• 00403 1 Su"' OOOR88002 I September 20, 1988 I | SUMMARY REVIEWS OF REMEDIAL ACTION PLANS _ INCLUDING COMMENTS OF INDIVIDUAL REVIEWERS I I Page GREEN BAY 1 RIVER RAISIN 37 • MANISTIQUE RIVER 95 TORCH LAKE 117 WHITE LAKE H7 DEER LAKE 167 MUSKEGON LAKE 193 ------- ------- I • September 20, 1988 I • SUMMARY REVIEWS OF REMEDIAL ACTION PLANS INCLUDING COMMENTS OF INDIVIDUAL REVIEWERS I | Page GREEN BAY 1 I RIVER RAISIN 37 • MANISTIQUE RIVER 95 TORCH LAKE 117 I WHITE LAKE 147 DEER LAKE 167 I MUSKEGON LAKE 193 I I I I I U.S. Environmental Protection Agency dLNPO Library Collsction (PL-1ZJ) 77 West Jackson Boulevaid, . Chicag"."- 60604-3590 I I I I ------- I I I I I I I I I I I I I I I I I I I 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 ------- I 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. • - 2 - I I I ------- I I I I I I I I I I I I I I I I I 1 1 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. - 3 - ------- I 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. - 4 - I I I I J ------- I I I I I I I I I I I I I I I I 1 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. - 5 - ------- I 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. • I I I I I I I I I I ------- 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 7 ------- I I 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 I I ------- I I I I I I I I I I I I I I I I I 1 I I 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 ------- 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 /o I I I I I I I I I I I I I I I I I I I ------- REVIEW OF LOWER GREEN BAY RAP I I I I I I I I I I 1 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. ------- 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) /z ------- I I I I I I I I I I I I I I I I I I I 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. ------- 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 ------- 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 r I I I I I I I I I I I I I I I I r 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. - ------- 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 ------- I I I I I I I I I I I I I I I I I / I I ~ !a 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 ------- 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 i i - 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? ------- I I I I I I I I I I I I I I I 6 I I - 3 - 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. j 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 ------- , 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 ------- 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]. I I I I I I I I I I I I I • <=?/ Gregory J. Wall, Ph.D. Research Scientist Land Resource Research Center ------- 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 ------- i - 2 - 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. I I • DP/cl ABS/88-1-20098-01C.1 I I I I I I I I I I i ------- 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 $. ------- I I I I I I I I I I I I I I I I I I I - 2 - 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. ------- - 3 - 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 ------- UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 1 1 •V J 1 1 I m 1 I ^w i i i i i i i i 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 ------- 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. ------- I I I I I I I I I I I I I I I I I I I 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-- • i— 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. ------- 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. ------- I I I I I I I I I I I I I I I I I I I 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" ------- 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. ------- I I I I I I I I I I I I I I I I I I I 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 ------- 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 ------- I I I I I I I I I I I I I I I I 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"------- Carlos M. Fetterolf , Jr. Executive Secretary cc: HAB members I 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. ------- I I I I I I I I I I I I I I I I I I I 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. ------- 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. ------- I I I I I I I I I I I I I I I I I I I 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. ------- I 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? I 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. • I I I ------- I I I I I I I I I I I I I I I I I I I 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. ¥/• ------- SUMMARY OF PROS AND CONS Pros I I 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. I I I ------- I I I I I I I I I I I I I I I I I I I 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. ------- 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 ------- I * ' < I I I I I I I I I I I Ir" I I I I I I 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 ------- 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- 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 ------- I I I I I I I I I I I I I I I I I I I 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. ------- 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 ------- 1 I • 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. I _ 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. I 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. ------- 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. ------- I _ 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, I 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. I I I I • <3V ------- 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. ------- I future remedial action, maybe a monitoring plan was deemed superfluous. I 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? I 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. I JL I I I I I I I ------- 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. ------- I I I I United States Department of the Interior I I I I I I I i i i i i i i 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 ------- I 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. ------- I I I I I I I I I I I Dr. E. T. Wagner 3 A. The Plan does not discuss likely Impacts to the Lake Erie ecosy•tea 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 . I I ii t '* 1; 1 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 . ' ' \» ------- 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 I I I I I I I I I I I I ------- I I I I I I I I I I I 1 I I I I I I 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 ------- ^*">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 ------- I I I I I I I I I I I I I I I 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? •' • •• 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. ------- 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. I I ------- I I I I I I I I I i i i i i i i 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 I I ------- Review of RAP for River Raisin, October 27, 1987 I have attempted to review the River Raisin RAP along the * 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 •' - •• considered in its formulation. The only persistent toxic ^ 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 U' ------- (such as expressed in Table 31) included near the beginning of this section would have been useful. The degree and ' * V 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 ™ jjl f • 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 -' - -^ 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? ------- 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 « 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 ------- I mentoring before remedial actions are taken. My review of ( I the report was hasty but it appears to me that sufficient * 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. I I I « T I 1 I ------- 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. ' ------- I I I I I I 1 I I I f I I I I I I I I -2- 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. ' ,......:.. . .\ .. ------- -3- 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. ------- I I I UNITED SERIES HWIROWEMmL PROTECTION AGENCY GREAT LAKES MVnOftL PROGRAM OFFICE 1 I I I I I I I I I I I I I 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 ------- 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? ------- I I I I I I I I I I I I I I I I I I I 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? ------- 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 ------- I I I I I I I I I I I I I i i i i i i 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... ------- 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. ------- I I I I 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. I I try .. .to determine what oontaminants are present in the I I I I I I I I i i I ------- 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* ------- I Rte/or Kaisin RAP Review Out File: 1 1 65- 36/C7 1-1 0 S. Humphrey Date: 16 February 1908 I i i 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. I I I I I I ------- »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 ------- I I I I I 1 I I I I I I • I I ' .'"-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? ------- 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- ------- I I I I I I I I I I I I I I I 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 ------- 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. ------- I I I I I I I I I i I s I i 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. ------- 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 ------- I I I I I I 1 I I I I I T f I I I I I 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. ------- 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 * 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 fo ------- I I I I I I I 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 1 I I I I I I II • 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? ------- 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 ------- I I I I I I I I I I I I I I I I I I I :. \ 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 i. 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. ------- I I I I I I I I I I I I I I I I I I I 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. ------- I 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. I ------- I I I I I I I I I I I I I I I I I I I 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. ------- 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. ------- 1 1 1 • 1 1 • 1 1 1 1 1 I.J.Vs. 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? ------- 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- 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 ------- 1 1 1 1 1 1 1 !• 1 1 I IV 1 1 1 1 1 1 • ^ 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 ------- 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. ------- FROM DE SUBJECT OBJET I I I I I I I 0 I I I I I I I I I I I I TO 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 ------- I" I M I ', ' 1 . )• !•• I' I •.•• I 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------- I I I I I I I I I I I I I I I I I I I 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? ------- 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? ------- I I I I I I I I I I I I I I I I I I I 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 ------- 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. -1- //z ------- I In my view, the ecosystemic relationships in Areas of Concern should be I 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 I I I I 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 -2- ------- 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 -3- ------- I I I I I I I I I I I I I I I I I I I 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. -4- ------- 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. -5- ------- I I I I I I I I I I I I I I I I I I I 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. ------- 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). ------- I I I I I I I I I I I I I I I I I I I 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. ------- 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. ------- I I I I I I I I I I I I I I I I I I I 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 ------- 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. ------- I I I I I I I I I I I I I I I I I I I 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. ------- 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. ------- I 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 I I I I I I I I I I I - ------- 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 ------- I 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 I ------- 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. ------- I I I I I I I I I I I I I I I I I I 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) /-> ^ ------- 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 ------- I 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. I 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. I I I • 4. Problem Definition As noted above, a problem remains in the sediments. As discussed in the ------- 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. ------- data. Why were these tables ommitted rather than being improved for the latest version ? i i 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 I I I 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 I /33 I ------- 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. ------- I • The impaired uses are then • a) Loss of suitability as a habitat for aquatic species due to sediment I I I I • I 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... I 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). ------- -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 ------- I I 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. I 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 . I I I I I I £ ------- 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 ------- I I I I I I I I I I I I I - 2 - I I • 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 ------- 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 ------- I I I I I f I I I I I I I I I I I I I 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. ------- 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 ------- I I I I I I I I I I I I f I I I I I 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. ------- - 2 - 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 ------- I I I I I t I I I I I I I I I I I i i - 3 - 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. ------- 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. ------- 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. ------- 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.) ------- 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. ------- 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. ------- 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. ------- 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 ------- 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. ------- 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 ------- 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*------- 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. ------- 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. ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- 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. ------- I I I I I I I I I I I I I I I I I I I 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. ------- 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? ------- I I I I I I I I I I I I I I I I I I I 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. ------- 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. ------- I I I I I I I I I I I I I I I I I I I 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. ------- 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. ------- I I I I I I I I I I I I I I I I I I I 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 ------- 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. ------- I I I I I I I I I I I I I I I I 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 ------- 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 ------- 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. ------- 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 ------- 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? ------- 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 ------- 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 ------- 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 turn—out at the two public hearings was meager. Is there any "environmental concern" within the community? ------- (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 non—speci al ist could have been develooed with much o-f the detailed data and araument added in an appendix. ------- 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. ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 ------- 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. ------- 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 : ------- 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). ------- Page 2 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. ------- 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. ------- I I t I I 1 I I I I i l I i I i i i i 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 ------- 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 I i t i i 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 >/^-y | I I I I ------- I I I I I 1 I I I I 1 I I I I 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 ------- 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 ------- I f I 1 I I I I I I I I I I I I I I I 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? ------- 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? ------- I I 1 I I I i t i i f I i i i I i i i 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 ------- 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) ------- I I I I I I I I i i i i t i i i i t - 2 - 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. ------- 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. ------- I I I I I I I I I I I I I i I i I i i - 4 - 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 ------- - 5 - 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). ------- Government of Canada Gouvernement du Canada MEMORANDUM NOTE DE SERVICE r i , UET I I I I I I I I 1 I I I I 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 ------- -2- 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. ------- I I I I I I I I I I I 1 I I 1 I I I -3- 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 ------- -------