oo
A n
1.0.
Dr. John Hartig
International Joint Commission
P.O. Box T?869 Piu>
Detroit, MI 48232-2869
Dear John:
I have reviewed the Manistique River RAP. The document provides a
good historical review of this Area of Concern. However, historical
data are not discussed in the context of the Great Lakes Water Quality
Agreement specific objectives. Because of this the severity or possible
severity of non-PCBs problems are treated too lightly. Specific
objectives have been exceeded for cadmium in river mouth water; iron,
silver, cadmium, copper, zinc, nickel, mercury, and lead in WWTP water;
and cadmium, chromium, copper, lead, and zinc in the paper plant's
discharge water. Specific PCBs objectives for fish were exceeded for
almost all reported fish analyses. There is no attempt to address the
quality of the data base. Many metal analyses have too high a limit of
detection and many fish were analyzed for only one PCB isomer; not total
PCBs. Recent work by Camanzo et al. (1987) in the JOURNAL OF GREAT
LAKES RESEARCH illustrate that the PCB problem may be critical in
species other than carp. Whole fish PCBs concentrations exceeded 2
mg/Kg in northern pike and small-mouth bass collected in 1983. More
recently collected fish analyses reported in the RAP do not seem to
consistently cover all species each year.
Future remedial action alternatives or the details of studies
currently being done or proposed to be done are not discussed; the
reader is left with nothing to judge with respect to future remedial
actions. Plans of studies currently or about to be conducted should be
discussed in detail. An effort should be made to propose detailed study
plans necessary for the region as well as various remedial action
alternatives. A Remedial Action Plan must be more than an exercise in
presenting historical information, otherwise where is the plan?
Sincerely,
w^UYi+Jd yCfifoyr^+rvr-t
Ronald Rossmann
Associate Research Geochemist
Member IJC Lake Michigan Task Force
RR:nd
cc: G. She r bin
B. Lesht
7?
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United States Department of the Interior
FISH AND WILDLIFE SERVICE IH "triLV *"" T0:
Federal Building, Fort Snelling
Twin Cities, Minnesota 55111
FWS/AE-ES
FEB 1 2 1989
Dr. B. T. Wagner
Chairman, Surveillance Work Group
International Joint Commission
P.O. Box 32869
Detroit, Michigan 48232-2869
Dear Dr. Wagner:
We provide these consents, as requested, through our participation on the
Surveillance Work Group. The Remedial Action Plan (Plan) for the Manlstique
River Area of Concern was reviewed using the three stage review process in the
1987 Amendments to the Great Lakes Water Quality Agreement, Annex 2,
4(d)(iMiii). As detailed herein, we believe the Plan has partially satisfied
the requirements for Stage 1 review - Definition of the Problem. Further work
is needed on sources and description of impaired uses for completion of Stage 1
requirements. Although some remedial measures have been taken, insufficient
attention to the problems within Area of Concern and its relationship to Lake
Michigan preclude this Plan from satisfying Stage 2 and 3. Relative to the
category designation for the Area of Concern, we believe the Category 2
designation assigned in the Plan is acceptable although considerable
additional work will be required by various entities to continue planning and
implementation of remedial measures for restoration of beneficial uses. Of the
State's Areas of Concern on Lake Michigan, we believe the Manistique River is a
significant source of polychlorlnated biphenyl (PCS) contamination to northern
Lake Michigan and possibly northern Green Bay. As such, this area should
receive high priority in the allocation of available resources to implement a
remedial strategy.
General Comments ...... _......
The Plan takes an extremely narrow view of use impairment. While the Plan
correctly identifies PCBs as being the main cause of the problem, it limits the
Identified impaired uses to exceedence of the Federal Food and Drug
Administration action level for PCBs of 2 parts per million (pom) wet weight in
fish (carp). It is inconsistent to limit discharges of PCBs on the basis of
risk assessment procedures for National Pollutant Discharge Elimination
System discharges using the State's toxic substance rule procedures, and then
rely upon the non-risk assessment Federal Food and Drug Administration action
level in fish fillets as the use impairment threshold for remedial action
planning. This approach potentially underestimates risks to public health and
provides no remedial goals relative to ecosystem health. Another use
impairment that may occur in and near the Area of Concern is contamination of
waterfowl with contaminants including PCBs. Nuoerous examples exist within the
/CO
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Dr. E. T. Wagner 2
Great Lakes which show waterfowl continue to exceed the Food and Drug
Administration action levels for PCBs in poultry (currently 3.0 ppn, lipid
weight basis) and our own data shows rapid PCB contamination In mallards (lass
than 10 days exposure exceeded the action level). We believe this suspected
use impairment should be so designated subject to confirmation by sampling
within the Area of Concern. Limiting the use impairment downstream to the
mouth of the harbor ignores fish consumption advisories for Lake Michigan,
which receives Hanistlque River water and sediment contaminated with PCBs.
We believe the plan should Identify the following Lake Michigan use impairments
affected by the Manistique River:
Human Consumption Advisories:
Pish (whole body or fillet data) in
excess of International Joint
Coraaission objective of 0.1 ppm
for the protection of fish-gating
birds and mammals;
Reproduction/deformity effects in
wildlife and fish:
trout over 20"; coho salmon
over 26"; chinook salmon over
21"; brown trout all sizes
all species sampled within the
Area of Concern exceed the
objective
mink, river otter, bald eagle
double-crested cormorant, Caspian
~~ tern, lake trout are suspected of
having reproductive probleas
related to contaminants,
particularly PCBs
The above documentation is readily available in State of Michigan files or in
our East Lansing Field Office. Our East Lansing Field Office will be assisting
in collating these data in a meeting to be arranged on this and other issues
discussed herein.
There seem to be other impaired use categories within the Area. As outlined in
the 1987 Amendment9 to the Great Lakes Water Quality Agreement these include:
Degradation of Fish and Wildlife Populations, Annex 2 (l)(c)(ili); Degradation
of Benthos, (l)(c)(vi); Restrictions on Dredging Activities, (l)(c)(vii); and
Degradation of Aesthetics, (l)(c)(i). Impaired uses within the Area of Concern
should be evaluated relative to these categories and discussed accordingly
throughout the Plan.
The only substantive goal within the Plan relative to contanlnant residue
concentrations la the Area of Concern is to reduce carp fillets below 2.0 ppa
PCBs. While this is acceptable as a near term objective, it is not acceptable
as a final remedial goal. Specific numerical criteria for water, sediment
(instrearn sediment and terrestrial soils), and biota should be identified for
contaminants of concern to protect ecosystem health. In the case of PCBe, the
International Joint Commission objective for total PCBs in whole fish of <0.1
ppm-vet weight is to protect birds and mammals which consume fish. Likewise
the Fish and Wildlife Service (Service) suggests an objective for total PCBs in
sediments (instream sedinent and terrestrial soils) of <0.05 ppm-dry weight to
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Dr. E. T. Wagner 3
protect fish and wildlife via direct exposure and food chain bioaccumulation.
For siallar reasons, we further suggest an objective for total PCBs in water of
<1.0 parts per trillion. We note the Plan contains mention of Michigan's water
quality standards but the actual numerical values are not presented. Given the
high PCS contaaination, Michigan's value(s) need to be presented and a
discussion is needed as to what the value(s) seek to protect. What uses could
remain Impaired after remediation to these value(s)?
Specific Comments
Page 21. The discussion on page 21 should acknowledge the likely contamination
of waterfowl within the Area of Concern and that this contamination nay be in
excess of the Federal Food and Drug Administration action level of 3.0 ppm on a
lipid weight basis. Further, contaminated fish, waterfowl, and gulls may be
consumed by raptors such as bald eagles and snowy and great horned owls leading
to potential toxic effects in these species. Sampling and monitoring needs,
agencies responsible and timetables for actions should be developed.
We note that no sampling of salaonids near to or within the Area of Concern has
been reported in the Draft Plan. Since salmonids are generally on health
consumption advisories, the most recent samplings closest to the Area of
Concern should be addressed along with the respective contaminant
concentrations.
Page 22. The discussion of fish and wildlife habitat with respect to birds
should be revised relative to our comments on page 21. The discussion
regarding vood chip and sawdust accumulation should address the likely
adsorption of PCBs on these organic solids and transport to Lake Michigan. It
appears the wood chip accumulation is an impairment of habitat, albeit of
unknown significance.
Page 24. Table 3-2 should include PCS and metals concentrations for water and
sediment and relate these concentrations to full use attainment for aquatic and
wildlife resources within the Area of Concern and Lake Michigan.
Page 25. Section 4 should be revised to reflect the concerns expressed in our
general comments. The Service will provide documentation of these concerns for
the State's use. The discussions and Tables in Section 4 related to sediment
contamination should be clarified relative to physical characterization of the
sediment (size) and other data such as oil and grease, organic content and
relationship of PCS deposits to sawdust and wood chip deposition areas.
Likewise, fish sampling data in Table 4-8 should include information on fish
length, weight, lipid content, and age.
Page 48. Section 5.1.2 should address the pollutants which have been detected
in the Manistique Papers' effluent that are not currently limited in the
discharge permit for this industrial source. Have these pollutants been
assessed relative to fish and wildlife health or only public consumption
advisories of fish? If PCBs were assessed under the State's toxic substance
rule, would the PCS limit in the effluent of Manistique Papers be less than
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Dr. E. I. Wagner 4
current detection Units? If so, we recommend the Plan point out the need for
the National Pollutant Discharge Elimination System permit to Unit PCBs
according to the State's toxic substance rule procedures until detection Units
are more sensitive than the effluent Unit.
The discussion of Hanistique Papers' discharge neroit states that oil and
grease, biological oxygen demand and pH have exceeded permit limitations. It
would be helpful if the significance of these violations were discussed.
Further, what is the oil and grease limitation? It is not identified as being
regulated in Table 5.2.
Page 48. Section 5.2 indicates that PGBa were detected in a ponded water area
below a combined sewer overflow. It should be recognized that PC3s can be
volatilized from the lagoon site which is nearby and be washed from the air
into this combined sewer overflow pond during rainfall events.
Page 50-51. Table 5-3 contains information which shows PCBs not being detected
in Hanistique Papers' effluent at 0.5-1.0 parts per billion (ppb). Detection
limits should be set at the lowest practicable level (0.2-0.5 ppb) for
subsequent monitoring required in the effluent permit. Further, are efforts to
lower detection limits being required? What quality assurance/quality control
procedures are used to check the effluent and ambient water or sedlnent
chemistry for this Area of Concern?
Page 56. The last sentence Section 5.5 could be read as defending Manistique
Papers* lagoon as if it were not the dominant historic and existing source of
PCS contamination in the Maniatique River. Given the documentation in the
Plan, it is difficult to Justify any other source being responsible for the
documented severe sediment contamination. Removal of the lagoon, the soils
surrounding it and sediments in the River should alleviate most of the problem
provided no new sources are identified in remediation monitoring.
Page 65. Section 7 should be expanded to include other species of wildlife
which could be consumed by the public, such as waterfowl. It should also
recognize the need to reduce Impaired uses of fish and wildlife in the Lake
Michigan ecosystem. The goals should be consistent with the impaired uses
identified in our general comments. These should include:
1. removal to achieve most stringent human consumption advisory for all
species.
2. remediation to achieve no acute or chronic effects, Including
reproductive impairment, population degradation or continuing failure
of a population to be self-sustaining*
3. Improvement of fishery habitat within the Area of Concern following
remediation of the chemical problems in sediments and remediation of
physically limiting factors (the sawdust and wood chip deposition).
The habitat Improvement should be based on biological need. A
long-term need may be spawning and nursery substrate for walleye.
Given the PCB problem and walleye stocking initiatives reproductive
success may be compromised by lack of good substrate, damming of the
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Dr. E. T. Wagner !
river and contaminant-induced reproductive inpairtMnt. Goals Co assure
restoration of walleye, as a self -sustaining population should be developed.
Funding for such goals could cone from the Federal Aid program administered by
the Service.
Page 75. Section 9 contains recommendations for remedial action. The first
recommendation involves collecting oore sedlnent samples. Ue support this
concept but question how the number of additional samples was arrived at; why
these are sufficient given no location of these samples; and why no cores
beyond a 50 centimeters depth will be taken at any site. Other rivers have
sediaent contamination that is quite deep (>10 feet). This provides little
assurance that remediation measures will be sufficient.
Another recommendation concerns determining the bloavailability of PCBs in
sediments within the Area of Concern. We believe this to be of limited value
as stated. How would the study design be useful in determining remediation
measures or effectiveness? We recoramend that 0.05 ppm PCS in sediaent be the
remediation goal. If and when Michigan wishes to perform the bioavai lability
assessment, the Service can supply proven technology. Remediation actions
should not be delayed pending the bioavailability study. Present information
indicates availability.
It Is not necessary to determine if benthos are impaired by PCBs or metals.
Identification of PCB-contaninated sediment through a comprehensive sediment
sampling program (both areally and vertically), will provide sufficient
Information to assess likely remedial measures such as dredging, capping or
combination thereof.
Page 96. Appendix B provides 1983 sludge data for PCBs by the Michigan
Department of Natural Resources. The data indicates the detection limit was
3,100 ppm. If this is not a typographical error, this data should be removed
as being of no practical utility.
We appreciate the opportunity to provide comments on this important document,
and would be glad to discuss any of the above comments with you. Please feel
free to contact Tim Kubiak at our East Lansing Field Office, 517/337-6650.
Sincerely, -----
ysy UaryinE. MorlarJJ
Regional Director
cc: 'John Hartig, IJC, Windsor
John Gannon, NFC Great Lakes, Ann Arbor
East Lansing Field Office
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^ Environment Enwonnement
~ Canada Canada
Environmental Protection de
Protection I'environnement
Dr. D.J. Viviani
Chairman Toxic Substances
Regulatory Analysis Branch
U.S., EPA
401 M Street SW
Washington, DC 20460
Dear Donn:
I have reviewed the
number of general comments
clairification of anything
cc: I.G. Sherbin
»KmWK>co>a«n««nwgy AOnlmOnconsffHton
jnowsourcM iftsp*p*r OUtnityetiaianaounm
ccnr»ci/ Vt>nr"f rtirrrttrt ctMparcanMnrlSpaxctnr
~ni «*»«»«-
25 St. Clalr Avenue East
7th Floor
Toronto, Ontario
M4T 1M2
Telephone: (416) 973-5840
Your ttt Woe* ftH(9nc9
Our Mt NOIT9 r##*nc»
1165-36/J6-15-11
January 20, 1988
Commi ttee
, PM-223
Manistique River RAP very quickly and have a
and questions tooffer. If you want further
I have said, p^Ke give me a call.
\|/(
Jf^-
D.J. Pascoe
Manager
Environmental Contaminants 01 v.
Environmental Protection
Ontario Region
Conservation and Protection
fof
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Based on the discussion 1n the RAP, this does not appear to be a very
controversial Issue. Furthermore, the data tend to indicate (or the
RAP leaves the impression) that the problem is historic rather than a
continuing discharge.
It is not surprising that a deinking facility would be associated with
high PCB levels - especially since recycled paper was used as the
total source of raw material (p. 19).
Upstream sources appear to have been ruled out (p. 32, 52) although
several projects are noted in the "specific remedial actions" to
confirm this. This further supports the contention that the paper mill
was/is the primary source of PCBs.
A number of other possible, although probably less significant, sources
(paper mill landfill, sewer overflow) are also slated for
investigation. Will the sewer overflow (CSO 002) investigation (p. 76)
include a determination of the content of the overflow (as noted on
p. 27 and 48), and potential sources within the overflow system?
Has there been an investigation of potentially PCB containing equipment
in use, or previously used, at the paper mill, wastewater treatment
plant, or past industries in the area?
There is frequent reference to sediments "contributing" to impairment
of the AOC (p. 3, 25, 42). The evidence leads one to believe that the
sediments are the major source of the problem. This point should be
clarified - i.e. what are the other "contributing" sources and how
significant are they in relation to the sediments.
If the sediments are a major source, as they appear to be, then should
the RAP category become 3? What is the significance of a change in RAP
category to this AOC?
The specific remedial actions are drawn out over a lengthy period and
contain a number of studies that don't appear to contribute to the
resolution of the problem (i.e. bioavailability, impairment of benthic
macroinvertebrates). They look more like scientific studies that will
produce interesting papers.
What is the long (or short) term plan for the sediments? Is the
sediment sampling program outlined on p. 75 going to be used to
determine zones of sediment removal? If so this is important (since it
means removal of the source) and should be stated.
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FROM
DE
SUBJECT
OBJET
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A
MEMORANDUM
NOTE DE SERVICE
Griff Sherbin
Laurie Sarazin
February 22, 1988
RAP Review
I have completed my review of the Torch Lake and
Manistique River RAPS. Neither of these documents should
be considered complete RAPs since more studies are
required to document sources of contamination. I don't
know if it is merely a problem with terminology since in
Canada we are not calling our documents RAPs until all
studies are complete and remedial actions have been
defined. My attached comments address the specific work
that is required on the Torch Lake and Manistique River
RAPs .
L. Sarazin
cc. Ian Orchard
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I" I M I ', ' 1 . ) ! I' I .
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I
h smnllri v.colt.' mop wouKi !« tiM-iul lo pi: i mi t locating t h i '-.
Ai en Of OoMCt'ir. iclotivi- t ^ tin- '.ir.it :.oki-r, n ;; t r» t r of
M i fh i cm .
_
2. On page 17 3.3.3 it. states th
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TO:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
j 5 ^ 1988.
SUBJECT: Review of the Manistique River Rwnedia* Action Plan (RAP)
FROM: vacys J. Saulys, Chief
Remedial Programs Staff, 5GL
Griff Sherbin, Canadian Point Source Coordinator
Summary:
My review of United States Environmental Protection Agency data
sources did not reveal any other sources than those described in
the RAP. Source definition and remedial programs are in part in-
complete or lacking. AOC PCB problems and potential contribution
to lakewide problems are in part in-complete or lacking. AOCr PCB
problems and potential contribution to lakewide problems are
miminized. Category 2 or 3.
Sources:
While it is clear from the information provided that Manistique
paper company operations in the past resulted in contamination of
Manistique Harbor, the information is inadequate to exclude any
additional sources. In fact, the RAP seems to implicate some:
1. Highest ambient levels of PCBs in the AOC in the vicinity
of one CSO.
2, Deinking wastes were taken to a company operated
landfill (the one currently accepting wastes?).
Discussion implies this landfill is under
investigation. Its location within the AOC as well
as that of the other landfills is not presented on
a maps in the RAP.
3. Soil sampling indicates a number of areas may
be significantly above TSCA definition of
50 ppm as a PCB "item," covering such areas with
crushed rock is not a generally accepted cleanup procedure
under TSCA or RCRA. What is the status of this site with
respect to Federal criteria? Does the fact Manistique
Harbor is on a CERCLIS list imply that this site will be
under future USEPA review?
Remedial Action:
There are serious questions raised about the veracity of the data
produced by Canton Analytical based on the split sample data
presented in the report. QA should be addressed in the report.
The report itself is not explicit as to whether erosion control
PA FORM »MO-« (KCV. $-M)
to?
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actions taken on site constitute a temporary measure or "final"
action. The RAP is vague about the type of the follow up actions
that will be taken on CSOs, landfills and the contaminated areas in
the Harbor, Statement in See. 4.2.1 that the PCB levels in the
River are similar those that "receive PCBs only through atmospheric
deposition" is not supported by our data. E.A. Marti and D.E.
Armstrong in their paper on PCB in the Lake Michigan tributaries
estimated a PCB loading to Lake Michigan approximately 17 to 65
kg/yr. They discuss the river as follows:
" The average PCB concentrations for the Menominee and
Manistique Rivers (15 and 24 ng/L for the Group I Rivers
are atmospheric or nonpoint rather than industrial point
sources. However, paper recycling plants are located"
near the mouth of both rivers.No data were available on
whether PCBs are dischargedl_to_ the riyersjlgut pager
recycling of carbonless copy paper can Ite a source of
PCBs (National Academy of Sciences, 1979)."
This discussion is significantly different than the conclusion
presented by MDNR.
Rather than spending the effort on benthic studies, it appears
greatest effort should be expended in gathering the RAP notes harbor area
was home to a former chemical plant. What did it make, mix sell? Did
its wastes and products contribute to the current heavy metal problons?
will the AOC support a cold water fishery, if sawdust & other debris are
left in the harbor? If not, is this a violation of Michigan Water
Quality Standards? Does plant sites contaminated runoff require an NPDES
permit?
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Ministry
of the
Environment
Ministers
de
I'Environnement
Ontario
135SI Clair Avenue West
Suite 100
Toronto, Ontario
M4V1P5
323-4926
135. avenue St Clatr ouest
Bureau 100
Toronto (Ontario)
M4V1P5
May 3, 1988
Mr. G. Sherbin, Manager
Pollution Abatement Division
Environmental Protection - C & P
Environment Canada
25 St. Clair Ave. E., 7th Floor
Toronto, Ontario
Dear Mr. Sherbin:
RE: MANISTIQUE RIVER RAP
JEnvironmental Protection Service
Ontario Region
INITIALS
DATE
We have reviewed the Remedial Action Plan for Manistique River
sediments and provide the following comments.
The information on the status of sediments in the River suggests
contamination by PCBs and heavy metals. The report provides limited
chemical comparative data collected above and below the dam. Most of
the information is based on bulk chemistry although limited data on
benthic macroinvertebrates collected at 7 stations are included.
Although this information provides some indication of sediment quality
in the river, it does not provide the type of information that would be
required to determine whether remedial action would be needed.
In this regard we recommend that the document "Guidance on Assessment
and Remediation of Contaminated Sediment Problems in the Great Lakes"
(International Joint Commission) be consulted for a comprehensive
treatment of the problem with particular emphasis on functional and
structural bioassessment.
We hope that our comments and suggestions will be of some help to you
in the evaluation of the Manistique River Remedial Action Plan.
Yours truly,
Deo Persaud, Chairman
IJC Sediment Subcommittee
DP/rmg
cc: M. Zarull
20419-05C.1 /ABS/88-2.0
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18 January 1988
REVIEW OF MANISTIQUE RIVER REMEDIAL ACTION PLAN
BY
LYNTON K. CALDWELL, SCIENCE ADVISORY BOARD I.J.C.
In preparing for this review I consulted three sources of policy and
information: (1) Draft Protocol for Review . . . (12-10-87); (2)
Guidelines for Preparation . . . (5-7-85); and I.J.C. leaflet Remedial
Action Plans for Areas of Concern (undated). My evaluation should
therefore be prefaced by the following observation. If the R.A.P. is
reviewed only for conformity with the Guidelines of 1985, the evaluation
might differ from a review based on either the Draft Protocol for Review
of 1987 or on the reviewers understanding of what an adequate Remedial
Action Plan should be. An additional criterion for evaluation would be
the 1987 Protocol to the Water Quality Agreement of 1987 adopted at
Toledo, Ohio on 18 November, 1987.
My review is based upon my understanding of the fundamental principle
acceded to by the governments of Canada and the United States in the Water
Quality Agreement of 1978 and reiterated with special reference to the
RAP's in the 1987 Protocol. This principle is that an ecosysteaic
approach be taken to problems of policy and planning for the Great Lakes.
My criticisms in the following review reflect my assumption that a purpose
of the action plans is to put into effect this ecosystem principle in
areas of concern as well as throughout the Great Lakes Basin.
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In my view, the ecosystemic relationships in Areas of Concern should be
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the scope and focus of the RAP's. Short of thus perspective. I do not see
law effective environmental results are likely to follow from the RAP
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exercises.
With Specific Reference to the Manistique River R.A.P.
In my opinion the Manistique River R.A.P. does not adequately meet the
ecosystemic criterion as adopted by the governmental Parties to the Water
Quality Agreement, and by the I.J.C. If it satisfies the objectives of
the Water Quality Board, I believe those objectives to fall short of the
Intent of the Parties and the I.J.C. My principal objection to the R.A.P.
is its inadequacy as an operational plan. Hissing from the Plan is
consideration of the demographic, economic, and political circumstances
that must be mobilized If remedial action is to occur. The R.A.P.
provides minimal indication of the community in which remedial action must
be taken. The R.A.P. is no more than a technical analysis of the things
that need to be done to remove Manistique from the Areas of Concern. The
greater part of the R.A.P. document consists of technical data and the
_ plan is chiefly a list of research tasks for biologists and chemists that
hardly add up to a funded and administered plan of action.
I
Manistique appears to be an economically poor community. The 1980
U.S. Census listed the population as 3,962 and the 1984 estimates (most
recent) indicated decline to 3,386. It also appears to be a one industry
town. The R.A.P. says nothing about levels of age or education or citizen
involvement in public affairs. An inference that environmental Issues may
have low priority may be drawn from a reported total of 38 public
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attendees at the 2 September 1986 public Meeting, and only 24 at the 30
July 1987 meeting. The presence of the city manager in the audience
suggests that some part of this small number were local government
officials or employees. A .01 percent turnout at the 1986 meeting did not
suggest that the people of Manlstlque were vitally concerned about the
area. The few questions asked related primarily to fishing. It may be
that the attending public learned about the meeting through the Michigan
Department of Natural Resources Newsletter, which is the only announcement
mentioned in the R.A.P. and which would most likely be received by
sportsmen or commercial fishermen (if any).
If the Manistlque R.A.P. is Intended to move the public and its
governments to action, a different type of report would be required. The
greater part of the present R.A.P. (in my judgment) should be in an
appendix or companion volume to the Plan. The Plan document should be
written in plain English comprehensible to a non-scientists reader. There
is room (not to be used here) for commentary on the evident preparation of
the R.A.P. by a consulting firm in McLean, Virginia (Science Applications
International). It is surprising to me that the State of Michigan
evidently lacks the resources to undertake such an activity. In as much
as the investigation appears to have been strictly scientific, technical,
and restricted to water quality, a meaningful participation from residents
of this small community seems unlikely. Yet they will have a major
responsibility for putting any remedial action plan into practice.
I realize that my assessment of the Manistique River R.A.P. may differ
fundamentally from what the Water Quality Board expects of reviews. On
the basis of the criteria that I have used, however, mindful of the
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Guidelines, Protocol for Review and the Great Lakes Water Quality
Agreement and Protocol of 1987. I respond to the Protocol questions as
follows:
t
Stage 1 (adequacy of problem definition)
Q. Are the goals and objectives clear and precise? Are they
consistent with the general and specific goals of the Great
Lakes Water Quality Agreement?
A. In »y judgment they are not.
Q. Have the environmental problems in the Areas of Concern been
adequately described, including identifying beneficial uses
impaired, the degree of impairment and the geographic extent
of such impairment?
A. I do not think so.
Q. Have the causes of the use impairment been identified,
including a description of all known sources of pollutants
involved and an evaluation of other possible sources?
A. Appears generally to be satisfactory.
Stage 2 (identification of remedial and regulatory measures)
Q. Have remedial measures in place been evaluated?
A. Somewhat, but not in context of a comprehensive task.
Q. Have alternative additional remedial measures to restore
beneficial uses been evaluated?
A. None noted.
Q. Have additional remedial measures to restore beneficial uses
been identified, including a schedule for implementation:
What beneficial uses (if any) will not be restored? Does
the R.A.P. indicate why?
A. I don't think so. Societal aspects are lacking.
Q. Have the persons or agencies responsible for implementation
been identified? Have the beneficiaries or organizations
Impacted by the R.A.P. been identified? Has there been
adequate and appropriate consultation with the public?
A. Not sufficiently in my view.
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Stage 3 (restoration of beneficial uses)
Q. Have all Identified remedial Measures to restore beneficial
uses been Implemented according to the schedule In the
R.A.P.? If not, why?
A. No. Evidently deficiencies In funding capability and
commitment.
Q. Do surveillance and monitoring data confirm restoration of
beneficial uses? If not, why?
A. Uncertain.
I find In this R.A.P. no evidence of the educational and local
involvement effort that I believe essential to secure adoption of a Plan
that addresses the essential realities of the situation.
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May 25, 1988
WATER QUALITY PROGRAMS COMMITTEE
COORDINATED REVIEW
of the
REMEDIAL ACTION PLAN
for
TORCH LAKE
Preface:
This Remedial Action Plan (RAP) was prepared under the guidelines
prescribed by the Water Quality Board (WQB), which is consistent with Annex 2
(Section 4) of the 1987 Agreement. This review assesses the adequacy of the
Torch Lake RAP against the original Water Quality Board guidelines. These
guidelines are structured according to the new three stage review protocol,
for the purpose of this review.
Participation:
This summary brings together the individual reviews of various members of
the WQB committees, the Science Advisory Board, and the Great Lakes Fishery
Commission, so as to provide a wide range of expertise in reviewing the
various technical details of the RAP. Reviews (attached) were received from
the following:
Surveillance Work Group C. Edwards, Lake Erie Task Force
R. Moriarty, U.S. Fish & Wildlife Service
Point Source Coordinators L. Sarazin, Environment Canada
V. Saulys, U.S. EPA
Sediment Subcommittee D. Persaud, Ontario MOE
A. Mudroch, NWRI
Toxics Subcommittee R. Weiler, Ontario MOE
Science Advisory Board H. Humphrey, Michigan DPH
STAGE 1: WHEN A DEFINITION OF THE PROBLEM HAS BEEN COMPLETED UNDER SUBPARAGRAPHS
4(a)(i) and (ii).
1. Are the goals and objectives clear and precise?
The environmental problems have been adequately described. However,
Michigan's goal should be to eliminate the factor(s) causing fish tumors in
order to be able to remove the fish consumption advisory issued for Torch Lake
in 1983. Studies have also documented benthic invertebrate impairments and a
specific goal is lacking. This was a result of the large quantities of
contaminated tailings deposited into the lake from former copper mining and
milling operations.
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2. Are the goals and objectives consistent with the general and specific
goals of the GLHQA?
No. Goals consistent with the GLWQA are missing. For example, specific
goals for tumor Incidences 1n fish, contaminated sediments, Impacted benthos,
and violations of the GLWQA objective for copper are missing.
3. Is the Information base sufficient to adequately define the problems and
Identify the causes?
The Information base does adequately define the problems. However, the
RAP does not Identify the causative agent(s) for tumors 1n fish. Reviewers
noted that no GC/MS scans have been performed on fishes with tumors to help
determine the causative agent(s). Some reviewers believe the probable cause
of the tumors 1s creosote and xanthate chemicals 1n the tailings from the ore
processing operations which previously discharged to Torch Lake. The Issue of
elevated levels of benzo(a)pyrene (3-17 pg/kg) found 1n sediments was noted
1n one review. This chemical 1s a known carcinogen and can cause liver tumors.
The Impact of heavy metals 1n Torch Lake sediments 1s not well defined 1n
view of the fact that Torch Lake was listed as a CERCLA site. Further,
reviewers noted that future ambient water and sediment analyses require lower
detection limits.
STAGE II: WHEN REMEDIAL AND REGULATORY MEASURES ARE SELECTED UNDER
SUBPARAGRAPHS 4(a)(111), (1v), (v), and (v1).
4. Are the Identified remedial actions sufficient to resolve the problems
and restore beneficial uses?
No. The causative factor for tumors In fish 1s not known. Further
studies are recommended 1n the RAP. Some reviewers, however, pointed out that
the fish consumption advisory 1s the result of sediment contamination and
resultant Impairment of the health of the fish populations. It will,
therefore, require remedial programs to be focused on the contaminated
sediments. As noted 1n the RAP, Michigan DNR proposes to let natural forces
remediate the situation. Some reviewers stated that the situation 1n Torch
Lake (benthlc Impairments) will not change 1f the contaminated sediments are
not removed. Reviewers questioned whether or not there 1s sufficient
deposition material and natural transport to bury or remove the copper
tailings (further studies to determine the availability of clean sediments are
needed). Another reviewer, however, felt that the large volume of tailings
was not amenable to remedial programs, their effect minimal and supported the
suggestion on the natural deposition option.
5. Are the remedial actions consistent with the goals of the RAP?
No. The goals are not specific enough to determine whether or not the
actions will achieve the stated goals. The proposed actions only go part way
1n addressing the real problems (I.e. tumors 1n fish, contaminated sediments,
Impacted benthos, and violations of the GLWQA objective for copper).
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6. Hhat beneficial uses. If any, will not be restored? Does the RAP
Indicate why?
Until Michigan determines the causative agent(s) for tumors 1n fish, we
will not know what remedial actions are required or 1f the fish consumption
advisory can be rednded. The RAP should state that biological Impacts due to
copper contamination may not be eliminated by natural deposition of sediments.
7. Is the Identified schedule for Implementation of remedial actions
reasonable?
No specific schedule 1s presented.
8. Have the jurisdictions and agencies responsible for Implementing and
regulating remedial measures been Identified?
For the remedial actions Identified 1n the RAP, no responsible agency Is
Identified.
9. Have studies necessary to complete the RAP been Identified and have
schedules for their completion been established?
Some studies have been Identified, but they are Insufficient to complete
the RAP and 1t 1s not clear when the studies will be Initiated or completed.
One reviewer supported the fish restocking tumor study along with the
tumor Induction test. Another reviewer, however, had reservations concerning
the restocking program. Other reviewers stated two reasons for not
restocking; namely, questionable spawning success and Insufficient food.
10. Have work plans and resource commitments been made?
Michigan DNR proposed to spend $10,000 per year ver a 5-year period to
restock Torch Lake. U.S. EPA 1s planning a remedial Investigation and
feasibility study under Superfund. Torch Lake 1s listed 24th on the Michigan
Sites of Environmental Contamination Priority List. No additional commitments
are Identified.
11. Is the monitoring and surveillance program sufficient to document
Improvements as a result of the remedial actions Implemented and confirm
the restoration of beneficial uses?
No surveillance and monitoring program 1s Identified. This 1s essential
to track effectiveness of programs and confirmation that uses have been
restored.
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12. Has there been adequate and appropriate consultation with the public?
Two public meetings were held (75 people attended the two meetings).
Concern was expressed by reviewers for whether or not this approach would move
the governments to action.
STAGE III: NHEN MONITORING INDICATES THAT BENEFICIAL USES HAVE BEEN RESTORED
UNDER SUBPARAGRAPHS 4(a)(v11) and (v111).
Stage III requirements await completion and Implementation of the RAP.
SUMMARY:
In 1982, tumorous growths were found on Torch Lake sauger and walleye.
The Michigan Department of Public Health, shortly thereafter, Issued a fish
consumption advisory. Michigan DNR stated that "the advisory was Issued, as a
precaution, until the causative agent or agents, 1f present 1n Torch Lake,
could be determined." The causative factor Is still not known. As a result,
some reviewers stated that Torch Lake should be classified as 1n Category 2
(causative factors are unknown and an Investigative program 1s underway to
Identify the causes). One reviewer suggested that Torch Lake be classified 1n
Category 4 with no reasonable chance for man-Induced remediation.
It 1s recommended that revisions be made 1n the Torch Lake RAP 1n order
to satisfy the requirements of Stage I 1n the 1987 GLHQA. This should Include
a more precise definition of goals and establishing the cause-and-effect
relationships.
The Hater Quality Board views the RAP process as iterative, where RAPs
are updated and Improved based on a better understanding of the problems and
their causes and the development of new technologies to remedy the problems.
The challenge of RAPs 1s to make them focused and specific enough to
demonstrate progress. RAPs are Intended to identify when specific remedial
actions will be taken to resolve the problems and who 1s responsible for
implementing those actions. If remedial actions cannot be identified and
additional studies are needed, the RAP should Identify when the studies will
be initiated, when they will be completed, and when this new information will
be used to identify remedial actions.
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INTERNATIONAL JOINT COMMISSION
GREAT LAKES HATER QUALITY BOARD
Surveillance Work Group
100 Ouellette Avenue, 8th Floor
Windsor, Ontario, Canada N9A 6T3
or P.O. Box 32869, Detroit, Michigan 48232-2869
File # 2610 January 19, 1988
Mr. E. T. Wagner
Regional Director
Inland Waters Directorate
Environment Canada - Ontario Region
P.O. Box 5050
Burlington, Ontario
L7R 4A6
Dear Tony:
I have finished reviewing the Torch Lake RAP and my comments are
attached. In my opinion, Michigan is attempting to set a precedent that,
if successful, will render the Areas of Concern RAP process null and void.
Apparently, they have the notion that it is sufficient to describe the
problem, then imply that there is nothing that can be done to resolve it and,
therefore, it is no longer an Area of Concern. The logic behind this approach
totally escapes me and I suggest the Programs Committee/Water Quality Board
have some serious deliberation to determine if this is the level of resolve
that can be expected from Michigan and other jurisdictions. If this represents
a common attitude, then I suggest the WQB terminate the RAP process
immediately and save the SWG from further embarrassment in its treatment of
the Task Forces.
Sincerely yours,
C. J. Edwards
CJE:sc
cc: J. H. Hartig
/at
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January 19, 1988
REVIEW OF TORCH LAKE REMEDIAL ACTION PLAN
by
C. J. Edwards
IJC Regional Office, Hlndsor, Ontario
The stated goals of the Torch Lake Remedial Action Plan are to assemble
and summarize all existing data on the Area of Concern, identify impaired
designated uses, sources of the problems and data gaps and propose
alternatives to restore impaired designated uses and resolve identified
problems. Where sufficient data to define a problem or sources do not exist,
the RAP will propose investigations to provide the needed data. The RAP
achieves most of the stated aims and arrives at an illogical conclusion to
declare the area a category (6) six.
There appears to be several major problems in Torch Lake which no doubt
stem from several sources; all of which are apparently contaminant based. The
first problem is the high incidence of tumors in fish, especially the sauger
population. These tumorous fish have resulted in the issuance of consumptive
warning. One goal is to remove this warning.
The data provided on tumor prevalence and the likely inducing source(s)
would indicate that the source of the problem is not currently active.
Whether the sources, probably the aromatic hydrocarbons (AHs), are inactive or
buried is irrelevant if we can be assured that resuspension will not occur.
The RAP does not provide sufficient information to reach that conclusion. For
this reason, the RAP should state to what depth the sediments were drawn to
perform the tumor/cancer testing.
Fortunately, the heavy metals of concern and the AHs, the suspected
primary cause of the Torch Lake problems, do not have a propensity to
bioaccumulate in fish. However, the data on other contaminant burdens
provided in the RAP are not definitive but do pose some element of concern
over the high PCB and DDT concentration in one sample (spleen). The presence
of DDT is especially perplexing. For these reasons, the RAP should provide a
strategy for a comprehensive survey to evaluate contaminant burdens in
northern pike, walleye/sauger, and bullhead/white suckers using whole fish and
fillets.
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TORCH LAKE RAP
Page 2
According to the RAP, the sediments are acutely toxic to benthlc test
organisms. Limited data also demonstrate a depauperate benthlc community.
The fish community assessment data (what little there 1s) demonstrate a lack
of young fish of all species using experimental gill nets. Such data Indicate
that there 1s Insufficient food for the early life stages of resident fish.
There may also be insufficient spawning habitat or acute toxidty to
eggs/early life stages. The nine consecutive missing age classes of sauger is
definitive proof to support one or all of these reasons for a highly stressed
fish community. Young-of-the-year surveys should be Implemented to ascertain
the magnitude of spawning success (or alternatively spawning habitat
surveys). If there is sufficient spawning success, it would preclude,
actually augur against, the stocking program suggested as a remedial option.
If insufficient food is the problem, then the stocking program will surely
result in failure.
As part of the food chain assessment data provided within the RAP, a
somewhat enigmatic situation appears. Hith the extraordinary high dissolved
copper concentration found in the lake, 1t is hard to imagine phytoplankton at
densities rivaling those found in the western basin of Lake Erie. Indeed
these two pieces of data are incompatible. For this reason, the RAP should
require standard phytoplankton surveys to verify the earlier data reported
therein.
Finally and perhaps most importantly is the RAP conclusion to declare the
area a category (6) six. To remove the lake from Area of Concern designation
while still grossly violating the state standard for copper seemingly
undermines their own permitting system and certainly undermines the Area of
Concern process. For instance, how could the state enforce its point source
discharge law when an effluent could have a pollutant concentration
(undiluted) less than the waters of a lake with a confirmed restored use
classification? It would seem that the best course is to declare Torch Lake a
Category 4 (four) with no reasonable chance for man-induced remediation. ..-The
RAP should then provide a surveillance/monitoring strategy to periodically
check the condition of the lake as natural forces are at work resolving the
problem.
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COPY
UNITED STATES DEPARTMENT OF THE INTERIOR
FISH AND WILDLIFE SERVICE
Federal Building, Fort Spelling
Twin Cities. Minnesota 55111
FWS/AE-ES June 7, 1988
Dr. E.T. Wagner
Chairman, Surveillance Work Group
International Joint Commission
P.O. Box 32869
Detroit, Michigan 48232-1869
Dear Dr. Wagner:
We provide these comments, as requested, through our participation on the
Surveillance Work Group. The Torch Lake Remedial Action Plan (Plan) was
reviewed using the three stages of the review process 1n the 1987 Amendments
to the Great Lakes Water Quality Agreement, Annex 2, 4(d)(l)-(111). We have
determined that the Plan only partially satisfies Stage I of the review:
Adequacy of Problem Definition. Further work 1s needed on the description of
Impaired uses for completion of Stage 1. The Plan falls to fully satisfy
Stage 2: Identification of Remedial and Regulatory Measures; and Stage 3:
Restoration of Beneficial Uses.
Many of the same deficiencies which we have Identified in previous review of
the State's plans exist 1n this Plan. Most notably are the lack of an
ecosystem approach, time schedules, and fish and wildlife objectives
Identification. The Plan 1s narrowly focused and conclusions are not
supported by scientific evidence. We are also concerned with the State's
Intent to limit active remediation 1n the future.
The tumor problem 1n walleye and sauger has been Intensively Investigated.
However, the current tumor rate 1s relatively unknown and causative factors
have not been Identified. Remediation plans cannot be formulated until
causative factors are reasonably understood. Further research 1s necessary to
determine whether remediation can be accomplished 1f tailings are the
continuing problem.
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Dr. E. T. Wagner
We appreciate the opportunity to provide comments on this Important
document* and would be glad to discuss the above comments with you.
Please feel free to contact Tlat Kublak at our East Lansing Ecological
Services Field Office 517/337-6650.
Sincerely,
1
: «7oh
cc: «7ohn Bar tig, IJC, Windsor
I John Gannon, NFC-Great Lakes, Ann Arbor
East Lansing Field Office
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MEMORANDUM
NOTE DE SERVICE
TO
A
Griff Sherbin
FROM
DE
SUBJECT
OBJET
Laurie Sarazin
February 22, 1988
RAP Review
I have completed my review of the Torch Lake and
Manistique River RAPs. Neither of these documents should
be considered complete RAPs since more studies are
required to document sources of contamination. I don't
know if it is merely a problem with terminology since in
Canada we are not calling our documents RAPs until all
studies are complete and remedial actions have been
defined. My attached comments address the specific work
that is required on the Torch Lake and Manistique River
RAPs.
L. Sarazin
cc. Ian Orchard
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Torch Lake RAP
1. In the executive summary (pg 2, para 4) it states that
"Since tumor inducing agents have not been found in Torch
W Lake, the basis for fish consumption advisory and thus the
m designation as an AOC no longer exists. Unless the basis
for the consumption advisory is changed it is recommended
that this Area of Concern be reclassified as a category
six." This RAP concentrates on the fact that although
there are widespread tumours in certain fish species, the
m cause of these tumours has not been determined even though
fairly extensive studies have been done. Removing the site
from the list of AOC can not be justified because the
source has yet to be determined. In fact this means that
| Torch Lake should be classified as a category 2 (causative
H factors are unknown and investigative programs are
underway to identify causes). The RAP states that "higher
trophic levels in aquatic ecosystems, such as fish,
reflect conditions at lower trophic levels of biological
g organization, as well as physical and chemical
j conditions". In the discussion of remedial actions, it is
noted that further studies can still be done to try and
A determine why these fish have tumours. It would be
irresponsible to remove the restriction on these fish
P and the AOC designation just because the source of
0 contamination has yet to be determined. Irregardless of
* the fish tumours, this area must still remain an AOC
because of the elevated levels of contaminants in the
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sediments and the impaired benthic community.
2. Page 33 section 4.4.3 - The last sentence appears to
continue on page 42 after the diagrams, however, it
appears as if one words or sentences are missing.
3. Page 44 section 4.4.1 - The first paragraph says creosotes
degrade slowly in water yet the previous paragraph (4.4)
states that this suspected causative agent degrades
rapidly.
4. Page 50 section 6.1 - What are the point sources that are
not significant and not controllable?
5. Page 52 Section 8 - The primary goal of the RAP is not to
"remove the fish consumption advisory for Torch Lake
sauger and walleye on the basis of its issuance". The
purpose of the RAP is to improve the quality of the
aquatic ecosystem and then, as a result the fish may be
removed from the fish consumption advisory list.
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DATE:
SUBJECT
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
AfK
' Review of Michigan DNR Draft ofwfcorch Lmk*
FROM:
TO:
Vacys J. Saulys, U.S. Point
Source Coordinator
Griff Sherbin, Canadian Point
Acti. a
Environmental Protection Santo
Ontario Region
APR26I988
FILE:
TO
INITIALS
DATE
After a careful reading of the subject Remedial Action Plan (RAP), we
have concluded that it does not address the issues. The problems
in the RAP appear to stem in part from the statement of goals which
appears repeatedly throughout the RAP and sets the tone for the document
as a whole : "The primary goal of this RAP is to remove the fish
consumption advisory for Torch Lake sauger and walleye on the basis of
its issuance."
The goal of any RAP should be to establish a plan of remedial actions to
alleviate the contamination which caused the impairment of uses in the
AOC, not to deny that the problems exist.
In addition to the problem of defining goals which are consistent with
the Great Lakes Water Quality Agreement, errors in English usage,
typographic errors, mistakes in page numbering and omission of important
information were obvious. An example of the latter is the failure of the
the authors to respond appropriately to the concerns of earlier reviewers
about the limited amount of data supplied on (a) concentrations of
polycyclic aromatic hydrocarbons, and (b) fish tumor incidence.
Rather than searching for additional data or writing a more complete
discussion of the data at hand, the authors omnitted the section dealing
with PAHs, as well as tables of tumor and parasite incidence which were
included in the August 1987 draft RAP. These problems are detailed in
the specific comments section below.
Taken together, these problems make the October 27, 1987 revision of the
RAP an inferior, and less credible document than the August 1987 draft
which was available to us last year.
I recorrmend that the statement of goals, be reconsidered, and that
corrections to the RAP address thye specific comments which follow.
Attachments
O»A FORM 1330-6 {REV. S-76)
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TORCH LAKE REMEDIAL ACTION PLAN
Specific Comments
Section
Executive Summary
Pages 1-2 The sentence which reads "... further long term exposures and
continuous low level exposure using xanthates and wood creosote are
desirable." should read
"...further studies of the chronic effects of mixtures of xanthates and
creosote on fish are needed to resolve these questions."
Page 2 states : "Fish tissues (muscle, spleen, liver, tumors) have been
analysed for parasites, heavy metals, and chlorinated organic compounds.
Although these chemical data are limited neither heavy metals or
chlorinated organic compounds were found at concentrations of concern."
The historical uses and industrial activities do not suggest any input of
chlorinated organics. The early use of coal tar, and later wood
creosotes in the copper flotation process is an obvious, large input of
polycyclic aromatic hydrocarbons (PAHs). Why is no mention of sediment
levels of PAHs made in the summary ? These compounds, and not
chlorinated organics, should have been analysed in fish, water, and
sediments.
Paragraph # 4 states "...since tumor inducing agents have not been found
in Torch Lake, the basis for the consumption advisory and designation as
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an AOC no longer exists." As is mentioned later in these comments, the
lake was listed as a CERCLA site and as an IJC AOC on the basis of
serious contamination of lake sediments with toxic metals, in addition to
a tumor frequency which is dramatically elevated relative to that
I observed for both walleye and sauger in environments which are known to
~
be clean. Since the lake is on the CERCLA national priorites list, the
site must undergo a Remedial Investigation and a Feasibility study before
it could even be considered for deletion from the AOC list.
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Concentrations of the most likely tumorigenic agents, PAHs, are reported
only in an incomplete paragraph on page 42. This paragraph appears to be
a remnant of section 4.2.3 Environmental Fate of Xanthates and Creosotes
which appeared in the August 1987 draft of this RAP.
2. Introduction
On page 8, the last sentence of the last paragraph should be changed to
read "Apparently, the dissolved organic substances_ (7.0 mg/1) give the
lake its dark color, and chelate_ the copper..." (substances_ chelate_, a
substance_ chelates).
9 2.2 - States that "In 1985, the State of Michigan has[sic] determined
that Torch Lake was a Category 2 AOC..."
This designation is still appropriate, since the causative factors remain
unknown, despite an intensive, if misdirected, initial investigation.
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4. Problem Definition
As noted above, a problem remains in the sediments. As discussed in the
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draft RAP, the density of benthic communities is low - studies with
mayflies and Daphnia indicated that Torch Lake sediments are toxic.
Page 33 - Text is missing at the top of the page. This page appears to be
duplicated at page 44.
4.2 - Sediment Quality - This section does not start on page 33 as
indicated in the Table of Contents. The incomplete retains of this
section appear on the top of page 42. This paragraph was originally part
of section 4.2.3-Environmental Fate of Xanthates and Creosotes, in the
August 1987 draft RAP. This section described analyses of benzola]pyrene
that were performed on sediment samples by Dorie (1986). This data is
not mentioned elsewhere in the RAP. The concentrations found by Dorie
(1986) are 10-50 X higher than sediments in Lake Michigan, and about 500
X those occuring in Lake Superior sediment samples.
The implication that the tumors are caused by viruses (particularly the
hepatcmas) is not supported by the documentation presented.
The second paragraph on this page, concerning the probability of tumor
occurance, is speculation. The experiments of Black and Evans did not
duplicate conditions in the lake, in that exposure was primarily to
water, rather than to a contaminated sediment bed and benthic organisms
which are normally part of the food chain. Experiments with sauger and
walleye in an environment containing all of the most significant elements
of the existing environment (including appropriate food chain organisms)
would be required to test the theory that contamination in the sediment
was causing the tumors.
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data. Why were these tables ommitted rather than being improved for the
latest version ?
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B (Old) Tables 4.4 and 4.5 - Tumor Incidence in Walleye and Sauger
The tables in the August 1987 draft presented appropriate, if limited
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4.4 Contaminants of Concern
g The first paragraph (summary) of this section contains statements which
f contradict one another and which do not follow logically from the
evidence presented in the remainder of the section. The first sentence
states : " Substances known to induce tumors have not been found in Torch
Lake." The evidence for input of PAHs is overwhelming, but, with the
| exception of an incomplete paragraph of a missing section, the RAP
tm presents no measurements of PAHs in Torch Lake. How can the authors
claim that these contaminants have not been found "...due to rapid
degradation...", if they have not been measured ? The last sentence
proceeds to state that creosote components are the suspected causative
9 agents for tumors in sauger and walleye!
4.4.4 What amount of sediment was recovered by Black and Evans (1986)
for extraction ? The total sediment from 30 liters of water could amount
to only a few milligams, if the water was clear. This would not be
enough material for detection of PAHs by the methods described. Exposure
to carcinogens/nutagens usually occurs by ingestion of sediment and/or
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benthic organisms. Without an estimate of the amount of sediment ingested
the water column sediment extraction data cannot be related back to the
fish and the occurance of tumors.
The authors also claim that PAHs are known to be the causative agents
for fish tumors in the Black and Buffalo rivers. Citations would be
appropriate here.
7. Historical Record of Remedial Actions
7.1 Completed Actions
The sentence which reads "Xanthates were found to be shore lived in the
environment." should be corrected. No reference is given for the
environmental fate of creosote. Because creosote is used as a wood
preservative, and has been found in some AOCs long after its use was
discontinued, many readers will find it hard to believe that it is short-
lived in the environment.
4.5 Summary
The Sutrmary states that "Two impaired uses exist in Torch Lake at this
time: a consumption advisory based on tumors in sauger and walleye and a
degraded benthic macroinverte[sic] community due to sediment copper
toxicity." The fish consumption advisory is the result of contamination
(possibly viral in nature) and resultant impairment of the health of the
fish population. Laboratory toxicity tests indicate that the sediments
are toxic to many organisms that might otherwise inhabit this lake. This
situation is not likely to change without removal of the mining spoils.
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The impaired uses are then
a) Loss of suitability as a habitat for aquatic species due to sediment
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toxicity.
b) Loss of suitability as a fishery because of (a) and fish tumors
suggestive of PAH contamination.
c) Loss of suitability as a source of drinking water because of known
II and suspected contamination.
d) Loss of suitability for water contact recreation for the same reasons
as (a) and (c) .
8. Definition of Specific Goals, Objectives, and Milestones...
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All of the comments for section 2 and 4 apply to the logic of the goals
and conclusions of this section.
In the second paragraph on page 52 the authors state "As the problem
appears to be due to historical exposures to short-lived organic
chemicals...it is unlikely that such agents will be found in the lake."
This statement is illogical and inconsistent with itself. Discharges of
Coal Tar Creosote have not occured in this lake since 1930. Tumors were
noted in 1979-1980. If these compounds are short-lived they should not
be causing tumors 40-50 years after the last discharges. Yet this
statement implies that these compounds are the causative agents. This
reviewer concurs with the latter assumption, on the basis of evidence of
input, and on the basis of what remains in your report of the deleted
section 4.2 (on page 42).
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-Restocking-
The experiment proposed could be performed in the laboratory under more
carefully controlled conditions, with more conclusive results. Restocking
the lake at the present time would encourage fishing and consumption of
fish which the MDPH advisory was intended to discourage. If natural
reproduction is insufficient to restock the lake, that fact suggests that
remedial actions are required to restore impaired reproductive
conditions.
9. Programs and Participants.
The following statement was made by MDNR in meetings and in the subject
RAP: "At both meetings the public was assured that the water in Torch
Lake was safe to swim in... The public was also informed that there was
no evidence to suggest that consuming fish or other animals with tumors
poses a risk of tumors to the consumer. " We concur with the Michigan
Department of Public Health, the Michigan Toxic Substances Control
Commission, and others who found fault with this statement.
The basis of the fish consumption advisory should not be changed, as it
follows the logic of cause-and-effect. The cause has not been found, but
the effect is clear.
10. Remedial Action Steps.
As part of the Remedial Investigation, the MDNR should conduct studies of
the fate of tailing/coal tar creosote mixtures identical to those used
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in the early 1900 's. Physical processes occuring in those mixtures
clearly lead to flocculation, and may encapsulate the creosote in a
manner that prevents the rapid degradation observed under other
* conditions. Simultaneously, sediment cores should be taken at several
fl locations around the lake bed, with emphasis on sites near historical
discharge of effluent from the coal tar creosote flotation process.
P Laboratory studies should be conducted with sauger and walleye raised in
the presence of a sediment bed composed of Torch Lake material, as well
* as in tanks containing synthetic sediments spiked with the same amounts
V of PAHs found in the sediments which have been analysed.
As it has been suggested that the fish tumors resulted from viral or
I parasite infections, a more intensive effort should be make to find these
organisms or demonstrate antigenic reactions symptomatic of their
presence.
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Changes in the status of the Torch Lake AOC should only be considered
p after a complete Remedial Investigation and Feasability Study have been
^ completed .
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Ontano
Ministry
of the
Environment
Ministere
de
I'Environnement
Mtt
e.
135 Si CUir Av«nu« Wtst
Suit* 100
Toronto. Ontano
M4V 1 PS
135 av«nu*St Clanrotmt
Bureau 100
Toronto (Ontario)
M4V1P5
323-4926
February 11, 1988
Mr. Griff. Sherbin
Water Quality Programs Committee
Great Lakes Water Quality Board
International Joint Commission
100 Ouellette Avenue - 8th Floor
Winsdsor, Ontario
N9A 6T3
Dear Mr. Sherbin:
Re; Review of Torch Lake RAP
The above RAP report has been reviewed by the
IJC Set>ms//r Subcommittee. Unfortunately, a proper
review could not be carried out because of confusion
resulting from missing information and inconsistent
section numbering in Section 4. Notwithstanding this,
the following were noted.
The report provides an extensive discussion on
the potential of xanthenes and wood creosotes for tumor
induction in fish. However, it was suggested that these
compounds were not found in sediment or water due to
their rapid breakdown. It should be pointed out that
these compounds are quite persistent but often occur in
very low concentrations (nano or pico grams) in
sediment. In order to detect these low concentrations
and the different isomers of PAH in xanthene and
creosote mixtures, a lower analytical detection limit
and nitrogen-and sulphur-specific detectors would be
required. Improvements in analytical detection limit
together with a complete GC/MS scan for identification
of degradation products of these compounds in Torch Lake
sediment should be considered.
The recommended remedial action related to
benthic organisms in the lake includes sediment removal
by natural processes and deposition and burial of
contaminated material on the lake bottom. It must be
pointed out that these processes will be effective only
if sufficient material is available to cover the
contaminated sediment and provided all external sources
of contaminants are curtailed. Information on the
availability of clean sediment entering the system
should be obtained. If natural "burial" of contaminated
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such as capping (artificial placement of clean material)
sediment will require an extensive period, other options
such as capping
may be required
If you require, we will be pleased to review a
"corrected" version of the report. In the meantime, if
you have any questions on the above, please give me a
call.
DP/vf
00784F
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Environment Environnement
Canada Canada
an " 1 ~
ro ;-or In I '.\r-i".i! |i-p
.-:.- F d. -.--). :;o
, '.}' * JO ?," -i
u.c
R.O.W"
19SO.
Dear Mi ke:
Re: Remedial Action Plan -For Torch Lake -review
Please find enclosed my comments -for the above Remedial Action
Plan. There are also -few comments on the margins in the enclosed
copy a-f the Report.
Please call me i -f you need additional in-f ormat i on .
Sine ar e 1 y , your s
Alena Mudroch
Lakes Research Branch
iMa.tional Water Research Institute
Canada
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REMEDIAL ACTION PLAN -for TORCH LAKE, MICHIGAN
Comments
A. Muriroch
Lakes Research Branch
Water Research Ins
1. . Tries- (? i
missing in
fiijur difficult to follow the text in this part
of
The Report contains an e,:tensj ve discussion on the potential
xanchenes and wood creosotes for tumor induction in the fish.
However, these compounds were not found in the sediment or water,
due to their fast degradation. These compounds are actually quite
persistent; however, they occur often in small concentrations
(nano- or picograms) in sediments. Very low detection limit and
nitrogen- and sulfur-specific detectors are required to detect
these low concentrations and different PAH's in the xanthane and
creosote mixtures in sediments. These analytical methods should
be considered together with a complete GC/MS scan for the
identification of degradation products of these compounds in the
sediment from Torch Lake.
3. Recommended remedial action regarding to benthic organism in
the lake includes natural transport, deposition and burial of
contaminanted material on the lake bottom. These processes will
be effective if there are sufficient quantities of clean material
available for the deposition over contaminated sediments. Is
there any information on the amount of clean sediment entering
the lake and about its deposition on the bottom"1 Freshly
deposited material may be derived mainly from the erosion of the
contaminated tailings. It will be important to estimate the input
(and depositlonal areas) of clean material to assess the time
required for covering contaminated bottom sediments in the lake.
If the natural burial will take an unreasonable time, capping or
artificial burial by clean material may be considered to isolate
contami nated sedi merits.
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Ontario
Ministry
of the
Environment
Ministers
de
I'Environnement
135 SI Clair Avenue West
Suite 100
Toronto. Ontario
M4V1P5
135. avenue St Clair ouest
Bureau 100
Toronto (Ontario)
M4V1P5
January 26, 1988
Mr. J. Hartig
Great Lakes Regional Office
International Joint Commission
100 Ouellette Avenue
Windsor, Ontario
N9A 6T3
Dear Mr. Hartig:
My review of the Remedial Action Plan (RAP) for the
Torch Lake Area of Concern (AOC) is attached. On the
whole, I find the RAP satisfactory and I feel that the
remedial action plan proposed by Michigan's Department
of Natural Resources will identify whether the causative
factors for the tumours in sauger and walleye in the
lake still exist. If no further tumours are found in
the fish used to restock the lake, and if the tumour
induction test for xanthates and creosote is negative
then the hypothesis that tumour induction was caused by
past chemical exposure is almost certain to be correct.
The fish consumption advisory, which is the reason that
Torch Lake was classified as an area of concern, can
then be rescinded.
The other problem, that of an impoverished benthic fauna
in areas where sediments are contaminated with copper,
is not readily amenable to remedial programs because of
the large mass of such sediments. The effect of such
sediments is, however, minimal, and the suggestion to
allow natural deposition to isolate the sediments from
the water column is reasonable.
Yours sincerely.
R.R. Weiler
Supervisor, Substance Review
Hazardous Contaminants Coordination Branch
International Year off
cc: J.J. Smith
Shelter for the Homeless
RW/lg
I.J.C.
R.O.WINDSOR
FEB-21981
SectyWQB
SectySAB
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REVIEW OF REMEDIAL ACTION PLAN FOR
TORCH LAKE AREA OF CONCERN, MICHIGAN
Stage 1; Adequacy of problem definition
The goals of the RAP are to remove the fish consumption
advisory issued in 1983 for the lake. This advisory
affects the sport fishing in the lake, and is the reason
for classifying Torch Lake as a Category 2 AOC. A
Category 2 AOC is one where the "causative factors are
unknown and an investigative program is underway to
identify the causes".
The environmental problems have been adequately described.
The causative agents of the tumorous growths in the liver,
spleen and mesenteries of the sauger and walleye have not
been determined. The tumours were discovered in the late
1970's.
In addition, investigations have shown that the benthic
biota are impoverished in density, diversity and biomass
because of the large quantities of contaminated tailings
in the lake from the former copper mining and milling
operations on its shore. However, despite the elevated
copper concentrations (20-80 ug/L) in the lake waters, the
phytoplankton and zooplankton communities are healthy.
Mutagenicity tests with bacteria (Ames test) were negative
using sediments or extracts of sediments. The heavy metal
and chlorinated organic compound concentrations in the
fish were in the normal range. Tumour induction studies
in fish, using the copper flotation chemicals, showed
hepatic abnormalities. No tumour induction in rainbow
trout eggs were found using aqueous elutriates of
sediments.
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The probable causes of the tumours are creosote and
xanthates which were used in copper ore flotation. The
components of creosote are carcinogenic and xanthates
cause liver damage. These chemicals are no longer present
in either water or sediments as their half-lives in the
aquatic environment are short. The copper mine and
milling operations stopped in the late 1960s. There has
not been any recruitment to the sauger population for at
least a decade; hence, these fish cannot be used to
investigate whether the conditions that caused tumours in
the older saugers still exists. There has been
recruitment of walleye, however, and liver tumours are
present. There is no information on the distribution of
tumors with age, although the percent of fish having such
tumours appears to be decreasing.
There is, however, one factor that requires further
consideration. Elevated levels of benzo(a)pyrene (BaP)
(3-17 ug/kg) have been found in sediments. BaP is a known
carcinogen and can cause liver tumours. However, it is
odd that only sauger and walleye were affected but no
other bottom dwelling fish and that the sediments show no
mutagenic activity.
Stage 2: Identification of remedial and regulatory
measures
The proposed remedial measures appear adequate to restore
the beneficial user.
The Michigan Department of Natural Resources has adopted
an interim remedial action plan which will also help to
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answer the problem of tumour causation. Sauger and
walleye fingerlings will be added to the lake and examined
for tumours. If none are found, then the hypothesis that
tumour induction was caused by past chemical exposure is
almost certain to be correct. This hypothesis will be
further tested by using fish bioassays to determine the
tumour induction potential of xanthates and creosote. If
the test is positive, the hypothesis is confirmed.
However, if it is not confirmed, then further
investigations to determine and, if possible, remove the
causes of the tumours is warranted.
No remedial program is proposed for the copper
contaminated sediments as the amount of such sediments is
large and its effects appear minimal. Hence, the
suggestion of allowing natural deposition to isolate the
sediments from the water column is logical.
The remedial action steps and the agencies involved are
identified, but details are lacking on execution.
Stage 3; Restoration of beneficial uses
The planned remedial steps will be implemented within 2-3
years.
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TORCH LAKE, MICHIGAN AREA OF CONCERN
Harold E.B. Humphrey, Ph.D.
This area concerns a nearly land locked lake which is tributary to Lake
Superior. In essence the situation represents historic discharge of
manufacturing wastes (mine process tailings) directly into the body of
water. What is left is a lake visibly choked with islands of fine grained
debris which is only partially stabilized and a nearly 100% disease rate
(tumors) in one species (sanger) and a high rate in a second species
(walleye) of recreationally caught fish.
Apparently the existence of a risk management advisory (fish consumption
advisory) is the primary reason this is an area of concern. I disagree with
the over-emphasis placed on the advisory and feel that the sad and lasting
evidence of disregard for the environment of the lake should be of equal
consideration.
I disagree that the goal of this RAP or any RAP is to remove a risk
management action. The goal should be to identify and remediate, if
possible, the causative agent(s) or factors which necessitate advisories or
degrade the aquatic environment. There is consensus among reviewers that
the fish consumption advisory should remain in place until a reasonable
explanation for the fish tumors is found.
The RAP takes a rather cavalier attitude about the risk management advisory,
its origin and necessity. The documentation of a 100% incidence of disease
in a biological population is_ a significant finding. Tumors are found
elsewhere but not at this rate. From a public health perspective, risk
management requires consideration of a number of factors beyond the obvious,
and this distinguishes it from other disciplines in natural resources.
The RAP was considered adequate as a descriptive document but a bit weak in
Sections 8-10 in the view of the reviewers. In my view there may be very
little which can be done to take away the piles of tailings in the lake and
that situation should be left alone or stabilized more rapidly.
All reviewers endorsed the recommendation to continue research in order to
determine why the sangers get tumors. However, I believe a critical
emission exist; a thorough G.C-mass spec scan of tumors and fish tissue has
not and should be performed. Attempts to quantitate half a dozen common
contaminants does not adequately address this need nor the mystery of
identifying causative agents in edible fish flesh which might be of human
health significance. Until this is done, I have reservations concerning a
sauger plauting program which may accumulate an uaknown carcinogen to which
the next generation of anglers would then bo exposed in their recreational
fishing. Otherwise the sauger planting experiment has merit in that it
would determine whether or not the tumor incidence was a one time event.
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May 26, 1988
WATER QUALITY PROGRAMS COMMITTEE
COORDINATED REVIEW
of the
REMEDIAL ACTION PLAN
for
WHITE LAKE
Preface:
This Remedial Action Plan (RAP) was prepared under the guidelines
prescribed by the Water Quality Board (WQB), which is consistent with Annex 2
(Section 4) of the 1987 Agreement. This review assesses the adequacy of the
White Lake RAP against the original Water Quality Board guidelines. These
guidelines are structured according to the new three stage review protocol,
for the purpose of this review.
Participation:
This summary brings together the individual reviews of various members of
the WQB committees and the Science Advisory Board, so as to provide a wide
range of expertise in reviewing the various technical details of the RAP.
Reviews (attached) were received from the following:
Surveillance Work Group J. Ball, Wisconsin DNR
M. Moriarty, U.S. Fish & Wildlife Service
Point Source Coordinators G. Sherbin, Environment Canada
V. Saulys, U.S. EPA
Nonpoint Source Subcommittee G. Wall, Agriculture Canada
Science Advisory Board W. Lyon, et al.
Sediment Subcommittee D. Persaud
STAGE 1: WHEN A DEFINITION OF THE PROBLEM HAS BEEN COMPLETED UNDER
SUBPARAGRAPHS 4(a)(i) and (11).
1. Are the goals and objectives clear and precise?
The Michigan Water Resources Commission has designated water uses for
which all waters of the state are to be protected, specific parameter
objectives to meet these water uses for White Lake are not identified. Public
consultation should be considered to confirm water use goals or identify
additional local water use goals and objectives.
The water use goals and quality objectives have been generally stated.
More specific objectives should be identified for parameters associated with
degraded benthos, contaminated groundwater seepage, etc.; action levels are
identified for PCBs and chlordane in carp.
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2. Are the goals and objectives consistent with the general and specific
goals of the GLNQA?
Goals consistent with the GLHQA have not been specifically Identified and
should be Incorporated. Michigan Nater Resources Commission designated water
uses are stated and Michigan Department of Public Health, U.S. Food and Drug
Administration and IJC guidelines for toxic substances are tabled.
3. Is the Information base sufficient to adequately define the problems and
Identify the causes?
Several unidentified Impaired uses appear to exist 1n addition to fish
consumption. Both lake water and groundwater for drinking 1s an Impaired use,
as 1s the use of sediment as habitat for bentMc organisms and Its use by carp
and other bottom feeders.
The discussion of causes of the problems 1s Inadequate 1n that loadings of
various chemicals from Occidental Chemical and other sources was not
discussed. Non point sources are poorly addressed.
Definition of the problem 1s limited to some pollution sources and does
not discuss the technological Issues which created the problem. Cause-effect
relationships need to be yet defined. For example:
1. PCB and chlordane sources for the carp contamination are suspected
but not confirmed.
2. White Lake sediments are undergoing further analyses to determine 1f
they are a potential source to the fish contamination.
3. Additional lake surveys are recommended 1n the plan to determine 1f
remedial actions are needed to reduce nonpolnt source nutrient and
pesticide loadings to the lake.
STAGE II: NHEN REMEDIAL AND REGULATORY MEASURES ARE SELECTED UNDER
SUBPARAGRAPHS 4(a)(111), (1v), (v), and (vl).
4. Are the Identified remedial actions sufficient to resolve the problems
and restore beneficial uses?
The linkages between remedial actions, problems and restoration of uses
cannot be fully Identified, due to the lack of some environmental and source
data. There are no new remedial actions Identified; recommendations are made
for further assessments and monitoring.
5. Are the remedial actions consistent with the goals of the RAP?
The goals are not specific enough to determine whether or not the actions
will achieve the stated goals. The actions already taken may not address all
the problems (I.e. Impaired drinking water, contaminated sediments, Impacted
benthos, etc.)
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6. Hhat beneficial uses. If any, will not be restored? Does the RAP
Indicate why?
A number of remedial actions have historically been taken. Only
Investigations and continuation of existing programs are recommended 1n the
RAP. It 1s not clear 1f any beneficial uses will be restored as a result of
these steps. Emphasis Is placed on further studies.
7. Is the Identified schedule for Implementation of remedial actions
reasonable?
No specific schedule 1s presented.
8. Have the jurisdictions and agencies responsible for Implementing and
regulating remedial measures been Identified?
For the Investigations Identified 1n the RAP, no responsible agency is
Identified.
9. Have studies necessary to complete the RAP been Identified and have
schedules for their completion been established?
Some studies have been recommended, and 1t Is not clear when the studies
will be Initiated or completed.
10. Have work plans and resource commitments been made?
No. Only recommendations for monitoring have been made.
11. Is the monitoring and surveillance program sufficient to document
Improvements as a result of the remedial actions Implemented and confirm
the restoration of beneficial uses?
No specific surveillance and monitoring program (e.g. what, when, where)
1s identified. This is essential to track effectiveness of programs and
confirmation that uses have been restored.
12. Has there been adequate and appropriate consultation with the public?
Two public meetings were held. Consideration should be given to further
involve the public in setting water use goals, Identifying and evaluating
remedial options and finally reviewing and sanctioning the RAP.
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STAGE III: NHEN MONITORING INDICATES THAT BENEFICIAL USES HAVE BEEN RESTORED
UNDER SUBPARAGRAPHS 4(a)(v11) and (v111).
Stage III requirements await completion and Implementation of the RAP.
SUMMARY:
Many remedial actions have historically been taken on Hhlte Lake. The
RAP at this stage recommends additional Investigations and does not fully
Identify remedial actions to achieve water use goals (Incompletely stated).
The major contaminant source Identified for Hhlte Lake 1n the 1985 HQB
Report was the Occidental (Hooker) Chemical Co. contaminated groundwater
plume. Organic chemicals from the plume were found In HMte Lake but no
Impacts or Impaired uses were Identified. Remedial program development and
actions by Michigan DNR and Hooker Chemical Co. since 1979 have been effective
1n capturing 95X of the groundwater plume using a purge well system.
Other Industrial and municipal contaminant sources Identified 1n the
early and m1d-70s have been curtailed; however residual sediment contamination
and underdralnage from land application remain.
The current problem 1n White Lake 1s very narrowly defined (I.e. PCBs and
chlordane 1n fish). There appear to be other Impaired uses (e.g. benthos,
drinking water, contaminated sediments, etc.). Michigan DNR notes that White
Lake has no known effect on Lake Michigan.
The most important deficit 1n this RAP 1s the abbreviated section: 10.0
Remedial Action Steps. This section 1s very brief, recommending further
monitoring. A Remedial Action Plan should consist of a summary of specific
actions designed to address contamination in the Area of Concern. The plan
should compare alternative actions, both in terms of cost and efficiency 1n
attaining the goals of the plan. A RAP should also contain a preliminary
timetable for the activities planned, and identify the agency responsible for
implementation. The White Lake RAP at this stage does not meet these
requirements.
It is recommended that the White Lake RAP be revised following completion
of the recommended investigations in order to satisfy the requirements of
Stage I 1n the 1987 GLWQA. This should Include a more precise definition of
goals and establishing the cause-and-effect relationships. Use of more
extensive public consultation should be considered in defining water use goals
and objectives. Further, White Lake should be classified 1n Category 2 due to
the fact that further Investigative programs are recommended.
The Water Quality Board views the RAP process as iterative, where RAPs
are updated and improved based on a better understanding of the problems and
their causes and the development of new technologies to remedy the problems,
The challenge of RAPs 1s to make them focused and specific enough to
demonstrate progress. RAPs are Intended to identify when specific remedial
actions will be taken to resolve the problems and who is responsible for
implementing those actions. If remedial actions cannot be Identified and
additional studies are needed, the RAP should Identify when the studies will
be Initiated, when they will be completed, and when this new information will
be used to identify remedial actions.
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X 608 267 3579 W1S DNR 02
State of WiHContdn \ DEPARTMENT OF NATURAL RESOURCES
^ /w«
0X79*1
MADISON, WISCONSIN 537^7
April 15, 1988 ,***-. 3200
Dr. John Hartig
International Joint Commission !
Lake Michigan Task Force |
P.O. BOX 32869
Datroit, Michigan 48232-2869
Daar Dr. Hartig:
I have reviewed the White Lake RAP along with Lynn Per aeon, ona of
the principal authors of the Green Bay RAP. Baaed on our review, I
will first try to address the questions in the raviaw protocol, and
than make a faw ganaral comment*.
Stage l
Goals and objactivaa ara vary general, not claar and precise.
Specific objectives could be listed for parameter* and problems
identified as concerns.
The RAP does a good job of identifying sources of problems with the
exception of nonpoint sources and nutrients. However, I got the
impression that use impairment may be more of a problem than was
expressed.
Stage 2
The RAP appears to do a good job of describing remedial measures.
Michigan has been working on the major problems for a long time and
has made good progress. However, it looks like additional effort
could go toward the contaminated sediment problems and nonpoint
source impacts, especially nutrients.
No time table was provided for initiating additional studies or
remedial measures. With the progress already made, and the apparent
high level of effort, 1 don't view this as a major problem.
Stae
Data provided indicates progress is being made toward restoring
beneficial uses.
The RAP provides a good summary on the Area of Concern problems and
sources. However, less thought appears to have been given to goals,
objectives, and recommendations. Inplace contaminate recommendationi
don't appear adequate to address ths problems identified. Also, the
recommendations in the Executive summary, Table 10-1, and the text in
Chapter 10 don't appear to be consistent.
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X 60S 267 3579
yis DNR ,e3
It doea not appear that White Lake la a major problem compared to
other Lake Michigan Area* of Concern
Sincerely,
Joe Ball
Surface Water Standard* fc Monitoring Section
Bureau of Water Resources Management
JBtbm/S0202-17
cct Fred Fleiihcer - Ontario MOE
Dr. Barry Leant - Argonne National Laboratory
9700 Caaa Avenue
Argonne, IL 60439
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FWS/AE-ES
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Federal Building, Fort Snelling
Twin Cities, Minnesota 55111
JUN7 |888
IN ntPLV ntrta TO:
I.J/
R.O. WI*
JUN 1 OI988
Dr. E. T. Wagner 1.0-
Chairman, Surveillance Work Group
International Joint Commission
P.O. Box 32869
Detroit, Michigan 48232-2869
Dear Dr. Wagner:
We provide these comments, as requested, through our participation on
the Surveillance Work Group. The White Lake Remedial Action Plan (Plan)
was reviewed using the three stages of the review process in the 1987
Amendments to the Great Lakes Water Quality Agreement, Annex 2, 4(d)(i)-
(iii). We have determined that the Plan only partially satisfies Stage
1 of the review: Adequacy of Problem Definition. Further work is
needed on the description of impaired uses for completion of Stage 1.
The Plan fails to fully satisfy Stage 2: Identification of Remedial and
Regulatory Measures; and Stage 3: Restoration of Beneficial Uses.
Many of the same deficiencies which we have identified in previous
reviews of the State's plans exist in this Plan. Most notably are the
lack of an ecosystem approach, time schedules, and fish and wildlife
objectives identification. The Plan is narrowly focused and conclusions
are not supported by scientific evidence. We are also concerned with
the State's intent to limit active remediation in the future.
The benthic degradation and sediment contamination remain significant
sources of impairment within White Lake. Polychlorinated biphenyl and
heavy metal contamination need to be remediated. Only monitoring is
proposed. The fishery and wildlife values will remain impaired until
the sediment problem is removed. We suggest capping hot spot sediments
could greatly eliminate existing use impairments. Goals for fish and
wildlife resources need to be set. The most restrictive (International
Joint Commission) objective should apply. This is not an ecosystem
approach plan and does not fully satisfy Stage 1 requirements under the
new evaluation system. Progress made to date is laudable but
insufficient to delist this Area of Concern.
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Dr. E. T. Wagner
We appreciate the opportunity to provide comments on this important
docuaent. and would be glad to discuss the above cements with you.
Plaaae feel free to contact Ti» Kubiak at our East Lanaing Bcological
Services Field Office 517/337-6650.
Sincerely,
cc: iJohn Bartig, LJC, Windsor
John Gannon, MFC-Great Lakes, Ann Arbor
East Lanaing Field Office
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Environment Erwironnement 25 St. Clair Avenue East
Canada Canada 7th Floor
Toronto, Ontario
Environmental Protection de u*-r -i M«
Protection I'environnement mi irtc
Telephone: (416) 973-5840
Your Mi
Our Mt Motrt itrtttnct
1165-36/C71-10
February 16, 1988
Mr. Fred Fleischer
Water Quality Programs Committee
Great Lakes Water Quality Board
International Joint Commission
c/o Ministry of the Environment
1 St. Clair Avenue West
6th Floor
Toronto, Ontario M4Y 1K6
Re: Review of White Lake RAP
Attached are a summary of comments on the above RAP. The
document was reviewed in the context of the RAP review protocol. In
general the RAP has addressed all stages outlined in the protocol,
however, some area requiring further clarification, as well as a need
for additional data collection have been identified.
Yours truly,
G. Sherbin
Manager
Pollution Abatement Division
Environmental Protection
Ontario Region
Conservation 4 Protection
GS/kp-0052
Attached
__ aenneiytaatinaouKti
cw«*ns«5p*
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WHITE LAKE RAP - COMMENTS
4.
5.
6.
The RAP demonstrates a good understanding of the control options
necessary for the continuous point sources. A better understanding
Is needed of the Intermittent point sources such as stormwater
loadings and the Impact of Industries and services using the storm
sewer system.
Since large volumes of non-point source pollutants potentially
enter the storm sewer system yearly what attempts have been made
Identify and characterize these sources and estimate loadings where
feasible? Non-point sources to the White River contribute 98% of
total phosphorous loadings to White Lake and 99.1% of the dissolved
inorganic nitrogen and this is after all point source discharges
have been diverted to Muskegon County WMS No. 2.
It has been calculated that a 50% reduction of phosphorous loadings
to White Lake is necessary to eliminate entrophic conditions. This
reduction would require controls on basin-wide diffuse and natural
sources. An attempt, therefore, should be made to identify sources
on a watershed basis.
Measures should be outlined for identification of the source of
chlordane in the watershed in addition to the recommended
monitoring outlined on page 113. some consideration should be
given to rural sources.
Groundwater supplies 79% of the White River water upstream of
White Lake. Consideration should be given for contaminant Inputs
to groundwater from intermittent point sources.
The Remedial Action Steps as outlined appear to be feasible and the
ongoing investigative studies should not only determine the
efficency of measures taken or underway but also determine future
steps.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OREAT LAKES NATIONAL PROGRAM OFFICE
DATE: May 20, 1988
SUBJECT; Review of White Lake Area of Concern
Remedial Action Plan-, 7 r>
fow*T fV**+
I FROM: Vacys Saulys, U.S. R#P Coordina
i._ _~^,~~ ' 'por**
r . ^~^TOt Griff Shecbin, Canadaian RAP Coordinator
-My staff has reviewed the^DBpBfllDA of Concern Remedial Action
.. ^Plen. in general the document: was wen written (in terms of
"readability), but contains major flaws, especially in regard to the
remedial action plans themselves. These problems are listed below.
General Cerements
The discussion of sources of pollution is inadequate in that the
quantities of the various chemicals used or produced by Occidental
(Hooker) Chemical and, other major sources was not discussed. This type
of information would be helpful in estimating loadings and the adequacy
of propsed remedial actions.
The most important deficit in this RAP is the abbreviated Section :
10.0 Remedial Action Steps. This section is only three pages long,
recommends nothing beyond monitoring. A Remedial Action Plan should
consist of a summary of specific actions designed to address
contamination in the AOC. The plan should compare alternative actions,
both in terms of cost and efficiency in attaining the goals of the plan.
A RAP should also contain a preliminary timetable for the activities
planned. The White Lake AOC RAP does not meet these standards.
Although there is some discussion in the RAP to the effect that
replacement wells were needed in certain cases, neither the use of the
groundwater nor the potential for use of the Lake as a source of drinking
water was considered to constitute an impaired use. Given the tojicity
of the sediment, use of the benthic environment by aquatic species for
reproduction should also be considered to be impaired. In general,
public waterways should be fishable, swinmable and drinkable unless these
uses are impaired by navigational uses.
Although the text .was readable and contained few grammatical, spelling or
typograpical errors, the citations and bibiography are inadequate. Many
citations were not listed in the bibliography, or were cited incorrectly.
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Specific Comnenta
1.0 Executive Summary
Fish consumption, and not the advisory, is the impaired use. This
error in english usage has occured frequently in various Michigan
RAPs.
Several impaired uses exist in addition to fish consumption.
Impairment of fish consumption is the result of contaiminated water
and sediment. Thus the use of both lake and groundwater for drinking
is an impaired use, as is the use of sediment as a habitat by
benthic organisms, and its use by carp and other bottom feeders as a
feeding and breeding ground.
2.0 Introduction
The U.S. EPA (GLMPO) and the State of Michigan are Parties to the
Great Lakes Water Quality Agreement. Thus the naming of each of
these parties in addition to the international Joint Commission is
redundant.
Page 24 - Jamsen (1986 ... increased from 23,00[sic] to 60,000 ...
3.5 Water Quality Standards, Guidelines, Objectives ...
Page 28, 3rd paragraph - Currently ... using updated (1986)
Michigan Water Quality Standards that includesI sic] Rule 57
defines[sic] procedures...
Why is the table which follows this paragraph not defined or listed
as a table ?
Table 4-6 - This table is very difficult to read.
5.2.1 Groundwater Contamination
Page 65 - Occidental Chemical and Plastics.
" This chlo-alkalilsic] industry ..."
Henzman (1979) - this citation was not in the bibliography
10.0 Remedial Action Steps
There are no real remedial plans in this section - only
recommendations for further monitoring. If no actions are planned,
this should be clearly stated, and the reasons for this decision
(not to act) outlined.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
10.1.3 Contaminated ediraants
"Poor sediment quality ... species used to dominant[aic].
Appendicies - Many pages of the appendices were difficult to read or were
unreadable.
iiAisiijbr
''^§-,
-------
Michigan Department of
Natural Resources
Remedial Action Plan
for
White Lake
Stage 1
-Goals and objectives of the plan are clear and appear consistent
with the goals of GLWQA.
-Use impairment with respect to fish contamination has been well
documented. It is not clear if the eutrophic state of the lake
is contributing to any use impairment.
-The causes and sources of the use impairment (fish advisory) have
been identified.
Stage 2
-Remedial measures are in place (well purge) and their
effectiveness are being evaluated.
-Beneficial uses effected by eutrophic conditions are not
addressed.
-A surveillance and monitoring program has not been well
documented to track the effectiveness of the remedial action
plan.
-Responsible agencies for Implementation and further study have
not been identified.
-Public consultation has been minimal.
Stage 3
-Remedial measures to reduce contaminate loadings to the Lake have
been implemented.
-Surveillance and monitoring data to track restoration are not
well described.
General Comments
The remedial action plan appears to address the fish consumption
advisory (Carp) reasonably well. The study concludes that White Lake
has not known effect on Lake Michigan and one would wonder how It ever
became an area of concern.
The remedial action plan would have benefited from greater public
participation Inputs on use Impairments and restoration issues.
Gregory J. Wall
Nonprlnt Source
Subcommittee
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International Joint Commission
Commission mixte Internationale
GREAT LAKES REGIONAL OFFICE
SCIENCE ADVISORY BOARD
File No. 3000 March 4, 1988
Mr. Fred Fleischer, P. Eng.
Manager, Great Lakes Section
Water Resources Branch
Ontario Ministry of the Environment
135 St. Clair Avenue West
Toronto, ON
M4V IPS
Dear Mr. Fleischer:
re: Science Advisory Board Review of White Lake
Remedial Action Plan and Guidelines for Review
Please find attached specific RAP comments reviewed by the Board, together with
the generic guidelines upon which the reviews are based. This matter was a major agenda
item at the 70th meeting held in Erie, Pennsylvania on February 24-26, 1988.
It was the consensus of the Board that all of the RAPs reviewed, while not perfect,
nonetheless represent remarkable achievements when viewed as progress towards
implementing the GLWQA. None of the RAPs fully embodied an ecosystems approach,
however, the Green Bay RAP was acknowledged as the plan most closely adhering to this
principle. Accordingly, jhe BoarRAn rVrrnir Mirhicnn *R-o-» (51^ -<->A-->Tin
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2/17/88
SUBJECT: COMMENTS ON WHITE LAKE RAP
TO: SAB ERIE MEETING
FROM: LYON, MACKAY & EDINGER summarized by LYON
THE DESCRIPTION OF THE ENVIRONMENTAL SETTING IS TECHNICALLY
SOUND
THE RECENT REGULATORY ACTIONS ARE WELL DOCUMENTED. THE KEY
ISSUE SEEMS TO BE THE MIGRATIONS OF ORGANO CHLORIDE CHEMICALS
FROM DUMPS, LAND FILLS AND GENERALLY CONTAMINATED SOILS.
The report goes a thorough assessment of the background,
history, and relevant geographical factors. The problem is
clearly identified in terms of impairment, and the identified
causes seem to be reasonable.
WATER USES
SECTION 3 ON WATER USES DOES NOT BUT SHOULD REQUIRE AN OVERALL
COMPREHENSIVE WATER-BUDGET FOR THE LAKE. WATER DATA IS
SCATTERED THROUGHOUT THE REPORT BUT A WATERBUDGET IS ESSENTIAL
FOR A SCIENTIFICALLY AND TECHNICALLY BASED ECOSYSTEM EVALUATION
OF ANY WATERBODY.
NO SEASONAL PICTURE OF VERTICAL OR LONGITUDINAL TEMPERATURE
STRUCTURE WHICH WOULD PROVIDE ESSENTIAL INFORMATION ON
STRATIFICATION AND LIMITATIONS IN EXCHANGE BETWEEN SURFACE
AND BOTTOM WATERS AND WITH LAKE MICHIGAN. NO BATHYMETRIC
INFORMATION IS PROVIDED.
DEFINITION OF THE PROBLEM IS LIMITED TO POLLUTION SOURCES AND
DOES NOT DISCUSS THE TECHNOLOGICAL ISSUES WHICH CREATED THE
PROBLEM AND HOW THEY CAN BE PREVENTED.
THE POLLUTION PROBLEM
THE REPORT TELLS THE READER THAT HOWMET WAS MAKING TURBINE
ENGINE COMPONENTS BUT NOT HOW THAT RELATES TO THE POLLUTION
PROBLEM AND HOW THE TECHNOLOGY COULD BE CHANGED TO PREVENT THE
POLLUTION PROBLEM. DATA ON POLLUTION EFFECTS AND CAUSES IS
PRESENTED IN AN ANECDOTAL MANNER WITHOUT ADEQUATE ANALYSIS.
A SIMPLE STATISTICAL TEST OF THE INTERPRETATION OF DATA IN
TABLE 4-4 SHOWS A 20-30% LEVEL OF CERTAINTY OF THE CITED
REMOVAL OF TOXICS FROM A GROUNDWATER PLUME.
SECTION 6 ON POLLUTANT LOADINGS IN BOTH REPORTS IS COMPLETELY
INADEQUATE IN TERMS OF SCOPE, DETAIL, QANTIFICATION AND
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DESCRIPTION. DATA ON POLLUTANT LOADINGS IS CRUCIAL TO THE
SUCCESS OF THE PROCESS OF CLEANING UP THE PROBLEM-CERTAINLY
IN WHITE LAKE. NOT EVEN THE MOST MINIMAL INFORMATION ON
MASS BALANCE (INCLUDING INFLOW AND OUTFLOW) OF CHEMICAL
AND BIOCHEMICAL CONSTITUTENTS IS PROVIDED.
STORM WATER AND SEDIMENT LOADINGS, WHICH CAN BE SIGNIFICANT
ARE TREATED MUCH TOO LIGHTLY IN PARA 1 PP 23, PARA 6 PP 109, AND
PARA 4 PAGE 26.
THE EMPHASIS ON ATMOSPHERIC CONTRIBUTIONS SHOULD BE QUESTIONED.
IS THERE ANY REASON TO BELIEVE THAT ATMOSPHERIC LOADINGS IN THE
REGION WILL BE ANY GREATER PER UNIT THAN ELSEWHERE IN THE
STATE ? A SIMPLE CALCULATION WILL SHOW THAT LOCAL (SURFACE)
LOADINGS WILL TOTALLY SWAMP ANY CONCEIVABLE ATMOSPHERIC
LOADINGS.
THE RESTORATION PLAN
SECTION 8. IS INADEQUATE FROM AN ECOSYTEMS POINT OF VIEW SINCE
IT DOES NOT ADDRESS LAND-USE AND TECHNOLOGICAL ISSUES NOR ISSUES
RELATED TO THE FUTURE USE OF THE LAND, WATER AND OTHER RESOURCES
OF THE BASIN. THIS IS NECESSARY IN ORDER TO PREVENT OF FUTURE
PROBLEMS.
THE RAP TAKES A SHORT TERM VIEW OF THE PROBLEM AND DOES NOT
ADEQUATELY ADDRESS ISSUES SUCH AS: (i) How much contaminant IB
there "in place" in the basin? Is it a 2 year or 2000 year
supply? (ii) What are the loadings to the lake of these
chemicals? (iii) Are the loadings likely to increase as
non-aqueous phase liquids get closer to discharge? Or are we
seeing a problem that is getting better with time? (iv) What
about getting at the source of the problem, or is the source so
dispersed as to be impossible to treat? (v) Are present
industrial processes behaving in such a way that they are not
worsening the "in place" problem? (vi) Are soil treatment
options being considered?
There is little "science" in the Report. There is not a single
reference to a refereed scientific publication. No attempt to
draw on experience elsewhere
SECTIONS 9 & 10 ARE INADEQUATE AS THEY DO NOT ADDRESS
ALTERNATIVES. THEY LACK AN INDICATION AS TO HOW THE SELECTED
ALTERNATIVE WAS ARRIVED AT, SPECIFIC WORK PLANS, BUDGETS,
SOURCES OF FUNDS, PERSONNEL REQUIREMENTS, AND MOST IMPORTANT
RESEARCH REQUIREMENTS.
THE ACTIONS REQUIRED TO RESTORE WHITE LAKE REQUIRE A WIDE
DIVERSITY OF EFFORTS AND NEITHER SECTION 9 OR 10 SHOW ANY
INTEGRATION OF THESE EFFORTS, ESPECIALLY INVOLVING THE PUBLIC,
INDUSTRY, ENVIRONMENTAL GROUPS, GOVERNMENT AGENCIES, LAND AND
WATER USERS-. ALL THAT IS GIVEN IS A DIVERSITY OF FRAGMENTED
-------
EFFORTS.
THE REPORT CODLD BE IMPROVED BY DSING BETTER GRAPHIC TECHNIQUES
SDCH AS WERE USED IN THE MILWAUKEE HARBOR ESTUARY PLAN PREPARED
BY SWRPC.
SUMMARY
THE DESCRIPTION OF PROBLEM IS DONE FAIRLY WELL. THE ANALYIS OF
THE PROBLEM IS SCOPED TOO NARROWLY AND LACKS SCIENTIFIC DEPTH.
THE SOLUTION STATEMENT IS MOST INADEQUATE BOTH IN SCOPE AND
DETAIL.
In general, the report lacks a global, comprehensive, long term
view of the road to restoring the entire area to an
ttnviroriramtally acceptable condition. It reads like a "band-aid"
attempt to solve an immediate problem - which is quite
appropriate in the near term.
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Re; Hhite Lake RAP Comments
I finally managed to review the sections of White Lake RAP which deal
with the contaminated sediments. I would have liked to review the entire
document but the time constraints would not permit me to do so. My
comments should, therefore, be viewed in that light.
The authors of RAP report should be complimented for assembling and
reviewing a fairly large collection of data on White Lake Sediments. The
data, however, has been presented in a manner which makes it difficult to
establish any trends, temporal as well as spatial. It does not provide
any information regarding the type of sediment sampling involved such as
deep cores or surficial grabs. Since the authors have attempted to
establish trends for various contaminant concentration levels based on
sediment samplings carried out in 1972, 1980 and 1986 it is assumed th>y
must have taken the samplings techniques in consideration. This point
should be explained and clarified in the RAP document. More ispecific
comments pertaining to various sections in the report are provide below.
/
Section 4.2.2 Hhite Lake Sediment Quality:
P. 40: U.S. EPA sediment criteria listed in table 4.5 are\ for
heavily polluted sediments only. The guideline value xfor
'unpolluted' and 'moderately polluted' sediments should also
be listed for comparison purposes.
/
P. 40: PCB detection levels of 68 to 3500 ppb for 1986 data are
inexplicably high. It is understood that the samples are
being re-tested with lower detection limits. Also, the PCB
results should be compiled on the basis: of total PCB's rather
than it's individual isomers for be'tter comparison with
various jurisdiction guideline values. |
P. 44: The units listed in table 4.7 are erroneous; they should be
ppb rather than the ppm.
P. 46: Does Appendix 4.2 contain U.S. Army Corps 1979 sampling
results?
Reading through this section it seems that the sediment quality improves
from east to west with the sediments in the White Lake outlet near Lake
Michigan being completely clean and acceptable for open water disposal.
The document should point this out if that is the intent.
8.2.2. Sediment Contamination:
Can the conclusion regarding the source of sediment contamination be
fully substantiated by the data provided in Section 4.2.2.?
10.13 Remedial Measures:
Suspected sources of elevated PCB's and chlordane in carp are sediments
and/or atmospheric deposition. Does 1t mean that carp are directly
exposed to atmospheric PCB's? I suggest that the exposure route for carp
to atmospheric PCB would still be through the sediments.
Further detailed analysis of existing sediment quality data should be
carried out before undertaking any further sediment contaminant
monitoring.
In aeneral T
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May 26, 1988
NATER QUALITY PROGRAMS COMMITTEE
CO-ORDINATED REVIEN
of the
REMEDIAL ACTION PLAN
for
DEER LAKE
Preface:
This Remedial Action Plan (RAP) was prepared under the guidelines
prescribed by the Water Quality Board (WQB) before the signing of the Accord
of 1987 which amended the GLWQA of 1978. Therefore, this review assesses the
adequacy of this RAP against the original WQB guidelines. The WQB guidelines
were amended somewhat as they were incorporated into the Accord, and these
changes in structure will be recognised in the final statement regarding the
way in which this RAP fits into the three phases of the new RAP guidelines in
the amended Agreement.
Participation:
This coordinated review brings together the individual reviews of various
members of the WQPC committees, so as to provide a wide range of expertise in
reviewing the various technical details of the RAP.
Reviews (attached) were received from the following:
Surveillance Work Group M.E.Moriarity U.S. FWS
C.J. Edwards IJC
Point Source Coordinators G. Sherbin Can. DOE
Non Point Source Subcommittee G. Wall Can. Agr.
Sediment Subcommittee D. Persaud Ont. MOE
Science Advisory Board H. Regier et al
Great Lakes Fishery Commission C. Fetterolf GLFC
This co-ordinated review was writen by A.R. Le Feuvre Can. DOE
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STAGE II: NHEN REMEDIAL AND REGULATORY MEASURES ARE SELECTED UNDER
SUBPARAGRAPHS 4(a)(111), (1v), (v), and (v1>.
4. Are the Identified remedial actions sufficient to resolve the problems and
restore beneficial uses?
The identified remedial actions are adequate with regard to the Improved
NWTP but the natural process of sedimentation may, or may not, resolve the
problem of contaminated sediment. This aspect of the RAP is extremely
speculative. No data are provided regarding the "natural" rate of
sedimentation. How long will it take to bury the contaminated sediment under
enough "clean" sediment to eliminate the release of methylmercury into the
food chain? Biota from lower on the food chain than the fish will give an
earlier indication of the effectiveness of this process.
5. Are these actions consistent with the stated goals of the RAP?
Yes! The remedial actions are consistent with the stated goals of the RAP
but are they adequate from an ecosystem perspective? The two primary actions
were the stopping of the mercury source to the WWTP and the upgrading of the
NHTPs to a new secondary system with phosphorus and nitrogen removal. The
separation of the storm and sanitary sewer systems further reduced the load of
contaminants reaching Deer Lake. These actions clearly support the stated
goals of the RAP.
6. Hhat beneficial uses, 1f any, will not be restored? Does the RAP Indicate
why?
The RAP refers to only fishing, by man and other wildlife, as the impacted
use of the lake. The highly eutrophic condition will be remedied to some
degree by the reduced phosphorus load, but the RAP gives no indication if
"swimable" conditions will result.
7. Is the Identified schedule for Implementation of the remedial actions
reasonable?
Yes! In fact, both of the required remedial actions, 1e. eliminating the
major source of mercury and removing phosphorus and nitrogen at a new WWTP,
already have been Implemented. The schedule for the natural burying of
contaminated sediment, however, is very indefinite and speculative.
8. Have the jurisdictions and agencies responsible for Implementing and
regulating remedial measures been Identified?
Yes! A court decree mandated the elimination of the major mercury source
and the State required the upgrading of the NWTPs to remove phosphorus and
nitrogen.
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NOTE
The question of "other" problems 1n the Area of Concern, beside the
primary concern for which the AOC was listed, must be addressed 1n a generic
sense. In this case the problem was mercury contaminated fish. The RAP 1s a
response to this problem. Are we justified 1n critiquing the RAP for "other"
problems? Should the "other" problems be considered as the basis for a new AOC
on Deer Lake?
On these questions there was a wide divergence of opinion among the
reviewers. This coordinated review attempts to Incorporate most of the
comments from the reviewers without regard to the appropriateness of
considering the "other" problems.
STAGE I: WHEN A DEFINITION OF THE PROBLEM HAS BEEN COMPLETED UNDER
SUBPARAGRAPHS 4(a)(1) and (11).
1. Are the goals and objectives clear and concise?
The stated goals of the RAP are clear and precise but may be rather
simplistic. The specific goal of restoring a "safe to eat" sport fishery is
laudable but does not adopt an ecosystem approach to the Area of Concern.
Other forms of wildlife, such as the bald eagles, have been Impacted. A pair
of bald eagles nesting on Deer Lake failed to fledge a single eaglet 1n 15
nesting attempts during the period of 1964 - 1980. Eagle feathers collected
from the ground beneath the nest Indicated quite elevated mercury
concentrations. Eutrophlcation also 1s an obvious problem and other heavy
metals are of concern.
2. Are the goals and objectives consistent with the specific goals of the
1978 GLHOA?
The general and specific objectives of the GLWQA are not addressed
directly but the objective of "flshable" clearly Is consistent. Additional
goals should have been stated such as a target concentration for phosphorus
and contaminated sediments.
3. Is the Information base sufficient to adequately define the problems
and Identify the causes?
There 1s good Information on contaminants in fish flesh and the
character of the WWTP effluent and sludge 1s quantified. Other point sources
were noted but not quantified. Non-point sources such as the mine tailings
runoff and ice load were not quantified.
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9. Have studies necessary to complete the RAP been Identified and have
schedules for their completion been established?
No new studies have been required, but the natural burial of contaminated
sediments can be considered a large scale study because the expected results
are very speculative.
10. Is the proposed Monitoring and surveillance program sufficient to
document Improvements as a result of the remedial action Implemented and
confirm the restoration of beneficial uses?
Yes! The ten year monitoring program mandated 1n the Court Judgment will
monitor the levels of mercury In the fish 1n the lake, and when the levels
drop to the 0.5 mg/kg limit, the fish consumption advisory will be removed.
This will signal the achievement of the primary objective of the RAP. However,
some reviewers recommended that MDNR monitor also the reproductive success of
the bald eagles nesting on Deer Lake. Also, the RAP does not Indicate how the
eutrophlcation problem will be monitored, 1n response to the reduction 1n
phosphorus and nitrogen loading to the lake.
11. Has there been adequate and appropriate consultation with the public?
Two public meetings were held but there seemed to be minimal public I
interest, especially at the second meeting. The RAP does not indicate how much
effort was put into the development of public interest. If this lake is such
an important sport fishery, it is surprising that public interest was so small.
STAGE III: WHEN MONITORING INDICATES THAT BENEFICIAL USES HAVE BEEN RESTORED m
UNDER SUBPARAGRAPHS 4(a)(v11) and (viii). J
Stage III requirements depend upon monitoring data generated from the RAP.
SUMMARY OF PROS AND CONS
Pros: |
The primary Goal 1s clear cut and the remedial measures required to
address it already are 1n place. The monitoring program should be able to
measure the lakes response to the remedial measures.
Cons:
A major weakness of the RAP 1s the speculative nature of the expected
results. Another is the narrowness of the Goals that leaves many questions
unaddressed. Hhat about uses other than fishing? What is the impact, if any,
on the nearshore of Lake Superior 1n the vicinity of the mouth of Carp River?
What about metals other than mercury? What about the effectiveness of nutrient
removal on the trophic status of Deer Lake? What about the reproductive
success of the bald eagles?
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OVERALL RATING (NHhln the Six WQB Categories)
N1th regard to the primary objective of the RAP (the fish consumption
advisory due to mercury contamination), 1t 1s 1n category 5, 1e.
Causative factors known, RAP developed , and all remedial measures
Identified 1n the plan have been Implemented. Several of the reviewers,
however, suggested that there were a number of problems 1n the Area of
Concern (AOC) which were not addressed 1n the RAP. For these concerns (I.e.
other metals, eutrophlcatlon) the RAP 1s a category 1 or 2 1e., Causative
factors are unknown and there, 1s or 1s not, an Investigative program
underway to Identify causes.
POSITION HITHIN NEH THREE STAGE PROTOCOL
This RAP 1s at stage 2 with regard to the problem of the mercury
contaminated fish, but It Is only at stage 1 with regard to other problems
as noted above.
RECOMMENDATIONS
The RAP team 1s to be congratulated for a very clear statement on the
remediation of the mercury contaminated fish problem. The remaining
questions, of concern to various reviewers, need to be addressed in a
similar fashion.
The HQB should provide clear instruction on whether to include problems, not
part of the original designation as an AOC, in the review of RAPs.
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TAKE
United States Department of the Interior 8Ea8'
FISH AND WILDLIFE SERVICE
FEDERAL BUILDING. FORT SMELLING
TWIN CITIES. MINNESOTA 55111
MAR 1 1 1988
Dr. E. T. Wagner
Chairman, Surveillance Work Group
International Joint Commission
P.O. Box 32869
Detroit, Michigan 48232-2869
Dear Dr. Wagner:
We provide these comments, as requested, through our participation on the
Surveillance Work Group. The Remedial Action Plan (Plan) for the Deer Lake
Area of Concern, was reviewed using the three stages of the review process in
the 1987 Amendments to the Great Lakes Water Quality Agreement, Annex 2,
4(d)(i)-(iii). We have determined that the Plan only partially satisfies Stage
1 of the review: Adequacy of Problem Definition. Further work is needed on
the description of impaired uses for completion of Stage 1. The Plan fails to
fully satisfy Stage 2: Identification of Remedial and Regulatory Measures; and
Stage 3: Restoration of Beneficial Uses. Although some remedial actions have
taken place, the major remedial action is not detailed enough to enable an
evaluation of its potential effectiveness. Pursuant to the review process, we
do not concur with the Category 4 designation made in the Plan for Deer Lake.
This category indicates that causative factors are known and a remedial action
plan has been developed; however, remedial measures are not fully implemented.
The Plan considers only mercury sources, and it does not fully identify
impaired uses within the Area of Concern. Specific problem areas with the Plan
are discussed as follows:
1. The Plan does not specify the goals and objectives related to fish and
wildlife by which remedial actions will be designed, and monitored over
time. The Plan refers to both the Food and Drug Administration's 1 part
per million (ppm)-wet weight mercury level in fish fillets, and the
Michigan Department of Public Health's 0.5 ppm-wet weight mercury level,
used to designate a fish consumption advisory. The latter action level
is the sole criterion chosen to evaluate the Plan. The Federal criterion
is at best a human health criterion, based on national exposures from
average national fish consumption with little or no relationship to the
health or well-being of the other portions of the environment. The
Michigan action level is similarly based on human health considerations,
therefore, neither criteria should be the sole criteria used to evaluate
the effectiveness of the proposed remedial actions. Neither criteria
necessarily satisfies the ecosystem approach required by the 1978 Great
Lakes Water Quality Agreement between the United States and Canada.
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Dr. E. T. Wagner 2
For all contaminants of concern, the Plan needs to Identify the specific
numerical criteria for water, sediment and biota which will insure
protection of ecosystem health. The Plan clearly illustrates the need for
criteria on mercury. The Plan also presents sufficient data to warrant
environmentally-based criteria for copper, chromium and nickel. Other
heavy metals may also need to be considered. Criteria for mercury and
other contaminants of concern should take into consideration the combined
effects with other contaminants. Criteria for all contaminants of concern
need to be developed with the intent to protect fish and wildlife via
direct exposure, as well as food chain accumulation. These criteria are
essential prerequisites to the development of remedial actions regardless
of whether the action is implemented under Federal, State or local
statutes or authority. These criteria will establish the framework from
which to determine the extent of remedial actions. In the absence of
these criteria, the full extent of impaired use identification cannot be
determined nor can the effectiveness of remedial actions be evaluated.
2. The Plan does not recognize the full range of impaired uses potentially
occurring in the Area of Concern. The only impaired use specified in the
Plan is the fish consumption advisory issued for mercury contamination.
However, the Plan does provide other data that strongly suggests or
confirms impaired uses in addition to fish consumption, as defined in the
1987 Amendments to the Great Lakes Water Quality Agreement, Annex 2(l)(c).
This includes mercury residue data for waterfowl, turtles, raptors and
wading birds that suggest degradation of fish and wildlife populations
(See (l)(c)(iii) of Annex 2), and bird and animal deformities or
reproduction problems (l)(c)(v). The above is supported by long-term
surveys indicating that a pair of adult bald eagles nesting on Deer Lake
failed to fledge a single eaglet in 15 nesting attempts during the period
of 1964-1980. Additionally, eagle feathers collected from the ground
beneath the nest Indicated quite elevated mercury concentrations.
The Plan provides sufficient evidence for conventional pollutants
discharged from the Ishpeming Wastewater Treatment Plants and historical
water quality data to include eutrophication and undesirable algae
(l)(c)(viii), and degradation of aesthetics (l)(c)(xi) as impaired uses.
Based on known discharges of heavy metals and conventional pollutants to
the Area of Concern, use impairments from degradation of benthos
(l)(c)(vi), degradation of phytoplankton and zooplankton populations
(l)(c)(xiii), and loss of fish and wildlife habitat (l)(c)(xiv) are
strongly suspected.
Thus, the Plan needs to outline a program to collect and analyze benthos,
fish and wildlife in order to more fully document the presence and degree
of use impairment. Benthic invertebrates, forage and sport fish (remnant
or newly stocked), juvenile and adult waterfowl, loons, osprey, bald
eagles, mink, muskrat, otter, and turtles are species suitable for
evaluation relative to human consumption, foodchains and wildlife health.
These evaluations should continue throughout the life of the Plan to
monitor restoration of impaired uses identified.
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Dr. E. T. Wagner 3
The Plan estimates that 4-8 kilograms of mercury per year enter Lake
Superior from the Area of Concern. While the Plan may correctly assume
this input is only a small fraction of the overall mercury loading to the
lake, it may be a significant loading to the lake in the vicinity of
Marquette, near the mouth of the Carp River. The Plan should discuss, to
the degree possible, the impacts of this mercury loading and other
contaminants of concern, to the nearshore ecosystem of Lake Superior in
the vicinity of the Carp River mouth. Important resource areas that exist
in the nearshore area such as existing or historic fish spawning areas,
waterfowl staging areas and colonial bird breeding sites should be
outlined. In addition, the Plan should discuss whether or not residue
data from fish sampled in the nearshore areas have contributed to the
issued consumption advisory for lake trout from Lake Superior. Other
examples of potential impaired use evaluations in the nearshore waters
should be discussed in the Plan.
3. The Plan lacks a sufficiently detailed description of the theory and
development of the proposed remedial action for inplace sediment
contamination. Such a detailed description is necessary to estimate the
potential effectiveness of the remedial action. The stated Intent of the
proposed remedial action is to minimize the transformation of inorganic
mercury to methylmercury via a plan of natural sediment restoration. The
Plan calls for the 10-year stabilization of water levels on Deer Lake at
near maximum to minimize disturbance of contaminated sediments. This is
expected to keep the more deeply buried, contaminated sediments stable and
in an anoxic condition. With time, the contaminated sediments will become
buried by clean sediments and maintained under anoxic conditions.
The Flan needs to further discuss the transformation process of Inorganic
mercury to organomercury forms, under what conditions it occurs and the
anticipated future potential for transformation in the Area of Concern.
The Plan does not indicate that biological methylation of mercury occurs
in anaerobic, as well as aerobic situations by sediment microorganisms.
While the rates of these two methylation processes may be expected to
differ under varying aquatic situations, the anaerobic methylation process
needs further elaboration in the Plan. Also worthy of discussion is the
interaction of humlc materials with mercury in sediments as it relates to
its effect on the methylation of mercury by microorganisms and benthos.
While methylmercury may be the most bioaccumulative form, other
organomercury compounds such as dimethyl and phenylmercury need to be
discussed in the Plan relative to the transformation processes occurring
in sediments and the impacts to aquatic resources.
The Plan needs to evaluate the sediment disturbance potential of natural
events occurring on the lake. These events include spring/fall turnover
and storm events (wind, precipitation, an/or floods). Factors influencing
the sediment disturbance potential of these events Include the depth
profile of the lake and the physical attributes of sediments (density,
grain size distribution, etc.). This includes current sediment deposits
and those expected to occur in the future.
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Dr. E. T. Wagner 4
The Plan relies on burial of existing contaminated sediments by clean
sediments to minimize the exposure of biota. However, the Plan does not
provide historical, present-day or anticipated future sedimentation rates
to evaluate whether significant burial will occur within this time frame.
Considering the recent improvements to the Ishpeming Wastewater Treatment
Plant and the separation of Combined Sewer Overflows, it is anticipated
that future sedimentation rates will be lower than historical rates.
Historical rates likely were accelerated by the eutrophication resulting
from conventional pollutants originating from the City of Ishpeming.
Therefore, future sedimentation may be insufficient to show an improvement
in impaired uses within the 10-year monitoring program.
Low density, flocculent sediments will not provide much burial of
contaminated sediments and disturbance factors discussed above may further
reduce its effectiveness. Therefore, information on the future rate and
type of sediment anticipated is in need of elaboration. The Plan has no
discussion of continued water level stabilization after 10 years, or other
methodology, should the proposed action prove ineffective. Additionally,
the Plan does not discuss the need for remedial actions in Carp Creek or
the Carp River.
The Plan indicates that the contaminated fish in Deer Lake were killed
during the period 1984-1987, but not removed. The Plan suggests that the
mass of mercury in these dead fish is an insignificant source compared to
the magnitude of existing contamination. This statement needs
documentation. While this input may be small compared to the inorganic
mercury in the sediments, the mercury in the fish flesh may be a larger
portion of the organomercury compounds in the Area of Concern.
The stocking of Deer Lake in 1987 with stunted adult yellow perch and
walleye fry may not allow for easy interpretation of results from the
proposed fish monitoring program. Changes in contaminant residues in fish
tissue may be masked by variable growth rates during the 10-year
monitoring period. Perhaps more appropriate would be to track residues
over time for a single age cohort as well as a few key forage organisms.
4. The Plan indicates that the Ishpeming Wastewater Treatment Plant will be
monitored for mercury over a 10-year period for influent, digestor
effluent, sludge, and final effluent. The Plan also indicates that there
have been no effluent limitations placed on heavy metals in the August
1987 National Pollutant Discharge Elimination System permit for the
wastewater facility. This was based on initial monitoring of the new
facility's effluent in December 1986-January 1987. Based on the
historical discharge of conventional pollutants and several heavy metals
from the old wastewater facilities, and the elevated concentration of
mercury and copper in the new facility's digestor sludge, we believe it
may be necessary to amend the permit to Include limits on certain heavy
metals. The source of the elevated concentrations of certain heavy metals
in the digestor sludge should be further investigated. We suggest that
sediment/sludge deposits be collected from within the Ishpeming sewer
collector system and analyzed to see if this may be the source of heavy
metals to the digestor sludge. If the results indicate the
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Dr. E. T. Wagner 5
sediment/sludge deposits are a source, remedial actions should be
developed and Identified in the Plan to eliminate these deposits from the
sewer system. If the source cannot be identified by this or other
methods, then we recommend the permit be amended to include effluent
limitations for those heavy metals found to be elevated in the digester
sludge. This will be particularly important if the elevated
concentrations of metals in the sludge persist through the end of the
10-year monitoring period.
The Plan indicates the existence of other point source dischargers in the
Area of Concern which are not believed to be significant sources of
contaminants. The Plan should inventory these point source dischargers,
and indicate permitted discharge limitations and reveal monitoring and
compliance records for these discharges.
5. As part of the Consent Agreement with the Cleveland-Cliffs Iron Company,
the newly stocked fishery in Deer Lake will be monitored for 10 years.
The Plan anticipates that the existing fish consumption advisory, the sole
designated impaired use in the Area of Concern, will be lifted and
impaired uses will eventually be restored. The Plan does not indicate
that restoration will be complete within 10 years, but only that
restoration will have begun. We believe, based on the inadequate
Identification of impaired uses and adoption of clean-up criteria, that
the monitoring plan is inadequate to meet Stage 3 of the review protocol.
In addition, we doubt the adequacy of the "natural restoration" remedial
action proposed in the Plan to affect its desired goal of minimizing
methylation of mercury in inplace sediments within a reasonable period of
time. Therefore, we believe the Plan is too optimistic in its goal of
achieving partial or complete restoration within the 10-year monitoring
period. The Plan does not indicate whether the monitoring program will
continue after 10 years, or which agency will be responsible for
continuing the monitoring, should restoration not be complete. The Plan
needs to fully develop a monitoring plan to follow restoration of all
impaired uses utilizing criteria protecting fish and wildlife resources,
as well as human health. The Plan needs to obtain commitments from the
appropriate agencies to continue the monitoring until restoration of
impaired uses is complete.
6. The Appendices to the Plan should contain two documents upon which the
Plan derives considerable data. First, the Appendices should contain the
1981 Environmental Research Services, Inc. report which initially
documented the mercury contamination of resources in the Area of Concern.
Second, the Appendices should contain the 1983 Assessment of the mercury
problem in Deer Lake by Dr. F.M. D'ltri. This report is apparently relied.
upon heavily in the Plan for development and justification of the proposed.
remedial action for inplace contaminated sediments, and needs to be
readily available for reference in the Appendices.
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Dr. E. T. Wagner 6
In summary, Che Plan has two major shortcomings regarding Stage 1 of the review
protocol* First, the Plan falls to evaluate Impaired uses to species other
than fish. Other potentially Impaired uses need to be evaluated, and If
present, monitored throughout the implementation of the Plan until restoration
is complete. Secondly, the Plan does not present environmentally-based goals
and criteria for mercury and other contaminants in water, sediment, and biota.
Without these criteria, neither the extent of contamination nor the
effectiveness of proposed remedial actions can be objectively evaluated. An
expanded evaluation of impaired uses and the adoption of criteria to protect
fish and wildlife via direct exposure and food chain accumulation should
eventually satisfy Stage 1 of the review protocol.
Additional information needs to be presented to support the technical merit of
the proposed "natural restoration" remedial action. At this time, we believe
that the proposed remedial action, and that currently being implemented, will
not restore the full range of impaired uses within a reasonable period of time.
For these reasons, we do not believe the present Plan satisfies Stages 2 and 3
of the review protocol.
We appreciate the opportunity to provide comments on this important document,
and would be glad to discuss any of the above comments with you. Please feel
free to contact Dave Best at our East Lansing Field Office, 517/337-6650.
Sincerely,
Acting
Regional Director
cc: John Hartig, IJC, Windsor
John Gannon, NFC-Great Lakes, Ann Arbor
East Lansing Field Office
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INTERNATIONAL JOINT COMMISSION
GREAT LAKES WATER QUALITY BOARD
Surveillance Work Group
100 Ouellette Avenue, 8th Floor
Windsor, Ontario, Canada N9A 6T3
or P.O. Box 32869, Detroit, Michigan 48232-2869
File #. 2610
January 19, 1988
Mr. E. T. Wagner
Chairman, IOC Surveillance Work Group
Regional Director, IWD, Ont. Region
Environment Canada
P.O. Box 5050
Burlington, ON
L7R 4A6
Dear Tony:
I have reviewed the Deer Lake RAP and my comments are attached. Perhaps I
was fortunate in having seen the extremes in production emanating from the RAP
process. The Deer Lake RAP, while quite recursive, represents an
document which neatly explains the problem, defines the sources,
corrective actions taken to date, and provides a clear cut
monitoring scheme for measuring success of the remediation. This
careful editing could and should be used as the ideal prototype
and comparing all RAPs.
used as the model to be
In contrast, the Torch Lake
avoided by the jurisdictions.
excellent
outlines the
and logical
report, with
for preparing
RAP could and should be
Sincerely yours,
C. J. Edwards
CJErhk
ATTACHMENTS
cc: J. H. Hartlg
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January 19, 1988
REVIEW OF DEER LAKE REMEDIAL ACTION PLAN
by
C. J. Edwards
IJC Regional Office, Hlndsor, Ontario
The stated goals of the Deer Lake Remedial Action Plan are to assemble and
summarize all existing data, Identify Impaired designated uses, sources of the
problems and data gaps and propose alternatives to restore Impaired designated
uses and resolve Identified problems. The RAP admirably achieves the stated
goals and declares the Areas of Concern a category (4) four.
High Incidence of mercury In fish required a consumptive warning for Deer
Lake, Deer and Carp Creeks. Removal of these warnings 1s the stated goal of
the RAP. This condition was exacerbated by high loadings of nutrients
resulting 1n hypol1mn1a anoxia 1n summer and winter.
The source of mercury was Identified and corrective action taken through
legal action resulting 1n a consent decree. The source of nutrients has been
addressed by construction of a new sewage plant with 2° treatment and
phosphorus and nitrogen removal. The lake was drained and restocked with
uncontamlnated fish and water level functions will be minimized through
controlled releases.
The RAP recognizes that the contaminated sediments of the lake will likely
contribute to body burden levels 1n the restocked fishery but, with the active
direct sources eliminated, will rely on natural forces to gradually eliminate
this as a problem. The 10 year monitoring program proposed will adequately
assess the efficacy of this hypothesis.
This Is an excellent RAP and the MDNR and the RAP coordinator are to be
commended on a job well done. The only suggestion I can offer for
Improvement, would be to monitor the nearby eagle nest(s) for successful
hatching/fledging. A positive result from eagle reproduction combined with
decllng trends 1n fish body burdens would seemingly provide the acid test for
a successful rehabilitation program.
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I*
Environment
Canada
Environmental
Protection
Enwomement
Canada
Protection de
renvirormement
25 St. Clalr Avenue East
7th Floor
Toronto, Ontario
M4T 1M2
Telephone: (416) 973-5840
OUMt
1165-36/C71-10
February 22, 1988
Dr. A.R. LeFeuvre
Water Quality Programs Committee
Great Lakes Water Quality Board
International Joint Commission
c/o NWRI
867 Lakeshore Road
P.O. Box 5050
Burlington, Ontario
L7R 4A6
D^^Sir: ^Q
Re: Review of Deer Lake RAP
Attached is a review of the above RAP for all stages of the RAP
review protocol. In general the RAP provides a good problem definition
and identification of sources. Some further studies may be needed to
reinforce Stage 2 discussions relating to alternative remedial measures
and in the outline of surveillance and monitoring programs.
Simularly, Stage 3 restoration will require some monitoring and
surveillance to confirm restoration. Aside from some data requirements
and the need to clarify some assumptions, the RAP appears to meet the
protocols.
Yours truly,
IO/kp-0053
attached
n cuoei locoiMnictnngy
* an imoe contwvMon
ccMM'Spcrcurt'ccrtwa ctMowcanMA^Spourcwv
posi-can>un*< Mm
G. Sherbin
Manager
Pollution Abatement Division
Environmental Protection
Ontario Region
Conservation & Protection
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DEER LAKE RAP - COMMENTS
1. The Identification of point and diffuse sources appears adequate.
The RAP appears to clearly demonstrate that the Ishpeming WWTP and
combined storm sewer overflows are the primary sources of
contamination to Deer Lake. Remedial measures and beneficial .uses
associated with restoration are adequately discussed. Sources
requiring further Investigation so as to confirm or refute
assumptions contained in the RAP Include run-off from Ropes'
Goldmine tailings and run-off of meltwater from ice and snow above
the tailings. Sampling of run-off of meltwater from the tailings
and in meltwaters in the watershed should be included in the 10
year monitoring program.
2. Biological studies will be needed to ensure that earlier
assumptions are correct in guaging the progress of natural
restoration and reducing the bioavailability of mercury in
sediments through sedimentation of the lake. Benthic organisms
other than fish should be studies.
3. Since remediation is to be achieved through .natural restoration
(burial of contaminated sediment by new and less contaminated
sediments) some indication should be given as to the existing
sediment loading rate to Deer Lake, as well as the future loading
through the restoration phase. Some consideration should be given
to augmenting the expected sediment load with imported material if
the loading is seen to be inadequate.
4. Suspended sediment should be monitored at the mouth of Carp Creek,
before the spillway at the dam and in the Ropes' Goldmine area.
5. The impairment to the fishery has been documented and monitoring is
expected throughout the restoration phase. Wildlife and waterfowl
studies should also be maintained to ensure effectiveness of
remedial actions.
6. Although the Ishpeming WWTP is considered to be the major point
source discharge to Deer Lake the statement is made that other
point source dischargers in the area are not believed to
significantly impact the AOC (page 104). What are these other
point source discharges. It is also pointed out on page 111 that
the Ishpeming WWTP may be receiving mercury from sources that are
undocumented. Restoration would be enhanced if potential sources
were identified and surveyed.
7. What are the loadings from the Ishpening WWTP to Carp Creek (daily
average and annually)? Since natural restoration of the lake is
dependent on an optimum flow and sediment load, what will the
loadings from the Ishpeming WWTP be during this period.
8. What are the loadings of contaminants from the secondary sources to
Deer Lake (tailings and run-off from ice and snow)? Existing
calculations are speculative.
9. Is any downstream work contemplated during the restoration phase to
ensure that there will continue to be a minimum impact on the Lake
Superior ecosystem?
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Water Quality Programe Committee
Co-ordinated Review of the
Remedial Action Plan
For Dear Lake, Michigan
1. The goals and objectives are clear and concise.
2. The goals and objectives are consistent with the specific goals of the
1978 Agreement.
3. The information base appears sufficient to define the problems and
causes.
4. It remains unclear if the proposed remedial action will resolve the
problem. There appears to be some uncertainty with respect to mercury
releaae from the in place sediments. It remains to ba seen if 1)
natural sedimentation rates will bury the contaminated sediments or 2)
the maintenance of higher water levels in the lake will reduce mercury
contamination from in place pollutants.
5. Actions proposed are consistent with the RAP goals.
6. Water based activities (recreational) that are affected by the algae
blooms will not be restored.
7. RAP studies have been initiated and completed.
8. Implementation schedule for remedial actions appear appropiate.
9. Implementing and regulatory agencies have been identified.
10. It appears that resources have been committed to implement the work
plan.
11. A monitoring and surveillance program has been proposed that should
track progress of tha implementation plan.
12. Public consultation has been minimal.
general Comments
The remedial action plan reliea heavily upon natural procesess of
sedimentation & high water levels to keep in place contaminants out of
the water column. No data are given on sedimentation rates that would
improve confidence in the approach. Further, little evidence it
presented in terms of a feasibility study or model simulation that would
suggest that the higher water levels will promote the desired oxygen
status to keep the mercury In place.
Gregory J. Wall, Ph D.
Land Resource Research Institute
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Ontano
/'/'AC t^
Dr. A. R. Le Feuvre
Water Quality Programs Committee
International Joint Commission
100 Ouellette Ave., 8th Floor
Windsor, Ontario N9A 6T3
135 Sl Cl«ir Av«nu« West
Suit* 100
Toronto. Ontario
M4V1P5
135. avenue St Gar ou**t
Bur»au 100
Toronto (Ontano)
M4V1PS
F I
Dear Dr. Le Feuvre:
Re: Review of DEER LAKE RAP
Attached are comments from the IJC sediment subcommittee on
the above RAP. According to the IJC's RAP Review Protocol, some
deficiencies exitst in the stage 2 portion of the document
relating to alternative remedial measures as well as in the
discussion of surveillance and monitoring programs. In general,
additional data (noted in attached comments) will be required to
verify some of the assumptions being made in the RAP document.
If you have any questions regarding the comments, please give
me a call.
0-61
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DEER LAKE RAP - COMMENTS
1. The identification of point and diffuse sources appears adequate.
The RAP appears to clearly demonstrate that the Ishpeming WWTP and
combined storm sewer overflows are the primary sources of
contamination to Deer Lake. Remedial measures and beneficial uses
associated with restoration are adequately discussed. Sources
requiring further investigation so as to confirm or refute
assumptions contained in the RAP include run-off from Ropes'
Goldmine tailings and run-off of meltwater from ice and snow above
the tailings. Sampling of run-off of meltwater from the tailings
and in meltwaters in the watershed should be included in the 10
year monitoring program.
2. Biological studies will be needed to ensure that earlier
assumptions are correct in guaging the progress of natural
restoration and reducing the bioavailability of mercury in
sediments through sedimentation of the lake. Benthic organisms
other than fish should be studies.
3. Since remediation is to be achieved through natural restoration
(burial of contaminated sediment by new and less contaminated
sediments) some indication should be given as to the existing
sediment loading rate to Deer Lake, as well as the future loading
through the restoration phase. Some consideration should be given
to augmenting the expected sediment load with imported material if
the loading is seen to be inadequate.
4. Suspended sediment should be monitored at the mouth of Carp Creek,
before the spillway at the dam and in the Ropes' Goldmine area.
5. The impairment to the fishery has been documented and monitoring is
expected throughout the restoration phase. Wildlife and waterfowl
studies should also be maintained to ensure effectiveness of
remedial actions.
6. Although the Ishpeming WWTP is considered to be the major point
source discharge to Deer Lake the statement is made that other
point source dischargers in the area are not believed to
significantly impact the AOC (page 104). What are these other
point source discharges. It is also pointed out on page 111 that
the Ishpeming WWTP may be receiving mercury from sources that are
undocumented. Restoration would be enhanced if potential sources
were identified and surveyed.
7. What are the loadings from the Ishpening WWTP to Carp Creek (daily
average and annually)? Since natural restoration of the lake is
dependent on an optimum flow and sediment load, what will the
loadings from the Ishpeming WWTP be during this period.
8. What are the loadings of contaminants from the secondary sources to
Deer Lake (tailings and run-off from ice and snow)? Existing
calculations are speculative.
9. Is any downstream work contemplated during the restoration phase to
ensure that there will continue to be a minimum impact on the Lake
Superior ecosystem?
-------
REVIEW OF THE DEER LAKE RAP
Henrv Regier. Richard Frank. Timothv Allen
We will use the Dra-ft SAB Guidelines for Review of RAPs for
AOCs dated Feb. 4. 1988.
(a) Does the plan embadv an ecosvstem approach?
We have appended a list o-f references which together
explicate the "ecosvstem approach", according to Jack
Vallentyne's statement at the SAB meeting in Erie, Pa, on Feb.
24, 1988. In general the Deer Lake RAP, dated Oct. 27. 1987, is
consistent with such an ecosystem approach. The statement o-f
purpose (Section 2.4) seems to implv that the -focus o-f this RAP
was primarily technical, though it was also recognized that the
RAP process had a more comprehensive purpose. The strengths o-f
the document are greatest with respect to the natural ecology.
less with socio-economic -features and least with institutional
aspects. This is not meant to implv that the RAP is
i nsu-f -f iciently developed so that progress with its implication
should be hindered. But more attention should be directed to
socio-economic and institutional aspects during the program
reviews and revisions that will follow in -future years.
Remedial measures had already been undertaken at Deer Lake
prior to the completion of this RAP. Thus the document specifies
what was done and whv, and what is now being done to monitor the
-------
conseauences o-f remediation in order to assess its suf-ficiencv
some years -from now.
Remediation was largely imposed on Deer Lake and its various
user groups -from the outside - bv the relevant state and -federal
agencies. This aspect o-f the Deer Lake remediation program
should also be assessed so as to alert the outside agencies of
anv -future problems that may stem -from this as a cause. Is such
imposition of action likelv to be the rule in remote, resource-
based communities?
The key goal, as specified in Section 1.2.2. is to create an
uncontaminated fishery in the lake and its tributaries. This
goal statement seems a bit simplistic in that it makes no mention
of any threat of mercury contamination to Great Lakes waters.
which threat was presumably the reason why Deer Lake was added to
the list of AOCs in the first place.
(b) Have effects been adequately linked to contributing
causes and examined in terms of societal factors?
Obviously this was done to a sufficient degree of rigor to
satisfy the affected interest grouos so that the remediation
measures were undertaken. A reconsideration of the facts and
arguments as presented in the RAP convinces us that sufficient
was known to justify the actions actually undertaken.
-------
(c) Are the remedial actions adeauate to sustain the
bene-ficial uses inoe-f ini tel v?
The document makes no such claim but rather casts the
remedial actions actuallv undertaken as a practical experiment.
the outcome o-f which will be assessed in the -future. We have no
scienti-fic basis for questioning the optimism o-f the executive
agency that some degree o-f imorovement will occur. Whether or
not the improvement will be su-f-ficient to open the -fisherv (and
to demonstrate that mercury has been inactivated in the
sediments) remains to be seen.
(d) Have non-governmental responsibilities -for implementing
remedial actions been indenti-fied?
The primary polluters re. mercurv have ceased polluting and
have discharged their -future resoonsibi 1 ity bv making a pavment
to the executive agencv -for monitoring contaminantion levels in
the 1O years -following the kev remediation actions.
Relatively little in-formation is o-f-ferred with respect to
the interests and concerns o-f people in the nearbv communitv o-f
Ishpeming. Obviously the anglers on the whole were not much
concerned about contaminants. The eutrophication due to
pollution -from sewage took many years to resolve. The turnout
at the two public hearings was meager. Is there any
"environmental concern" within the community?
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(e) DC studies necessarv to comolete the RAP comorise a
balanced in-formation system o-f societal, technological and
ecological elements?
This issue was alreadv mentioned with respect to guideline
(a) above, and also addressed indirectly in (d) above. Ecosystem
husbandry can only be assured i-f there are committed and in-formed
husbandmen locally to watch and act continuously. Is this
lacking with respect to Deer Lake? I-f so. why? What can be done
to -foster local responsibility? Such questions need -further
attention with respect to Deer Lake.
(f) Is there provision -for periodic public review and
updating o-f RAPs by the jurisdictions?
Yes, but it apoears likelv that the dominant actor in this
review process will be the executive agency itsel-f (see item (e)
above).
Concluding Statements
We three reviewers were pleased with what has happened at
Deer Lake. Our comments above should not detract -from our
compliments to the people responsible for this RAP and the prior
remediative actions.
-------
I
I
The "plan" or "storv-line" is not alwavs easv to follow in
this RAP document. Something more immediately intelligible to
the nonspeci al ist could have been develooed with much o-f the
detailed data and araument added in an appendix.
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APPENDIX: ECOSYSTEM APPROACH REFERENCES
Christie. W.J.. M. Becker. J.W. Cowden. and J.R. Vallentyne.
1986. Managing the Great Lakes Basin as a home. J. Great
Lakes Res. 12:2-17.
Francis. G.R.. J.J. Magnuson. H.A. Reqier, and D.R. Talhelm.
1979. Rehabilitating Great Lakes ecosvstems. Great Lakes
Fish. Comm. Tech. Rep. No. 37. 99 p.
Great Lakes Research Advisorv Board. 1978. The ecosystem
approach: scope and implications o-f an ecosystem approach
to transboundary problems in the Great Lakes Basin. Great
Lakes Reaional 0-f-fice, Int. Joint Comm. , Windsor, Ont. ix -
47 p.
Lee, B.J., H.A. Regier, and D.J. Rapport. 1982. Ten ecosystem
approaches to the planning and management o-f the Great
Lakes. J. Great Lakes Res. B:5O5-519.
Vallentyne, J.R.f and A.L. Hamilton. 1987. Managing human uses
and abuses o-f aquatic resources in the Canadian ecosystem.
p. 513-533. In M.C. Healey and R.R. Wallace Ced.3
Canadian aquatic resources. Can. Bull. Fish. Aquat. Sci.
215.
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I
IJ.C
R.O.WINDo.-;
APR 2 01988
Dir
Sacty WQB.
Secty SA8.
ESTABLISHED BY CONVENT.ON BETWEEN CANADA AND THE UNITED STATES TO IMPROVE AND PERPETUATE F.SJHERY RESOURCES
April 19, 1988 ""
Mr. M. P. Bratzel, Jr., Secretary
Water Quality Board
Great Lakes Regional Office
International Joint Commission
100 Oullette Avenue
Windsor, Ontario, Canada N9A 6T3
Dear Marty:
Please advise the International Joint Commission's Water Quality Board that
the Great Takps Fishery Commission's Habitat Advisory Board (HAB) noted, at its 13
April meeting, the excellent reviews of the remedial action plans (RAPs) for the
lower Green Bay, the River Raisin, and the Deer Lake areas of concern by the U.S.
Fish and Wildlife Service. The Board also considered the comments of the Ontario
Ministry of Natural Resources made through HAB member, Dr. Douglas Dodge, and noted
that GLFC Commissioner Regier was a member of the Deer Late RAP review team for the
IJC/Science Advisory Board. The Habitat Advisory Board will notify the GLFC that
there was adequate review by fishery interests of the Lower Green Bay, River
Raisin, and Deer late RAPs. The Board awaits the judgement of the Water Quality
Board on the overall adequacy of the RAPs as blueprints and schedules for resolving
the problems of the areas of concern.
Further, the HAB members have initiated a survey to assess the adequacy of the
fishery involvement with the RAP process. Preliminary results suggest that there
has been extremely variable involvement to date. Perhaps the more in-depth
responses expected later this month from our Late Committee liaisons will be more
encouraging to report to the Fishery Commission.
The Habitat Advisory Board now has a team in place to review the RAPs, but we
hope that the Water Quality Board can release them in a more steady flow rather
than in batches of seven. The team will use the excellent reviews by the Fish and
Wildlife Service as an example, and encourages other reviewers to do the same.
It is clear from the plans reviewed to date that toxics should be treated as
an ecosystem problem, rather than simply a water quality problem. The Habitat
Advisory Board encourages the Water Quality Board to consider solutions to the
Page 1 of 2
1451 Green Road Ann Arbor, Michigan 48105-2898 Telephone (313) 662-3209 / FTS-378-2077
-------
Mr. M.P. Bratzel, Jr., Secretary
Page 2
April 19, 1988
toxics problems which will ensure that abnormalities due to food chain accumu-
lations do not occur in aquatic birds and animals, and that fish from the Great
lakes, including the areas of concern, can be consumed confidently by fishermen and
the general public without reference to public health advisories.
If there are ways the HAB can work cooperatively with the WQB toward our
shared objectives and goals, please let HAB Co-Chairmen Bill Pearce (NYSDEC) and
Doug Dodge (CMNR), or me know.
Sincerely,
Carlos M. Fetterolf, Jr.
Executive Secretary
cc: HAB members
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May 25, 1988
WATER QUALITY PROGRAMS COMMITTEE
COORDINATED REVIEW
of the
REMEDIAL ACTION PLAN
for
MUSKEGON LAKE, MICHIGAN
Preface:
This Remedial Action Plan (RAP) was prepared under the guidelines
prescribed by the Water Quality Board (WQB), which is consistent with Annex 2
(Section 4) of the 1987 Agreement. This review assesses the adequacy of the
Muskegon Lake RAP against the original Water Quality Board guidelines. These
guidelines are structured according to the new three stage review protocol,
for the purpose of this review.
Participation:
This summary brings together the individual reviews of various members of
WQB committees, the Science Advisory Board, and the Great Lakes Fishery
Commission, so as to provide a wide range of expertise in reviewing the
various technical details of the RAP. Reviews (attached) were received from
the following:
Surveillance Work Group
Point Source Subcommittee
Nonpoint Source Subcommittee
Sediment Subcommittee
Science Advisory Board
R. Hess
M.E. Mori arty, U.S. FWS
T. Tseng
V. Saulys
G. Wall
D. Persaud
R. J. Allan
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FROM ENi'IPONMENTCfiNflDO 3.27.1988 9:47 P.
-2-
STAGE 1: WEEN A DEFINITION OF TUB PROBLEM HAS BEEN COMPLETED UNDER
SUBPARAGRAPHS 4(a) (i) and (ii).
1. Are the goals and objectives clear and precise?
Chapter 8 provides a discussion on the extent to which Michigan plans-
to restore impeire-a1 usrss.
Water uses are to protected for: agriculture; navigation; industrial
water supply; public water supply at the point of water intake; warm-
water fish; other Indigenous aquaLiu life and wildlife; partial body
contact all year; and, total body contact recreation from May 1 to
October 31.
Biota and habitat goals call for Lhe restoration of localized areas
tributary to the Area of Concern to the point where they can support
a healthy, diverse benthic population.
Finally, water use and quality objectives are generally stated as the
elimination or substantial reduction of detrimental effects on
Muskegon Lake from runoff, point source discharges, atmospheric inputs
and sediment contributions from the Muskegon Lake Basin.
2. Are they consistent with the goals of the Great Lakes Water Quality
Agreement?
The approach taken by Michigan, as described in Chapter 8, would
appear to be in concert with the spirit of the general and specifl-c
gvals of the CatMtfa-U.S. Grwmt Lakes Water Quality Agreement. These
qualitative statements, however, need to be translated into quantita-
tive goals in order to demonstrate compliance to the standards and
objectives of the GLWQA.
3. IK the information base sufficient to adequately define the
problems and Identify the causes?
The authors are to be commended for their efforts in compiling the
available data in a very readible format. Nevertheless, there is a
general feeling amongst the reviewers that the information is too
qualitative in nature. The major weaknesses related to the informa-
tion base centre on the lack of detail and quantitative data and are
illustrated by the following general comments. Specific concerns are
identified in the attached reviews.
i - The basin descriptions for the Area of Concern are unclear.
It is important to clarify the boundaries of the impact area
as well as the boundaries of the source areas.
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FROM ENUIRONMENT
3.27.1983
: 48
-3-
ii - It would app*ar a* though Mona Lake la connected to the
Muskegon Lake AOC in two wayst first} facilities from outside
the drainage basin discharge to the Muskegon County Waste
Watar Management System, and, second; the discharge from the
WWMS is to both the Muskegon Lake via Mosquito Creek and Lu
Mona Lake via Black Creek.
iii - The infomration presented regarding waste generation treat-
ment, storage and disposal practices and their potential dis-
posal practices and their potential for impacts upon Muskegon
Lake appears to be Incomplete.
iv - Tile listing of known or potential sites of ground-water con-
tamination is incomplete.
v - The inability to safely consume fish, or ingest water from a
tributary does constitute a use impairment and should be
acknowledged as such (i.e. the exceedances of 1,2
dlchlorethane, vinyl chloride and mercury levels referred to
on page 29),
vi - The suggestion that atmospheric input of PCB is the most
significant source of PCB is questionable because of:
- the level of waste generation and disposal activities
in the Muskegon River Basin and the Muskegon Lake area;
- lack of PCB deposition data specific to Muskegon Lake;
- the presence of a bleached kraft pulp mill in the area;
- the high PCB levels at the Teledyiie Continental Motors
defunct discharge.
vii - The suggestion that atmospheric input of mercury is the most
significant is questionable because of the loadings from the
Division Street storm sewer and possible mercury loadings
from Bear Creek indicated by WMSRDC sediment Station 5 (1932).
viii - Section 5,1.1 re: Municipal and Industrial Point Sources
provides a listing of permitted dischargers without giving
details on flow, toxic parameters regulated, waste loadings,
compliance status etc.
ix - More detailed information is required to substantiate the
statement that "industrial discharges in the Muskegon Lake
area are not believed to be contributing any substantial
amounts of pollutants of concern."
x - The report currently lacks sufficient data for an adequate
assessment of the impacts associated with contaminated sedi-
ments. Presently, there is no data pertaining to benthic
tissue concentrations or existing inputs of contaminated sedi-
ments. It is strongly recommended that the authors recognize
the significance of the missing sediment data and withdraw
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FROM ENVIRONMENT CflHflDfi 3.27.1988 9:49 p. 4
-4-
their assurances concerning the "negligible" effect of con-
taminated sediments until they have sufficient supporting
data.
xi - There is concern over the validity of the comparison of
sediment data.
STAGE II: WHEN REMEDIAL AND REGULATORY MEASURES ARE SELECTED UNDER
SUBPARAGRAPHS 4(a) (ill), (iv), (v), an (vi).
4. Are the identified remedial actions sufficient to resolve the
problems and restore beneficial uses?
The Muskegon Lake RAF provides a historical record of those remedial
measures instituted since 1973. These measures, have and will
continue to have an effect on reducing pollution for this AOC.
Recommended actions for the remaining problems are suggested.
However, because the goals and objectives are qualitative in nature
it is difficult tu judge their relevancy. Furthermore, there is no
apparent commitment to the proposed actions.
In addition, it is obvious that more research is needed, particularly
regarding atmospheric deposition, contaminated sediments and polluted
groundwatar.
5. Are these actions consistent with the stated goals of the RAF?
The development of appropriate remedial actions must stem from an
organized and concise definition of problems and goals. Further re-
search is needed in some cases in order to fully define additional
remedial measures. In addition a more quantitative approach to
addressing the goals would assist in determining and evaluating the
remedial actions necessary to fully restore and delist the Muskegon
Lake AOC.
6. What beneficial uses, if any* will not be restored? Does the RAP
indicate why?
The State of Michigan appears determined to restore all uses as
outlined in Part 1 of this review. The existing remedial actions
identified will not fully accomplish this as more research is required
as described in Part 5 of this review.
7. Is Lhe identified schedule for implementation of remedial actions
reasonable?
A number of proposed actions and studies have been identified. No
implementation schedule is provided. Furthermore, the Muskegon Lake
RAP indicates a number of remedial measures that would require the
cooperation of industry. There is no statement as to the willingness
of these industries to implement the proposed measures.
.../5
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FPOH ENMJRONMENT CONODfi 5.27.1933 ?!4« P. 5
-5-
8. Hava that jurisdictions and agencies responsible for implementing
and regulating remedial measure been identified.
Agencies responsible for carrying out a number of proposed measures
are referred to. However, no commitments are provided.
9. Have studies necessary to complete the RAF been identified and have
schedules for their completion been established?
A number of studies have been proposed. No commitment or
implementation schedule is provided.
10. Have work plans and resource commitments been made?
Die recommended actions are listed as proposals and lack resource com-
mitment .
11. la the proposed monitoring and surveillance program sufficient to
document improvements as a result of the remedial actions implemented
and to confIra the restoration of beneficial uses?
Although monitoring and surveillance programs are referrenced in the
plan, the details of these activities appears to be lacking as well as
a time table for implementation and the agency(ies) responsible for
such activities. Primary responsibility is assumed to rest with the
Michigan Department of Natural Resources.
12. Has there been adequate and appropriate consultation with the
public?
Two public meetings were held but there is no explicit mention of
which interest groups or individuals might be regarded as stake-
holder**. It is not clear from the report what effect public
participation has had on the content or direction of the Plan.
STAGE III requirements await completion and implementation of the RAP
SUMMARY:
The Muskegon Lake RAP provides a historical account of the
environmental problems confronting this AOC as well as identifying or
speculating on the major sources of contamination. The documentation
clearly indicates the remedial actions implemented since 1973 and
demonstrates the positive impact these measure have and continue to
have. In fact, the authors provide evidence that the lake seems to
have recovered in many ways and is now, in some ways, an environmental
asset.
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FROM ENUIRONMENT CflNfiDfi 5.27.1988 13M4
-6-
emphasis is now roquired to resolve problems associated with
contaminated sediments, contaiminated groundwater, and atmospheric de-
position. This will require further research and study in order to
develop appropriate remedial measures. As a result, it is concluded
that Muskegon Lake AOC is in Category 2 (causative factors are unknown
and an investigation program is underway to identify causes).
Further, the Muskegon Lake RAP does not satisfy the requirement of
Stage 1 in the 1987 GLWQA (because futher study is required).
The Water Quality Board views the RAP process as iterative, where RAPs
are updated and improved based on a better understanding of the
problems and their causes and the development of new technologies to
remedy the problems. The challenge of RAPs is to make them focused
and specific enough to demonstrate progress. RAPs are intended to
identify when specific remedial actions will be taken to resolve the
problems and who is responsible for implementing those actions. If
remedial actions cannot be identified and additional studies are
needed, the RAP should identify when the studies will be initiated,
when they will be completed, and when this new information will be
used to identify remedial actions.
-------
Illinois
Department of Conservation
life and land together
LINCOLN TOWER PLAZA 524 SOUTH SECOND STREET SPRINGFIELD 62701-1787
CHICAGO OFFICE ROOM 4-300 100 WEST RANDOLPH 60601
MARK FRECH, DIRECTOR
May 12, 1988
Dr. John Hartig
International Joint Commission
100 Ouellette Avenue
8th Floor
Windsor, Ontario N9A 6T3
Dear Dr. Hartig:
Please find enclosed my comments on the Muskegon Lake
(Michigan) Remedial Action Plan on behalf of the Lake Michigan
T^sk Force. I have tried to follow the Protocol document
prepared by the Water Quality Board for stages 1 and 2.
Please contact my office should you have any questions.
Sincerely,
Richard Hess
Lake Michigan Program Manager
Illinois Dept. of Conservation
100 W. Randolph St., Suite 4-300
Chicago, Illinois 60601
312/917-3447
RHrbhs
Enclosure
CC: Ron Shimizu, Environment Canada
Robert White, IJC
Barry Lesht, Chairman, Lake Michigan
Task Force
I.J.C.
R.O. WINDSOR
MAY 171988
SectyWQSL
Secry 5*3,.
A :
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MUSKEGON LAKE REMEDIAL ACTION PLAN-REVIEW
Adequacy of Problem Definition
Major sources of pollutants have been clearly or potentially
attributed to municipal and industrial point sources, urban
stormwater discharges, combined sewer overflows, rural land runoff,
atmospheric deposition, contaminated ground water and release from
contaminated sediments.
Extensive data has been collected on water quality, sediment quality
and biota. Impaired uses of Muskegon Lake and its tributaries have
been listed and described in terms of resources/activities affected,
causes and sources.
Goals have been expressed in terms of restored uses, water quality,
biota and habitat and appear to be in concert with the general and
specific goals of the Great Lakes Water Quality Agreement.
Identification of Remedial and Regulatory Measures
Remedial measures already in place have been described in terms of
wastewater treatment and the removal and excavation of contaminated
soils and containers from both Superfund and non-Superfund sites.
Nutrification of Muskegon Lake has been assessed in terms of reductions
of total phosphorus, total nitrogen and chlorphyll-a concentrations
following the diversion of municipal and industrial discharges to the
Muskegon County Wastewater Management System in 1973. The plan also
reports that there are no known unpermitted industrial discharges
to the AOC at the present time.
Proposed remedial actions addressing impaired uses within the AOC
are identified and described for Muskegon Lake and tributaries.
Surveillance and monitoring programs to assess remedial actions are
addressed for urban stormwater runoff, contaminated groundwater and
contaminated sediments. Further studies on the impacts of stormwater
runoff and thermal loadings are recommended. The continuance of
regulatory actions under Superfund and the Michigan Environmental
Response Act to clean up contaminated groundwater sites is also
recommended. Fish contaminant monitoring of Muskegon Lake and
Bear Lake is recommended onk three to five year basis to determine
toxic contaminant trends and to update the fish consumption advisory
for Muskegon Lake. Fish contaminant monitoring of Ryerson Creek nad
Ruddiman Pond is also recommended. Airborne toxics monitoring for
PCB, chlordane and mercury is recommended for the Muskegon County
region to determine loadings and assess impacts. Additional
recommendations include termination of subsurface disposal of
industrial waste without proper treatment, connecting industries
generating processed wastewater to the Muskegon County Wastewater
Management System, and transportation of hazardous wastes to approved
disposal sites (but not in the Muskegon Lake area due to sandy .Soil
conditions).
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Although appropriate surveillance and monitoring programs are
referenced in the plan, other than adherence to state and federal
health and environmental regulations, details of surveillance and
monitoring activities appear to be lacking as well as a time table
for implementation and the agency(ies) responsible for such
activities. Primary responsibilty appears to rest with the Michigan
Department of Natural Resources.
Public input to the plan was provided through public meetings on
August 2, 1986 and in July, 1987. In addition, the plan provides
a listing of agency contacts and citizens involved in the develop-
ment of the plan.
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United States Department of the Interior
FISH AND WILDLIFE SERVICE
Federal Building, Fort Spelling
Twin Cities, Minnesota 55111
J'JN 7 1388
FWS/AE-ES
IN *cri.Y Hen* TO:
IJ.C.
H. WINDSOR
JUN 131938
Dr. E. T. Wagner
Chairman, Surveillance Work Group "'"
International Joint Commission
P.O. Box 32869 rj;«,
Detroit, Michigan 48232-2869 /r~ ~'
Dear Dr. Wagner:
We provide these comments, as requested, through our participation on
the Surveillance Work Group. The Muskegon Lake Remedial Action Plan
(Plan) was reviewed using the three stages of the review process in the
1987 Amendments to the Great Lakes Water Quality Agreement, Annex 2,
4(d)(i)-(iii). We have determined that the Plan only partially
satisfies Stage 1 of the review: Adequacy of Problem Definition.
Further work is needed on the description of impaired uses for
completion of Stage 1. The Plan fails to fully satisfy Stage 2:
Identification of Remedial and Regulatory Measures; and Stage 3:
Restoration of Beneficial Uses.
Many of the same deficiencies which we have identified in previous
reviews of the State's plans exist in this Plan. Most notably are the
lack of an ecosystem approach, time schedules, and fish and wildlife
objectives identification. The Plan is narrowly focused and conclusions
are not supported by scientific evidence. We are also concerned with
the State's intent to limit active remediation in the future.
Sediment contamination should be addressed relative to remediation
options. Capping should be investigated as a potential remediation tool
for the more contaminated deep depositional areas. International Joint
Commission objectives should be used for fish and wildlife health. The
Plan does not fully satisfy Stage 1 review requirements. Progress made
is laudable, however, it is inadequate to justify delisting the Area of
Concern.
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Dr. E. T. Wagner
We appreciate the opportunity to provide comments on this important
document, and would be glad to discuss the above comments with you.
Please feel free to contact Tim Kubiak at our East Lansing Ecological
Services Field Office 517/337-6650.
Sincerely,
Marvin E. Moriarty
Acting Regional Director
cc: "dohn Hartig, IJC, Windsor
John Gannon, NFC-Great Lakes, Ann Arbor
East Lansing Field Office
£03
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F»on ENUIRONMENT
5.26.l?Q8 13109
I ! i 11. i : y i ' . i >
1 1 AN <(. r7 1 ] (;
Tv> : G . l>lu'1 h 11.
t . Oi rum U
F t c m : T . T B c n q
Wo: Draft RAP lov MuiAegcn Lake
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l have reviewed th° sections velaturi to Pollution GOUICT. oC
this dvaft RAP find foel thai the o£f.oii i c incompi.e1. <. M t hoxmh
the clcaCt includes a lir.timj of. majoi ond minor r.^-icn -. , v h-;
Ucjsci ipt ions o i c in genoiol non-qviant i r at i vn . i disii.ii>'*. M
with the summaiy statemont r.li/:it it is unnecessary t. ^ e;'.V.inote V
pollutant leadings for sources other than, the MuSKe'ior. Iiclic
System (page 7 f\, last pora.)
Section 5.1.1 otily gives a listing of permiurod di sc-ho L qe i r
(Table 3.6) without giving details on flow, toxic p-irniv.ec.ers
regulated, waste loadings, compliance status etc. Mere devailsB
should be provided to substantiate the statement "industrial |
discharges in the Muskegon Lake area are not believed to be
contributing any substantial amounts of pollutants of concern."^
(page 53, last para.) 8
To complete "Stage 1" of this RAP, the description o£ sources ^
should be more complete and quantitative, comparisons cf
pollutant loadings should be attempted to clearly identify m
areas for additional remedial efforts.
Urban stormwater runoff, contaminated gtoundwater and m
contaminated sediments are noted as the major pollutant sources*
(page 101, 2nd para.) The recommendations proposed for these ^
major sources are essentially "studies" and "continuation of
current programs". More specific remedial measures and W
implementation schedules should be developed for "Stage 2"
of this RAP.
T. Tseng
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
GREAT LAKES NATIONAL PROGRAM OFFICE
DATE: May 20, 1988
SUBJECT: Review of Muskegon Lake Area of Concern Remedial Action ?\it\
/P~~7Z£*>>-+iv-^7^*~x^ (^
FROM: Vacys Saulys, U.S. Point Source Coordinator<^Vv<>^<^tx>^/ ^
TO: Griff Sherbin, Canadian Point Source Coordinator
My staff has reviewed the Remedial Action Plan for the Muskegon Lake Area of
Concern and have the following general and specific comments:
General Comments
The basin descriptions for the Area of Concern are unclear. It needs to be
made clear what the boundaries of the impact area are as well as the
boundaries of the source area.
Through the alteration of local hydrology due to discharges to and from the
WWMS, Mona Lake 1s connected to the Muskegon Lake AoC 1n two ways: facilities
from outside the drainage basin discharge to WWMS, and the discharge from the
WWMS is both to Muskegon Lake via Mosquito Creek, and to Mona Lake via Black
Creek.
The information presented regarding waste generation treatment, storage and
disposal practices and their potential for impacts upon Muskegon Lake is
incomplete.
Specific Comments
Figure 3.2 Muskegon River Basin
The Figure shows just a small portion of the 6,822 km^ Muskegon River drainage
basin. A figure showing the entire basin which occupies parts of nine
counties should replace this figure and be called the Muskegon Lake AoC Source
Area.
p. 16 Waste Disposal Lands
Only 6 waste sites are listed here, whereas the there is a far greater number
in Muskegon County and even more when the entire Muskegon River drainage basin
is considered:
Muskegon County . Muskegon River Drainage
CERCLIS Sites 84 151
Act 307 Sites 44 *
Underground
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000-04-'00 22:02 ID: TEL NO: 8004 FQ3
Injection Wells 18 404
RCRA ID#s 186 *
RCRA TSDS 10 *
RCRA Transporters 19 *
* Facilities 1n the drainage basin were not quantified.
This paragraph needs to be modified to more accurately reflect the large
concentration of hazardous materials and waste generation, transport and
disposal activities in both the impact Area of Concern and the source Area of
Concern,
Table 3-3
p. 15 What land use category is the Muskegon County Wastewater Management
System (12,000 acres) included in? According to the acreage figure provided"
1n this table, it could only be in the "recreational" category. Total acreage
described 1n this table is only 85,275 compared with the 6,822 km2 for the
basin on p. 7. This inconsistency needs to be reconciled.
p. 30 Change "IJC Guidelines" to "Great Lakes Water Quality Agreement
\tJLWQA) Specific Objectives".
Appendix 5.1 The Act 307 list provided is far from being a complete list of
known or potential sites of ground-water contamination. Review of the USEPA
CERCLIS list for Muskegon County reveals 32 sites which were not represented
in the portions of the ACT 307 list provided for both Muskegon Lake and White
Lake areas. Among the more notable of these sites on CERCLIS are:
o Bear Creek
o Little Bear Creek
o Muskegon County Waste Water System
o Scott Paper
and also other areas of ground-water contamination, landfills and industries.
In addition, a total of 67 other CERCLIS sites are located in the Muskegon
Lake Area of Concern Source area, the Muskegon River hydro!ogic basin. All
told, 151 CERCLIS sites are located 1n the Muskegon River drainage basin.
Table 4-2 Fish consumption advisories for exceedances of MDPH and FDA action
levels of PCBs, mercury and total chlordane in Bear Lake is not an impairment?
Exceedances of 1,2 dlchloroethane, vinyl chloride and mercury levels (p. 29)
aoove Kuie a/U) buiaenne levels oasea upon cancer nsK ana numan nre-cycie
concentrations does not constitute a use impairment? The inability to safely
consume fish, or ingest water from a tributary does indeed constitute a use
impairment ana snoufa oe acKnowieagea as sucn.
Table 4-7 The accumulated knowledge of sediment chemistry has shown sediment
quality to be very patchy both horizontally and vertically: adjacent samples
often have very different chemical and physical characteristics. Comparison
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GOG-Q4-'0G 22:03 ID: TEL NO: S004 P04
of sediment data in this table, by general area, without consideration of
different sampling or analytical methodologies is absolutely invalid.
p. 56 National Priority List (NPL) sites in the area include, in addition to
Ott/Story/Cordova and Duel! and Gardner Landfill, SCA Independent Landfill and
Thermo-Chem. Two other sites have a strong possibility of inclusion to the
NPL with the seventh update: Bofors-Nobel Lakeway, and Kaydon Corp. The
proposed treatment for Bofors dichlorobenzidine contamination is to pump
treated wastewater to the WWMS.
p. 70 Section 5.3 Given the level of waste generation and disposal activities
1n the Muskegon River Basin and especially in the Muskegon Lake area, and also
given the lack of PCB deposition information specific to Muskegon Lake, 1t is
indefensible to suggest that atmospheric input of PCB is the most significant
loading. This is especially difficult to justify when one considers the
presence of a bleached kraft pulp paper mill 1n the area, and the high PCB
levels at the Teledyne Continental Motors defunct discharge. The same holds
true for the statement regarding mercury inputs form atmospheric sources when
considering loadings from Division Street storm sewer and possible mercury
loadings from Bear Creek indicated by WMSROC sediment Station 5 (1982).
Appendix 4.5 Muskegon Lake Sediment Sampling Data (GLNPO, 1981) Replace this
section with the enclosed section from the GLNPO Lake Michigan Sediment
Report.
p. 39 The GLNPO 1981 Sediment Survey additionally shows very high cyanide
levels (3.1 ppm), very high chemical oxygen demand levels near the mouth of
Bear Lake and elevated chlorinated aromatlcs, halomethanes, and polynuclear
aromatic hydrocarbons in the vicinity of the mouth of Ryerson Creek.
p. 81 Section 7.1.2 Superfund Sites Also SCA, Thermo-Chem, Bofors, and
Kaydon, see above.
p. 87 Section 7.1.3 Include other CERCLIS sites noted above, including the
WMS.
P. 101 Section 10.0 Remedial Actions - Ground-Water Contamination
Contaminated ground-water inputs to Muskegon Lake and Its tributaries are
considered insignificant in the absence of adequate hydroloqic and chemical
information. The high hydraulic conductivities and the large number of known
and potential sources of ground-water contamination cause concern about
present and potential impacts. An estimated water budget for Muskegon Lake
and estimates of toxic loadings from all components of the water budget are
necessary to ascertain the impacts from contaminated ground water. Superfund
and MERA remedial investigations and cleanups need to be coordinated to ensure
that appropriate loadings information is developed and ground-water loadings
issues addressed.
Additional Recommendations
RCRA TSOs in the area should be given high priorities for RCRA Facilities
Jo?
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Assessments (RFAs). The RFAs should be scheduled expediently so that RCRA
enforcement or permitting actions could be made to expedite control of
releases. If information collected in the RFA confirms that releases did
occur, a RCRA Facility Investigation should be conducted to define the rate
and extent of contaminant releases. Appropriate administrative orders should
be issued for investigation of ground-water impacts upon surface water and for
corrective action to clean up contributing sources.
State-permitted landfills and seepage lagoons should have ground-water
monitoring requirements in their permits.
Enclosure
30?
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Michigan Department of
Natural Resources
Remedial Action Plan for
Muskegon Lake
Stage 1.
The goals and objectives are relatively clear and consistent
with the goals of the Great Lakes Water Quality Agreement.
Environmental problems in the study area have been described
as well as the use impairment. The degree of the impairment
and geologic extent are not always well documented.
The causes of these impairment are recognized but the
sources of the contaminants are not always understood.
Stage 2.
The major in place remedial measures (eg Waste disposal site)
are being evaluated.
Alternative remedial measures (eg removal of in place
pollutants) have not been evaluated.
No schedule for implementation of further remedial action is
presented.
A surveillance and monitoring program to track progress has
been suggested but not described in detail.
Some of the agencies responsible for implementation have been
identified.
Public consultation and participation in the process has been
minimal.
Stage 3
Remedial measure implementation is ongoing but without a
fixed schedule.
Surveillance data are indicating improvement in water quality
and return of beneficial uses.
Gregory J. Wall
Nonpoint Source Pollution
Control Committee
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Ministry Mmistere
of the de
Environment I'Environnement
135 Sl Oaif Avenue West 135 avenue St Cairouest
Suite 100 Bureau 100
Toronto Ontario Toronto (OntarioI
M4V1P5 M4V1P5
323-4926
February 17, 1988
W.A. Steggles
Water Quality Programs Committee
Great Lakes Water Quality Board
International Joint Commission
100 Quellette Ave. 8th Floor
Windsor, Ontario
N9A 6T3
Dear Mr. Steggles:
RE: REVIEW OF MUSKEGON LAKE RAP
The sediment related portions of the above report have been reviewed by
the IJC Dredging Subcommittee and our comments are attached.
If you have any questions regarding the comments please give me a
call.
Yours truly,
Deo Persaud, Co-ordinator
Sediment Quality Assessment
& Biomonitoring
Aquatic Biology Section
Water Resources Branch
DP/cf
Att.
cc: M. Zarull
20180-02C.l(ABS/88-1.0)
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REVIEW OF MUSKE60N LAKE RAP
General Comments and Recommendations
While the authors should be commended for collecting and compiling a
great deal of information on sediment chemistry, the report currently
lacks sufficient data for an adequate assessment of the impacts
associated with contaminated sediments (although in fairness to the
authors, they acknowledge the relatively weak sediment data base and
identify the need for future sediment and benthic community
monitoring). At the moment, the impact assessment is weak in the area
of benthic enumeration, and has no information at all on benthic tissue
concentrations or existing inputs of contaminated sediments all of
which are necessary for an initial assessment of contaminated
sediments.
Observation of benthic community structure in the absence of tissue
concentrations will fail to identify the potential causes for observed
acute or chronic effects (including uptake of contaminants into the
food web). Likewise, the absence of data concering the quantity and
quality of current sediment inputs means that no estimate of the
relative effects of current sources versus historical accumulations can
be made. It also makes predictions concerning the outcome of remedial
actions, including the "do nothing" option advocated in the report
(involving future blanketing of contaminated sediments with clean
material) highly speculative.
It is recommended that the authors identify more clearly the
significance of the missing data base, and that they withdraw their
assurances concering the "negligible" effect of contaminated sediments
until they have sufficient supporting data. In addition, the present
recommendation concerning future monitoring (contained in the "Remedial
Actions" chapter) should be expanded to include benthic tissue
analysis, and characterization of potential contaminated sediment
sources (i.e. analysis of suspended sediment chemistry at inputs).
Neither addition need be undertaken at a prohibitively expense scale
during the initial assessment phase, and the data will be of use not
only for impact assessment, but for selection of appropriate remedial
options.
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Special Comments
Page 37, par. 2
It would be more accurate to indicate that bioassay and bioaccumulation
tests are not yet standardized rather than stating that "...acceptable
testing methods and procedures have yet to be developed." As described
in our Subcommittee "Guidance" document, there are various methods and
procedures all of which may be considered acceptable depending upon the
specific objectives of the experiment.
Page 37, par 3
Although the existing disposal guidelines (U.S. EPA and MOE) are far
from satisfactory in terms of relating sediment chemistry to
parameter-specific biological effects, it is not entirely true to state
that they "...do not represent effect-based criteria...". The original
data base used in their derivation (harbours in the jurisdiction of the
Chicago and Cleveland offices of the FWPCA) may be inappropriate for
general application throughout the Great Lakes, however, the pollution
ranking was based on observation of benthos (i.e. complete absence of
benthic invertebrates, presence of only pollution tolerant species) and
thus provides some basis for inferences concerning biological effects.
Since criteria based upon single parameter dose-response experiments
are unlikely to e available for several years, short-term improvements
in sediment criteria will also have to rely upon empirical evidence
(albeit with a more comprehensive data base).
Page 69, par 1
The statement that "Conditions continue to improve" does not appear to
be supported by the information presented on page 46, paragraphs 1 and
2 concerning improvements in benthic communities.
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Page 70, par 6
Although atmospheric loadings of PCBs may be significant on a lakewide
basis, the relatively smaller surface area of Muskegon Lake may well
reduce the significance of atmospheric loadings from the local point of
view. The issue of fish exposure to PCBs from Lake Michigan (and hence
of atmospheric origin) versus exposure within Lake Muskegon and local
sources will be difficult to resolve. However, if local PCBs can be
shown to be biologically available then local action should be
considered, regardless of the potential for exposure to external
sources.
Page 72, par. 4
The analysis of sediments and fish for pesticide residues demonstrates
that (at relatively high detection limits) pesticide contamination does
not appear to be a local problem. It does not provide direct insight
into sources.
page 74, par 3
The assertion that although sediment contamination is continuing to
affect benthos in the deeper basins of the lake its contribution
"...to the contaminant levels in the fish appears to be negligible..."
overstates the case. No evidence is presented to demonstrate the
significance of historically contaminated sediments relative to active
sources, nor have contaminants associated with sediments been shown to
exist in a biologically unavailable form.
The statement on this page also appears to contradict that on page 69,
par. 4 which indicates that "...these (contaminated) sediments are a
suspected source of elevated concentrations of PCBs in carp and mercury
in walleye and largemouth bass".
Page 91, par 1
The current statement concerning sediment quality objectives will need
to be more fully explained in subsequent drafts of the report. A
"...naturally occurring community of aquatic organisms" could be
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interpreted several ways. The Subcommittee "Guidance" document
suggests that a healthy community will include clean water organisms
such as amphipods or mayflies, or at least will not be dominated by
oligochaetes.
Page 102, par. 3
Recommendations for future monitoring in connection with contaminated
sediments should include analysis of benthic tissue, and a basic
characterization of sediment input (for the reasons outlined in the
first section of this review).
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Government
of Canada
Gouvernement
du Canada
MEMORANDUM NOTE DE SERVICE
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Canada Centre for Inland Waters
867 Lakeshore Road, PO Box 5050
Burlington, Ontario, Canada L7R 4A6
January 26, 1988
SECURITY CLASSIFICATION . 06 SiCURITE
OUR FILE - N / REFERENCE
YOUR FILE - v / REFERENCE
DATE
Mr. Peter C. Boyer
Secretary
Science Advisory Board
International Joint Commission
100 Ouellette Avenue
Windsor, Ontario, Canada
Dear Mr. Boyer:
Re: MDSKEGON LAKE RAP
General Review Points. The document appears to be comprehensive, at
least in terms of recording the problems and either identifying or
speculation on the major sources of contamination. It is clear that
several major remedial "actions" have been implemented over the years
and that these have and will continue to have an effect on reducing
the polluted "status" of Muskegan Lake-Bear Lake and their
tributaries. Other major activities such as the clean-up of the
Ott/Story site are on-going or will be further developed. My general
impression is that a lot has been and is being done in terms of
remedial actions . The general results of actions already taken or
imminently planned is that the lake seems to have recovered in many
ways and is now a recreational site of some value. One would have to
visit the site and talk to locals to get a personal impression, but
the report does document clear reversal of previous problems.
The problems that remain appear to be ones common to many RAPS, namely:
1. Is atmospheric deposition a source of PCBs, Hg, chlordane and
other pesticide chemicals to the AOCS that are large lakes/bays,
e.g., Green Bay, Saginaw Bay, Hamilton Harbour, Bay of Quite,
Muskegon Lake? (Page 68, 70)
75*0-21.798-8998
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2. What is the significance, role of contaminated sediments in
terms of present levels of toxics in biota and what to do about
them? (Page 29, 36)
3. Protocols for polluted groundwater assessment and remedial
options art needed. (Page 74)
These three questions can only be answered by a site-specific research
programme and this will have to be reflected in a research needs
section in the final RAP report.
Another general comment is that there seems to be very little overall
Socio-Economic/Ecosystem/Environment-Economy thread running through
the report. What is the economic potential of the lake in terms of
social aspects, jobs through pollution reduction or clean technology
or enhanced tourism?
Specific answers to the Questions in the Protocol for Review of RAPS
for AOCS are:
Stage 1 . No. There needs to be greater emphasis on a total
ecosystem - environment economy plan.
. Yes. The problems appear to be adequately described but
data is still limited.
. No. There is no mass balance of sources involving in-situ
polluted sediments or the atmospheric component.
Stage 2 . Yes, but some are on-going.
. No. There is no plan for some waste sites for groundwater
sources or in-situ sediments other than to leave them.
. Some have, but see above item.
. Yes, but it will have to continue.
. Yes. The public appears to have been adequately involved.
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Stage 3
No. Some major actions have taken place and others are
underway. Some need to be developed. The complete
clean-up of the Ott/Story site would be a major step
forward.
No. There are still pollution issues to be addressed.
Chronic effects on biota are not considered; only
concentrations. Some concentrations still exceed
guidelines.
R.J. Allan
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