United States
               Environmental Protection
               Agency
Great Lakes National
Program Office
230 South Dearborn Street
Chicago, Illinois 60604
wER<\   Environmental
               FACT  SHEET
                                                           905N00001
                                    HIGHLIGHTS
                       U.S. ENVIRONMENTAL PROTECTION AGENCY

                  GREAT LAKES POLLUTION PREVENTION ACTION PLAN
         THE OBJECTIVE

         EPA believes the time has come:

         •    for a highly-focused and action-oriented approach to seeking the goal established
              under the Great Lakes Water Quality Agreement of virtually eliminating persistent
              toxic substances in the Great Lakes; and

         •    to promote Basinwide pollution prevention efforts as the preferred way of achieving
              that goal.
         THE GAME PLAN

         EPA's Pollution Prevention Strategy includes the following principles:

         •    selecting specific pollutants, sources, and geographic Areas of Concern as the focus
              of their efforts, such as in Northwest Indiana and the Niagara River;

         •    setting benchmarks to  measure progress toward the goal of virtual elimination;

         •    focusing institutions and programs throughout the Great Lakes Basin on this effort
              through the Great Lakes Pollution Prevention Challenge;

         •    integrating  pollution  prevention into existing environmental efforts, including
              permitting, regulatory development, and enforcement; and

         •    ensuring the involvement of all concerned parties in the public and private sectors
              through Lakewide Management  Plan and Remedial Action Plan processes, the
              International Pollution Prevention Symposium, and other efforts.

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THE GREAT LAKES POLLUTION PREVENTION CHALLENGE

The Governors of the Great Lakes States, in cooperation with EPA, will:

•     challenge all  sectors of society  in  the  Great  Lakes Basin including industry,
      agriculture, academia, communities, public interest groups and consumers to create
      and carry out  innovative projects to reduce or eliminate releases of pollutants into
      the Great Lakes ecosystem;

•     examine any technical and/or regulatory roadblocks to meeting the Challenge; and

•     recognize those who excel in meeting the Challenge.

This Basinwide effort will provide the framework for the following four major initiatives that
will be launched under  this Action Plan.  These initiatives were chosen because, taken
together, they  address the broad spectrum of pollution prevention opportunities available
in the Basin.


AUTO INDUSTRY INITIATIVE

First,  in  a public/private initiative, EPA and  the States will work in  conjunction with
Chrysler, Ford and General Motors to promote voluntary pollution prevention of persistent
toxic substances that  adversely affect the Great Lakes.

•     These automobile companies will participate with EPA and the States in a basin-wide
      effort to determine which persistent toxic substances are of greatest concern to the
      Great Lakes ecosystem. Once priorities have been established, these companies will
      evaluate which materials are in use in their manufacturing.

•     These automobile companies will document their  past efforts to reduce the use and
      generation of these  toxic substances; establish priorities for additional in-house
      pollution prevention efforts; and  work with  their suppliers to  promote pollution
      prevention.

•     Further, these companies will participate in technology transfer forums to share non-
      proprietary information on pollution prevention techniques and success stories, and
      participate in  similar forums to share information about  their efforts  to establish
      pollution prevention as a way of doing business.

•     In addition, these automobile companies commit to continue exploring new ways of
      reducing waste streams.

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LAKE SUPERIOR INITIATIVE

As  the second major  initiative, EPA, in partnership  with  Minnesota, Wisconsin, and
Michigan, will work cooperatively on pollution prevention efforts on Lake Superior.  Lake
Superior has  not experienced the intensive development, urbanization and pollution that
characterize of the lower Lakes.  It has remained relatively  pristine.  Although it  is  the
largest of the  Great Lakes, Lake Superior is also the most vulnerable to pollution from toxic
substances, since toxic substances  tend to remain longer in  Lake  Superior.   Once
degradation does occur, it takes a longer time for Lake  Superior to recover.

Public interest groups support the International Joint Commission's call for strong measures
designed to protect the Lake. EPA and the Lake Superior States are committed to:

•      Reducing the quantity of persistent toxic substances entering the Lake by building
       upon and accelerating  existing  environmental protection  programs such as  the
       Remedial Action Plans around Lake Superior.

•      Preserving the high quality waters of the Lake by developing and reaching agreement
       on  common procedures to stop degradation.

•      Developing an inventory of Lake Superior's problems and reaching a consensus on
       "critical" pollutants.

•      Establishing an  improved international air toxic monitoring network in the  Lake
       Superior Basin and conducting  modeling to  identify the major local  and distant
       sources of pollution.

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

•      Supporting Minnesota's  and Wisconsin's  work with the St. Louis River Remedial
       Action Plan citizen committees  and the private sector in developing  an overall
       pollution prevention approach to eliminate or reduce major sources of discharge to
       the western end of Lake Superior.

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

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URBAN NON-POINT POLLUTION

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

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

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

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

EPA will co-sponsor with Canada an International Pollution Prevention Symposium to take
stock of current pollution prevention efforts and chart future activities. This Symposium will
be held in conjunction with a meeting of the International Joint Commission meeting in Fall
1991 in Traverse City,  Michigan.
CONCLUSION

These are some, but by no means all, of EPA's and the State's efforts to prevent pollution
and to protect the Great Lakes ecosystem.  The efforts are envisioned as ways to enhance
and buttress the  aggressive  regulatory and enforcement programs already in place.  For
instance, to fulfill their requirements under the Great Lakes Water Quality Agreement, EPA
and the States are actively working to:

•     Establish consistent water quality standards for the Great Lakes.  It is anticipated

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       that  pollution prevention  technologies will  help dischargers  meet  these new
       standards.

       Develop and carry out Remedial Action Plans for each of the 43 Areas of Concern
       identified by the International Joint Commission.  EPA and the States will work
       diligently to ensure that cleaned up areas remain clean.
•     Identify the critical pollutants that threaten each Lake and thus the ecosystem as a
      whole.  This knowledge will  enable Federal and State  agencies to make informed
      decisions on the best ways to prevent critical pollutants from entering the Lakes in
      the first place.

The U.S. Great Lakes Pollution Prevention Action Plan is an important step in breaking the
cycle of contamination and cleanup in the Great Lakes.  Through EPA/State leadership and
partnership, and by example,  pollution prevention can become a way of life for all those
who live  and work in the Basin.

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             U.S. ENVIRONMENTAL PROTECTION AGENCY

       GREAT LAKES POLLUTION PREVENTION ACTION PLAN



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

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

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

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

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Disposal or other release into the environment should be the management option of last
resort, and should only be done in an environmentally protective manner.

EPA places a high priority on incorporating this hierarchy of options into all Agency
activities and on encouraging all sectors of society - including government, industry,
agriculture, transportation, educational  institutions and  individual consumers  - to
incorporate pollution prevention into their environmental decision-making as well.
Industry, in particular, is increasingly aware that reevaluating products and processes
for environmental reasons can lead to improvements that pay off competitively in lower
costs  and higher quality. A commitment to pollution prevention is a commitment to
innovation - and innovation is the key to a competitive U.S. economy.

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

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

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

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

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

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

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

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

   3  The 33/50 Program (formerly called the Industrial Toxics Project) is an important element of
the national EPA Pollution Prevention Strategy.  Through this project, EPA  has targeted specific
chemicals that are reported and tracked  in the  Toxic Release Inventory and will seek voluntary
reductions from the major industrial emitters.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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