905R77114
            REPORT OF SUB-GROUP A
REVIEW OF GREAT LAKES WATER QUALITY AGREEMENT
              April 29,  1977

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                                 UNITED STATES
                       ENVIRONMENTAL PROTECTION AGENCY
                                    REGION v
                             230 SOUTH DEARBORN ST
                             CHICAGO. ILLINOIS 50604
PRO^"

    APR 2 9  1977


    Ms. Barbara Blum,  Chairperson
    United  States Senior Review  Group
    Great Lakes Water  Quality Agreement Review

    Dear Ms.  Blum:

    The accompanying Report  of Sub-Group A of the Great  Lakes Water Quality
    Agreement  Review is submitted  in  fulfillment of  the  Sub-Group A assign-
    ment to review the operation and  effectiveness of  the Canada-U.S.  Great
    Lakes Water Quality Agreement  and  to make recommendations as appropriate.

    This review exercise was carried  out within a period of  three months.
    Because of this time constraint the Report includes  informal contribu-
    tions from many Federal  and  State  experts who participated  in preparation
    of the  Report through telephone calls and informal meetings and discussions,
    which supplement documentation in  the Position Papers and other written
    commentary accompanying  the  Report.

    A debt  of gratitude is owed  to the many persons  who  contributed to this
    Report, particularly the 72  members of Sub-Group A and the Advisory Groups
    listed  in the attachment to  the Report.   Their contributions are  all the
    more notable when  it is  realized that this review  was accomplished outside
    of the  normal scope of duties  of most of  the participants,

    A draft of this Report was sent to the Public Interest Groups listed in
    the Report for review and comment, and a  copy of this final Report is also
    being sent to them.  The Canadian  representatives  who will be meeting with
    the Sub-Group Chairmen on May  16,  1977, have also  been provided with a copy
    of the  Report.

    We have appreciated "the  opportunity to participate in the review  and trust
    that this  Report provides the  desired information.

    Sincerely yours,
    George R. Alexander, Jr.    /r
    Chairman, Sub-Group A
    Great Lakes Water Quality Agreement Review

    Attachment

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                       TABLE OF CONTENTS
                                                                          Page

Report of Sub-Group A As a Whole
     Introduction 	   1
     Background 	   2
     Problems under the Agreement	   6
     General Summary and Recommendations 	   9
     Detailed Discussions § Recommendations 	  10
          Preface (Preamble)	  12
          Article I - Definitions	  14
          Article II - General Objectives § Goals	  17
          Article III - Water Quality Objectives 	  20
               Annex 1. Specific W.Q. Objectives	23
          Article IV - Standards £ Other Regulatory Requirements	  37
          Article V - Programs § Other Measures 	  39
               Annex 2. Control of Phosphorus	47
               Annex 3. Vessel Design, Construction § Operation 	  51
               Annex 4. Vessel Wastes	  52
               Annex 5. Studies of Pollution from Shipping Sources. ...  53
               Annex 6. Identification § Disposal of Polluted Dredge
                        Spoil	  54
               Annex 7. Discharges from Onshore § Offshore Facilities. ..  55
               Annex 8. Joint Contingency Plan	  58
               Annex 9. Hazardous Polluting Substances 	  59
          Article VI - Powers, Functions § Responsibilities of the IJC ..  67
          Article VII - Joint Institutions	70
          Article VIII - Submission £ Exchange of Information	72
          Article IX - Consultation $ Review	
          Article X - Implementation 	
          Article XI - Existing Rights § Obligations 	
          Article XII - Amendment 	
          Article XIII - Entry Into Force § Termination 	
          Article XIV - Supersession	  77

Attachments:
1.  Fourth Annual Report of IJC on Great Lakes Water Quality
2.  1975 Annual Report of Water Quality Board fSummary")
3.  Draft Position Papers of Sub-Groups B, C § D
A.  Sub-Group A  Functional Chart and Membership
5.  Comments from Public Interest Groups and Others


Appendix I - Position Papers (Bound Separately)
     Water Quality Objectives Work Group
     Surveillance Work Group
     Phosphorus Work Group
     Point Source Discharges Work Group
     Non-Point Sources Work Group
     Hazardous Substances Work Group
     Nuclear Wastes (Radioactivity) Work Group
     Research Work Group

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                    REPORT OF SUB-GROUP A AS-A-WHOLE




                            IN REVIEW OF



                 THE GREAT LAKES WATER QUALITY AGREEMENT






INTRODUCTION




     In connection with the Fifth Year Review the Canada-U.S. Great Lakes



Water Quality Agreement of 1972, Sub-Group A was organized during February



1977 as part of the U.S. Government's Great Lakes Water Quality Agreement




Review Structure,  Sub-Group A was charged with reviewing the principal



environmental issues involved in the Agreement and was requested to prepare




specific position papers on the following eight topics; water quality, surveillance




(in broad general terms in addition to water quality surveillance and monitoring)



phosphorus, point source discharges, non-point sources, hazardous substances,




nuclear wastes (radioactivity), and research.






     As was further requested by the Senior Review Group, this report of Sub-



Group A discusses the general aspects of the Agreement in'addition to the



topics mentioned above.  It presents a general summary and recommendations and




addresses, in greater specificity, each Article and Annex of the Agreement in a



separate prefacing discussion and presents conclusions and recommendations in



the form of recommended changes in the wording of each of the parts of the



Agreement.  The specific discussions highlight any minority views where appro-



priate which do not appear in the separate Position Papers included with this



report.




     The separate Position Papers from the Work Groups for each of the




subjects listed in the first paragraph are also appended to provide the Senior




Review Group with background information on each topic and with the full

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range of issues and views considered in this review, some of which may not

be reflected in the recommendations of the Sub-Group as a whole.   Each Position

Paper is designed to stand alone and contains an introduction and discussion

of the issues involved and its own summary, conclusions and recommendations.


     Because the topics assigned to Sub-Group A cover the entire  environmental

spectrum a brief general background for the Agreement is also provided to

supplement the background statements in each of the separate Work Group

Position Papers.


BACKGROUND


     The Great Lakes are a major and unique international water resource which

we share with Canada,  The Lakes constitute 80% of the fresh water surface

area of the United States arid over 97% of the nations fresh surface water
                              \
storage.  Within the Basin lives 15% of the nation's population,  most of

whom depend on teh Great Lakes for their drinking water.  The Lakes are

heavily used for swimming, sports fishing, and pleasure boating.   Approximately

20% of the nation's manufacturing activity, and 17% of the nation's income

derives from the Great Lakes Basin.  Fifty percent of the nation's steel is

produced in the Basin and 100 billion ton-miles of shipping is carried on the

Great Lakes annually.  The Lakes still support what is now a declining commer-

cial fishing industry, which will probably disappear unless a method is found

for controlling toxic materials and other people-induced stresses.


     The attached map shows the Great Lakes and the drainage basin which

constitute the "Great Lakes System" as defined in the Water Quality Agreement.

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Great Lakes Basin

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The system drains in a generally easterly direction, via the five lakes?their




inter-connecting channels and the St. Lawrence River, into the Atlantic Ocean.




The Basin encompasses portions of eight States and the Province of Ontario,




and the map vividly illustrates the need for a basin-wide approach to water




quality management of the Great Lakes as recognized in the Agreement.






     Early pollution control philosophy regarded the Great Lakes as an in-




exhaustible  pollution sink.  The fallacies of such assumptions became




obvious in a rather dramatic way several years ago when stories (albeit not




completely accurate ones) on the "Death of Lake Erie" were prevalent in the




press.  Although the volumes of water contained in the Great Lakes is enormous,




the cummulative consequence of continued pollution is far more serious and




long lasting in these large lakes than in a river.  When pollution abatement




has been implemented on a stream segment, the improvement of water quality




is usually noted in a relatively short time.  This is not so in the Great




Lakes.  In Lake Michigan, for example, which has a flush out time on the order




of 100 years, it is obvious that we are yet to see the consequence of current




pollution loads.  The worldwide PCB problem, particularly acute in Lake



Michigan, is dramatic evidence of the unknowns we face in attempting to



design pollution control programs in these large bodies of water.   Mirex (de-




chlorane) and uncounted other organic persistent contaminants have caused most




Lake Ontario fish to be unsuitable for human consumption.  While it is expected




that adequate control programs and sufficient time will restore most of the




beneficial uses of the lakes, there is no guarantee that all of the changes




that have occurred can be reversed.  Five years of intensive surveillance of

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 pollution control  programs  by  the institutions of the Agreement, particularly




 the Water Quality  Board of  the International Joint Commission have shown that




 much now needs  to  be done if we are  to  achieve the objectives of the Agreement,




 The attached copies  of the  International Joint Commission's Fourth Annual




 Report  of Great Lakes Oater Quality  and the summary of the 1975 Great Lakes




 Water Quality Board  Report  give an accurate picture of the progress made




 and actions needed.   For the reasons mentioned above special attention has




 been focused both  in Canada and in the  U.S. on the water quality problems of




 the Great Lakes.






      The U.S.-Canada Great  Lakes Water  Quality Agreement, a Federal Executive




'Agreement signed on  April 15,  1972,  provided a special cooperative mechanism




 under the Boundary Waters Treaty of  1909 for focusing pollution control efforts




 of the  two nations on clean-up of the Great Lakes through the adoption of




 common  objectives  and development and implementation of remedial programs and




 other measures.  The lead Federal role  in water quality matters has been given




 to the  U.S. Environmental Protection Agency.  Environment Canada has the lead




 Federal role in that country.   Full  cooperation of the eight Great Lakes States



 and the Province of  Ontario has been effected through the Agreement.






      The two countries separately have  focused attention on the Great Lakes.




 In the  U.S. Public Law 92-500  recognizes the special nature of the Great Lakes



 since it makes  special provisions for research and technical development




 activities- under Section 104Cf),  for a  Great Lakes Pollution Control Demonstration




 Grant Program under  Section 108Ca) and  for a special study of Lake Erie under
                                     •5

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Section 108(d).   Similar attention has been focused on the Great Lakes by Canada




by special agreements between the Canadian Federal government and the Province




of Ontario.  These Federal-Provincial agreements use the Great Lakes Water




Quality Agreement as a basis for their programs.






     In summary, the uniqueness of the Great Lakes as an important international




fresh water resource, the preservation of present areas of excellent water




quality, present areas of degradation, and the continued pressure from man-




made activities are the principal reasons for the special national and inter-




national attention given to protecting and improving water quality in the




lakes and their tributaries.






PROBLEMS UNDER THE AGREEMENT






     The Water Quality Agreement was signed on April 15, 1972.  The U.S.




negotiators attempted to anticipate the then pending legislation to amend




the Federal Water Pollution Control Act,   However, the full signifiance of




the amendment in the form of PL 92-500 which was enacted on October 18,




1972,  was not fully realized until long after the law was enacted and in




some instances has not even yet been fully realized.  Such far-reaching



changes in pollution control in this country have created very signif-




icant   differences in the actual approach of the two countries to pollution




control.  The Canadian approach, which is essentially that of the Province




of Ontario because it is the only Province bordering the Great Lakes, is




similar to the pre-PL 92-500 approach by the U.S.  which is reflected in the




Agreement and which was found to be ineffective.  At the same time it must

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 be recognized that progress was  made under the Agreement and particularly by




 Ontario  with respect to the phosphorus effluent  limitation on Lakes Erie and




 Ontario,, and even  more so in their establishment of phosphorus limitations for



detergents.   But  there is  a  need to look forward, not  backward,  and  to do  so,



a comparison of the Canadian and U.S. approaches to  pollution control is necessary.






      Sub-Group A believes that,  despite  the many recognized deficiencies  in



 PL 92-500,it is  the most progressive water pollution control law ever enacted




 and that the Agreement must be brought  into compatibility with it, and to do




 so will  require  significant changes in  the Agreement and in Canada's




 participation in the Agreement.   Some comparisions of U.S. and Canadian




 approaches follow:



      —  The Canadians do not have water quality standards as the U. S.  does.




         They adopt objectives which are little more  than  criteria as defined



         in the U.S.




      —  The Canadians have no universally applicable effluent requirements




         as the U.S. does.   (The principle of universal applicability of




         uniform  effluent limits was recently affirmed in the U.S.  law by



         the U.S. Supreme Court).  Instead the Canadians attempt to tailor




         the discharge to the assimilative capacity of the receiving water




         without  having any legally mandated mimimum  effluent requirement.



         This results in primary treatment for some municipalities and




         generally a maximum of primary equivalent  for industry, as opposed




         to the minimum of BPT in the U.S.




      —  Canada has no effluent discharge permit system.  Instead they




         (Ontario)  have "program orders" which are  not legally enforceable.




         While their program has  been comparatively more effective for




         municipalities, it has been much less so for industrial dischargers.




                               7  _

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     — The Canadians have interpreted the Water Quality Agreement to apply



        only to boundary waters (i.e., the Great Lakes and interconnecting



        channels) contending that the "internal waters of Canada" are not


        subject to the Agreement;  e.g., the Canadian Chairman of the Great



        Lakes Water Board at the last IJC meeting in July 1976 extended this



        interpretation even to dischargers to the Weiland Canal,an artificial



        interconnecting channel between Lakes Erie and Ontario paralleling



        the Niagara River and wholly within Canada.


     -- Canada unlike the U.S., has no system for tracking  land use practices



       nor  does  it provide local technical assistance  to the landowner in


       planning  agricultural conservation practices.







     This is a rather bleak picture on the industrial side and belies the



frequently voiced position that Canada is ahead of the U.S. in pollution  control



efforts.


     As mentioned previously, the Agreement has been interpreted by the



Canadians to imply a distinction between the waters of the system and the



boundary waters and this distinction must be ended for purposes of pollution



control because we cannot address the problems in the Great Lakes by


interpreting the provisions of the Agreement to apply just to the boundary


waters when it is convenient to do so.  Article V, para 3, specifically states


that remedial programs are applicable to the tributary waters.'  This  provision
                                                                •*


should be literally interpreted.  All  of the discharges to surface waters


of the entire basin are of mutual concern to both the U.S. and Canada.  This



poses problems for the Canadians,  especially with regard to industrial dis-



charges,  since they do not have the same requirements for public disclosure





                                      8

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 as we do.  Their "in camera" approach to pollution control is perhaps more




 ingrained than in any other aspect of their society.  However, on the more



positive side^  there  have  he^n recent discussions in the Canadian parliament




to open up the system by a Freedom of Information type approach - this should



be strongly encouraged.






      Not only must the basin as a whole be looked at from the standpoint of




 pollution control, but eventually a basin-wide approach to water and related




 land resources planning must be addressed,






 GENERAL SUMMARY AND RECOMMENDATIONS
 	" •"•"••• •• •• I" ' •• • •	-      l-l  I' - ' •'• I	• •"••! "• •"•' '• "  J





      To summarize, significant  changes  in pdllution control laws in the U.S.




 require significant changes in  the  Agreement if the U.S. is to continue to




 be  a party to  the Agreement.  Broadly these are:




      — A system-wide approach  must be made to water pollution control.




         The distinction between "boundary waters" and "tributary waters" must




         be ended.




      — The principle of  "objectives"  merely as goals must be replaced by a



         recognition that  objectives are to be translated into enforceable 'standards




      — The basic thrust  of the Agreement must be changed to  require the



         application of system-wide  legally enforceable minimum treatment




         requirements for  each and every point source dishcarge,




      — Some common system-wide planning criteria must eventually be agreed



         upon for the Great Lakes System.



      —  In order  to  control toxic pollutants the general  ongoing surveillance



         program must be supplemented with detailed process evaluations for




         those  industries  which are most likely to be sources of  persistent



         toxicants (coke plants,  pharmaceuticals, electroplating,  mining,  organic




         and  inorganic chemicals, etc.

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      Notwithstanding  all  of  these problems the Agreement  itself has  served
 a useful  purpose  and  can  continue,  in  a  changed  form,  to  serve a  useful
 purpose in the  future.  It provides both countries  with an  opportunity to
 focus attention at  the  highest  levels  on the  unique needs  of the Great  Lakes
 and it provides for an  independent  expression of opinion  through  a binational
 organization.  Furthermore, we have a mutual need with the Canadians to deal
 not just  with the boundary waters but with the waters of  the entire system.

 DETAILED  DISCUSSION AND RECOMMENDATIONS

      The  rest of this paper will be based on the premise  that we  should attempt
 to renegotiate the Agreement to bring it into line  with water quality and pol-
lution control programs  in this country.  The preface to the  Agreement and each of
 the Articles and Annexes will be dealt with separately in the following dis-
 cussion.   The existing  text of the Agreement  is reproduced  in regular type,
 deletion  of wording is  shown by dash line-out, and new wording has been
 inserted  in script.
                               10

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           AGREEMENT BETWEEN

CANADA AND THE UNITED STATES OF AMERICA

     ON GREAT LAKES WATER QUALITY
                 2
      Revised Ottawa,
              In Force AB?ii-iST-49r2
                      11

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DISCUSSION OF PREFACE






          The Sub-Group believes  that  the preface is essentially as appropriate



today as it was when the Agreement was first signed.   Accordingly,  only minor




word changes have been proposed in the attached draft  of the revised preface.






          The original Agreement  did not include a  title for the  prefacing




statement and it is suggested that the word "Preamble" be used.   The revised




Preamble and Agreement will be based upon the Fourth Annual  Report  of the




International Joint Commission, because that report is the latest that has




been accepted and includes some of the conclusions  and recommendations of




the report of the Upper Lakes Reference Group which has not, as yet,  been




acted upon by the Commission.  Another change in wording is  the suggestion




that the words "adoption of common objectives" be deleted and that  the phrase



"agreement on common goals and objectives" be used  instead.   While  Canada




actually adopts objectives as part of their Federal-Provincial"Agreement the




United States has never formally  adopted objectives although the  Federal




government does encourage their use in the adoption of Federal-State  Water




Quality Standards; therefore, the term "agreement on"  rather than "adoption



of" is more appropriate terminology.






          The revised preface follows:
                                   12

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 •  .                                  PREFACE
.  \                                        ~~

           The Government of Canada and the Government  of the United States of


 America having previously entered into Agreement  en  Great Lakes Water Quality


 now are -




        *  determined Reaffirming  their determination to  restore and enhance water


 quality in the Great Lakes  System.


        *  Continuing to  be  seriously  concerned about the grave  deterioration of


 water quality on  each  side  of  the  boundary to an  extent  that  is causing  injury


 to health and property on the  other  side, as described in the 19?8-?epe3?t-e£


 Fourth Annual Report on  Water  Quality of the Great Lakes "by  the International


 Joint Commission,  en-Pel lH£ien-e£-kake-Ej?ieT -take-Out asio-and-the-lRt e
        *•'-• Reaffirming their  intent upon preventing  further pollution of the Great


 Lakes  System owing  to continuing population growth, resource development and


 increasing  use  of water;


        * ' Reaffirming in  a spirit of friendship and cooperation  the  rights  and


 obligations of  both countries under the Boundary Waters- Treaty signed on


 January 11, 1909, and in  particular their obligation not to pollute  boundary


 waters;


        * ReeegHising Continuing to recognize the rights of each country in the  use


 of its Great .Lakes- waters;


        *? . Satisfied that  the 1979-rep9Ft Great Lakes Water Quality Agreement of


 April  *15t 19^2- and the Fourth Annual Report of the International Joint Commission


 provide a sound basis for new and more effective cooperative actions to restore  and


 enhance water quality in 'the Great Lakes System;


        ** Convinced that  the best means to achieve  improved water quality in the


 Great  Lakes System  is through the adeptien-e-f agreement on common goals and

 objectives, the development  and implementation of-eeeperative conrnon remedial programs


 and other measures, and the  assignment of special responsibilities and  functions  to


 the International Joint Commission:


        * Have-agreed Entering into a new Agreement as follows:

                                    13

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DISCUSSION OF ARTICLE I - DEFINITIONS






        In general the definitions as existing are satisfactory except




that it is proposed to define the term "agreement" in order to distin-




guish this document from the original.  It is also proposed that a de-




finition of the word "parties" be included since the term is used through-




out the Agreement without having been defined.






        It is  proposed that the definitions of "research" be added in




this part of the Agreement.  The definition of research has been changed




to include reference to air quality.  The existing Reference on the




Research Advisory Board is proposed to be deleted and its provisions




included under Article VII of the Agreement.






        It is suggested that two additional new terms be added to the




list of definitions to accommodate proposed changes or additions to




Article V.  The terms are "Best Practicable Treatment (BPT)" and




"Best Management Practices (BMP)",  The rationale for these defini-




tions are given in the Position Papers on Water Quality and Point and




Non-Point Sources attached to this Report.






        The revised definitions and the added terms and their defini-




tions follow:
                           14

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                    ARTICLE I

                   DEFINITIONS

   As used in this Agreement:

 (a)  "Agreement" mear.s this revised Agreement as distinguished from
     the oriainal Agreement of Avril "is, 1972.


00   "Parties" means the Federal government of the U.S.  and the
    Federal government of Canada,

(cl   "State and Provincial Governments"  means the Governments
     of the States of Illinois,. Indiana, Michigan, Minnesota,
     New York, Ohio, Pennsylvania,  and Wisconsin, and the
     Government of the  Province of  Ontario;


 (d)   "International Joint Commission"  or "Commission"  means
      the International Joint  Commission established  by the
      Boundary Waters Treaty;

 (e)   "Boundary Waters  Treaty" means  the  Treaty between
      the United States  and Great Britain Relating to
      Boundary  Waters,  and Questions  Arising  Between  the
      United  States  and  Canada, signed at Washington  on
      January' 11,  1909;

 tf)   "Boundary waters  of the Great  Lakes System" or
      "boundary waters"  moans boundary waters, as defined
      in the  Boundary Waters Treaty,  that are within  the
      Great Lakes System;

 („}   "Tributary waters  of the Great Lakes System" or  "tributary
      waters" means all  the water of the Great Lakes System that
      are not boundary waters;

 00  "Compatible regulations"  means regulations- no  less
     restrictive than agreed principles;

 (i)   "Great Lakes System"  means all of the streams,  rivers,
     lakes and other bodies  of water that are within the
     drainage  basin of  the St. Lawrence  River at or up-
     stream from the point at which this river  becomes the
     international boundary  between Canada and  the  United
     States;

 (j)   "Harmful  quantity" means any quantity of a substance
      that if discharged into receiving waters would be
      inconsistent with  the achievement of  the water quality
      objectives;

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00    "Hazardous polluting substance"  means any element or
      compound identified by  the Parties which, when  dis-
      charged  in any  quantity into or  upon receiving  waters
      or adjoining shorelines,  presents an imminent and
      substantial danger to public health or  welfare;   for
      this purpose,  "public health or  welfare"  encompasses
      all factors affecting the health and-welfare of man
      including but  not limited to human health, and  the
      conservation and protection of  fish, shellfish,
      wildlife, public and private property,  shorelines and
      beaches;

 (1)   "Phosphorus" means the  element phosphorus present as a
      constituent of  various  organic and inorganic complexes
      and compounds;

  (m)  "Specific  water quality objective" means the level  concentration
      of a substance or physieal level of effect that the Parties agree,
      after investigation, to recognize as a maximum or minimum desired
      limit for  a defined body of water or portion thereof, taking into
      account the beneficial uses of the water that the Parties desire to
      secure and protect;

 (n)  "Water  quality objectives" are broad descriptions of water
      quality conditions which will protect  the boundary waters
      of the  Great Lakes System for the beneficial uses that the
      Parties desire to secure and which will provide overall wa-
      ter management guidance and a framework for the development
      of the  specific water quality objectives. "

 C°)  "Research" means  development, demonstration and other research
      activities but does not include regular- monitoring and sur-
      veillance of water or air quality.

  (p)   "Best Practicable  Treatment (BPT)" means the level of treat-
      ment for wastewaters from municipal and industrial sources
      aa defined in Article III and Annex J»

  (q)   "Best Management Practices  (BMP)" means the most  practical
      and effective measure or combination of measures, which
      when applied to agriculture, forestry  practices,  road
      construction, mining,  urban development, urban drainage and
      other land use activities,  will prevent or reduce the gen-
      eration of pollutants to a  level compatible with  the  water
      quality goals and objectives of this Agreement.
                    16

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DISCUSSION OF ARTICLE II






        The Sub-Group believes that the general water quality objectives,  now



under Article II should be combined with the Specific Water Quality Objectives



under Article III and that Article II should become a statement of goals  and




policy.






        This new Article is considered necessary to emphasize the new




approach of "minimum treatment requirements" and a basin wide approach to




pollution control and water quality management for the restoration and



preservation of the Great Lakes.   The rationale for this new Article is




given in the introductory paragraphs and in the appended Position Papers.






        The Pennsylvania representative on the State Advisory Group (See



letter included in attachment 5)  has objected to what he considers an




attempt to force the Canadians into a PL 92-500 type law.   The Sub-Group,  how-




ever, did not agree that this is  the thrust of the Report.   The intent of  the



report is to bring the Agreement  into conformance with pollution control



programs in the U.S,









The proposed revised Article II  follows:
                               17

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                                ARTICLE  II

                 GENERAL WATER-QUAim GOALS AHD OBJECTIVES
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          27ze objective of this Agreement is to restore and maintain

the chemical physical  and biological integrity of the waters of the

Great Lakes System.  In order to achieve this objective it is hereby

agreed that consistent with the provisions of this Agreement: -

     (a)  It is the goal that minimum treatment requirements for

          discJiargcrs  of pollutants into boundary waters and tributary

          waters of the Great Lakes System be met no later than
     (b)  It is the policy that the  discharge of toxic pollutants in toxic amounts

          be prohibited and that as  an ongoing goal, the discharge of any or all

         persistent toxicants  be reduced to the maximum feasible extent.
                                        IS

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(a)  Financial assistance to construct publicly owned waste treat-



     ment works be provided by a combination of localj  state and



     federal participation.



(d)  Great Lakes Systemuide planning processes  and best management




     practices be developed and implemented to  assure adequate



     control of all sources of pollutants.





(e)  A major research  and demonstration effort  be  mads  to develop




     technology necessary for an understanding  of  the Great Lakes



     and to eliminate  the discharge  of pollutants  to  the boundary



     waters and the, tributary waters of the  Great  Lakes System,
                              19

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DISCUSSION OF ARTICLE III
     As discussed in Article II,  The General Water Quality Objectives are
proposed to be included in Article III along with the Specific Water Quality
Objectives.
     Revised General Water Quality Objectives as recommended by the Great Lakes
Water Quality Board are proposed.
     Revised Specific Water Quality Objectives essentially as recommended by
the Great Lakes Water Quality Board are proposed.
     Revisions to Annex 1 are related to the Specific Water Quality Objectives
of this Article.  Annex 1 (as are the other Annexes)  is discussed separately
and follows the corresponding revised Article for convenience of the reader,
rather than as an attachment at the end of the Agreement.
     Significant change is proposed in the specific Water  Quality Objectives
to bring the concept of a minimum level of treatment into  the Agreement.   The
rationale for this is discussed in the Position Paper on Water Quality Objectives
which is attached to this Report.
     The Revised Article III and a discussion of Annex 1 and revisions thereto
follow:
                          20

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                              ARTICLE III


                           - WATER QUALITY OBJECTIVES



1.        The following general water quality objectives for the


waters of the Great Lakes System are adapted agreed upon.  These waters


should be:


      (a)  Free from substances that enter the waters as a result of


           human activity and that will settle to form putrescent or


           otherwise objectionable sludge deposits, or that will ad-


           versely affect aquatic life or waterfowl;


      (b)  Free from flotsam fieafeing-debris and other floating mate-


           rials such as oil, scum, and immiscible substances entering


           fehe-watep-as-a-j?esttlfc-©£ resulting from human aefcivity activities in


           amounts stiff ieienfe—fee-be that are unsightly or deleterious.


      (c)  Free from materials andjheat entering the waters as a result


           of human activity pseeaeing that atone, or in combination with


           other materials,  will produce colour, odour, taste, or other

                                                         •
           conditions in such a degree as to effeate-a-mjiaanee interfere


           with any beneficial uses;


      (d)  Free from substances materials and heat entering the waters


           as a result of human activity in eeneenfe*a-feiens—fehafe-are that


           alone,  or in combination with other materials, will produce


           conditions that are toxic or harmful to human, animal or


           aquatic life.


      (e)  Free from nutrients entering the waters as a result of human


           activity in eeneentsetiens amounts that create Rttisaaee growths


           of aquatic wee^s-ane-aigae plants that interfere with beneficial


           uses.

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2.  The specific water quality objectives for the boundary waters of the

Great Lakes System and minimum treatment requirements for the boundary-

waters of the Great Lakes System set forth below and in Annex I are adopted

agreed upon:

    (a)  The minimum treatment requirements  and specific water quality

         objectives may be modified  and  additional specific water qual-

         ity objectives -fo-g- feke benndasy wates-ef -tfee -Gr-eat -Lakes -S-y-s-

         -tem -or -&av partieirta-r a-eefriens  fchese©£ may be adepted agreed

         upon by the Parties  in accordance  with the provisions of

         Articles IX and XII  of this Agreement.

    (b)  The minimum treatment requirements  and the specific water

         quality objectives adopted  pursuant to this Article repre-

         sent the minimum levels of  treatment and the minimum  desired

                 l-water quality-in .fche  feeundeey- wa*e*s- of- t-he- 0&&a£-

               •System* and are not' intended to preclude the establishment

         of more stringent requirements.
                                                                  •
    (c)  Notwithstanding the  adeptien-ef- agreement onminimum  treat-

         ment requirements and specific  water quality objectives, all

         reasonable and practicable measures shall be taken to maintain

         the ±evels-e€ water  quality existing at the date of entry into

         force of this Agreement in  those areas •&£ -t-he betjtt£aj?y -watjw*

         -of the- Croafe- Lakes- S-y-s-fcea where such leveis-eseeed-the water

         quality is better than that prescribed by the specific water

         quality objectives.

    (d)  In areas designated  by the appropriate jurisdiction as having

         outstanding natural  resource value  and which have existing

         water quality better than that  prescribed by the specific water

         quality objectives,  that water  quality should be enhanced.
                             22

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DISCUSSION OF ANNEX I



     The Great Lakes Water Quality Board in their Annual Report for 1975 made




certain recommendations for the adoption of new objectives to the International




Joint Commission.   The Commission has already held hearings on the objectives but



has not made a recommendation to the Parties.  In view of this and in view of the




fact that the Senior Review Group proposes to hold hearings on the revisions to




the Agreement it appears that it would be an appropriate time to act upon the




recommendations of the Board.  Accordingly it is proposed that Annex I be re-



organized substantially as recommended in the 1975 Annual Report of the Water




Quality Board.  The contents of Tables 17 and 18 of the Water Quality Board Report




have been incorporated into the proposed revision to the Annex.  The original




Annex I is not reproduced since this is a complete revision and reorganization of




the existing Annex and the Tables from the Board Report and reflects both the new



and old material.   New material is done in script and existing material brought




forward is done in regular type.  The asterisk   items are proposed for further  study.




Existing criteria for iron and temperature are continued in the revised Annex and are



shown in regular tyge.






     The specifics of the "minimum treatment" concept are proposed in paragraph  3



and as previously indicated, the rationale for this is discussed in the Position Paper



on Water Quality Objectives attached to this report.






     The majority of Sub-Group A recommends that the radioactivity objective be  included



in this Annex as had previously been recommended to the Parties by the U.S. and  Canadian




Advisory Groups onuRadioactivity.  The rationale for this recommendation is contained



in the Position Paper on Radioactivity attached to this Report. Controversy still



surrounds this matter .and the various views are discussed in the Position Paper  on



Radioactivity appended to this Report.
                                     23

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                              ANNEX 1

                     SPECIFIC WATER QUALITY OBJECTIVES

1,  Specific Objectives,  The Specific Water Quality Objectives  for the boundary
waters of the Great  Lakes System are classified as follows  and defined in para-
graph 2 of this  Annex.
    (a)      Chemical Characterint ics
            (1)  Persistent Toxic Substances

                 a.    Organic
                      (i)  Pesticides
                                Aldrin/Dieldrin
                                Chlordane
                                DDT and Metabolites
                                Endrin
                                Heptachlqr
                                Lindane
                                Methoxychior -
                                Toxaphene

                      (ii) Other Compounds  -
                                Phthalic Acid Esters
                                Polychlorinated Biphenyls
                                Other Organic Contaminants

                 b.    Inorganic

                      (i)  Metals

                                Arsenic
                                Cadmium i
                                Chromium
                                Copper J[_
                                Iron
                              .  Lead "  ^
                                Mercury"
          '                      Nickel *
                                Selenium
                                Zinc

                      (ii) Others

                                Fluoride
                                Total Dissolved Solids

            (.2)   Non-persistent Toxic Substances
                     t
          ''_~      a.   Organic

                      (i)  Pesticides

                                General  Objective
                                Diazinou
                                Guthion  *
                                P.ir.ithior, *
                                 24

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                (ii) Other Compounds
                          Cyanide *-
                          Oil and Petrochemicals
                          Unspecified Non-Persistent Toxic
                            Substances and Complex Effluents
                              i
           b.  .  Inorganic
                     Ammonia *
                     Chlorine *
           •          Hydrogen Sulfide*
      (3)   Other Substances
           a.    Dissolved Oxygen
           b."  PH
           c.    Nutrients             ,   •
                (i)   Phosphorus  *
           d.    Tainting Substances
(b)   Physical Characteristics
      (1)   Settleable and Suspended Solids and Light Transaission
      (2)   Temperature *
      (3)   Asbestos
      (4)   Radioactivity
(c)   Microbiological Characteristics
*Speci£ic water quality objective  for  further immediate consideration by
 the International Joint Commission  for recommendations of definitions to
* the-Parties
                                  25

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2.   Definition of Specific Objectives.  The specific water quality objectives
for the boundary waters of the Great Lakes System, listed in paragraph  1  are
defined as  follows:

                                    PESTICIDES  (PERSISTENT)


               A Idrin/Die Idrin
               The sum of  the concentrations of aldrin and dieldrin  in
               water should not exceed the recommended quantifi-
               cation limit of 0.001 micrograms per litre.  The sum  of
               concentrations of aldrin and dieldrin in the edible
               portion of fish should not exceed 0.5 micrograms per
               gram for the protection of human consumers of fish.

          Note I  Based on U.S. Food and Drug Administration guidelines.


               Chlordane
               The concentration of chlordane in water should not
               exceed 0.06 microgrcms per litre for the protection
               of aquatic life.
               DDT and Metabolites
               The sum of the concentrations of DDT and its metabolites
               in water should not exceed the recommended quantifi-
               cation limit of 0.003 micrograms per litre.  The sum of
               the concentration of DDT and its metabolites in whole
               fish (wet weight basis) should not exceed 1.0 micro-
               grams per gram for the protection of fish consuming
               aquatic birds.
               Endrin
               The concentration of endrin in water should not exceed
               the recommended quantification limit of 0.002 micrograms
               per litre.   The concentration of endrin in the edible
               portion of fish should not exceed 0.3 micrograms per
               gram for the protection of human consumers of fish.

          Note:  Based on U.S. Food and Drug Adminiscration guidelines.
             Heptachlor
             The sum of the concentrations of heptachlor and hepta-
             chlor epoxide in water should not exceed the
             recotnmended quantification  limit of 0.001 micrograms
             per litre.  The sum of the concentrations of heptachlor
             and heptachlor epoxide in edible portions of fish
             should not exceed 0.3 micrograms per gram for the
             protection of human consumers of 'fish.

        Note:  Based on U.S. Food and Drug Administration guidelines.
                                   26

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                        PESTICIDES  ((Tont'd)
     Lindane                                ,  , •»    .      j
     The concentration of Undone in water should not exceed.
     0.01 micrograms per litre for the protection of aquatic
     life.  The concentration of lindane in edible portions
     of fish should not exceed 0.3 micrograms per gram for
     the protection of human, consumers of fish.

Note:  Based on U.S. Food and Drug Administration guidelines,
     Methoxuchlor                                     ,
     The concentration of methoxychlor in water shou^a not
     exceed 0.04 micrograms per litre for the protection of
     aquatic life.


     Toxaphene                                        ^
     The concentration of  toxaphene  in water should no*
     exceed 0.008 microgrcms per  litre for  the protection
     of aquatic life t

                 OTHER PERSISTENT  TOXIC SUBSTANCES

      Phthalic Acid Esters •
      The concentrations of dibutyl phthalate and di(2-
      ethylhexyl) phthalate in water should not exceed 4.0
      micrograms per litre and 0.8 microgrcms per litref
      respectively, for the protection of aquatic life.
      Other phthalic acid esters should not exceed the
      recommended quantification limit of 0.2 micrograms per
      litre in waters for the protection of aquatic life.
     	j L_ _ _..	!_-„_,_-	 	 _    - _   	 --_... ."_-- .—-  *--	.— -  —- — .--	-j-.._m._i	-i_-»-_.-^	

      Polychlorinated Bipheny Is (.PCBs}
      The concentration of total poly chlorinated biphenyls
      in fish tissues (whole fish3 calculated on a wet
      weight basis•), should not exceed 0.1 micrograms per
      gram for the protection of fish consuming birds and
      animals.

 Note;
   The detection limit for PCBs in water samples is not  low enough
   to permit setting a water quality objective for concentrations
   in water.   Therefore the proposed  objective is based  on levels
   detectable in fish tissue.   It is  believed that water concen-
   trations less than 0.001 micrograms per litre would be required
   to preclude significant  bioaccuinulation of PCBs.

   The U.S. Food and Drug Administration has set an administrative
   guideline of 5 micrograms  per gram of PCB as  the maximum levels
   acceptable in the edible portion of fish for  human consumption.
   The  Canadian Department  of  National Health and Welfare  has set
   a sjLcrilar guideline at 2 micrograms per gram,.of PCB.   The above
   defined limitation is  a  more  stringent  objective  for the  Great Lakes  to
   protect birds and animals whose main  diet consist of  fish from the
   lakes.

                           27

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             OTHER PERSISTENT TOXIC SUBSTANCES
Note:  ^Continued}
  Under Sec 307Ca)  of PL  92-500, US EPA has recently promulgated
  regulations to control  PCB,  in the transformer/capacitor industry.
  The FDA has proposed that  the administrative guideline of five
  micrograms per gram of  PCB in fish flesh Be lowered to two micrograms
  per gram.
     Other Organic Contamln
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                    METALS (Cont'd)
Lead
Concentrations of total lead in an unfiltered water
sample should not exceed 10 micrograms per  litre in
Lake Superior, 20 micrograms per litre in Lake Huron
and 25 micrograms per litre in all remaining Great
Lakes to protect aquatic life.

Mercury   ~                 ~ '           •	~~	
Concentrations of total mercury in a filtered water sample
should not exceed 0.2 micrograms per litre  nor should the
concentration of total mercury in whole fish exceed 0.5
micrograms per gram (wet weight basis)  to protect
aquatic life  as well as fish-consuming birds.
Selenium
Concentrations of total selenium in an unfiltered water
sample should not exceed 10 micrograms per litre to
protect raw water for public water supplies.
Zina
Concentrations of total zinc in an unfiltered water
sample should not exceed 30 micrograms per litre to
protect aquatic life.
             OTHER PERSISTENT TOXIC INORGANICS

Fluoride
Concentrations of total fluoride in an unfiltered water
sample should not exceed 1.2 milligrams per litre to
protect raw waters for public water supplies.

Total Dissolved Solids.    In  Lake Erie,  Lake Ontario
and  the International  Section of the St.  Lawrence
River, the  level of total dissolved solids  should  not
exceed 200  milligrams  per litre.    In  the  St. Clair
River, Lake  St. Clair,  the Detroit River and the
Niagara River,  the level should be consistent with
maintaining  the levels of total dissolved solids  in
Lake Erie and Lake Ontario at net to exceed 20-0 milli-
grams per litre.   In  the remaining boundary waters,
pending further s'tudy,  the. level of total dissolved
solids should not  exceed present levels.
                        29

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          .ORGANIC   PESTICIDES  (NON-PERSISTENT)

General Objective                                _      ...
Concentrations of unspecifiedf non-persistent organic pesticides
should not exceed 0.05 of the median lethal concentration
in a 96-hour test for any sensitive local species.
Diazinon
The concentration of Diazinon in an unfiltered water
sample should not exceed  0.08 micrograms per litre.
                   OTHER NON-PERSISTENT TOXIC ORGANIC SUBSTANCES

 -/
Oil and Petrochemicals
Oil and petrochemicals should not be present in concen-
trations that:
1)   can be detected as visible film, sheen or dis-
colouration on  the surface;
2)   can be detected by odour;
3)   can cause  tainting of fish or edible
invertebrates;
4)   can form deposits on shorelines and bottom
sediments • that  are detectable by sight or  odour, or
deleterious to  resident aquatic organisms.


Unspecified Non-Persis tent Toxic Substances  and Complex
Effluents
Unspecified non-persistent toxic substances  and complex
effluents of municipal3 industrial or other  origin should
not be present  in  concentrations which exceed 0.05 of the
median lethal concentration (96-hour LCSO) for any
sensitive local species to protect aquatic  life.


                OTHER  SUBSTANCES
 Dissolved Oxygen.    In the Connecting  Channels and  in
 the upper waters of the  Lakes,  the dissolved  oxygen
 level  should  be not less  than 6.0 milligrams  per litre
 at any time;   in hypolimnetic waters,  it should be  not
 less than necessary for  the support of fishlife,
 particularly  cold water  species.
 Values of pH should not be  outside the range of 6.5  to
 9.0,  nor should discharges  change, the pH at the boundary
 of the designated mixing zone more than 0.5 units from
 the ambient.

                       30

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                          OTHER SUBSTANCES (Cont'd)
     Phosphorus  (P).    Concentrations should be  limited to
     the  extent  necessary  to prevent  nuisance growths  of
     algae,  weeds and slimes that are or may become  injurious
     to any  beneficial water use.

     Tainting Substances
     1)  Raw public water supply sources  should be essentially
     free from objectionable taste  and odour for aesthetic
     reasons.
     27  Substances entering the waters as  a result of human
     activity that cause tainting of edible aquatic organisms
     should not be present in concentrations which will lower
     the acceptability of these organisms as determined
     by organoleptic tests.
                         PHYSICAL CHARACTERISTICS
      Settleable and Suspended Solids and Light Transmission
      for the protection of aquatic life, waters should be free
      from substances attributable to municipal, industrial or
      other discharges resulting from activity that will
      settle to form putrescent or otherwise objection-
      able sludge deposits or that will 'alter the value
      of the Secchi disk depth by more than 10 percent.

      Temperature .
     Asbestos
     Asbestos should be  kept at the lowest practicable
     levels and in any event should be controlled to the
     extent necessary to prevent harmful effects on health.

Radioactivity .

             The specific water quality objective for radioactivity in  the
Great Lakes is  that level of radioactivity which results in a wholebody
dose commitment not exceeding one millirem due to the ingestion of water
in any one year.  Source  investigation and corrective action if releases are
not as low as reasonably  achievable are recommended for dose commitments between
1 and 5 millirem.  For dose commitments greater than S millirem corrective action
by the responsible regulatory authorities is recommended.
                            31

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                 MICROBIOLOGICAL CHARACTERISTICS


Microbiology.   The geometric mean  of  not less  than
five samples taken over not nore  than  a  thirty-day
period should not exceed  1,000/100  millilitres  total
co.liforms, nor 200/100 millilitres  fecal coliforms.
VJaters used  for body contact recreation  activities
should be substantially free from bacteria,  fungi,  or
viruses that may produce  enteric  disorders  or eye,  ear,
nose, throat and skin infections  or other human
diseases and infections.
                         32

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        3.   Minimum  Levels of Treatment.   To  accomplish these objectives,  the Parties




        shall require the  following:



                  a. municipal sources shall  be provided a minimum  level of




                     treatment which shall produce an effluent described as



                     follows:



                     —BODs     30 day arithmetic mean,  30 mg/l



                                7 day. arithmetic mean,   45 mg/l



                                plus not less-, than 85% removal (30 day period)



                     --TSS     30 day arithmetic mean,  30 mg/l



                                7 day arithmetic mean,   45 mg/l




                                plus not less than 85% removal (30 day period)



                     ~PH       6.0 to 9.0 '



                     —Total Phosphorus (P) I mg/l maximum




                     —Disinfection, as required to:




                                1) protect potable water supplies



                                2? protect aquatic life




                                3) protect irrigation and agricultural waters



                                4) protect waters where human contact is likely



         Where such treatment is inadequate to  meet water quality standards



         or to meet the objectives of this Agreement, additional treatment shall



         be required.   .__



                 b.  Industrial sources shall be provided a minimum level



                     of treatment that shall produce an effluent consistent



                     with  the best practicable control technology currently



                     available for that industry.  Where such treatment is




                     inadequate to meet water quality standards or to



                     meet  the objectives of this Agreement, additional



- M                   treatment shall be required.





                                        33

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- 6.   Sa mp 1 i ng  Pat a .    The  Parties agree  that the determination  of
compliance with specific objectives  shall  be based on statistically
valid sampling data.


 7 .   Mixing Zones
      The responsible regulatory agencies may designate
      restricted mixing zones in the viciniuj of outfalls
      within which the specific water quality objectives
      shall not apply-  Mixing  zones shall  not be
      considered a substitute for adequate  treatment or control
      of discharges at their source.

      The following guidelines  should be used in. the
      designation of mixing zones.
          A mixing zone is an area,  contiguous  to a point
      suurcs, where exceptions to water quality  objectives and
      conditions otherwise applicable to the receiving water-.
      body may be granted.
          Specific water quality objectives  and conditions
      applicable to -he receiving waterbody  should be met at
      the boundary of mixing zones.
     {<•)'  Limitations on mixing zones should be  established by
       trie responsible regulatory agency  on a case-by-case basis3
       where  "case" refers to both local  considerations and the
       waterbody as a whole, or segment of the waterbody.

      (d)  Mixing zones, by definition, represent a  loss of  -
       value.

      (e)  Many of the general water quality  objectives should
       apply to discharge-related materials within mixing zones.
       The zones should be free of:
           (1)  objectionable deposits;
           ^jj  unsightly or deleterious amounts of flotsam3
                debris, oil,  scion and other  floating matter;
           (3)  substances producing objectionable  colour, odour,
              " taste, or turbidity;  and
           (4}  substances and conditions or combinations thereof
                at levels which produce  aquatic  life in nuisance
                quantities that interfere with other uses.
                             34

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 (f)    No conditions within the mixing zone should be permitted
  which are either (a) rapidly lethal to important aquatic
  life (conditions which result in sudden fish kills arid mortality
  or organisms -passing through the mixing zone) ; or Cb) which cause
  irreversible responses which could result in detrimental post-
  exposure effects; or (c)  which result in bio concentration of
  toxic materials which are f armful to the organism or its
  consumers .
       Concentrations of toxic materials at any point in the
  mixing zone where important species are physically capable
  of residing should not exceed the 24 to 96-hour LC50.

 (h)   When designing conditions to protect specific organisms
  it is necessary to know that the organisms would normally
  inhabit the area within the mixing zone.   Zones of passage
  should be assured either by location or design of conditions
  within mixing zones.   Mixing zones should not form a barrier
  to migratory routes of aqua'ic cyjcies or interfere with
  biological communities or populations of irrrportant species,
  to a degree which is damaging to the ecosystem, or diminish
  other beneficial uses disproportionately.
(.i)   Mixing zones may overlap unless the combined effects
 exceed the conditions set forth in other guidelines.

(j)    Municipal and other water supply intakes and
 recreational areas should not be in mixing zones as a
 general condition, but local knowledge of the effluent
 characteristics and the type of discharge associated
 with the zone could allow such a mixture of uses.

(k)   Areas of extraordinary value may be designated off-
 limits for mixing zones.

(I)   Tne size, shape and exact location of a mixing zone
 snould be specified so that both the discliarger and the
 regulatory agency know the bounds.

(m)    Existing biological,  chemical, physical and hydro-
' logical conditions should be known when considering location
 of a new mixing zcne or limitations on an existing one.
                          35

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                         s-r -- There
   — axea r-trivg-h -a-s
-wkore  existing  cQadafca^n-s^s-aeJ^^as—±a**4-
    *yp\yant—the—objectives—£rom -being  me-fe
       	«-»* >^i>\ __-f\ +i-^ -* r-  V^^\T.Tr!% ^r^i *^ v«»
              -a-s- possib.le  by the
                    and, uco  wi-U. -p
                                            aec9*d-aflee-wi-th—Ar-ticie  V'SIIr
  5.     Special Areas.  In addition to mixing zones there will be other areas
  where objectives will  not be met as follows:

        (a)  NATURAL AREAS - Areas that do not meet water quality objectives
                           due to natural conditions.

        (b)  PROBLEM AREAS - General geographical locations where water
                           quality objectives and/or standards are not being
                           met.  The water quality in these locations can be
                           improved through remedial measures.
7.  Flow Augmentation.

   The responsible regulatory agencies  shall not consider flow augmentation
   as a substitute for the use of adequate treatment to meet water quality
   standards.
8.      Amendment.

       (a)  The objectives  adopted agreed to herein shall be kept under
            review and may be amended by mutual agreement  of
            the Parties.

       (b)  Whenever  the International Joint Commission, acting
            pursuant  to Article VI  of the Agreement,  shall
            recommend the establishment of  new or modified
            specific  water quality  objectives, this  Annex  shall
            be amended in accordance with such: recommendation
            on the receipt by the Commission of a letter from
            each Party indicating its agreement with the
            recommendation.

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DISCUSSION OF ARTICLE IV



     The changes proposed in this Article relating to standards and other



regulatory requirements are made to be consistent with the proposed changes




in Articles II and III.                   .                 . •+ .         ...



     The revised Article IV follows:
                                      37

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                                ARTICLE IV
          STANDARDS AND OTHER REGULATORY REQUIREMENTS

          Water quality standards and other regulatory requirements  of the
Parties shall be consistent with the achievement of the wate?-quality-efejeetives
objectives and goals of this Agreement.   The Parties shall  use their best efforts
to ensure that water quality standards and other regulatory requirements of the
State and Provincial Governments shall similarly be consistent with  the achieve-
ment of the water-qnality-ebjeefeivesT objectives and goals  of this Agreement.
                                     38

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 DISCUSSION OF ARTICLE V
      This Article on programs and other measures is really the heart  of the
 Agreement.  It is here in addition to the revised Article II and III  that the
 philosophical difference between the U.S. and Canadian programs must  be also
 dealt with if we are to get an effective control program for the entire
 Great Lakes System..

      Significant changes are proposed in the wording of Article V to  conform
,to the philosophy of "minimum treatment requirements" conforming to the
 recommendation in the Position Papers on Water Quality and Point Source Dis-
 charges appended to  .this Report.

      No change is necessary in the paragraph on, "Phosphorus", but  a  completely new
 Annex 2 is proposed  dealing with this subject as recommended in the Position
 Paper on Phosphorus  appended to this Report.
                                     .
      Changes in wording are proposed in the paragraph dealing with non-point
 source pollution conforming to the recommendations in the Position Paper on
 Non-Point Sources appended to this Report.

      Several wording changes have also been proposed conforming to recommendations
 by Sub-Group B related to pollution from shipping activities.

    .. No change is proposed, in the paragraph on dredging but further comments
 are presented in the discussion of Annex 6.

      No change is proposed in the paragraph on Pollution from Onshore and
 Offshore Facilities  but additional commentary is provided in the discussion
 of Annex 7.
                                     39

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     Comments related to the paragraphs on Contingency Plans are presented
in the discussion of Annex 8.

     Changes are suggested in the paragraph on Hazardous Polluting Substances.
It is further proposed that the Annex 9 developed by the Work Groups under the
original Agreement be included in the new Agreement.   Further discussion
 is provided  in the Position Paper on Hazardous Substances  appended to
this report.

     Article V appears to be where the question of pollution of the  lakes  from
 atmospheric fall-out should be dealt with.  (Parts of the  Agreement  dealing with
 research have also been revised to include air pollution.)
     A section on Surveillance has been added based on the recommendations
in the 'Position Paper on Surveillance appended    this Report.

     Other self-explanatory changes are also proposed,
                                    •
     Although responsibility for Position Papers dealing with Annexes 3,
4, 5, 6, 7 and 8 was given to other Sub-Groups, Sub-Group A was asked to
comment on these . Annexes and the Position Papers of Subgroups B, C, and D and
accordingly these comments are provided in separate discussions.

     The revised Article V and separate discussions and revisions to Annexes
3 through 9 follow:
                                  40

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                                ARTICLE V

                        PROGRAMS AND OTHER MEASURES

1.        Programs and other measures directed toward the achievement of the
wates quality goals and objectives shall be developed and implemented as soon
as practicable iH-aeeei?danee-witk-legisla€ieB-iH-feke--fewe-eeHHtriesT--UHiess-
fallowing* on all point and non-point sources of pollution in the Great Lakes
System.  Polluti.cn control programs and measures in both Countries should be
fully compatible in all respects -including mimimum levels of treatment 3 maximum
schedules of compliance, breadth 'of program implementation and public account-
ability.  These pollution control programs and other measures shall be imple-
mented and completed in the shortest possible time but no later (date to be
negotiated) .   The programs and measures shall include the following:

     (a)  Pollution from municipal Sources.  Programs for the abatement
          and control of discharges of municipal sewage into the Great Lakes
          System including:

          (i)  construction and operation in all municipalities having
               sewer systems of waste treatment facilities providing
               levels of treatment consistent with the achievement of the
               watea? quality objectives, including minimum prescribed levels
               of treatment and phosphorus removal, taking into account the
               effects of waste from. other sources with additional treatment
               if the achievement of prescribed water quality so requires.

         (ii)  provision of financial resources to assist prompt construction
               of needed facilities;

        (iii)  establishment of requirements for construction and operating
               standards for facilities;

         (iv)  requirements for the control of the discharge of toxic
               pollutants into the Great Lakes Basin thru comprehensive
               programs;

           (v)  measures to find practical solutions for reducing pollution
               from overflows of combined storm and sanitary sewers;

         Cvi}  embodiment of all pollution abatement requirements including
               schedules, monitoring and effluent restrictions in a single
               document that is periodically reviewed and placed before the
               public;

        (vii)  monitoring and surveillance activities necessary to ensure
               compliance with the foregoing programs and measures;

        (viii)  establishment of effective enforcement programs to ensure
               the above pollution abatement requirements are fully met.
                                41

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b.  Pollution from Industrial Sources.  Programs for the abatement and
    confirol of pollution from industrial sources, including:

    (i)  establishment of waste treatment or control requirements for
         all industrial plants discharging waste into the Great Lakes
         System, to provide levels of treatment   ---
         ©f -wast e-f sen -efches-seuseesfr at least as restrictive as best
         practicable control technology currently available.
         establishment of pre-treatment requirements for all industrial
         plants discharging waste into publically owned treatment works;
  (iii)
          requirements  for  the  control of the  discharge of toxic
          pollutants into the Great Lakes Basin  thru comprehensive
          programs;

    (iv)   embodiment of all pollution abatement  requirements including
          schedules,  monitoring and effluent restrictions  in a single
          document  that is  periodically reviewed and placed before  the
          the public;

     Cv)   establishment of  effective, enforcement programs  to ensure the
          abdve pollution abatement requirements are fully met.
c.
    (vi)  measures to control the hauling and disposal of toxicants by
   _ _    contract disposal services.


   (vii)  requirement: that intake and discharge  structures be designed
         to  avoi,d any adverse environmental effects.


   Eutrophication   Measures for the control of inputs of phosphorus
   and other nutrients including programs to reduce phosphorus inwts
   in accordance with the provisions of Annex 2       u*P™rus inputs,
                        42

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(d]   Pollution from Agricultural, Forestry and Other Land Use Activities.
     Measures for the abatement and control of pollution from agricultural,
     £e£es-&£y-aR4-&tke-£-laRd-usa-aetivi£iesT-iH6ludiHg* agriculture,
     forestry practices,  road construction, mining,  urban development,
     urban drainage, and other land use act-i-VL.ti.es.

     Ci)  measures for the control of pest control products  (pesticides)
         with a 'view to limiting inputs into the Great Lakes System,
         including regulations to ensure that pest control  products
         judged to have long term deleterious effects on the quality
         of water or its biotic components shall be used only as
         authorized by the responsible regulatory agencies, and that
         pest control products shall not be applied directly to water
         except in accordance with the requirements of the  responsible
         regulatory agencies;

    Cii)  measures for the abatement and control of pollution from
         animal husbandry operations, including encouragement to
         appropriate regulatory agencies to adopt regulations governing
         site selection and disposal of liquid and solid wastes in order
         to minimize the loss of pollutants to reseiving waters;

   liii)  measures governing the disposal of solid wastes and
         contributing to the achievement of the water quality
         objectives, including encouragement to appropriate regu-
         llatory agencies to ensure proper location of land fill/- arid
         land dumping sites and regulations governing the disposal on
         land of hazardous polluting substances;

         advise3?y-p3?eg5a»s-aHd-HeasH3?es-£hafc-sea?ve-fce-abate-aHd
         aetivities.

         advisory programs and measures that serve  to abate and control
         inputs of nutrients, sediments,  and other  pollutants into
         receiving water from agriculture,  forestry practices, road
         construction,  mining, urban development, urban drainage and
         other land use activities including encouragement to appro-
         priate agencies to  adopt and implement Best Management
         Practices .

  (e)   Polluti o^ from Shipping Activities..    Measures  for  the
       abatement and .control of  pollution from shipping sources,
       including:

       (i)'   programs  and compatible regulations  for vessel
             design,  construction and  operation,  to prevent
             discharges of harmful quantities  of  oil and
             hazardous polluting  substances,  in accordance with
             the  principles  set forth  in Annex 3;

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    (ii)   compatible regulations for the control of vessel
          waste discharges in accordance with the principles
          set forth in Annex 4 ;

   (iii)   such compatible regulations to abate and control
          pollution from shipping sources as may be deemed
          desirable in the light of studies to be undertaken
          in accordance with the terms of references set
          forth in Annex 5;
                 ^^-       ^j   shove
    (iv)   programsTfor the saTe and ef f icient "handling" ~6i:
          shipboard generated wastes, including oil,
          hazardous polluting substances, garbage, waste
          water and sewage, and their subsequent disposal,
          including any necessary compatible regulations
          relating  to the type, quantity and capacitv^gf
          shore reception facilities -in aannrdanGejJi-th. the
          ;set for tn' in 'Annexes 3 and ^f                   -  -
     (v)   establishment of a coordinated system for the
          surveillance and enforcement of regulations
          dealing with the abatement and control of pollution
          from shippinq activities.
(f)  Pollution from Dredging Activities.    Measures for  the
    abatement and  control of pollution from dredging
    activities,  including the development of criteria for
    the  identification of polluted  drc'dged spoil and com-
    patible programs for disposal of -polluted dredged spoil,
    which shall be considered in the light of the review
    provided  for in Annex 6;  pending the development of
    compatible criteria and programs,  dredging operations
    shall be  conducted in a manner  that will minimize
    adverse effects on the environment.

(g)  Pollution from Onr.horo and Offshore Facilities.
    Measures  for the abatement and  control of pollution from
    onshore and offshore facilities, including programs and
    compatible regulations for the  prevention of discharges
    of harmful quantities of oil and hazardous polluting
    substances, in accordance with  the principles set forth
    in Annex  7.
 (h)   Contingency Plan.    Maintenance of a joint contingency
      plan lor use in the event of a discharge or the
      imminent threat of a discharge of oil or hazardous
      polluting substances, in accordance with the provisions
      of Annex 8.
                            44

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            Hazardous Polluting Substances.
2.
            purp9se-e£-devel9piHg KpTementatitrrvf -ZK- Annex If identifying,
            hazardous polluting subs tances~7 'Tire Parties shall" further  con-
            sult from time to time for the purpose of revising the list of
            hazardous substances,  of identifying harmful quantities of these
            substances and of reviewing the definition of "harmful quantity
            of oil" set forth in Annexes 3 and 7.
              a               ->
       (j)   Pollution from Atmospheric Fallout.   Programs and measures from the
            identification ana control of water pollution caused by transfer of
            pollution from the atmosphere.


t          Notwithstandir^! the proceeding surveillance monitoring and  analysis  re-
quirements a coordinated," bilateral program that will meet the following  oojectives:

       (a)  'Surveillance.  Programs to detect excursions from objectives to
            determine water quality trends and to describe and quantify  cause and
            effect  relationships, specifically;

             (i)  Surveillance to detect excursions  from water quality  objectives  for
                  parameters  with numerical limits.

            (ii)  Surveillance to determine water  quality  and biological trends  for the
                  purpose of evaluating compliance with the  non-degradation requirement
                  and determining long-term effects  of remedial programs.

           (Hi)  Surveillance, to describe and quantify cause (loads) and effect
                   (water quality) relationships to understand how the  Great Lakes
                  physical, biological and chemical system operates.   Together
                  with mathematical modeling, this forms the' basis for determining
                  whole lake response to remedial programs,   the need for  new re-
                  medial programs such as the phosphorus control program, alter-
                  ing or establishing new water quality objectives,  "and a means
                  to detect new and emerging problems.

            (iv)  Surveillance to include quality  assurance  programs to provide  for
                  sampling and analytical methodology,  inter-laboratory comparisons, and
                  compatible  date, management.


       (I)   Sample  Collection, Analysis., Evaluation and Quality Assurance.  As  a minimum
   the program will include sufficient sample collection, analysis and evaluation in-
   cluding  quality  assurance  to allow assessments of the following:

           (i)   Inputs  from tributaries, point source discharges,  atmosphere,  and
                connecting cliannels.

          (ii)   Whole Lake including nearshore areas, such as harbors and embayments,
                general shoreline and cladophora growth area, open waters  of the Lakes,
                fish contaminants, and wildlife contaminants.

         (Hi)   Outflows including connecting channels water intakes and outlets.

          (iv)   Point  source  discharges  including detailed process evaluation for
                critical industries.

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3.          The Parties shall develop and implement such additional programs
as they jointly decide are necessary and desirable for the achievement of the
water quality goals and objectives.

4.          The programs and other measures provided for in this Article shall
be designed to abate and control pollution of tributary waters where neeessary-
er desirable f-er the achievement ef the water quality ebj-eetives f-er the boundary
waters of the Great Lakes System.
                                   46

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DISCUSSION OF ANNEX 2






     A completely revised Annex on control of phosphorus is proposed, as



recommended in the Position Paper on Phosphorus appended to this Report.






     The Sub-Group recognizes the difficulties that have been experienced



in attempting to control phosphorus and agrees with the  Position Paper that a




phosphorus control program is still valid.  The Sub-Group particularly takes



note of and concurs with the recommendation for:




     — a phosphorus limit in household detergents



     — a phosphorus effluent limitation



     — development of phosphorus load allocations






     The proposed new Annex 2 follows:
                                     47

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                          ANNEX  2

                     CONTROL OF PHOSPHORUS

1.      Objectives.      The  objective of the following programs is to minimize
eutrophication problems  in the boundary waters Great Lakes system.  It is
anticipated that successful  implementation of these programs will accomplish
the following results, which are  of critical importance to the success of the
joint undertaking to preserve and enhance the quality of the boundary waters
of the Great Lakes system:


         (a)  Restoration  of year-round aerobic  conditions  in the bottom
             waters  of  the  Central Basin of Lake Erie.

         (b)  Substantial  reduction in the present  levels of algal biomass  to
             a  level below  that  of a nuisance condition in Lake Erie.

         (a)  Reduction  in present  levels of algal  biomass  to below that of  •
             a  nuisance condition  in Lake Ontario  including the International
             Section of the St.  Lawrence River.

         Cd)  Maintenance  of the  oligotrophic state and relative algal bio-
             mass of Lakes  Superior and Huron;

         (e)  Substantial elimination of algal nuisance growths in Lake Michigan
             to restore it to an  oligotrophic state,

         (f)  The elimination of  algal nuisances in bays and in  other areas
             wherever they  occur.

2.      Program shall be  developed and implemented to reduce inputs of phes-
phorus to achieve the objectives.  These programs  shall include:

         (a)  Construction and operation of municipal waste treatment facil-
             ities  to achieve an effluent concentration of 1 mg/1  total
             phosphorus (P)  maximum in the Great Lakes system or such lower
             levels  as  may  otherwise be required.

         (b)  Regulation of  phosphorus introduction from industrial discharges
             to the  maximum practicable extent.

         to)  Reduction  of phosphorus introduced from non-point  sources to
             the maximum  extent  practical.

         (d)  Reduction  of phosphorus to at least 0.5 percent by weight in
              household  detergents  to' control phosphorus introductions from  raw
              or inadequately treated sewage.
                              48

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         (e)  Maintenance of a viable  research program to seek maximum effi-
             ciency and effectiveness -in the  control, of phosphorus introduc-
             tions into the Great Lakes.

 3.       Reductions for the Great Lakes.   In additions  the above stated
 programs are designed to control input of phosphorus to the Great Lakes
 system,  which will, or are,  projected to maintain ollgotrophlc conditions
 and reduce  eutrophic  conditions in other areas.   To meet all of the objectives
 of the phosphorus control program accurate phosphorus loadings and lake load
 limits must be  estimated:

         (a)  The Parties, in cooperation with the State and Provincial
             government and with, the  International Joint Commission,  shall
             within one year through  the joint scientific effort of the
             applicable jurisdictions,  estimate the phosphorus loading,
             lake load limits and reductions  required to meet the above
             stated objectives.   In-Lake phosphorus and chlorophyll con-
             centrations necessary to achieve the objectives are to be
             determined and included in Ar*nex 1.
         (b)  The Parties, In consultation with the State and Provincial
             Governments and with the International Joint Commission, shall
             within one year after establishing the phosphorus loading,
             determine the allocation of phosphorus on a jurlsdlctional
             basis through a joint scientific effort of the applicable
             jurisdiction.   The jurisdiction  shall also furnish phosphorus
             load allocations to eliminate nuisance plant growths In bays
             and other areas.   The jurisdictions will provide compliance
             schedules within one year after  the establishment of the
             allocations.  In some cases,  this will Include controls on
             non-point sources.
 4.      Refinement of Data.   '^ie loads shall be based upon best available
 data.   The Parties,  ^n cooperation with the  State and Provincial Governments
 and with  the International Joint Commission,  shall continue to refine these
 estimates to ensure a comparable data base.   These estimates are subject to
 revision  upon  agreement by the  Parties to  reflect future refinement of the
 data.

 5.      The Parties shall consider recommendations of the International Joint
 Corrmls&ion made  as the result of the  studies of the pollution from agricultural,
 forestry  and other land use  activities,  In order to develop and implement
 appropriate programs for control of Inputs of phosphorus from these sources.

 6.      Monitoring.   The Parties, In  cooperation with the State and Provincial
 Governments and  wi-tn the International Joint Commission,  shall continue to
 monitor the extent of cultural  eutrophic atlon In boundary waters in the Great
Lakes System and  the progress  being made in reducing or preventing it.  Thdy
                              49

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shall consult periodically to exchange the results of research and to pursue
proposals for additional programs to control cultural eutrophication.

7.      Submission of Information.  The International Joint Commission shall
be given information at least annually3 in accordance with procedures estab-
lished by the Commission in consultation with the Parties and with the State
and Provincial Governments3 concerning:

        (a)  Total reductions in gross inputs of phosphorus achieved.

        (b)  Anticipated reductions in gross inputs of phosphorus for the
             succeeding twelve months.
                               50

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DISCUSSION OF ANNEX 5






     This discussion of Annex 3,  which deals  with vessel  design,  is based




on the Position Paper of Sub-Group B.   The revision of par.  4 proposed by




Sub-Group B should include specific dates  by  which the various programs are




to be completed.   Rather than calling  for  measures "to be adopted," these




wordings should be changed to say that measures "shall be adopted by




 (specify date)	".  The lack of  time tables for these  programs was a




deficiency in the original Annex and should not be repeated  in the new



Agreement.






     For reference purposes,  a copy of the draft Position Paper of Sub-Group




B which was referred to this  Sub-Group for comment is included in attachment 3,
                                      51

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DISCUSSION OF ANNEX 4






     This discussion of Annex 4 dealing with vessel wastes is based on the




Position Paper of Sub-Group B.  The 4th Annual Report of the Great Lakes Water




Quality Board summarizes the problem with vessel wastes most succinctly and




reflects the views of the majority of Sub-Group A on this matter.  A copy of




the Board Report Summary is attached to this Report.  Apparently the only level



afwhich the conflict can be resolved is in direct negotiation with the Canadians.




The States of Wisconsin and Michigan already prohibit discharge under PL 92-500




and other states may follow suit.  Minnesota has a request pending for authority



to prohibit discharge.






     The Senior Review Group should be aware of a recent communication and




Resolution by the Michigan Wastes Resources Commission on this subject, a copy




of which is included  in Attachment 5.  This issue is one of the most controversial



on the Great Lakes.   Since some and possibly all eight Great Lakes States intend



to prohibit discharges under PL 92-500, the only way compatibility can be achieved



is if the Canadians prohibit discharge from commercial vessels.





     For reference purposes, a copy of the draft Position Paper of Sub-Group



B which was referred to this Sub-Group for comment is included in Attachment 3.
                                    52

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DISCUSSION OF ANNEX 5






     This discussion of Annex 5,  dealing  with Studies of Pollution from Shipping




Sources is based on the Position  Paper of Sub-Group B.






     Sub-Group A defers to Sub-Group B on para l.(a)  through l.Ce) since these




are subjects not within the expertise of  this Sub-Group.






     The Sub-Group B Position Paper was completely silent on paragraphs l.(f),




l.(g) and l.(e) which are of primary concern to this  Sub-Group.   These three



sub-paragraphs should be included in the  Sub-Group B  Position Paper.   The Paper




should tell what has been done regarding  study of these items and what further




needs to be done.






     Sub-Group A suggests that the Coast  Guard be required to address a full




reporting and any necessary re-writing of this Annex.  If this Annex is continued,




it should include required studies of vessel hold cleaning practices  and the



disposal of washings therefrom and also include a study of the need for shore



facilities for the reception of such vessel  washings  and other vessel waste



discharges.






     For reference purposes, a copy of the draft Position Paper of Sub-Group




B which was referred to this Sub-Group for comment is  included in Attachment 3.
                                    53
                      s.

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 DISCUSSION OF ANNEX  6

     This discussion of  Annex  6,  dealing  with dredged spoil,  is based upon the
 Position Paper of  Sub-Group D.

     A majority  of Sub-Group A agrees  with  the position taken by the Great
 Lakes Water Quality  Board  as stated  in '  the  Board's Summary Report attached
 with this  Report.

     Sub-Group A took additional note of commentary previously provided by the
 Regional Administrator of EPA Region  V  on  the  1975 Report of the  International
 Dredging Work Group and a copy  of  the Region V commentary is included in
 Attachment 5.
     In summary, Sub-Group A recommends that  dredging activities be brought
 under the purview" of a standing committee of  the Water Quality Board of the
 International Joint  Commission, and  a  further study  should be required for
 the development  of general criteria  which was called for in the original
 Agreement.
     For reference  purposes a copy of the  draft Position Paper of Sub-Group D
which was  referred  to this  Sub-Group  for comment  is included in Attachment 3.
                                    54

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DISCUSSION OF ANNEX 7






     Annex 7 "fell through the cracks" in administration of the original




Agreement.  The broad comprehensive nature of this Annex and the lack of




any defined responsibility resulted in this lack of attention.






     The Annex still appears to be needed and should be continued without



change in the revised Agreement.  To remedy the lack of defined responsibility




changes have been proposed in Article VI.  A new par l.(d) is proposed and re-



porting on Annex 7 as well as other Annexes by the International Joint Commission




is proposed in a change to Par 3.  Furthermore Sub-Group A concurs in a recommen-



dation by the Water Quality Board to establish a standing committee under its



purview to deal with Annex 7 as well as all other Annexes.   Sub-Group A




further believes that with the above mentioned changes in Article VI, the



establishment of such a committee could be handled administratively and need



not be  specified in the Agreement.




     For reference,  a copy of the original Annex 7 is  reproduced  on the following



pages.
                                    55

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      DISCHARGES FROM ONSHOUE AND OFFSHORE 'FACILITIES

1.    Def in it ions_.'   As used in this Annex:

     (a)  "Discharge" means the introduction of oil or
          hazardous polluting substances into receiving
          waters and includes, but is not limited to, any
          spilling, leaking, pumping, pouring, emitting or
          clumping;   it does not include continuous effluent
          discharges from municipal or industrial treatment
          facilities;                          .               :

     (b)  "Harmful quantity of oil" means any quantity of oil
          that,  if discharged into receiving waters,  would
         • produce a film or sheen upon, or discoloration of
          the surface or the water or adjoining shoreline, or
          that would cause a sludge or emulsion to be deposited
          beneath the surface of the water or upon adjo.ining
          shoreline;

     (c)  "Offshore facility" means any facility of any kind
          located in, on or under any water;

     (d)"  "Onshore facility" means any facility of any kind
          located in, on or under, any land other than sub-
          merged land.   '

2.    Facilities.   The term "facility" includes motor vehicles,
rolling stock, pipelines, and any other facility that is used
or capable of being used for the purpose of processing, pro-
ducing, storing, transferring or transporting oil or hazardous
polluting substances, but excludes vessels.

3.    Oil.   As used in this Annex, "oil" refers to oil of any  :
kind or in any form, including, but not limited to petroleum,
fuel oil, oil sludge, oil refuse, and oil mixed with wastes,
but does not include constituents of dredged spoil.

4.    Principles. ' Regulations shall be adopted for the preven-
tion of discharges' into the Great Lakes System of harmful
quantities of oil and hazardous polluting substances from on-
shore and offshore facilities in accordance with the following
principles:

     (a)  Discharges of harmful quantities of oil or
          hazardous polluting substances shall be prohibited
          and made subject to appropriate penalties;

     (b)  As soon as any person in charge has knowledge of
          any discharge of harmful quantities of oil or
          hazardous polluting substances, immediate notice of
          such discharge shall be given.to the appropriate
          agency in the jurisdiction whore the discharge occurs;
         . failure to give this notice shall be made subject to
          appropriate penalties. .

                             56 _

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5'    Programs anrl Measures.   The programs and measures to be
adopted shall include the following:
                     f'r
     (a)  Programs to. review .the design, construction, and
          location of both existing and new facilities for
          their adequacy to prevent the discharge of oil or
          hazardous polluting substances;
     (b)  Prog^jms to review the operation, maintenance and
          inspection procedures of facilities for their
          adequacy to prevent the discharge of oil or
          hazardous polluting substances;

     (c)  Programs to train personnel to perform all functions
          involving the use and handling of oil and hazardous
          polluting substances;

     (d)  Programs to ensure that at each facility plans and
          provisions are made for appropriate equipment for
          the containment and clean up of spills of oil or
          hazardous polluting substances;

     (e)  Programs including compatible regulations for the
          identification and placarding of containers and
          vehicles carrying oil or hazardous polluting
          substances.
                           57

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DISCUSSION OF ANNEX 8

     This discussion of Annex 8 dealing with shipping regulations and contingency
plans is based on the Position Paper of Sub-Group C.

     Sub-group A has no objections to the thrust of the recommendations on
Article V.l.(e)v., but recommends the following language to give better focus
to the ongoing activities of the agency involved:
     (v)  establishment by the U.S.  and Canadian Coast Guard of a coordinated
          system of aerial and surface surveillance and enforcement of regula-
          tions directed toward the early identification,  abatement and clean-
          up of any spills of oil or any other hazardous polluting substances.

     The revised Annex 8 proposed by Sub-Group C is acceptable with the foilowing
replacement of the second sentence of Par 1.:
          The Parties further agree that.the U.S. and Canadian Coast Guard shall3
          in cooperation with all other affected •oarties,  identify and provide
          detailed contingency plans for areas of high risk and of particular
          concern in augmentation of the CANUSLAK.
     For reference purposes, a copy of the draft Position Paper of Sub-Group 'C
which was referred to  this Sub-Group for comment is included in Attachment 3.
                                   58

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DISCUSSION OF ANNEX 9 (New)






     The original Agreement, by Article V l.(i)>  called for the development



of a hazardous materials Annex to the Agreement.   A proposed Annex 9 with



the list of hazardous materials as appendixes was developed by a Joint  U.S.-



Canadian Work Group and submitted to the Parties  in 1976 for inclusion  in




the Agreement,



     Sub-Group A understands that since that time, there have been differences




of opinion related to Section 311 of PL 92-500.   This apparent conflict must



be resolved at EPA Headquarters, but in the interim Sub-Group A is not  aware



of any other reason why the Joint Work Group recommendations should not be




incorporated in the new Agreement,




     The proposed Annex 9,  which is the latest version of the Joint Work



Group recommendation available to Sub-Group A, follows this discussion.   The




appendixes to Annex 9 comprising the lists are not reproduced since the



lists seem to be a large part of the apparent conflict.
                                59

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                          ANNEX 9

               HAZARDOUS POLLUTING SUBSTANCES




i.    pcmr-onr-:

          This Aimcx v/ns prepared pursuant io Article V(l)(i) of the

     Canada-D. S. Great Lakes Wai. or Quality Agreement \vhich calls

     for the development of an Annex identifying hazardous polluting

     substances.  The list in Appendix I of this Annex will facilitate

     the development of other related programs such as the prompt

     joint spill reporting and response action (Annex 8), compatible

     regulations or programs for the prevention and control of dis-

     charges of such substaiices from vessels (Annex 3),  from shipping

     activities (Annex 5), from dredge spoil disposal (Annex 6)  and

     from onsJLiore-offshore facilities^(Annex 7).

          The list in Appendix II will serve as a guide for indicating

     other potentially hazardous polluting substances, and will be sub-

     ject to review and revision as described below under Section 4.

          Consideration will be given to the eventual development of

     Appendix III which will designate harmful quantities of hazardous

     polluting substances.  This is further described in section 5.

2.   PRINCIPLES OF LISTING AND REVISION FOR  HAZARDOUS
     POLLUTING SLJBST^CES (APPENDIX lj
                                                               S
    .t     The Parties recognize that any list of hazardous polluting

     substances  should not be regarded as complete, all-encompassing,

     or final.  Any such li<;t will require revision since discharges of

     noil-listed  substances threatening human health, human welfare,

     or the living resources of tlie Great Lakes  could occur at any time.

     Inclusion of ihe elements and compounds listed in  Appendix I will

     be bnsod upon the folio\vm.ft principles:


                                   60

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     - Selection of all havsardci/> substance::; idcnlif.'t.d in
       this Appendix v/j'U bo bur;ed upon documented ioxi-
       cologica!. and discharge potential data which have
       been ovaliu-i.od  by the parties  and doomed to bo
       mutually acceptable.

     - Revisions to Appendix I v/ill be initiated and reified
       through the jo::U  action of the parties.  Using rhe agreed
       to sc.lect.iou criteria, cilhor party may recommend at
       any time a substance^} 10  be  added 10 the  list in Appen-
       dix  I.  Such a ?ub£laricc(s) may or  may not be listed in
       Appendix II.  The party receiving ihe recomxnrndation
       has 60 days Lo review the associated documentation for
       purposes of acceptance or  rejection.  Cause for rejection
       must be documented and .submitted to the initiating party
       as the basis for any further negotiations if deemed
       necessary.  Acceptance of the initiating party's recom-
       mendation automatically affirms the substancc(c) as a
       candidate for the list of Appendix I, pending the completion
       of nny requisite modification of national implementing
       regulations or  alternative administrative procedures per-
       taining to the designation of new hazardous polluting
       substances. . S*. oh requirements from either party may  be
       necessary before programs and measures (Annexes  3
       and 7) to prevent discharges of the newly added substances
       can be legally implemenred. However,  any such adminis-
       trative delray in confirming the candidate substance(s) for
       Appendix I listing will not apply to  the carrying out of the
       provisions of Annex 8,  Joint Contingency Plan, in event of
       a pollution incident involving the candidate substance(s).

3.   HAZARDOUS POLLUTING SUBSTANCES SELECTION  CRITERIA

     Rationale

          The criteria for determining relative hazards posed by

     chemicals to the  environment fall within three general areas.

     These are toxicological data,  information relating to the pro-

     bability of a dischof gc -occurring (discharge potential),  and

     data on the chemical and physical properties of the  material

     which affect its dispersal and persistence in n given body  of

     wator.
                                  61

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      From :: 1o?-jco3
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     - one-half oT ;i tc.:;i. ponulrti'jn. oT animal:", in  1-1 clay:": or less v.'avn
       dcrrnally c:;Tic.s"fi 10 aa cm'.,-i.ril equal to 01^ loss than L'OO m:;/;..g
       body weight for l-I-i  hours; or
     - one-h:-ilf of a test population of aaimrJ^ in 14 days or less v/hcn
       exposed to a varur concenlra'i :on equal to or lesn li'uin 20 cubic
       coiii.irnolers  per cubj.c meler (volume/ volume) in ait* for one
       hour; or

     - aquatic flora as measured by a 50 percent decrease in eell con at.,
       biomass,  or pbovosynthelic  ability in 14  days or less  at concen-
       trations equal to or less 11: an 100 ing/1;

     k) Discharge Potential

          Substances must pose a reasonable potential to be dis-

     charged into the Great Lakes which is  determined by:

     - establishing information on  history of discharges or accidents;
                                • '  "*•
     - assessing the modal risks during transport and determining

       the use and distribution patterns;

     - identifying quantities manufactured or imported.

     Those substances which have the toxicologies! properties and

     reasonable potential to be discharged as specified  above are

     identified as hazardous polluting substances  in Appendix I to this

     Annex.

4.   PRN CIPI.ES OF LISTING AND REVISION  FOR POTENTIAL
          Substances listed in Appendix II will sei'vc as  a guide for

     indicating other potentially hazardous polluting substances which,

     due to  insufficient data or /or .. r.ny one of a vqricty of reasons, are

     not presently listed in Appendix I.   These substances will be

     given priority attention for examination and possible future
                                   63

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     inclusion ;n Appendix I.  Appendix II sho aid not be reg,:iiucd as

     complete, all encompassing or.final.  Inclusion of the elements

     or compound.-; listed irt Appendix II will be based upon the following

     principles:

            Either party rnr.y add new substances to .Appendix II by
       notifying ihc other h\ wit in 5 thvi: ihc substr^cc is consiriercd
       to be Q potential hazard because of  documented information
       concerning aquatic to::icjty, mammalian and other vertebrate
       toxicity,  phytotoxicity, persistence, bio-accumulation, muta-
       genicity,  teratogenJcJty,  carcino^enieity, environmental
       ti'anslo cation or because  of'documented information on the
       potential for relatively high discharge to the environment.   The
       documentation  of the potential  hazard and the selected criteria
       upon which it is based v,rill also be submitted.  Such an inter-
       change could usefully serve as a basis for any necessary
       revisions or additions i^he selection criteria for Appendix I.

            Removal  of substances from the list shall be by mutual
       consent.


5<    HARMFUL QUANTITY DSTSRIMINATIOM

          It is recognized that harmful quantities of hazardous polluting

     substances could be useful to clarify notification requirements for

     pollution incidents, alert levels, contingency planning coiicerns,

     and hazards  of transportation.  These quantities are to be specified

     in Appendix III of this Annex.  Until that Appendix is completed,

     the parties recognize that any quantity of substance listed in this

     Annex  may be harmful  and that in Canadian waters appropriate

     steps will,  therefore, be 1.:«J?un fear.-any discharge.

          In the XT. S.  waters appropriate notification and enforcement

     actions will be undertaken for discharges  in excess of harmful

     quantities specified in -!0 Ci-Tv, Piu-L 110.
                                  64

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           In con;-r^r--i5u:o v.'ith /-.niio: '<•> bolli parties v/ill take appiopriale

     joint response option Cur u spill of ray subsUm.cc of any magnitude

     judged to bo a pollution incident as claimed therein.


6-    CQ]Vi iv/nnij': :mpGT?jni r?T:\rcT,Qp^:r.^T STEPS              v

          The parlies agx-co to implonieut programs in keeping with

     the requirements of the Agreement and this Annex using appropriate

     federal, state, or provincial legislation.

     Canada

          The Canadian program of control of discharge of hazardous

     polluting substances is to be implemented through Federal and

     Provincial  authorities  using legislation such as:


                   Ontario Petroleum Resources Act.

                   Ontario Water Resources (OV/R) Act.

                   Environmental Protection Act.  (Ontario)

                   The Canada Shipping Act (R. S. C. S-9,
                    C. 381 [1st Supplement]; S. 65)

                   Fisheries Act (R. S. C.  1970, C.F-14)

                   Environmental Contaminants Act          /

          It should be noted that Canada can implement the spill control

     program for all  materials discharged into  Great Lakes areas under

     Canadian jurisdiction and, therefore,  materials listed in this Annex

     are noted as priority substances  and  do not limit Canadian authorities

     for discharges of unlisted subrlances.
                                    65

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     UniLecl States;

          The United Slates program of control of discharge of hazardous

     polluting substances is to be implemented through Federal and State

     Authorities using legislation such as:

                    The Federal. \Yater Pollution Control Act as
                    amended  1972 (P. L.  92-500)

                    The Ports cud Waterways Safety Act
                   .(P. L.  92-342)

          The Water Pollution Control  Act is to  be recognized as the

     primary instrument to allow the United States to implement the spill

     control program which is thereby limited to materials specif ior..'ly

     listed as Hazardous Substances (40 CFR  Part 116).


7.    ANNEX RE"V raw

         The parties shall conduct a comprehensive review  of the

     effectiveness of this annex during the fifth year of the agree-

     ment for this Annex.  Thereafter,  further comprehensive review

     shall be conducted upon the request of cither party.


8.  '  ENTRY INTO FORCE & TERMINATION
     	.          /

          This Annex shall enter into force upon signature by the

     duly authorized representatives of the parties and shall r cm air.

     in force for the period of the agreement unless terminated by

     twelve months notice given in writing by  ono of the parties to

     the  other.
                                66

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 DISCUSSION OF ARTICLE VI






     A new sub-paragraph l.(d) is proposed to bring the matters under Annexes



 3,  4,  6,  1 and  9 under the purview of the International Joint Commission.  The




 Commission appears to be the only practical mechanism to provide a continuing




 overview  of  these matters, a deficiency which has been previously called to




 the attention of the Parties in reports by the IJC.  The intent is to bring




 the shipping and dredging related activities under the purview of the IJC




 and its Water Quality Board.  •






     Par  l.(g)  is revised to reiterate the land use reference and to delete



 mention of the  Upper Lakes reference since the latter should be completed




 before this  Agreement is firmed up.






     Changed wording is proposed for the newly numbered par 1.(f) to conform




 to  changes proposed in Article VII and to conform to the Position Paper on




 Research  appended to this Report.






     Changes in wording are proposed for paragraph 3 to require a full report



 by  the IJC only biennially instead of annually and to extend the reporting



 responsibilities to shipping and dredging matters.  This also corresponds to



 a recommendation of the Water Quality Board.  The reporting requirement has



'also been enlarged to conform to the changes proposed in par_l.(d).






     A new paragraph 6 is proposed to conform to changes proposed in the




 administrative  support for Agreement-related work.






     The  proposed revised Article VI follows:
                                   67

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 i.
s
                          ARTICLE VI

 „••;       'POWERS,  RESPONSIBILITIES AND FUNCTIONS OF
              T1IL INTHRNATJONAL JOINT COMMISSION

1.        The International  Joint Commission  shall assist  in
the implementation of this Agreement.   Accordingly, the
Commission  is hereby given.,  pursuant to Article IX of the
Boundary Waters Treaty, the  following responsibilities:

      (a)  Collation, analysis  and dissemination of data and
          information supplied by the Parties  and State and
          Provincial Governments relating to  the quality of
          the boundary waters  of the Great Lakes System and  to
          pollution that enters the boundary waters from
          tributary waters;
    t
      (b)  Collection, analysis and dissemination of data and
          information concerning the water quality objectives
          and the operation  and effectiveness  of the programs
          and other measures established pursuant to this
          Agreement;

      (c)  Tendering of advice  and recommendations to the Parties
          •and to  the' State and Provincial Governments on problems
          of  the- quali-ty of  the boundary waters  of- the  Great
          Lake.*; System,  including specific recommendations con-
          cerning the water quality objectives,  legislation,
     .  ^   standards and  other  regulatory requirements,  programs
          and  other measures,  and intergovernmental  agreements
          relating  to the  quality of thes.e waters; fr
 "                          "
                     .        .                .  .   .    ,.     .
         (_dj    Tendering of advice end recormendsticns to tha Fartiks an
               in connection with mat-tars covered under Annexes S} 4j £.
         (a)  Provision of assistance  in  the coordination of the
              joint  activities envisaged  by this Agreement,  including
              cuch matters as contingency planning and  consultation
              on special situations;
         (f )   Provision of assistance in tKe-eGesdiHatieH-sf and advice on matters
              related to Great Lakes 'Water quality research, including identification
              of objectives for research activities, tendering of advise and recommen-
              dations concerning research to the Parties and to the State and Provincial
              Governments and dissemination of information concerning research to in-
              terested persons and agencies;

         (g)   Investigations of such subjects related to Great Lakes water quality
              as the Parties may from time to time refer to it.  At the time of
              signature of this Agreement, the Parties are 3-equestiHg- reiterating
              their request to the Commission to enquire into and report to them upon
                                         68

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            pollution of the boundary waters of the Great Lakes System
            from agricultural,  forestry and other land use activities, in
            accordance with the terms of reference to this Agreement.
            terras-ef-r-efeFenee-attaehed-te-t his -Agreement .

2.          In the discharge of its responsibilities under  this Agreement,  the
Commission may exercise all of the powers conferred upon it by the Boundary
Waters Treaty and by any legislation passed pursuant thereto,  including the
power to conduct public hearings and to compel the testimony of witnesses and
the production of documents.

3.          The Commission shall make a full report to the  Parties and to the
State and Provincial Governments no less frequently than annually biennially
concerning progress toward the achievement of the water quality objectives,
including matters related to Annexes l> 2,,  Z,  43  6t 7, and  9.   This report  shall
include an assessment of the effectiveness of the programs  and other measures
undertaken pursuant to this Agreement, and advice and recommendations. In
alternate years the Commission may submit a summary report.   The Commission may
at any time make special reports to the Parties,  to the State and Provincial
Governments and to the public concerning any problem of water quality in the
Great Lakes System.

4.          The Commission may in its discretion publish any report, statement
or other document prepared by it in the discharge of its functions under this
Agreement.

5.          The Commission shall have authority to verify independently the
data and other information submitted by the Parties and by  the State and
Provincial Governments through such tests or other means as appear appropriate
to it, consistent with the Boundary Waters Treaty and with  applicable legislation.

6.          The Commission shall carry out the provisions of this Article utilizing
principally the services of the Water Quality Board and the Science Advisory  Board
established under Article VII.
                                       69

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 DISCUSSION OF ARTICLE  VII






      This  Article  has  been  rearranged  to incorporate the concept of the Reference




 on the Research  Advisory Board  into  the  Article  itself.   The  Research Advisory




 Board,  re-named  the Science Advisory Board_,needs to  become  a  permanent institution




 of the Agreement and this is  the mechanism  proposed  for accomplishing it.   The




 purview of the Science Advisory Board  has for  obvious reasons,  been extended




 to "related fields" which is  intended  to include the problems of atmospheric




 fall-out as they affect water quality.   The rationale for the changes are



 contained  in the Position Paper on Research attached to  this  report,






      A change is proposed in  the wording, regarding  the  Water Quality Board to




 establish    what,  already  exists; i.e.,  the Water Quality  Board as the principal




 Advisor to the International  Joint Commission  on Great Lakes  Water Quality



 matters.




      This  Article proposes  to abolish  the Great  Lakes Regional  Office and



 distribute these duties to  the  Parties.   The Sub-Group A believes




 that  this  would  make for a  more efficient utilization of manpower and other




 services,  and would simplify  administration of the programs under the Agreement.






      Two members of the State Advisory Group and one member of the Federal



Advisory Group disagreed with  the proposed abolition of the Regional Office.



 (See Attachment 5 for their  comments),




      The revised Article follows:  (Since the proposed revisions are a complete



change in the sense of  the Article the existing Article has not been reproduced;



i.e.,  the line-out  is not used here):
                                   70

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                               ARTICLE VII
                           JOINT INSTITUTIONS
I.       The International Joint Commission shall establish the following:
Two Boards to serve as its principal advisors to assist in the exercise of
the powers and responsibilities assigned to the Commission under this Agreement:

    (a)  One board shall be the Water Quality Board to be the principal
         Advisor on all policy matters.   The Board shall be composed of an
         equal number of members from Canada and United States, including
         representatives from the Parties and from each of the State and
         Provincial governments.

    (b)  A second Board shall be the Science Advisory 'Board to advise on all
         scientific matters.   The Board shall consist of recognized experts
         on Great Lakes Water Quality problems and related fields.

2.       The members of the Great Lakes Water Quality Board and the-Resea?eR
Science Advisory Board shall be appointed by the Commission and their duties
determined after consultation with the appropriate government or governments
concerned.  In addition, the Commission shall have the authority to establish
as it may deem appropriate such subordinate bodies as may be required to under-
take specific tasks, as-weil-as-a-?0gieHal-effi€e7-whieh-may-be-J:e6a€ed-iH-the-
                                                        - She-Past ies-abeut- the-
3.       The Commission shall dis-establish the Great Lakes Regional Office and in •
lieu thereof the functions of the Regional Office shall be performed by the
lead agencies of the Parties.   The lead Agency for the U.S. shall be the U.S.
Environmental Protection Agency and the lead agency for Canada shall be Environment
Canada.  The personnel and resources of the Regional Office shall be reassigned
to the respective lead agencies of their governments.

4.       The GeHffitissieH-shall-SHbmit-an lead agencies of the Parties, as designated
in Par Zt shall include in their annual budget, ef anticipated expenses to be
incurred in carrying out its their responsibilities under this Agreement,  te-the-
Parties-fer-appseval.  Each Party shall seek funds to pay eRe-half-ef-the-aRRual-
b«dget-se-apprsve47-but-Heifchei?-PaF&y-shall-be-HHde3?-aR-obligatieR-te-pay-a- larger
aaeHHt-thaH-^he-etheF-teward-this-budget. thsc.portion of the annual expenses as
agreed upon by the too Boards and as approved by the lead agencies.
                                    71

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DISCUSSION OF ARTICLES VIII THROUGH XIV






    Changes in wording are proposed for Articles VIII through XII which



are self-explanatory.






    A new Article XIV has been added and is self-explanatory.






    With regard to Article X, Implementation, it should be pointed out




that one member of the State Advisory Group felt very strongly that the



Agreement should call for specific identification of costs associated with




meeting its terms.  However, the Sub-Group believes that pollution control



program costs for the Great Lakes are simply an increment of our State



and national pollution control programs which are already required under




our own State and federal laws, and that it would be misleading to attribute



costs to the Agreement other than those costs over and above what would be




considered normal program costs.  These latter costs will be identified in



agency budget proposals as required by Article X.  Furthermore, the specific



costs for administering the Agreement are identified separately in the annual




cost estimates required under Para 3 of Article VII.



    The rational for the proposed Article X, 2Cc) is contained in the .Position



Paper on Surveillance appended to this report.



    One member of the Sub-Group felt that a further in-depth look should be




made of the proposed surveillance program by means of a systems analysis



before committing to long-range funding.  The majority of Sub-Group A in



endorsing the surveillance proposals of the Water Quality Board was aware




that a continuing review would be required of the program but was also




cognizant of the extensive efforts by a wide range of experts that went
                             72

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into its preparation and believes that it is a valid program and further



that there is sufficient flexibility in the program to enable changes  to be



made if further study so indicates.




     The revised Articles follow:
                             73

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                               ARTICLE VIII

                  SUBMISSION AND EXCHANGE OF  INFORMATION

 1,        The  international Joint Commission  shall be  given  at  it  request
 any data or other information relating to the quality  of  the feetmdayy  waters
 of the Great Lakes System including quality of discharges thereto,  in  accord-
 ance with procedures fee-be established by the Commission^  witk-i
•^i? -»hO" -entry— Mit-e-fe¥«e-e-f -tkis— Aggeeaeftt-er  as-soon-thogfraftier
                  *» co&&ul'&a£iofi-wi;frh the  Pagtiea  as4 wtfch  tho  Stato  an-d-
 2,        The Commission  shall make  available  to  the Parties  and to  the
 State  and Provincial  Governments upon  request  all data or. other information
 furnished to it  in  accordance with this Article.

 3,        Each Party  shall make available to the  other at  its request  any
 data or  other information in its control relating to the quality of  the
 waters of the Great Lakes System, including quality  of discharges thereto.

 4,        Notwithstanding any other  provision  of  this Agreement,  the
 Commission  shall not  release without the consent  of  the owner any information
 identified  as proprietary information  under the law  of the place where such
 information has  been  acquired.

                                ARTICLE IX

                          CONSULTATION  AND REVIEW

 1.        Following the receipt of each report submitted to the Parties  by
 the International Joint Commission in  accordance  with paragraph 3 of Article
 VI of  this  Agreement,  the Parties shall consult on the recommendations con-
 tained in such report  and shall consider such  action as may be appropriate,
 including:

      Ca)  The modification of existing water quality objectives and  the
          addp€i«H  agreement on new  objectives;

      (JO  The modification or improvement of programs and  joint measures;

      Cc)  The amendment of this Agreement or any  annex thereto.

 Additional  consultations  may be held at the request  of either Party  on any
 matter arising out  of  the implementation of this  Agreement.

 2,        When a Party becomes aware of a special  pollution problem .that is
 of joint concern and  requires an immediate response,  it shall notify and consult
 the other Party  forthwith about appropriate remedial  action.
                               74

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3.      '  The Parties shall conduct a comprehensive review of the operation
and effectiveness of this Agreement during the fifth year  after its  coming
into force,  The3?eai%e3Fj-§HBtheB-esmp56heHsive-3?eviews-shall-'be-eeHdueted
                                 75

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                                 ARTICLE X

                              IMPLEMENTATION

1.        The obligations undertaken in this Agreement shall be subject
to the appropriation of funds in accordance with the constitutional
procedures of the Parties.

2.        The Parties commit themselves to seek:

     (a)  The appropriation of the funds required to implement this
          Agreement, including the funds needed to develop and
          implement the programs and o'ther measures provided for
          in Article V, and the funds required by-the International
          Joint Commission to carry out its responsibilities effectively;

     (b)  The enactment of any additional legislation that may be
          necessary in order to implement the programs and other
          measures provided for in Article V;


     Co)  Appropriation of not  less  than five  years advance funding of
          the Surveillance Program specified in Article,  V3  Par 23
          beginning with U.S. Fiscal Year  1978.  Funding  levels will
          be reviewed and adjusted annually  as necessary,
     Cd)   The cooperation of the  State and  Provincial  Governments in
          all matters relating to this Agreement.

                               ARTICLE XI
                       EXISTING RIGHTS AND OBLIGATIONS

          Nothing in this Agreement  shall be  deemed  to  diminish the rights
and obligations of the Parties as  set  forth in  the Boundary Waters Treaty.


                                ARTICLE  XII

                                AMENDMENT

          This Agreement and the Annexes thereto may be amended by agreement
of the Parties.  The Annexes may also  be amended as  provided therein, subject
to the requirement that such amendments shall be within the  scope of this
Agreement.
                                  76

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                                ARTICLE XIII

                       ENTRY INTO FORCE AND TERMINATION

           This Agreement shall enter into force upon signature by the
 duly authorized representatives of the Parties, and shall  remain in force
 for a period of five years and thereafter until terminated upon twelve
 months' notice given in writing by one of the Parties to the other.
                                 ARTICLE XIV
                                SUPERSESSION
          This Agreement supersedes the original Agreement of April 15,
19723  and should be referred to as the "Great Lakes Water Quality Agreement".
                            77

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SEE SEPARATELY BOUND VOLUME FOR






         APPENDIX NUMBER I

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    FOURTH ANNUAL
         REPORT

        GREAT LAKES
       WATER QUALITY
      INTERNATIONAL JOINT COMMISSION
          UNITED STATES / CANADA

WASHINGTON                     OTTAWA
             ATTACHMENT 1

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To the Government of Canada
       Government of the United States
       Government of the State of Illinois
       Government of the State of Indiana
       Government of the State of Michigan
       Government of the State of Minnesota
       Government of the State of New York
       Government of the State of Ohio
       Government of the State of Pennsylvania
       Government of the State of Wisconsin
       Government of the Province of Ontario
      The International Joint Commission is pleased to transmit, with its endorse-
ment, the 1975 Annual Report of the Great Lakes Water Quality Board, including its
assessment of the progress made in the United States and Canada during the year
1975 in  implementing the terms of the Great Lakes Water Quality Agreement of
1972. This progress, according to the Board, was "generally slow, uneven, and in
certain cases disappointing." Also included in the Board's report is an evaluation of
the water quality condition of the lakes at the end of 1975.


      The Commission wishes to first make note of this departure in form of
reporting to the various governments and the public from its previous three reports.
It is the Commission's view that the Great Lakes Water Quality Board, and its several
subgroups and committees have presented an excellent report on the effectiveness
of the Great Lakes Water Quality Agreement and efforts of the Parties to improve
the water quality of the lakes. Jts assessment is forthright everywhere and  critical
where necessary.  Its  findings and recommendations are well documented with
substantive data contained  in the four appendices. Therefore, the Commission
believes that it is not necessary for it to summarize and comment on all aspects of
the Board's report.
                                       ATTACHMENT 1

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        The Commission endorses, in general, all recommendations contained in the
report and offers the following special comments on several important matters as a
means of identifying those issues to which it believes the governments should give
substantial  priority consideration:
 Municipal  Treatment

      While the Commission recognizes that sizable programs for the construction of water pollution control
 facilities in the Great Lakes Basin are currently in progress in the United States and Canada, it nevertheless
 perceives that these efforts must be strengthened and in fact accelerated if the water quality objectives of the
 Agreement are to be achieved by the end of this century.

      The cities of Detroit and Cleveland continue to be the two largest sources of municipal pollution in the
 Basin. The Commission cannot emphasize  too strongly, the need to complete these  two major municipal
 projects on the highest priority basis.


 Surveillance


      Each  year since the signing of the Agreement, the Commission has advised governments that it could
 not report accurately on progress, or lack of it, toward achieving the goals of the Agreement because existing
 surveillance programs were inadequate. The Water Quality Board has now developed a comprehensive surveil-
 lance program which when implemented would  overcome the shortcomings of  the present  programs. The
 Commission fully endorses this program which is described in Appendix B of the Board's report.


      Because of the critical need to launch the program as soon as possible and recognizing time constraints
 of the budgetary cycle in the United States and Canada, the Commission has already taken action on this matter.
 In a separate communication, dated August 27,1976, to the Parties, the Commission has urged them to ensure
 that fiscal programs over the next 10 years provide ongoing funds at the level proposed ($16 million annually),
 for the Agencies of federal, state and provincial governments having responsibility for water quality surveillance
 and monitoring activities in the Great Lakes. The Commission now reiterates its concern and urges once more
 the recommended actions.


 Combined  Sewers


      The Commission is concerned that  programs to control pollution from the overflow of  combined
.stormwater and sanitary sewers are fragmented and obviously inadequate. The Commission is aware that any
 solution  to this problem will be extremely costly, but it also recognizes that strong efforts by appropriate
 authorities to find adequate solutions must be continued. It is imperative that this significant source of pollution
 from major metropolitan areas of the Great Lakes be brought under control at the earliest practicable time. The
 Commission, therefore,  recommends  that the governments  continue both research  and  demonstration
 programs at least at present levels, including programs for reducing the amount of pollutants reaching storm
 sewers and for treating the stormwater itself. The Commission also recommends that site-specific  studies be
 initiated or strengthened in the major  metropolitan areas of the Basin.


 Industrial Pollution


      In spite of the progress of governments in instituting remedial programs in industrial pollution control by
 the end of 1975 as provided m the Great Lakes Water Quality Agreement, the Commission notes with concern
 that a number of major polluting industries are not expected to have adequate controls in place by the end of
 1977. In view of the substantial increase in data available on the discharge of pollutants from point sources, the
 Commission urges the vigorous enforcement of the industrial pollution control laws in both countries without
 delay.


                                        ATTACHMENT 1

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Toxic  Substances


      Toxic substances, e.g., heavy metals and persistent organic contaminants, may well be the most serious
and long term problem governments face in ensuring future beneficial uses of the Great Lakes. They pose threats
to water quality, the fishery, human health and ecology in general. Too little is known about these substances,
their identity, sources, amounts present, characteristic forms and behavior, and their effects. Control and moni-
toring programs are imperative. Research is required to enable the establishment of objectives and the evalua-
tion of potential hazards. Effective control laws must be enacted and implemented to the fullest extent possible
in both  countries as quickly as possible.


Radioactivity


      A new, refined Great Lakes radioactivity water quality objective has been proposed by Task Forces
established by the two Governments and is now undergoing review by appropriate federal, state and provincial
agencies. The Commission believes that the Governments should reach agreement on  a refined radioactivity
objective as soon as possible. Public hearings on these objectives should be held in the Basin.

      Because of the growing number of nuclear facilities in the Great Lakes Basin, including power reactors,
mining and raw materials processing, as well as waste materials processing, storage and disposal, the Great
Lakes Water Quality Board has developed a special Radioactivity Surveillance Plan as part of the proposed IJC-
Coordinated Surveillance Plan described in Appendix B of the Board's report.


Non-Point Pollution


      As controllable discharges from municipal and industrial point sources are reduced to established limits,
the significance of non-point sources of pollution, especially atmospheric fallout and sediment transport, is
becoming more apparent. Research activities must provide improved methods of identifying such sources and
indicate mechanisms to accelerate the design and  implementation of control measures.
             \
      While recognizing that some investigatory programs are under way to address these problems, an interim
strategy is required pending the outcome of these studies. Accordingly, the Commission urges all governments
to strengthen their support of programs to identify loadings from diffuse sources, determine their relative signifi-
cance, and implement measures to control further increases in pollutional loadings from these sources.


Phosphorus


      The Commission believes that the United States policy of constructing phosphorus removal facilites has
not been an effective means of reducing phosphorus reaching the  lower lakes. The targets for phosphorus
loadings contained in the Agreement are not being met.

      Though completion and  proper  operation  of facilities at Detroit  and Cleveland, as well  as  other
municipalities, will produce an early and measurable effect on Lake Erie and in turn Lake Ontario, more must be
done to  accelerate the recovery of the Lakes, including solutions to the problem of phosphorus input from the
non-sewered population. Further, action must be taken to reduce loadings and thus prevent degradation of the
Upper Lakes.

      Since 1970 the Commission has recommended the limitation of phosphates in detergents. Recent studies
and short-term results where limitations have been implemented have not only supported this recommendation,
but suggest even greater limitations are  in order. Therefore,  the Commission believes that the Board's recom-
mendation that a uniform 0.5% phosphorus by weight limit be placed on all detergents manufactured for use in
the Great Lakes Basin, including dishwashing materials, should be implemented by the appropriate authorities
as quickly as procedures will permit.

      This action, however, will still not provide sufficient controls on phosphorus loading to the lakes. There-
fore, the Commission supports the Board's recommendations to extend a 1 mg/l effluent limitation on all point
source discharges of phosphorus throughout the entire Great Lakes System. In addition, there is an urgent need
to define the pathways and design regulatory schemes to control the phosphorus contributions from the
atmosphere, sediments and land drainage, and all other non-point sources.


                                       ATTACHMENT 1

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Water Quality Objectives


      The water quality objectives in the Great Lakes Agreement have been adopted by several governments as
water quality standards for boundary waters within their jurisdictions. New and revised water qualfty objectives
have now been developed by the Commissions's Water Quality Board and its subcommittees for adoption in the
Agreement.

      The Commission  intends to hold public hearings on these new and revised objectives to assist it in making
a firm recommendation to the Governments at an early date. The Commission suggests  that until its final
recommendations on all the objectives recommended in the Board's report are submitted, all the objectives be
accepted as guidelines  for the development of water quality standards by the various  jurisdictions and  for
planning future uses of  the Great Lakes.


Special  Studies


      In July 1976 the Commission received the report of the International Reference Group on Upper Lakes
Pollution.  The Commission will hold public hearings and submit its final report to the two Governments in 1977.

  The progress of studies being conducted under the Reference Group on Pollution from Land Use Activities is
reported in the attached 1976 report of the Group. A major public consultation program is planned by the study
group for implementation in 1977. this program is expected to increase public understanding of the objectives
of the study and the complexities of the problems of pollution from  land use. The final study report is expected
in 1978.

      The Great Lakes  Research Advisory Board  has again compiled  an extensive Directory of Great Lakes
Research and Related Activities, and is continuing its efforts to coordinate as closely as possible the Great Lakes
related research programs in both countries. These efforts are reported in the attached Annual  Report of the
Board. Several effective seminars were held during  the year under Commission auspices and others are planned
for the current year. Ail are designed to focus on  problems related to Great Lakes water quality.

      The Commission wishes to commend the individual and collective efforts of a significantly large number
of persons, including skilled scientists,  effective administrators and dedicated public servants who have worked
hard during recent months to collect large amounts of data, assess and evaluate it, and prepare these excellent
documents.  It reflects great credit on the cooperative efforts of both countries to correct the  very complex
problems of Great Lakes water quality which have resulted from human neglect over many years.

      Finally, the Commission notes  that the Agreement calls for the Parties  to "conduct a comprehensive
review of the operation and effectiveness of this Agreement during the fifth year after its coming into force." It is
the Commission's  intention to prepare a special report within the  next few months which will set forth the
Commission's views on  various provisions of the Agreement for consideration by the Governments during the
aforementioned review  process.
                                                             Respectfully submitted
      Henry P. Smith III
      Chairman, United States Section

      Charles R. Ross
      Victor L. Smith
Maxwell Cohen
Chairman, Canadian Section

Bernard Beaupre
Keith A. Henry
                                                             September 16,1976
                                     ATTACHMENT  1

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        EIUIMIS
        mil IDIIIIY B01BB
Copies of the complete Report and
the Appendices are available from:
         INTERNATIONAL
                   JOINT
            COMMISSION
                100 Ou«H«t* Av»
             Windsor, Ont. N9A 6T3
     ATTACHMENT 2

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WATER QUALITY AND SURVEILLANCE
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General Improvements in water quality were obaerved in aome local
areas of Lake Ontario and parts of Lake Erie where remedial programs
have been put In place. However, there are major municipal and Industr
remedial programs still to be completed and it will be several years
before significant improvements are likely to be observed in the open
waters due to the long response time.
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 DRAFT POSITION PAPERS






 SUB-GROUPS B, C AND D
A TTACS/M*?*/ T

-------
                                                              ./N. '

                                                            /**
                  Great Lakes Water "Quality Agreement



                           Five Year Review


                                                        '                 7
                 Report of the Work Group B on Annex 3



1.  Vessel Design, Construction and Operation (reference Annex 3)




     Title of annex should be changed to"""0il and Hazardous



Polluting Substances from Vessels" to bring it in line with other



annexes .



(A)  Definitions (ref . annex 3 par. 1 & 2)



     Definition of tanker changed to mean a vessel designed for the



carriage of liquid cargo in bulk.




     Even with the change, the definitions as used in the laws and



regulations of both Parties are fully compatible with definitions in



the reference paragraphs.



     Minor differences between the definition used by the two Parties



do existj for example, the term "tank vessel" is used in U.S.A. regula-
                   »

tions to designate both bulk oil and bulk chemical carriers, whereas



in Canadian regulations the differentiation is made.  The expression


"harmful quantity of oil" is not employed in either the Canada Shipping



Act or Regulations.  As the discharge of oil or oily mixtures from



ships is prohibited, the need to use this expression does not arise.



U. S.. A. regulations use the same definition for "harmful quantity of



oil" as the Agreement.




     Depending on outcome of EPA/USCG disc   Lons, discharge from



approved oil process equipment of 15 ppm o   LI or less will not be



considered a harmful quantity even if a she^rt is present.  If so,



there U.S. regulation wording will be changed which will, put it in



                       SUB-GROUP  B

                       ATTACHMENT 3

-------
                                                                       .**•"
                                                                         '..i
GLWOA
       conflict with the Agreement definition.  Changing the Agreement             _;.

       definition will not be incompatible with the Canadian Shipping Act

       or Regulations as they prohibit the discharge of oil.  There may be

       incompatibility with Canada's intentions^, however.

       (B)  General Principles (Annex 3 para. 3)

            Editorial change in paragraph 3b to add "of the vessel" after  '  '  '

       "person in charge".


            Both Parties have addressed themselves to the principles con-

       tained in the reference paragraph.  Both Parties have regulations

       prohibiting the.discharge of oil, oily mixtures and hazardous

       polluting substances from ships. . In accordance with the Canada

       Shipping Act, the term pollutant is used in place of hazardous

       polluting substances. , Under the Federal Water Pollution Control Act

       the term hazardous substance is employed.


            At such time as the Annex required by Article V, l(i) of the

       Agreement is complete and a list of hazardous polluting substances

       identified, both Parties will take the appropriate action to apply

       the principles of this paragraph of the Agreement to the substances

       so listed.


            With regard to the reporting of discharges to designated officials

       as reference in sufaparagraph 3(b) of Annex 3 both Parties have fully

       implemented this provision through legisls   -n and regulations.


       (C)  Programs (ref. annex 3 para. 4)

            Paragraph 4 has been rewritten to take _nto account substantive

       changes proposed by the working group which was worked into the
                              SUB-GROUP B
                              ATTACHMENT 3

-------
GLWQA                          ,



     basic format of the agreement.   It is as follows:


     4.  Programs.


          (a)  The^programs and measures to be adopted for the prevention

                                               \
     of discharges  of harmful quantities of oil~shall include the following:


                 (i)  Compatible regulations for design and construction


                      of vessels based on the following principles:


                      (1)  each tanker shall have a suitable means


                           of containing on board cargo oil spills


                           caused by loading or transfer operations;


                      (2)  each vessel shall have a suitable means of


                           containing on board fuel oil spills caused


                           by loading or transfer operations, including


                           those from tank vents and overflow pipes;


                      (3)  each vessel shall have a capability of


                           retaining on board oily wastes accumulated


                           during vessel operation;


                      (4)  each vessel shall be capable of off-loading


                           contained oily wastes to a shore facility.


                (ii) 'Compatible regulations for vessel operating procedures


                      based on the following principles:


                      (1)  tankers shall be provided with a means for


                           rapidly and safely stooping the flow of cargo


                           oil during transfer operations in the event of


                           an emergency;


                      (2)  suitable deck lighting shall be provided  to


                           illuminate all cargo and fuel handling areas


                           if the transfer occurs at night;
                            SUB-GROUP  B
                            ATTACHMENT 3.. •

-------
GLWOA
                                                                          ^*
                         (3).  hose assemblies used aboard vessels for oil

                              transfer shall be suitably designed, marked


                              and inspected to minimize the possibility of


                              failure.


                         (A)  oil transfer, loading and off-loading systems


                              shall be designed to minimize the possibility


                              of failure.
                  (iii)  Programs to train merchant vessel personnel in all


                         functions involved in the use,  handling and stowage
                                             '**

                         of oil and in procedures for abatement of oil


                         pollution.


             (b)  The programs and measures to ^^. adopted for the prevention of


        discharges of hazardous polluting substances shall include the


        following:


                    (i)  Compatible regulations for design and construction of


                         of vessels based on the following principles:


                         (1)  each tanker shall have a suitable means of


                              containing on board cargo  hazardous polluting


                              substances spills caused by loading or transfer


                              operations;                              __ ^	


                         (2)  each vessel shall have a capability of retaining


                              on board hazardous polluting substances wastes


                              accumulated during vessel  operation;


                         (3)  each vessel shall be capable .of off-loading con-


                              tained hazardous polluting substances wastes to


                              a shore facility.


                              SUB-GROUP B
                              ATTACHMENT 3

-------
GLWQA
                  (ii)   Compatible regulations  for vessel operating


                        procedures based on the following principles:


                        (1)   tankers shall be provided with a means of


                             rapidly and safely stopping the flow of


                             cargo hazardous polluting substances during


                             transfer operations in the event of an


                             emergency;


                        (2)   suitable deck lighting-shall be provided to


                             Illuminate  all cargo and hazardous polluting
                                            ••>.

                             substances  handling areas if the transfer


                             occurs at night;


                        (3)   hose assemblies used aboard vessels for


                             hazardous polluting substances transfer


                             shall be suitably  designed, marked and


                             inspected to minimize the possibility of


                             failure;


                        (4)   hazardous polluting substances transfer,


                             loading and off-loading systems shall be


                             designed to minimize the possibility of


                             failure.


                 (ill)   Programs to train merchant vessel personnel in all


                        functions involved in the use, handling and stowage


                        of hazardous polluting  substances and in procedures


                        for abatement of hazardous polluting substances


                        pollution.

                             SUB-GROUP B

                             ATTACHMENT 3

-------
GLWOA
                  (iv)   The programs and measures to be adopted for the
                        prevention of discharges of hazardous polluting
                        substances shall use as  a guide the Code for the
                        Construction and Equipment of Ships Carrying
                        Dangerous Chemicals  in Bulk of the Inter-
                        governmental Maritime Consultative Organization
                        (IMCO).    Such programs  and measures shall in-
                        clude design and construction features,
                        operating procedures, and merchant vessel
                        personnel qualification  standards  with respect
                        to handling hazardous polluting substances and"
                        pollution abatement.  In addition, the programs
                        shall establish compatible regulations for:

                        (1)  Identification  and  placarding of vessels
                             carrying hazardous  polluting  substances as
                             well as containers  and packages containing
                             hazardous polluting substances when carried
                             by  vessels;             .
                        (2)  Identification  in vessel manifests of all
                             hazardous polluting substances carried;   	
                        (3)  Procedures for  notification to responsible
                             authorities of  all  hazardous  polluting
                             substances carried.
             The United States Pollution Prevention Vessel and Oil Transfer
        Facilities regulations are fully compatible with the programs  and
        measures under the reference paragraph.
                              SUB-GROUP B
                              ATTACHMENT 3

-------
GLWQA
              The Canadian Oil Pollution Prevention Regulations are presently

         compatible with the programs and measures regarding oil transfer,

         loading and off-loading systems, hose assemblies and the means for

         rapidly and safely stopping the flow of oil during transfer operations.

         Regarding the provisions of subparagraph 4(c) dealing with the

         training of merchant vessel personnel, pollution prevention procedures

         and regulations are now being incorporated into the syllabuses for

         certificates of comoetency as master and mate.  A knowledge of the

         handling procedures for oil cargoes has been included in these

         syllabuses for many years.  A proposed amendment to the Canadian Oil

         Pollution Prevention Regulations has been drafted in order to cover

         the items contained in clauses 4(a)(i) to (iv) and clauses 4(b)(1) to

         (iv) of Annex 3.

              A further amendment to these Regulations is now being prepared

         in order to require that a licensed operator be in attendance on

         unmanned oil barges when oil transfer operations are in progress.

              Although knowledge of cargo Handling procedures has been a part of

         U. S. Merchant Officer License requirements for years, the Coast Guard

         is currently drafting new standards for the qualifications of Tankerman.

         These new Tankerman regulations will require specific qualifications

         (including Firefighting training) and examinations for all persons who

         serve as the person in charge of a transfer or tank cleaning, including

         those licensed officers who are now consic  ->.d qualified on the basis

         of holding a license.  Additionally, they    .1 provide for

         recertification at 5 year intervals.  The    ndards are expected to

         be published as a proposed rule in 1 April  'ill.

                               SUB-GROUP B
                             ' ATTACHMENT 3

-------
GLWQA
             Since July 1973 all applicants for U. S. Merchant Marine License

        and certificates have been required to demonstrate their knowledge

        of pollution laws and regulations, procedures for discharge contain-

        ment and cleanup and methods for disposal of sludge and waste material

        from cargo and fueling operations.

             Additionally, a manual for Safe Handling of inflammable and

        combustible liquids and other Hazardous Products has recently been

        revised for use as a guide for those persons involved in the transport

        or transfer of these products.

             At such time as the Annex required by Article V, l(i)  of the

        Agreement is complete and a list of hazardous polluting substances is

        identified, both Parties will take appropriate action to apply the

        programs listed in paragraph 4b.


        (reference Annex 3, paragraph 5)

             Title 46, United States Code of Federal Regulations, applies

        requirements which, with the exception of the provisions contained

        in svibparagraph 5(a) of Annex 3, are fully compatible with  the

        reference paragraph.

             In Canada, the proposed Chemical Carrier (Steamship) Regulations

        were drafted and circulated to the industry and other interested_ 	

        agencies for comment.  A second draft of the proposed Regulations has

        now been drafted and is now being examined for legal form and

        draughtmanship.  This second draft will eventually be circulated for

        further comment.  In addition to the provisions of the IMCO Code for

        the Construction and Equipment of Ships Carrying Dangerous  Chemicals

        in Bulk, the proposed Regulations would also specify the procedures  to

                               SUB-GROUP B
                               ATTACHMENT 3

-------
GLWQA
        be followed when dangerous chemical cargoes are being loaded and              &:

        unloaded.   All dangerous  chemical cargoes carried would have to

        be identified on the ship's manifest and information on the nature

        of the cargo would also have to be carried on board.

             All ships passing through the St.  Lawrence Seaway are now

        required to notify the Seaway Authority in order to identify cargoes
                                       >
        carried, however no provision has been  made with respect to the

        placarding provisions in subparagraph 5(a) of Annex 3.

             Definite pros and cons exist regarding the placarding of vessels

        and both Parties feel that this subject warrants continuing study.


        (D)  Additional Measures (ref. annex 3  para.5)

             Amended to read:

             Additional Measures shall be taken as necessary by both Parties

        to insure the provision of adequate shore facilities for the

        reception and treatment of oil and hazardous polluting substances

        waste from vessels.

        (E)  Article 5e (iv) should be amended  to reference annex 3 and 4
                              SUB-GROUP B
                               ATTACHMENT  3

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           PRELIMINARY REPORT OF SUBGROUPS B ON REVIEW OF
                          ANNEX- 4, G-LWQA
1.  Definitions - It is recommended the definition of-"garbage"  be


reviewed and that consideration be given to replacing  it with  the  defi-
                                                                   f

nition in Annex V of the 1973 Convention for the Prevention  of Pollution


from Ships  (i.e., "garbage" means all kinds of victual, domestic,  and
                                              "~~'   '                       ''

operational waste, excluding fresh fish and ports thereof, generated
                                             L.'\

during the normal operation of the ship and liable to  be disposed  of


continuously or periodically, except those substances  that are defined


or listed elsewhere in the Agreement).  This meaning  encompasses the in-


tent of the present one in the Agreement without becoming at all


restrictive.  It would, appropriately, also bring the  Agreement  more


into concert with another international accord.




2.  It is recommended that the phrase "within one year from  the  entry


into force  of the Agreement" be deleted, as' it is no  longer  applicable.
                                                      (

0-'  (b)  This will also remedy the problem  that regulations for waste


water do not exist on either side  (vaste water has been and  continue to


be a low priority item - not considered to be a pollution problem at


this time).


 2_ (c)  Question as to what constitutes an adequate  degree of  treatment


still exists. t  States prefer no-discharge, and apparently would  accept
 C.f/£C.u^C  "trt a ?"'£.•" 1" S~f '«-«cT -for-  f~  ir/M'£. il V C1- j "> f

that they don't  feel 150 tag/liter of suspended solids is adequate.



3.  It was  reaffirmed that critical use area designations may  be made


involving only  localized unilateral determination::.
 4.   No  comments.
                       ..SUB-GROUP B-
                   "-  ""ATTACHMENT 3"

-------

5.  It is recommended that a-new paragraph 5 be added:

            The Parties shall take action as necessary to ensure

            the provision of adequate shore facilities for the

            reception and treatment of garbage, waste water,  and

            sewage from vessels.
                       SUB-GROUP B.
                       ATTACHMENT  3

-------
 Report  of Working Group 3              JL^U'^^"'**  "  22 March 1977

 Studies of Pollution  from Shipping S&£yices

 (reference Article V  l(e)   (ill)  and Annex 5)

 1.   Navigational  Equipment (Annex 5, paragraphs  1 (a))

      Periodic  comparisons have been made of  the  requirements of the several

 Administrations respecting navigational equipment.   It  has been established

 that while variations in specialized equipment fittings are unavoidable,

'the  general equipment requirements are  common with  the  regulations of the

 U.S.C.G.,  C.C.G.  and  S.L.S.A./S.L.S.D.C.

      The S.L.S.A./S.L.S.D.C.  regulations are the result of a joint agree-

 ment between the  Administrations  of the U.S.A. and  Canada, and they reflect

 compatibility  with the intent of  the Great- Lakes Water  Quality Agreement  of

 1972.

      The following list of navigational equipment summarizes the actions

 taken be each  Administration  in establishing minimum safe standards.
                       U.S.C.G.
               S.L.S.A./S.L.S.D.C,
                    C.C.G.
Magnetic  Compass

Gyro  Compass

Sounding  Equip-
ment

Radar

'Internal  Com-
munications

VHF Radio

Radio Direction
Finder

Charts
Required
Required
Required
Required
Required
Required
Not Mandatory
Required
Required
Required
Required
Required
.*
Required
Required
Required
Required
Required
Required
• Required
Required
Required
Required
Required
                                                               Required
                          SUB-GROUP B
                        ''  A'TTACpENT'3'1

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.f
List of navigational equipment  (CONTINUED)

                         U.S.C.G.      S.L.S.A./S.L.S.D.C.      C.C.G.
             \
Course Recorder          Not required      Not Required         Required
                                                   .*
Maneuvering  System       Required          Required    *         Required
Indicators and
Appliances

     This equipment must be maintained in operating condition and

periodically tested.

     All mariners are required  by the ordinary practice of seamen  to make

proper use of all navigational  equipment.  Failure to  do so may result in

proceedings  directed toward revocation or suspension of the mariner's

license or certificate.

     Consideration is being given to and a NPRM has been published reflecting

the possible requirement for all vessels of 1600 GT or more to be  fitted with

LORAN C recieving equipment.  This equipment will facilitate vessel navigatior

during both  normal and ice operations.
                      SUB-GROUP B
                      ATTACHMENT 3.

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2.  Manning of Vessels



      (reference Annex 5,  subparagraph, 1



         A review of the  United  States Coast Guard  Rules  and  Regulations  for



the licensing and certificating  of Merchant Marine  personnel  and  the Canadian



Coast Guard standards under  the  Canada Shipping Act,  including  the  Ship's



Deck Watch Regulations, shows  a.  similarity of  snip-organization for larger

           .    •

vessels  trading in Great  Lakes waters.  In U.  S. and" Canadian vessels, all



officers in charge of a watch,  must possess a certificate  of competency.   It



is also  considered that the  existing  manning requirements provide an



acceptable minimum standard  with regard to towing vessels and to  all other



vessels  navigating in high traffic density and in ice or  in any adverse



-weather  condition.



         The training and examination systems administered in the U.S.A. and



in Canada reflect the intent of  the agreement and both exceed acceptable cini-



mum standards.  Both countries are revising their examinations  from the
             f» — --w


subjective type to the objective or multiple-choice answer form which will
                       •

serve to modernize the licensing programs.  The standardization of  the



licensing exam is considered to  be a  great step forward.  Throughout the U. S.
                   *


every applicant for the same grade of Great Lakes engineer's  license receives

                                                    «

the same examination which is  administered crfi the same* days at  a predesignated



schedule.  The examinations  are  then  graded at a "central control area.  Al-
                    •


though the Great Lakes Masters and Pilots objective type examination has not



been fully developed, as  yet,  an effort is currently  underway addressing this



area.  Questions on tankship safety,  pollution control, and engineering safety



are provided for in the new  examinations and the sysyera permits continual



updating as new-areas of  concern or^unsafe conditions are identified through



studies  or casualty evaluations.


                                    1

                       SUB-GROUP B

                       ATTACHMENT 3   -                                       --

-------
                         *** ?**•, rv  r31 TV
         Although the written examination is a necessary tool for determining



basic skill qualification, greater emphasis is being placed on the methods



of training and retraining for shipboard personnel, particularly in the



critical skill areas such as the knowledge and comprehension to load and
                                                 * .»
                                                     .  v

discharge oil tankers, liquefied gas carriers and hazardous chemical



carriers, radar piloting, ship maneuvering and firefighting.  Simulator



type proficiency Testing and training facilities for radar observer, sponsored

                                         t
by both government and private interests are presently available on all four



coasts of the U. S. for use in testing all applicants for original and



renewals of der.k officer licenr.es. .



         Although not specifically required by regulation encouragement has



been given and labor/management sponsored facilities providing automated



engine room console simulator training and automated cargo control simulator



training have been established.  In addition, government and private



sponsored firefighting schools have been established.  -In this area the



Maritime Administration with the cooperation of the Coast Guard is developing



a firefight hand book and standard classroom curriculum.  The government



sponsored firefighting field exercise tr?ining facilities will be expanded

                  f

in FY 78 with new facilities-being constructed one each in the Gulf of

                                                    *
Mexico and Great Lakes areas.



         A study of casualties involving towing vessels led to the enactment



of the Uninspected Towing Vessel Licensing Act in 1972.  This act and sub-
                        ^


sequent regulations have established a minimum requirement for licensed



operators on all towing vessels of 26 feet or more in length engaged in



the service of towing.





                       ATTACHMENT  3

-------
         In regard to foreign vessel competency standards, the Coast Guard

is active internationally, participating on the IMCO Sub-conraittee on

Standards of Tranining and Watchkeeping in an effort to establish the

highest international standard of qualifications and training for all
                                                       T

maritime personnel.  A conference to consider the subcommittees draft

convention and recommendations is scheduled for the autumn of 1978.  These
           «
efforts.will be reflected in regulatory action which will impact on the
                   >
crews of foreign vessels navigating the Great Lakes and will meet the


objectives of this agreement.

         The Ports and Waterways Safety Act of 1972 and implementing


regulations have provided the Coast Guard .additional authority to control

vessels in U. S. waters which includes control of vessels that do not meet

the minimum standards considered necessary for the existing circumstances.

Under this authority, Navigation Safety Regulations (33 CFR 164) have been

promulgated which vill becom^effective 1 June 1977.  These regulations

impose  standards of Performance _for the Navigation Watch and require
                                                     •

specific navigational equipment to be in operating condition, tested and

aboard  all vessels entering U. S. navigable waters.  The required navigational
                  f

procedures cover vessel operations underway general, in confined or congested
                                                    *
waters  and at anchor and are considered substantially compatible with the

Canadian Coast Guard Code of Navigating.Practices, and Procedures (1972 edition)

         The vessels-na-ttigating the Great Lakes are subject to compulsory

pilotage regulations administered under the terms of a separate joint agree-

ment.   These regulations are the subject of continuing review to ensure,

among other things, their compatability with the objectives of the Water


Quality Agreement.  The issuance of "Navigation Certificates  C"B" Certificates)


by the  Canadian Coast Guard has generated concern with respect to whether


                                  3
	                   SUB-GROUP B
                      ATTACHMENT -3

-------
or not this practice meets the objective of this agreement.  Basically


certificate^ provides or permits Master of Foreign flag vessels to be


their own pilot while transiting the Great Lakes.  The issuance of such


certificates should be reviewed.


         In-a continuing effort to keep abreasterapid changes in technology,


numerous studies have been initiated that address the man/machine interface


and standards of Qualifications of Personnel responsible for the security
                                                                •

and transfer of LNG and Hazardous and Noxious cargoes.  Undoubtedly as raore.


knowledge is acquired in the human factors area, additional regulatory


efforts to improve safety aboard vessels will be initiated.
                      SUB-GROUP B
                      ATTACHMENT 3

-------
                                                            3
                -  Great Lakes Water-Quality Agreement
                         Report of Sub_ Grpup_C_       "
Article V 1. (e) (v)/     *
                 r w j^
                tVjWork S
               Surveillance and EnforcementVjWork Shop)
                                  And

                                Annex 8

                 Joint Contingency Plan (Work Group 6)
1.  Sub Group C met, wfth not all members present, on 3 and k March 1977
to:

     a.  Review the terms of reference for completeness.

     b.  Review program activity and measures for the abatement and
     control of pollution form shipping sources including the review of
     the several joint stocktaking meetings, the Joint Report of Febru-
     ary 1976, and the Annual Reports of both the International Joint Com-
     mission and the V/ater Quality Board.

     c.  Analyze the specific language of the Agreement and measure ef-  •
     fectiveness towards achieving the objectives of the Agreement.

     d.  Make appropriate recommendations on language changes in the
     Agreement.

     e.  Make appropriate recommendations on program, if necessary.


                     Surveillance and Enforcement

Discussion;  Sub Group C endorses the Joint Progress Report of February
1976, pages 28 and 29, copies attached herewith as enclosure (1).   However,
the formal surveillance mechanism does not extend to surface as well as
aerial surveillance.  In making their recommendation, the Sub Group recog-
mized. and desired to emphasize, that the intent of Article V l.(e)(v)  is to
provide for visual observation and prosecution of violators of both countries'
water quality statutes and not to provide for actual water quality monitoring
as a function of determining the quality of the water.
                          SUB-GROUP C
                          ATTACHMENT 3

-------
Recommsndat ion:   That Article V 1.(e)(v)  of the Agreement be revised as
follows:

     (v)   establishment of a coordinated  system of aerial and surface

          surveillance, including  enforcement of regulations dealing

          with the abatement and control  of pollution from shippina
                                                          T         "ft *
          activities.                             -                 '*%?


                        Joint Contingency Plan

Discussion:  Sub Group C endorses  the  Joint Progress Report of February
1976, page 30; attached herewith as enclosure (2).   However, Annex 8 of
the Agreement does require revision to provide for:

     a.  reflecting the current title  of  the Joint Plan and custodians
         of the Plan.

     b.  identification of and increased  planning for high risk areas
         and areas of particular concern;

     c.  elimination of a misleading term in paragraph 3.(a), i.e.: "or
         any other substance"'as used  within the text of this paragraph
         is inclusive and when referring  to paragraph k, the inference
         can be drawn that a Party  would  bear the cost of operation, no
         matter what the pollutant.   If the term were changed to "or any
         hazardous polluting substance" 'it would more clearly conform
        .with the remainder of the  Agreement and U.  S. Lav;,'i.e. the Na-
         tional  Revolving Fund may  pay for operations related to hazar-
         dous (Polluting) Substance spills at such time as the substances
         are designated.
         ilimination of additional  misleading terms in paragraph 3(b)(iii).
         An objective of the Plan is not "to provide adequate equipment to
         respond to pollution incidents" but to "provide adequate cleanup
         response" including of course,  adequate equipment.

Recommendation:   That Annex 8 of the Agreement be revised as reflected in
enclosure (3)•

The Sub Group also recommends that  the Custodians of the Plan submit a joint
semi-annual report to the IJC on Contingency Planning Acti"ities in addition
to the current  practice of reporting on  major pollution incidents.   The Sub
Group agreed however, that such reports  need not be directed by Annex 8.
                         SUB-GROUP C
                         ATTACHMENT 3

-------
!       Report  of Vork Group 5


       Coordinated Systnn for Surveillance and Enforcement


       (reference Article V l(e) (vj)


   * _     In. July 1975» representatives of the Canadian Coast Guard and United


1       States Coast Guard signed a Memorandum of Understanding'Concerning Aerial


       Surveillance Pursuant to the Great Lakes Water Quality Agreement.  This


       Memorandum of Understanding established s. coordinated-Canadian/U.S. system


1  .     for the aerial surveillance of Great Lakes Waters the purpose of vhich is


       to abate and control pollution from shipping activities.  Pollution noted

•i                           •
  •  '   from other sources is not, of coarse, exempt from the Agreement.


        .  Under this programme of aerial surveillance the waters of *i_1 five


       Great Lakes- and their connecting waterways are patrolled,  on a regular


     '. "basis throughout the shipping season,  by aircraft of the Canadian or United
                                            *      .               •

       States Coast Guard vhich are manned by persons experienced in the identifica-


/•     tion of pollution  from  shipping activities..


•:j   •      Included in the Agreement is-a mechanics, for  the  expedient notification

1                                      :    '  •
i  •   of cognizant enforcement  officials,  whether  Canadian  or  U.S.,  vhich  is


;.    cosipatable with the rapid alerting'system established in the Joint Canada/U.S


j     Marine Pollution Contingency Plan.                     •  ' •   '

*
j    .     Both the Canadian and U.S. Coast Guard have pr-e-designated specific


•!-     officials, called Pollution Prevention-Of fie era and Captains of  the Ports

•'                          l                  '
j  -  respectively, who are strategically located-throughout the Great Lakes.  •
    ...

;    • These  officials are charged with, enforcement of pollution prevention regula-
      tions, investigation of and renovsJ. action on R-i-t pollution incidents


      reported frca any source and the initiation of .legal action for contro-.


      ventioa of pertinent legislation or regulations.  A close liaison and
                                     -   .28
                             ' SUB-GROUP C
                              ATTACHMENT'S

-------
  exchange of infcrnatioa is maintained betveen the Canadian and Unitd^ J


  .States Coast Guard toward effective investigative and -en


  activities.


      The Agreement has "been formally presented to tha International Joint
                                                        T

  Ccczaission.  Copies of applicable legislation and regulations have also


  been-deposited vith the Commission.


      Ehile not included in the formal Agreement,  incidents of pollution


-  observed by Canadian and U.S. Coast Guard surface vessels are also reported


  in consonance vith the Agreement.            .  •       "            . '
                      "SUB-GROUP C

                       ATTACHMENT 3

-------
 Report of Vorl:  Group  6

 Contingency Plan

 (reference Article V  l(h) and Annex 8)

     The Joint Canada  - United States Marine Pollution Contingency Plan,

 signed 20 June, 197^, provides for coordinated and  integrated response to

 pollution incidents by federal, state, provincial and regional contingents

 of both Parties.  The Plan provides for pre-designated Cn-Scene-Con^zanders

 and  Deputy On-Scene-Ccnnanders. who coordinate the response activities  to  •

 spills and for a Joint Response Team to provide advice and assistance  to

 the  On-Scene-Corsaanders.  It establishes, alerting and notification prccc-

 dures, -cozaand structure, post clean-up requirenents  and arrangements  for

 assuming the responsibility for the cost of operations.  The Plan replaced

 the  1971 Joint U.S./Canadian Oil and Hazardous' Materials Pollution Contingency

 Plan for the_Great Lakes Region.     '      .'..''.

     It is the riev of both the Canadian and U.S. Coast-Guard that emergencies

 in recent years, for vhich provisions of the Plan vere invoked and the Joint

 Resource Teaa activated, resulted" in prospt, direct  and decisive action by

 all  concerned.   The Canadian Coast Guard Emergency Office in the Central

 Region and the Marine Environmental Protection Branch in the. office of

 Coinaander, Hinth U.S.  Coast Guard District -enjoy a close and hamonious

relationship vhich has resulted, not only in prompt invocation of -the Plan

Trect frequent revievs and recommendations for change, cocmunication exercises

and a frequently updated directory of  cognisant personnel.

    A copy of the  Plan has -been  deposited vita the International  Joint

 Comnicsion.     '          •'..,..   .   ••.-.'..'.•••..
                       SUBGROUP'C  '••••-.
                       ATTACHMENT"-3   •

                            :      '30
                                    Ww

-------
                                                                              <>
                                                                          f'
                               SPECIMEN
                                ANNEX 8         .      '          V
                                —              :           •¥

                        JOINT CONTINGENCY PLAN
                                                       A
^-  The Plan.   The Parties agree that the "Joint Canada - Jnited States
Marine Pollution Contingency Plan for the Great Lakes (CAMUSLAK)", adopted
on 20 June \31k, shall be maintained in force, as amended from time to time.
The Parties further agree that areas of high risk and of particular concern
shall be identified and provided with detai led' contingency plans which will
augment the'CA?4USLAK,   It shall be the responsibility of the United States
Coast Guard and the Canadian Coast Guard to coordinate and to maintain the
plan, as so amended, in written form. .

2.-  Purpose.   The purpose of the Plan is to provide for coordinated and
integrated response to pollution incidents in the Great Lakes System by re-
sponsible federal, state, provincial and local agencies.  The Man supple-
ments the national, provincial and regional  plans of the Parties.

3.  Pollution Incidents.

     (a)  A pollution incident is a discharge, or an imminent threat of a
          discharge, of oil or any hazardous polluting substance, of such
          magnitude or significance as to require immediate response to
          contain, clean up or dispose of the material.

     (b)  The objectives of the plan in pollution incidents are:

          (i)  to develop appropriate preparedness measures and effective -
              systems for discovery and reporting the existence of a pol-
              lution incident within the area covered by the plan;

         (ii)  to institute prompt measures to restrict the further spread
              of the pollutant;

        (iii)  to provide adequate cleanup respon'se to" pollution incidents.

**•  Fundi ng.   Unless otherwise agreed, the costs of operations of both
Parties under the Plan shall be borne by the Party in whose waters the
pollution incident occurred.

5.  Amendment.  The United States Coast Guard and the Canadian Coast Guard
are empowered to amend the Plan subject to the requirement that such amend-
ments shall be consistent with the purpose and objectives of this Annex.
                        SUB-GROUP C
                        ATTACHMENT 3

                               SPECIMEN

-------
                                     DRAFT         '       15 March 1977
                                POSITION PAPER
                     GREAT LAKES WATER QUALITY AGREEMENT
                         SUBGROUP D, DREDGING SPOILS
BACKGROUND;
As a result of the concerns expressed in Article V, Section (f) of the

Great Lakes Water Quality Agreement, a joint Canadian-United States Working

Group was formed on 15 November 1972.  The Working Group was to look into

the environnental impacts of dredging activities on. the Great Lakes and

make recommendations for the compatible control of dredging so as to

protect environmental quality of the Lakes.  In May 1975, the Working

Group completed its report to the Secretaries of State for the United

States and for Canada.



REPORT'S CONCLUSIONS:



The Working Group's Report provides the basis for developing a position to

be used by the Department of State in the upcoming review of the Agreement.

First, it was apparent from a review of dredging performed prior to the

1970 Ts that the choice of disposal method, usually open water, did not

impose rigorous requirements for precise definition, of the sediment character-

istics.  Therefore, past experience provides a very limited basis for

evaluation of environmental factors involved in' dredging activities .

Second, the potential pollution hazards due to dredging are related to the

physical characteristics of the sediment as well as its biological and

chemical properties.  Third, a number of the chemical  analyses that are
                           SUB-GROUP D
                           ATTACHMENT 3

-------
used to assess the presence in sediments of heavy metals and organic

materials, provide a measure of total concentrations but "yields little

direct evidence of their availability for biochemical activity.  Fourth, -

many locations have natural background levels higher than the criteria

concentrations that have been used in the past to classify dredged sediments

as polluted.  Fifth, environmental protections will best be served by

site-specific evalutation.  Sixth, the effective formulation and

evaluation of projects will require continuing coordination- of experience

and the application of sound judgment to achieve a consistent and

compatible approach.  Seventh, the approach to evaluation of dredging

projects from an environmental standpoint must, of -necessity, proceed

with two fundamental objectives in view; the preservation of designated

water uses, including viable aquatic and terrestrial ecosystems, and the

optimization of net socio-economic benefits to society.  'Eighth,- to

accomplish dredging activates in an environmentally acceptable and

socially optimum manner will require evaluation of all practical alternatives

Nineth, confined terrestrial sites should make the best use of available

materials and engineering knowledge to achieve a facility which can be

of some future use to the community.  Tenth, maintenance dredging projects

are more likely to give rise to adverse and intense short-term pollutional

effects than would be expected from new or capital works projects.

Eleventh, the choice'of dredging plant, generally, has little influence

upon long-term effects.  However, plant and operating procedures should

be considered with respect to various short-term aspects of environmental

concern.  Twelfth, the consideration of project alternatives, of the

beneficial utilization of dredged material and of permanent works to

reduce or eliminate maintenance dredging require more lead time than has

been provided.  Working from a. five-year program forecasts, a reasonably
  '-*
    	?	
              •   • •  • ~ ~- -SUB-GROUP"b  '^~~r~~r-      •"""*—'7~   p*~~r**     .-*

-------
firm indication of programs should be established at lease two years

before execution which allow for detailed project formulation taking

fully into account considerations of environmental concerns.   Thirteenth,

there appears to be no lack of legislation as nay be required to implement

the procedures in the report for programming, assessment, and control of

dredging activities.  However, there may be a need to modify regulation

and improve administration procedures to implement the intent.  Lastly,

the question of financing, and of continuing responsibility for disposal

facilities requires further consideration by the different jurisdications.
                                               *
It will be essential to determine the basis for cost allocation between

purposes and to develop a workable basis for financing of multi-purpose

projects developed to meet environmental constraints.  The complete text

of the conclusions can be found on pages 139-143 of the Report.



REPORT'S RECOMMENDATIONS:.      •                                 '   '


                                                •                •
With respect to recommendations the Working Group was directed to conduct

its studies and formulate its recommendations on the basis of the following

principles:

     a.  Dredging activities should be conducted in a manner that will

minimize harmful environmental effects.

     b.  All reasonable and -practicable measures shall be taken to

ensure that dredging activities do not cause a degradation of water

quality and bottom sediments.                                            '.

     c.  As soon as practicable, the disposal of polluted dredged s^oir

in open water should be carried out in a manner consistent with the

achievement of the water quality objective, and should be phased out.
                           SUB-GROUP  D
                           ATTACHMENT 3

-------
"  With these  principles  in nHnd the Working Group  recommended  that  the




basic criteria for  all  dredging activities should be  the  preservation of  •




designated water uses,  including viable aquatic and terrestrial  ecosystems




and  the  optimization of the net socio-economic benefits to  society.




Accordingly, all future evaluations of dredging projects  will be site-




specific in  accordance  with the guidelines developed  to protect  the




water quality objectives established in the Great Lakes Water Quality




Agreement as well as any more strigent objectives imposed by  other




authorities  which are over-riding.  Further, that the characteristics of




bottom sediments at proposed open water disposal  sites, be  determined so




as to provide indications of chemical and other constituents  in  terms of




their availability  to the ecosystem.   To accomplish the foregoing, the




Working  Group recommended that:




      a.   Adoption of the recommended guidelines and criteria  for the




evaluation of environmental and socio-economic considerations relating




to all dredging projects be accomplished by administrative  action, and




that their application  be evaluated in practice before any  substantial




revision in  legislation is contemplated.




      b.   Research be encouraged to investigate advances in  dredging




technology and the  availability of materials such a^nutrients and  potentially




toxic substances as related to dredging procedures and to define specifically




the  nature of such  impacts.




      c.   Project proponents retain appropriate technical  competence to




ensure the recognition  of all potential environmental impacts and  the




adjustment of proposals as well as to facilitate  their audit  by  the




appropriate  regulatory  agencies.




      d.   Administrative procedures be adapted to  provide  a.  forward




indication of dredging  requirements on a  running •  five-year  basis and  a
                                                                                   par

-------
 minimum of  two years between commencing detailed project formulation and

 actual execution.

      e.  Project  financing policy for multipurpose dredging projects be

 addressed by  the  relevant authorities.  Finally, it is recommended,

 that:

      A standing committee be established:

        To ensure  the compatible implementation of the guidelines for

 environmental assessment as presented herein,

        To review  the effectiveness of the guidelines in maintaining

 water quality as  a result of dredging operations,

        To encourage the exchange of information from both experience and

 research, and

        To recommend, from time to time, changes in criteria and guidelines

 in the light  of advances in knowledge and the  accumulation of reliable

•experience  records.  The complete text of the  recommendations can be

 found on pages 144-145 of the Report.
           •
                    •


 U.S.  PERFORMANCE;



 Section 123 of PL 91-611 authorizes the construction,  operation, and

 maintenance of contained disposal facilities of sufficient capacity for

 a period not  to exceed ten years for the containment of polluted materials

 from dredging operations in the Great Lakes and connecting channels.

 Construction  of diked disposal facilities  have been completed to date at

 eight locations,  namely:  Milwaukee,  Manitowoc and Kenosha,  Wisconsin.;

 Grand Haven and Lake St. Clair,  Dickenson  Island, Michigan;  and Cleveland,

 Huron and Toledo,  Ohio.  The facility at Buffalo, New York,  is practically

 completed and will be operational by summer.

                                         5
._	r-r,	^	—....-..nCUD-SKGUm D	< •.--..- .•-	—rrr^-"	• •.  • • '—-••.

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 Construction contracts  are underway for  five more diked disposal  facilities,

 namely:   Saginaw River,  Pointe Mouillee.or Detroit-Rouge-River  site,  and

 Holland,  Michigan;  Lorain and a second  site at  Cleveland, Ohio.  A

 contract  for Holies Harbor, Michigan, is  being  advertised for bidders     '  •
 now.
 The $33,310,000  recommended in the FY 78 budget for  the diked  disposal

 program will provide for the completion of-all of the above  projects

 with the exception of the facilities at Cleveland, Ohio, which will

 continue in FT 79.  It also provides for two new starts, Green Bay,

 Wisconsin and Erie, Pennsylvania.   Design will continue for  the  balance

 of the projects  for which diked disposal facilities  are required.



 We have monies to start the disposal^site at Duluth/Superior.  This          -

 harbor, which has undergone major  port expansion, must be  provided a       -

 site this coming year.  The lake levels of Lake Superior are in  fact

 declining and our ability to dredge this vital harbor must not be impaired.



 In summary, we will provide 41 sites to accommodate  58 projects, which

 have polluted materials to be dredged.   The current  estimated  cost for

 construction, is  $265 Million; funding for this program prior to  FY 77   .

 was $102.3 Million; .'FY 77 funding  is $36.7 Million;  for a  total.to date    ..

 of $34.0 Million.



 The same River and Harbor Act of 1970 that authorized the  Confined Disposal

 Area Program, under Section 123 (i), authorized the  Dredged  Material  Research

 Program.  This $30 Million, 5-year study, has been under the management

 supervision of the U. S. Corps of  Engineers Waterways Experiment Station.

	^	f	  6	
                            'SUB-Gpr>UP D      *        ;  T"7""'"'

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 The study is  cd provide-through research-definitive information on the


 environmental impact  of  dredging and dredged material disposal operations


 and to  develop technically satisfactory,  environmentally compatible,  and


 economically  feasibly dredging and disposal alternatives,  including


 condiseration's of  dredged material as a manageable resource.   This


 program- is scheduled  for completion in March 1978.   The research output


 should  be useful in assessing the .environmental  impacts of dredging and


 dredge  material ,dis_posal.





 The U.  S. has issued  interim final guidelines persuant to  Section 404


 (b) of  the Federal Water Pollution Control Act Amendment of 1972, PL  92-500.


 These guidelines are  to  be applied in evaluating proposed  discharge of


 dredged or fill material in navigable waters. The pertient part of


 these guidelines.deals with the tests to  be used to evaluate the effects


 of proposed discharges of dredged or fill material.   To date,  certain


 physical and  chemical biological effects  have been identified and test


 procedures established to assess the impact of discharges  of dredged  or


 fill material.  The development of additional tests is on  going and it


 is the  intent of the  U.  S.  Environmental  Protection Agency and the U.  S.


 Army, Corps of Engineers, to issue final  testing procedures in the very


 near future.





 RECOMMENDED U. S.  POSITION;





 The Subgroup  conducted a public seminar on 11 March 1977 at Chicago,


 Illinois, to  assesss  the progress made to date by  the United  States with


 respect to the Agreement, in particular Article  V,  Section (f).   The


 concensus of  those attending the Seminar  was  that  the Working  Group



                                        7
	__	,—,	 .  - .jOUD-6RQUr B	=	' 	>•••"•	•	«——

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 Report, while it represented a good background document on dredging



 activity on the Great Lakes, it had not recommended "neasures for the
                                                                           f


 abatement and control of pollution froa dredging activities, including the



 development of Criteria  (emphasis added) for the identification of polluted



 dredged, spoil and  compatible Programs  for disposal of polluted dredged spoil."


 It was  the feeling of the Seminar that the site-specific approach recommended



 in the Working Group Report was valid, provided one did not have to



 start from "ground zero" each tine in evaluating a project.  The concensus
                                                        «

' of the  Seminar that the United States position should be to press for



 implementation of guidelines and criteria currently being formulated by



 the U.S. EPA-COE Technical Comittee for Regulatory Criteria for Dredge



 and Fill Activities.  Another view of the attendees at the Seminar was



 that additional effort, is  needed to reduce sediment loading to our



 waterways and thus reduce the need for. dredging in thes.e saaa waterways.



. Comments were made along the lines that guidelines and criteria similar



 to that contained in the final Ocean Dumping regulations (Federal Register



 11 January 1977) should be developed for inland waters, including the



 Great. Lakes.  The Subgroup accordingly, suggests .that the IT. S. position



 be that guidelines and criteria be compatible with that being developed



 for inland waters.  Further, it is suggested that the Working Group's



 recommendation that a Standing Corsaittee be established to provide a forun


 for continual updating of guidelines and criteria be adopted.
                            SUB-GROUP D

                            ATTACHMENT^

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   SUB-GROUP A




FUNCTIONAL CHART




      AND




   MEMBERSHIP


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                          MEMBERSHIP

                          SUB-GROUP A
George R. Alexander, Jr. (CHAIRMAN)
Regional Administrator
U.S. EPA, Region V

Gerald M. Hansler
Regional Administrator
U.S. EPA, Region II

Dr. Eugene Aubert
Director, GLERL, NOAA
Department of Commerce

Marvin Rubin
Office of the Secretary
Department of Commerce

Robert J. Schneider (SECRETARY)
Great Lakes Coordinator
U.S. EPA, Region V

Gerald Welsh
Soil Conservation Service
U.S. Dept. of Agriculture

Nelson A. Thomas, Chief
Large Lakes Research Program
U.S. EPA, ORSD

Ms.. Janis Rasgus
North Central Div.
Corps of Engineers
Ralph Christensen
108a Coordinator
U.S. EPA, Region V

Dale S. Bryson
Enforcement Division
U.S. EPA Region V

Dr. Albert Sherk
Fish & Wildlife Service
Department of the Interior

Dr. William A. Mills
Radiation Criteria £ Stds.
U.S. EPA, Hdqtrs.

Dr. Donald I.  Mount
Director, Duluth ERL
U.S. EPA, OR£D

Jack Hemphill
Regional Director
Fish £ Wildlife Service
Dept. of the Interior

Karl Bremer
ASHM Division
U.S. EPA, Region V
Div.
                         ATTACHMENT

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                     STATE ADVISORY GROUP
Eugene F. Seebald, Director
Division of Pure Waters
New York State DEC

Walter A. Lyon, Director
Bureau of Water Quality Management
Pennsylvania DER

Ms. Sandra Gardebring
Executive Director
Minnesota PCA

William G. Turney, Chief
Bureau of Water Management
Michigan DNR
Ned E. Williams, Director
Ohio EPA
Anthony S,
Wisconsin
 Earl
DNR
Secretary
Leo M. Eisel, Director
Illionis EPA

Oral H. Hert, Tech. Sec.
Stream Pollution Control" Bd.
State of Indiana
                    FEDERAL ADVISORY GROUP
Dr. Eugene Aubert
Director, GLERL, NOAA
Department of Commerce

James S. Gracey, RADM
9th Coast Guard District
Department of Transportation

Walter G. Belter
Analysis £ Assessment Programs
Biomedical and Environ. Research
ERDA, Washington, D.C.

Gerald Welsh
Soil Conservation Service
U.S. Dept. of Agriculture
Dr. Morris Tepper
Office of Applications
NASA,  Washington, D.C.

George Marienthal
Deputy Asst. SECDEF
DOD, Washington, D.C.

Ed Geismar
River Basins Coordinator
U.S. EPA, Region III
                           ATTACHMENT  4

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      WATER QUALITY OBJECTIVES AND SURVEILLANCE WORK GROUP
       Water Quality
       Surveillance
Lovell E. Richie, Jr. (LEADER)
Minnesota PCA

Gerald R. Lowry
Environmental Services Div.
Soil Conservation Service
Dept. of Agriculture

Dr. Andrew Robertson
GLERL, NOAA
Dept. of Commerce

Charles Walker
Fish £ Wildlife Service
Dept. of the Interior
(Alternate-Larry Sisk)

William Fox
Water Planning & Stds.
U.S. EPA, Hdqtrs.

Chris Potos
U.S. EPA, Region V

Tim Saylor
Erie Co. Health Dept.
Erie, PA
Christopher M. Timm  (LEADER)
Director, SSA Division
U.S. EPA, Region V

Robert Crim
Monitoring Branch
U.S. EPA, Washington, D.C.

William McCracken
Michigan DNR

Wayne A. Willford
U.S. Fish 6 Wildlife Service
Great Lakes Fishery Lab.
                      PHOSPHORUS WORK GROUP
Nelson A. Thomas (LEADER)
Large Lakes Research Program
U.S. EPA, OR£D

Dr. Andrew Robertson
GLERL, NOAA
Dept. of Commerce

Kenneth Mackenthun
Criteria £ Stds. Div.
U.S. EPA, Hdqtrs.

David Rockwell
SSA Division
U.S. EPA, Region V
Michael Stickler
Michigan DNR

Dr. Albert Sherk
Fish £ Wildlife Service
Department of the Interior

Ray Hasse
Regional Office, BWQM
Dept. of the Interior
                       ATTACHMENT 4

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                 POINT SOURCE DISCHARGES WORK GROUP
 Dale S. Bryson (LEADER)
 Enforcement Division
 U.S. EPA Region V

 Charles E. Fogg
 Soil Conservation Service
 Dept. of Agriculture

 Edwin C. Horn, Jr.
 U.S. EPA, Region V

 Mr. Barry S. Shanoff
 Office of Enforcement
 U.S. EPA, Hdqtrs.
Paul N. Guthrie
Wisconsin DNR

Wane A. Willford
U.S. Fish £ Wildlife Service
Great Lakes Fishery Laboratory

Joseph R. Tynsky
U.S. EPA, Region V

Tim Saylor
Erie Co. Health Dept.
Erie, PA
                     NON-POINT SOURCES WORK GROUP
 Ralph Christensen (LEADER)
 108a Coordinator
 U.S. EPA, Region V

 Gerald Welsh
 Soil Conservation Service
 U.S. Dept. of Agriculture

 Robert E. Thomson
 Water Planning Div.
 U.S. EPA, Hdqtrs.

 Dr. Stephen Yaksich
 Buffalo District
 Corps of Engineers
Carl D. Wilson
Water Division
U.S. EPA, Region V

Merle Tellekson
S£A Division
U.S. EPA, Region V

Kenneth Schoener
Div. of Water Quality
Pennsylvania BMQM
                    HAZARDOUS SUBSTANCES WORK GROUP
Karl Bremer (LEADER)
A£HM Division
U.S. EPA, Region V

Dr. Jesse Lunin
National Program Staff
Dept. of Agriculture
(Alternate-Dr. Robert Holt)

Charles Walker
Fish £ Wildlife Service
Dept. of the Interior
Albert Bromberg
Div. of Pure Waters
New York DEC

Dr. Andrew Robertson
GLERL, NOAA.
Dept. of Commerce
                            ATTACHMENT  4

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                 HAZARDOUS SUBSTANCES WORK GROUP cent.
David C. Rockwell
SSA Division
U.S. EPA, Region V
Thomas Kopp
Office of Toxic Substance
U.S. EPA, Hdqtrs.
William Libri^zi
Director, SSA Division
U.S. EPA, Region II
Dr. Hugh Thompson
Materials Transport Bureau
Dept. of Transportation
Washington, D.C.
            NUCLEAR WASTES (RADIOATIVITY) WORK GROUP
Dr. William A. Mills (LEADER)
Radiation Criterial S Stds. Div.
U.S. EPA, Hdqtrs.

Peter Tedeschi
ASHM Div.
U.S. EPA, Region V

Enrico Conti
Office of Stds. Development
NRC, Washington, D.C.

Paul Giardina
Radiation Rep.
U.S. EPA, Region II
Dr. Roger J. Mattson
Office of Stds. Development
NRC, Washington

Ms. Sandra Gardebring
Executive Director
Minnesota PCA

Margaret Reilly
Bureau of Rad. Health
PA Health Dept.
                       RESEARCH WORK GROUP
Dr. Donald I, Mount (LEADER)
Director, Duluth ERL
U.S. EPA, ORSD

Dr. Jesse Lunin
National Program Staff
Dept. of Agriculture
(Alternate-Dr. Robert Holt)

Robert Bowden
G.L. Surveillance Branch
U.S. EPA, Region V

Dr. Herman Mark
Lewis Research Center
NASA, Cleveland,.Ohio
Dr. Eugene Aubert
Director, GLERL, NOAA
Department o-f Commerce

John Carr
Great Lakes ERL, NOAA
Dept. of Commerce
Dr. J. Kutkuhn, Director
Great Lakes Fishery Lab.
U.S. Fish and Wildlife Service

Archie McDonnell
Land and Water Research
Penn State University
                          ATTACHMENT 4

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       Comments from Public Interest Groups and Others






The attached memorandum requesting comments from selected public



interest groups is self-explanatory and contains a list of the



groups to whom copies of the draft material was sent.  No comments




of substance were received form the public interest group because



of the short time frame in which comments were requested.






Also attached is a letter from one of the public interest groups,



Great Lakes Tomorrow, requesting copies of the original review



material.  A copy of the complete report of Sub-Group A will be




provided as indicated in the attached reply.






Other pertinent written commentary is also included in this




attachment.
                        Attachment 5

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MAILGRAM SERVICE C
MIDOLETOWN,  VA.  22645
                              western union
2-031163E103 04/13/77 ICS IPMHTZZ CSP CGAB
 7177879639 M6M TOMT HARRIS8URG PA 272 04-13  12U6P  EST
GEORGE H ALEXANDER JR

US £PA REGION 5
230 "SOUTH DEARBORN ST

CHICAGO IL 60604
                                             RECEIVED
 APR 1 A 1977


EPA REGION 5
OFFICE OF REGIONAL
DEAR GEORGE,
WE STRONGLY OBJECT TO THE POSITION SUGGESTED IN DRAFT  STATEMENT  OF
SUB-GROUP A WORKING ON THE GREAT LAKES WATER QUALITY  AGREEMENT  REVIEW,
WE UNDERSTAND THE PURPOSE OF THE POSITION TO BE THAT  CANADA  SHOULD
ADOPT A PROGRAM SIMJLIAR TO P.L. 92-500 AND THAT UNLESS  THIS HAPPENS
THE GREAT LAKES POLLUTION PROBLEMS WILL NOT BE SOLVED.  THE  STATEMENT  AS
DRAFTED EXPRESSES CONCERN ABOUT PROGRAM ELEMENTS AND  NOT RESULTS

THF. PURPOSE OF THE AGREEMENT IS TO PROTECT THE GREAT  LAKES  FROM
POLLUTION AND TO REMOVE THE CURRENT SOURCES OF POLLUTION,  THE PROPOSED
POSITION STATEMENT THAT WAS SENT FOR COMMENT INDICATES  THAT  CANADA  DOES
NOT HAVE AFFLUENT LIMITS SIMILIAR TO THOSE REQUIRED UNDER  P.L.  92-500
AND THEREFORE, THEY HAVE AN INFERIOR PROGRAM,  YET,  THE  ONE  AFFLUENT
LIMIT THAT WAS ESTABLISHED UNDER THE AGREEMENT*  THAT  IS  THE  PHOSPOROUS
LIMIT, HAS BEEN IMPLEMENTED IN CANADA AND HAS  NOT  BEEN  SUCCESSFULLY
IMPLEMENTED IN THE UNITED STATES EVtN WITH P,L.  92-500

WHILE WE DO NOT DISAGREE THAT THE PARTIES MIGHT CONSIDER AN  AGREEMENT
ON APPROPRIATE MINIMUM AFFLUENT LIMITS, WE DO  NOT  BELIEVE  THAT  THE
RECOMMENDED POSITION WILL ENHANCE THE CLEAN-UP AND  PROTECTION OF
QUALITY OF THE LAKES. OUR POSITION SHOULD EMPHASIZE RESULTS,  RATHER
THAN FORMS

THE SPECIFIC CHANGES TO MAKE THE AMMENDED AGREEMENTS  MATCH  P.L.  92-500
WILL PROBABLY DO VERY LITTLE TO IMPROVE THE QUALITY OF  THE  GREAT LAKES,
FORCING CANADA TO ADOPT THE CONCEPT OF P.L. 92-500  WILL  BE
COUNTER-PRODUCTIVE, WE DO NOT AGREE WITH RENEGOTIATION  OF  PROVISIONS
THAT ARE NEEDED TO ADEQUATELY ADDRESS PROBLEMS THAT HAVE BEEN
RECOGNIZED IN THE LAST FIVE YEARS, SINCERELY YOURS
WALTER A LYON,  DIRECTOR
BUREAU OF WATER QUALITY MANAGEMENT
DEPT OP ENVIRONMENTAL RESOURCES


12*46 EST


MGMCOMP MQM

                       ATTACHMENT 5

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             DEPARTMENT OF ENVIRONMENTAL RESOURCES
                          POST OFFICE BOX 2O63
                      HARRISBURG, PENNSYLVANIA  17120


                               April 26, 1977
Mr. George R. Alexander, Jr.
U.S. Environmental Protection Agency
Region V
230 South Dearborn Street
Chicago, Illinois 60604
Dear George:

     I would like to reemphasize the point that was made in my April 13,
1977 mailgram to you concerning the United States position on the Great
Lakes Water Quality Agreement review.

     The draft report of Subgroup A (with an April 29 date) would appear
to us to serve as an excellent stimulus for Canada to withdraw from a
Great Lakes agreement.

     The assumption that P.L. 92-500 is the only sound basis for a water
pollution control program is not a valid position to take, especially in
international negotiations.

     We have no objection to having the agreement consider all the
waters of the boundary waters system rather than just the boundary
waters themselves.  We have no disagreement with the concept of system-
wide planning criteria for the entire Great Lakes system.

     A rather significant recommendation, for which the need is not
documented in the report, is the recommendation to abolish the IJC Great
Lakes regional office.  Although we have had some disagreements in the
past over the staffing and organization of the regional office, it seems
to serve as a good resource for negotiations and doing work that the
agencies might have a difficult time doing otherwise.  As a matter of
fact, this is why the office was created.  To abolish it now would be a
serious error.  The discussion in the report provides no basis for this
decision.
                       ATTACHMENT 5

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                                -2-
     We urge that the "adopt P.L.  92-500 or else" policy be dropped in
favor of a much harder look at the goals,  objectives and standards that
are needed to protect the Great Lakes system.

     Our quick review does not disclose any proposal to strengthen the
program planning and evaluation aspects of the agreement.   No effort to
evaluate fiscal, legal and manpower resources  and gaps on a year-to-year
basis appears to be proposed.
                                   Sinoerely yours,
                                   Walter A.  Lyon,  Director
                                   Bureau of  Water  Quality Management
                       ATTACHMENT 5

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                                  U,&
                                                  OF
                                  Gre#t l«fc**
                                  2!KX> \te#bt
                                  Ana Arbor,
                                                    48104
       •'..  1977
                   R.
                             » Jr.
       r.  fcw-ger/e- J «
^^
\\\   'vO\l"°    ^J-
 \ Z.M   !> , *        '-^  ~.
 \ .\\  : '      --'' . r^~
 \-\       •  --'\\\V>!
                            A
            Cofes?P»tu oa April 20,  197V ^
                                            l»r»ft" of Sub-Group A
       three c^8HKtot» v&ich I would  l,tk* to «6S&e»  co»»iBte»t *ith
           I h*4 on the phone today  with &ob Scbx»fri<5er»  on ti>e
       1*  _LIC yiiribtoir Office.   I  sat i» f«v*r of retaittitsg the UC
  Office,  i  believe  it  serves  a useful function e# » tieutrdl Itti^
        on cmiftifto gxoorjd fo?'U,&.  *i»i«s* of
             that there *T«  dftficSeaties i» tbe presently
  OJflce, both with respect to  itg reepo%»ivim«^$ enrf staff c^ftbility.   X
        that  the tJC  {?1»49OT" Office b* iaprovefJ-^-that it b* T»a«J the Beferenee Cro»|s-s.  The fcojtrd of
  Directors  chosld have  reBpoasibility for spproval of persofiocl actiofts  (hiring,
  firtog, prossotiou^  «»«($») t«4 the piogrs* pl^ss.

                                                   I agree vith Don Kouat
                                                      to control poilotlo0
                                                            Thft water
                                                                 HQ0S/S8UQC

        of v«ter ^wility objectives i& not th*
    Great Lakes •  Oi«e B««d* to  control pollutloa lo&dft»
         cs, however » darveXoped  ot>er th* li»t
    Approved by the Hater Qu&lity  Board apply to tbe b«mitary waterg of
the Cr<&t L$k&s, cot to the water* of the Greet Lake? system or to
Specifically,  o* p«g« 6 of  the  tntrod\?etory r^sark* w« the report, the
point i» msd«  th*£ it fly*tea~vide  spprosd> tei*t be aside to water pollution
eoatroi «ad  the distinction betwcea bovmdary waters an4 tributary waters
swst be ea4edr Tbi* fe Rot true  with reftpect to the water quality
c-bjftctlv«MS which bsve b*w  agreed to by the Water Quality &o*rd ftlthougb
it is true with respect to  ttlttljttua creatcent r«QwlreK£-nt»,  M revised,
the Agreejae&t DW specifier  th*t the specific water quality objectives  apply
&}
                              ATTACHMENT 5
                                                                                        > .'-

                                                                                        ! '"
                                                                                      f_ .

                                                                                        |i-;|i

-------
                                      -2*
to all tb* waters of  the  Greet l^keo e^&terai  I fe«l tV>ls  i* oa*d«e be-
cause the objective*,-  were devt-Toy^d epecifically for the vgtfer*  of the
      Lefees  sod ere »ot applicable to ittlsrjii voters,  fuxthet ,  the pol-
       »fcer»»#U<*&al problem u»til  the pollutants
      the Gr&at Lsk^s sstS here the vr.iter quality objectives vilJ be
        if they &?& tat.   This teco/t u r*ded cbattgi' i» ef>j>e#j»t  requires
                        parts of ttie Hffr»*l dssftn!
( B ) /- 1 f i r •» P 7J J - 1, I'si _c 5 1J,- ? J
                                            r t
                                                        v be- ) v  it
                                                                                      K-
objectives  f&r the
     3*
                   the
                    Articlfe X-2c)
                                  I to re«ly good  job uaadcr the eircwsstancee
in developing * gurveilloore progr«»r  I belies*, bov^wr, tb*t thia study should
t»ot  be jwreued by cossaittee bwt ehould be undertaken  by * cotttt*etor i» Bfl*e
           t depth (a cost «pprox;tasting  $300 1 000, for o»e year)*  Tne develop-
      of «ueh * l*rge fturvfiillaAc« progr*a of « contin»ows rwitur* should h»v* em
           y*t*m$ cngifier/sritig sfialysia coupled  vith limnologioal arid ob*erva-
        data sequi«itic»» systems k»ov-bov*
                                                         ""*>

In liea of the text  contained in Article X, gfriticm 2(c) > I recossearf that such
a study be
                              ATTACHMENT 5
                                                                                      vs£r^#

                                                                                      ^'^jui'' '•• ".••-•1-
                                                                                          "

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RECORD OF
COMMUNICATION
TO:
Mr. Schneider
J^PHONECALL QDISCUSSION Q FIELD TRIP
Q OTHER (SPECIFY)
[^CONFERENCE
(Record of item checked above)
FROM: DATE
April 26, 1977
Oral Hert, Indiana Stream T1ME
Pollution Cont. Bd.
1
 SUBJECT
                Comments on Final Draft of Sub-Group A Report  on  Review of G.L.W.Q.A.

. ^u.HN,\ ' .' OF COMMUNICATION

               Mr.  Hert had the following comments:

               Article II (b) - Disagrees with the prohibition of discharges of toxic
               pollutants.  Believe that objective is impractical and  that paragraph
               should be changed to conform with similar paragraph of  PL-92-500.

               Article II (c) - Questions whether the Agreement can tie the States
               and local governments into an overall assistance program.

               Article V 1 (j) - Questions how a Water Quality Board can get 5nvolved
               with air pollution problems?

               Article V 2 (a) CO - Questions appropriateness of "detection of vio-
               lations of Water Quality objectives."  Suggest  that the word "Violation"
               be changed to "Excursions" (deviations).

               Article VII - Objects to abolishing Region Office.   Believes that the
               Regional Office provides the focal point for bi-lateral cooperative
               efforts and that government agencies could not  provide  this focus.
               Suggests that the functions' and direction of the Regional  Office may
               need to be changed and that the Boards need to  exercise better control
               of Regional Office.
CONCLUSIONS. ACTION TAKEN OR REQUIRED
               Article II (b) Changes made as suggested.
               Article II (c) Change not made.  This  is  a  goal  to work toward.
               Article V 1 (j) Boards' purview would  be  broaden by this change,
               Article V 2 (a) CO Change made as  suggested.
               Article VII Change not made—see discussion of Article VII.
INFORMATION COPIES
TO:
                                     ATTACHMENT 5
EPA Form 13004 (7-72)   REPLACES EPA HQ FORM 5300.3 WHICH MAY BE USED UNTIL SUPPLY is EXHAUSTED.

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                             STATE OF MICHIGAN
. RESOURCES COMMISSION

T. JOHNSON
LMTALA
I PfllDGEON
1Y F. SHELL
IY H. WHITELEY
l_ WOLFE
ILES G, YOUNGLOVE
          WILLIAM G. MILUKEN, Governor

 DEPARTMENT OF NATURAL RESOURCES
STEVENS T. MASON BUILDING. BOX 30O28. LANSING. MICHIGAN 48909
           HOWARD A. TANNER. Director


                   April lf 1977
                                                                  081977
     Mr.  Colgate S. Prentice
     Special Assistant for Liaison                           E?A REGION 5
       with the Governors                                    OI-FICE OF REGIQHAL
     United States Department of State                        "ov'lv'sTftAro
-------
Mr. Colgate S. Prentice        -2-             April 1, 1977


under observation.  When this same device is installed in a
vessel which may be subjected to only occasional inspection or
checking by the operator and when rough weather, lack of
maintenance equipment, etc., is the rule rather than the
exception, there is no assurance that it will continue to provide
adequate treatment.  Even the most sophisticated and automated
municipal sewage treatment  plant experiences breakdowns and
malfunctions and requires regular monitoring and maintenance,
conducted by trained and licensed personnel.

In this light, the Michigan Water Resources Commission was
disappointed over the promulgation of rules by the Canadian
Government allowing the discharge of partially treated sewage
from commercial vessels on  the Great Lakes.  While the Canadian
requirements are more stringent than those implemented by the
United States Coast Guard,  they are substantially less than the
U.S. Environmental Protection Agency requirements for municipal
discharges.

The Administrator of the U.S. Environmental Protection Agency has
granted Michigan authority  under Section 312 (f) (3), P.L. 92-500,
to enforce its statute prohibiting the overboard discharges of
sewage.  It is our full intent to do so in a reasonable manner.
The concerns of the Michigan Water Resources Commission are
expressed in the enclosed Resolution.

                               Very truly yours,

                               WATER RESOURCES COMMISSION
                               W. Gf. Turriey-essss=s=—s'
                               Acting Executive Secretary
cc:  Mr. Henry Smith III
     Mr. Karl Jonietz
     Mr. Douglas Costle     s
     Mr. George Alexander >/
     Premier William Davis
     Governor Milliken
     Governor Anderson
     Governor Lucey
     Governor Thompson
     Governor Bowen
     Governor Rhodes
     Governor Carey
     Governor Shapp
     Michigan Natural Resources Commission
     Canadian Department of the Environment


cc:  S & A
    Mr. Schneider

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          MICHIGAN  WATER RESOURCES COMMISSION

                      RESOLUTION

        COMMERCIAL WATERCRAPT POLLUTION CONTROL
WHEREAS, it has come to the attention of the Michigan
         Water Resources Commission that the Canadian
         Government on February 4, 1977, promulgated
         regulations allowing the discharge of partially
         treated sewage from commercial vessels cruising
         the Great Lakes and connecting channels; and

WHEREAS, the new Canadian regulations do not comply with
         the no discharge requirements of the State of
         Michigan covering all of Michigan's portion of '
         the Great Lakes and connecting channels, and
         the no discharge provisions of the states of
         Minnesota, Wisconsin, Illinois, Ohio and
         Indiana; and

WHEREAS, the new Canadian regulations contravene the
         no discharge recommendation for all Great Lakes
         water adopted by the Water Quality Board of the
         International Joint Commission in consideration
         of and in support of the 1972 Great Lakes Water
         Quality Agreement between the United States and"
         Canada.

NOW THEREFORE BE IT RESOLVED, that the Michigan Water
         Resources Commission hereby records its extreme
         disappointment in this action of the Canadian
         Federal Government and implores the United
         States Government to seek reconsideration of
         this matter; and

BE IT FURTHER RESOLVED, that copies of this Resolution
         be .sent to Governor Milliken, Michigan Natural
         Resources Commission, the International Joint
         Commission, United States Environmental Protection
         Agency, Canadian Department of the Environment/
         and to the Governors and Premiers of the other
         Great Lake States and Provinces.
At the Water Resources Commission March 24, 1977, meeting,
Mr. Quackenbush made a motion, supported by Mr. Lay, that
the above resolution be adopted and transmitted as stated
therein.  Motion unanimously carried.

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Review of Final  R'-port  -  Intcrr.t.tlonal Working Group
on  the Abatement and Control of  Pollution  fror.i        -      FPP  9 n  1f)7r
Dredging Activities                                            re D  ^ U  iy, 0

Acting Regional  Administrator
Region V


Office of i;ra-rr.;;tic,-.;i'J Activities (A-10C)


     This is  in  rcspop.se  to the  letter ciutcd fccer-ber 23* 1S7C;5  fro-n
fir. lihdsey Grant, Acting Deputy Assistant Secretary, Environi^nuil
rolo  ES the federal r.;&:;bcr of thy  V^tar Q^lity Board
      Let r;Q first c.ck;!owlc?d^ the ext^n?iv--i cn-j r.-^cellont
effort of th-2  Ucrkinq Group.  It h^s ucv^i^r::d s t.r-c-.nlEa c-si  thr-
subject clearly cx^rc^jrir.g t!;o  p;\:'-)lun»  ti.C' si'.^x= of i'^ art,  thG
;.;yriwu of t^chnicil anU  environ";;;! stil co;:ip]t::K!:a  invoivod,  and t'vi
challenges to  any regulatory -K.cucy who  v/oiud he;:-;;  to coritrol  this
activity in a  uunrjar consistent vntu tha Uater Qjility GL-jcci/ivos.

      In ti'.Ci HGCtion on Dsficlsnciss^ a iv:-;.c'..'r."cr;'S
and noc'io-*''::r-v:'r;ic concci-ns en  C;\;f'c1nq  activit:i-:  via th- ap^ric^ I'h-n
             *          *       "       '         "   '
rc-sp^ct to all.   ! strongly r,u;xort "<;his  cc-:---:-rr5 ;:nd  tho r.:-c::,.--n:-v'-t-icr::;
n::^!^ wit!; r-'-3r-"-Ct to this d.*fici::acy.  f-Mch :^u-,:.V^ G;:ojid 1-- tu;-^.' M -->;-:.
 tfi  >**"i '\ '{•;."", /*•'» { " '.' % f, c r^ * ". i" 't *i v%'t "fT*-V"* ' "-'v* '• *** " *"*"- *  t" f. *,'' "••  ' * "^r> J"  '•*,--. -^- » »-^ v> *' r  -" .•*  «*• *"*.•*» *,-"• _
 •*^  t^. t _. i J, \*- t t > -.-.::,..\-,:si:
pi'uv;-:!.t5 f'"r  t;,a nc-.'csr.ory prcl'-'riuiry pu;.'-)c  c;  "'si;', c- cv a project .^t


      Iii !:ec"nn? with this p]eir.!iir/.i expect,  t':c t :.;h:\1ccl c^;,;;^!:1: of the-



i.'s-,1  frr-; c:,.::]i;\;'^:; '.r! th '.i.'J'JS r-v  ..»'•.;'•.•..: -^> -••-^  :' --a  L'". -,-;•".-'"Lit; Y:.:

                              ATTACHMENT  5

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                                                                 FEB201976
      A r?o.jor  thcio in  the cor.crjsicnr*  find rGccr^tm^itlons is tint all
fVt-re ev/>lLK:tun~ l.-o  slt^r^iflc.   S-jch a casf-hy-cr'
t'.';'.'!'?^r';i]lv {'.'if.'•".'• <''";;• co: C':;Y;.  l!.~>.'evi :\ tMr  ;.r;T;?':c^ i:-:'. L>  r/";"'if!
any  ;••..•' 'j~Mtc.r/ sr;-.;'-:;y's rc^>;:rco.> p;>nr.1i;'jy '-•>•-•}'•'•-a vU cc;:jLi11! .y •.;?
e"cr-':-::i i^tiinf^ul canlrcl,   Ti.ar.: souis co >?.  * r';;j  to i-iora 'f:!• *. ' 'r. "N,^.t-» r. i -^ "s '•'.-»   f i» - - -,*•* --_• •  ^ -^-  i  '! •- ' '-^(* '•»-*
 ! i> l I ii.J i>Ut',:,urj ;.3 ;•. "._:<, '.. vi  U.i'J '.....i..^i  •.  - » 1 -_;  .-  x. •-  -.i:\-s i ^ ^,1 : \.. >.. -; ;, iv-^i
tl'^  ;".'.' '/!•;:" ccr..prc'%C'rVi*c1y ir; pulll;;] tC; ^c:<,j?'-  J'"\-.rra 1;jTorvi-i•;..•,! c:>:f
csis'-,vi:;;;i;xa  ?«•," rh:; firr.t t:::?. ^ id id Vr.,r,'3 ^f  v'..;nu-;::t1ou v:;  :^h c'; ;:;-/"ly
C'i-h:>:,ir:^ «.;«»-•|cf--..".:"ic:5 in the present prc-. r-v-;.   ;-:n-n ts'^ c;r-::'it.c;L:'Iu
cffc: t u!u! on t!;'!:. b;:ses I r..s  cere;!1?"  tr"t tl.s i-;.ropri^;,^ ccr-i':::^ can
procc/4 to t»i\5 t';ii st'ps nc"-';;"s<;ry to i.i^vrQ  uc... t i,. -« -••  i..-;c v;, ^-.tt, Ucs-.t,'^.
                           ATTACHMENT 5

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Review of CorjncntK by the National Wildlife Federation on the International
Working Group  Report on Abatement and Control of Pollution frora Dredging
Activities
Vald.ns V. Adamkus              ^"^
Deputy Regional Administrator/ (5) /
      ph Green/ OT./.  C/-106)
Attn:  Conrad  0.  ILlcvcno

In rcviev:inR the subject cctnaencs by  the  reparation, it wss note-1,  that
their view's arc r>"hctruii:ialiy in accord rlth the co;rtt.enf.n submitted  en
the (J'e->''r"- by  this Il:i;iion on February 20,.  1976.   The in-dcpth proposition
for developing usal-ld criteria for dredging projects vas particularly
Interesting.   This preposition recognises  the complexities and variables
inherent in dredging projects, takes  finn exception to the TTbrkirr Group's
recommendation that  univeraal criteria are not applicable, and ftoco  on to
indicate the kind of criteria that could  be developed for dredging projects s
criteria v'hich a Stand inp Comnittee could  reasonably be expected to  develop
in a relatively short ticie.

The Federr-tion's VICTIO stipport: this Reyion'o earlier coi'in^nts, copcsrnin^
the need ff-r a Stan din,1?; Cormiittrg to  be ertal-lichcd un.'.cr the T'ntor  Quality
Board.  Sr.ch Cor.'iiit:l''"-i.i'£5 recponsibiiities  ^/ould then foliovr to he  principally
oriented to tbc devcilopment of a usable systei?. in-'oivins nu:;crical criteria.
We reiterate our recc:^:.C:nd.ition (arid  the  Federation's) thr.t thr St-tulip^
Conrrittce be esr.cb2ic:ied under the (.'re.-? t  Ln-:pcI7at^rQv^litv;oar.   The
                                                __
reccrmandation by the Federation that  the  Standing Cor;nltrori's \--ori:  be
completed  in  not more then 12 laonths appears  to be a stiT>pcrt-:sblc  'c :^3 fr^./ci
and as nuch i.s fully e:;clurr,ed by this  Region,  and as I wa sure it vrould  be
by the Water  Quality Hoard.

cc:  Kenneth  A. Oaiaciy, director IJC,  IvTlO
                              ATTACHMENT  5

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