905R86107
LAKE MICHIGAN TOXIC POLLUTANT CONTROL/REDUCTION STRATEGY
FINAL
July, 1986
Illinois Environmental Protection Agency
Indiana Department of Environmental Management
Michigan Department of Natural Resources
Wisconsin Department of Natural Resources
U.S. Environmental Protection Agency
Region V
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A. INTRODUCTION
Two goals in both the Clean Water Act and the 1978 Great Lakes Water
Quality Agreement are: to restore, protect and enhance the physical,
chemical and biological integrity of the nation's waters, and to elimi-
nate the discharge of pollutants to those waters.
Lake Michigan is the largest body of fresh water totally within the
borders of the United States. It is used by millions as a drinking
T water supply and for recreation, such as boating, swimming and sport
fishing. It is also an important commercial fishery and transportation
resource. At present, however, lake uses are impaired because of the
concentrations of toxic pollutants found in its waters, sediments, fish
and birds. For example, Lake Michigan lake trout contain the second
highest levels of PCB's and DDT in the Great Lakes system, and cannot be
sold commercially because their level of pollutants exceed human health-
related U.S. Food and Drug Administration guidelines.
In recognition of these facts, Region V and the States of Illinois,
Indiana, Michigan and Wisconsin have agreed to work together to end the
Lake's toxic substances pollution problem. The Lake Michigan Toxic
Pollutant Control/Reduction Strategy (the Strategy) has been prepared as
an implementation plan to eliminate toxic pollutant problems from
the Lake Michigan system.
B. BACKGROUND: The Scott Versus Hammond Decision
In a decision dated August 16, 1984 (Scott vs. Hammond, et. al.,
(741 F.2nd. 992 C.A. 7, 08/16 and 21 ERC 1474) the Seventh Circuit
concluded that nondevelopment and nonsubmission of total maximum daily
loads (TMDL's) by a State over a period of years, may constitute a
constructive decision by that State that no TMDL is, in fact, required
for the particular waterway at issue. Such a decision must be reviewed
by USEPA under the provisions of .Section 303 of the Clean Water Act, as
amended. Under the Court's specific interpretation of the Scott vs.
Hammond, et a!. case, the States bordering Lake Michigan were required
to reach decisions on the need for TMDL's, and the U.S. Environmental
Protection Agency was required to review those decisions as soon as
possible, thereafter. The result of Region V's review of State decisions
was presented in the Report on Lake Michigan Total Maximum Daily Load
Requirements dated June 24, 1985. The report identifies nine pollutants
for which additional information is needed. The report concludes that it
is not appropriate to develop TMDL's for Lake Michigan at this time.
Appendix A briefly describes the information available on these pollutants
In part as a follow-up to the Region V Report, a meeting of Region V and
"" representatives of the States which border Lake Michigan was conducted in
, Chicago on January 9, 1986. Participants in that meeting unanimously
agreed that the preparation of a Lake Michigan Toxic Pollutant Control
Reduction Strategy to aid in dealing with the Lake's problem of toxic
substances contamination was both necessary and feasible.
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The agreement to develop and implement a toxic pollutant control/
reduction strategy for the Lake was also based on the recognition that
it is not currently possible to calculate a total maximum daily load for
pollutants that may be exceeding applicable water quality standards. The
calculations cannot be made at present because there is a lack of under-
standing of the source of these pollutants, their loadings and their
pathways through and transformations within the ecosystem.
This Strategy therefore is intended to define the relationship between
.fc toxicant loading rates and Lake Michigan toxicant problems, and to suggest
possible remedies.
C. THE STRATEGY: Overview
The objective of the Strategy is to fully restore the multiple uses
of the Lake Michigan resource and to protect human health and the
Lake Michigan ecosystem via a significant reduction in the loading
rates of problem toxic pollutants to the Lake. This will be
accomplished by identifying sources of toxicants, quantifying toxicant
inputs to the Lake, and reducing these inputs.
The two phase process described in this Strategy is intended to guide
Region V and State restoration efforts for the Lake beginning in 1986
and continuing thereafter for as long as necessary. Figure 1 is the
proposed timeline for Strategy implementation. An End of Year Report
will be published at the end of each calendar year to summarize accom-
plishments and describe near term activities needed to achieve
restoration of the Lake Michigan resource.
Phase I consists of several elements intended to: define, quantify and
control the major toxicant problems in Lake Michigan, and enhance the
States' ability to control toxicants in general. Table 1 is a preliminary
list of 11 Lake Michigan Toxic Pollutants of Concern (POC's). Specific
criteria for inclusion on the List were as follows: the pollutant is
present at levels which appear to violate State WQS, EPA Water Quality
Criteria recommendations, or IJC Objectives; or, the pollutant is present
in fish at levels sufficient to constitute a public health concern; or,
the pollutant concentration is increasing and it appears likely that WQS
or health advisories will be exceeded in the near term. This list was
derived in part from the list of Lake Michigan Basin Problem Pollutants in
the 1985 EPA Region V Report on Lake Michigan TMDL Requirements. As the
first step of Strategy implementation, the list will be reviewed and revised
based on available data. The extent of the area of pollutant impact will
be considered in determining whether a pollutant should be included on the
list. The list will serve to direct lake-wide toxicant control, monitoring
and modelling resources. Phase I toxicant control will focus on insuring
" that NPDES permits contain appropriate effluent limitations for POC's
based on water quality standards and appropriately defined mixing zones.
Where localized data indicate that toxicants other than POC's should be
controlled, appropriate effluent limitations will be incorporated into
NPDES permits. Once appropriate POC effluent limits have been incorporated
into NPDES permits, the intent is to calculate a mass balance for the Lake
Michigan POC's insofar as possible, based on available data.
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3
The mass balance approach is based on the principle that the quantities of
contaminants entering the system per unit time (the loading rate), less the
quantities stored, transformed or degraded within the system per unit time,
must be equal to the quantity leaving the system per unit time. If the
mass rates do not balance, then either there are significant sources yet to
be identified and quantified, or the environmental monitoring and laboratory
programs need to be refined to better quantify the rates.
The last part of Phase I will consist of efforts to determine if Lake
;• Michigan water quality and uses are adequately protected by current toxicant
control measures. Types of analysis may include modelling and additional
monitoring of Lake Michigan water and fish. The ability to carry out
modelling is dependent on the availability of appropriate models. Phase I
therefore includes an assessment of current modelling techniques, identifi-
cation of shortfalls and enhancement of modelling capabilities.
If water quality and uses are adequately protected, then the objective of-
the Strategy has been met. If th-ey are not, the Strategy provi-des for the
development and implementation of total lake ]oad reduction plans in Phase II.
If total lake load reduction plans are necessary, plans for implementing the
most cost-effective set of controls will be developed. Plans may include
implementation of best management practices for nonpoint-sources of pollution
and additional controls for point sources. TMDL's may be developed where
feasible and appropriate.
The decision regarding how total lake load reduction should be accomplished
will depend on the available data and will be deferred until it is decided
whether such controls are necessary.
D. RELATIONSHIP TO OTHER TOXIC POLLUTANT CONTROL INITIATIVES
1. State Permitting Authority and Water Quality Standards
All of the States bordering Lake Michigan have been delegated the
authority by Region V to administer the NPDES program within their
own borders. In compliance with NPDES regulations as administered by
the States, dischargers must provide a level of treatment for their
wastewaters which is equal to the more restrictive of technology-based
or water quality-based requirements. Each State already has in place
a strategy to deal with the issuance of permits to individual point
sources in order to meet water quality standards. However, not all
states have fully comprehensive mechanisms for controlling toxicants,
and all four Lake Michigan States still need to revise the antidegrad-
ation policy portion of their WQS and develop implementation procedures.
These needed revisions are part of the Strategy implementation plans.
The Lake Michigan Strategy is intended to coordinate the State's local-
ized control efforts by providing a framework which recognizes the
larger scale impacts of toxic substances pollution. A summary of the
• toxic pollutant control portions of the WQS for the Lake Michigan States
is provided in Appendix B.
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PRELIMINARY LIST:
SUBSTANCE
* PCB's
* DIELDRIN
t
* HEX'ACHLOROBENZENE
* 2,3,7,8-TCDD
TABLE 1.
LAKE MICHIGAN TOXIC POLLUTANTS OF CONCERN
WHERE DETECTED
Tributary mouth/Harbor,
nearshore and open
lake waters, sediment,
and biota
BENCHMARK EXCEEDED
FDA action level, IJC
fish flesh objective,
EPA water quality
criterion
EPA water quality
criterion
Fish from nearshore waters
CHLORDANE
Water column and fish from
nearshore and open waters
FDA acti-oo level and
EPA water quality
criterion
TOXAPHENE
HEPTACHLOR/HEPTACHLOR
EPOXIDE
IJC objective and EPA
water quality criterion
DDT/TDE
HEXACHLOROCYCLOHEXANE
*1 PCDF's
PAH's
Fish and sediments
EPA water quality
criterion
By analogy to
2,3,7,8-TCDD
EPA water quality
criterion
* This substance was also identified by the IOC's Water Quality Board as a
"Critical Pollutant" in the WQB's 1985 Report on Great Lakes Water Quality.
1 As 2,3,7,8-tetrachlorodibenzofuran
2 As (Jenzo(a)pyrene
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2. Great Lakes National Program Office (GLNPO) Initiatives
In August 1985 GLNPO published its "Five Year Strategy...1986-1990".
The three toxic pollutant control goals of that five year strategy
are:
1. to apply the ecosystems approach to Great Lakes management,
treating all Great Lakes components as an integrated system:
2. to develop and pilot the application of a mass balance
approach to remedial programs in specific geographic
areas, such as Green Bay, considering all sources of
toxic pollutants and their ultimate fate after they enter
the Great Lakes system; and
3. to assist the Great Lakes States in developing, implementing
and evaluating the effectiveness of Remedial Action Plans
for the sites of degraded water quality in the Basin, desig-
nated as "Areas of Concern" by the IJC.
The identification of toxic pollutant sources and the evaluation of
various source control and cleanup alternatives will be aided by
mathematical modeling. In this way, the mass balance approach can
be used to set research, remedial action and regulatory priorities as
well as to direct the allocation of available environmental protection
resources. The GLNPO mass balance approach is consistent with that
advocated by this Strategy.
3. IJC Initiatives
a• Identification and Control of Toxic Substances
To fully implement the toxic substances control provisions of the 1978
Great Lakes Water Quality Agreement between the United States and
Canada, the International Joint Commission (IJC) and its Water Quality
Board (WQB) established a two track process to address the more than
500 contaminants detected in the waters, sediments and biota of the
Great Lakes. This process was described in the IJC's 1985 Report on
Great Lakes Water Quality. As discussed in that 1985 Report, sources
of eleven Critical Pollutants on the "primary track" (j^.e., on the fast
track) are to be identified, quantified and reduced to tKe extent
practicable over the next three to five years. Substances which
are likely problems in Lake Michigan are included in the Strategy's
Toxic Pollutants of Concern List (Table 1). In the IJC's process,
remaining contaminants on the "comprehensive track" are those which
may require further ambient or source monitoring, laboratory testing
or modeling prior to being evaluated for addition to the primary
track. Criteria for addition and deletion and the mechanism for
setting further study priorities, are under development by the WQB.
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FIGURE 2. Areas of Concern in Lake Michigan
MANISTIOUE R
MENOMINEE R
FOX RIVER
AND
SOUTHERN
GREEN BAY
SHEBOYGAN
MILWAUKEE ESTUARY
WAUKEGAN HARBOR.
WHITE L., MONTAGUE
MUSKEGON L.
KALAMAZOO R.
GRAND CALUMET RIVER AND
INDIANA HARBOR SHIP
CANAL
MAP REF. NO
8
9
10
11
12
13
14
15
16
17
AREA OF CONCERN
Manistique River
Menominee River
Fox River/Southern
Green Bay
Sheboygan
Milwaukee Estuary
Waukegan Harbor
Grand Calumet/
Indiana Harbor
Kalamazoo River
Muskegon Lake
White Lake
JURISDICTION
Michigan
Michigan
Wisconsin
Wisconsin
Wisconsin
Wisconsin
m inois
Indiana
Michigan
Michigan
Michigan
PROBLEMS
PCB's
Arsenic
PCB's, PCDF's,
Mercury
PCB's
PCB's, Heavy
Metals, PAH's
PCB's
PCB's, Heavy
Metals, PAH's
PCB's
PAH's, Heavy
Metals
PCB's, Chromium,
Chlorinated
Organics
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b. Areas of Concern
The International Joint Commission (IJC) has established a Water
Quality Board to aid in focusing attention on specific actions
necessary to restore and protect the Great Lakes. EPA and the
States of Illinois, Indiana, Michigan and Wisconsin are active members
of the Water Quality Board. The Water Quality Board, in turn, has
identified a number of locations within the Great Lakes, including
Lake Michigan, where designated beneficial uses are significantly
impaired. These locations are termed Areas of Concern (AOC's) and,
for the most part, they represent places where deposition of contamin-
ated sediments has occurred to such an extent over the years that the
sediments now act as reservoirs of toxic pollutants for the Lake in
which they are located. Ten such AOC's have been identified for Lake
Michigan. Their location and the general nature of their problems are
shown in Figure 2. Remedial Action Plans (RAP's) are to be developed
by the States to guide actions necessary for the environmental restor-
ation of the individual AOC's. Work on some of the RAP's is well
underway, while schedules have yet to be,finalized for others.
E. STRATEGY IMPLEMENTATION
Implementation of the Lake Michigan Toxic Pollutant Control Strategy will
extend over several years as the Region and States gather information,
make program decisions and begin to implement controls. The near term
(Phase I) and long term (Phase II) elements are described below, including
basic toxicant control program elements needed for this Strategy as well
as for toxicant control in general.
Phase I
1. Review/Revise Water Quality Standards (1986-1988)
The States will review water'quality criteria and antidegradation
portions of existing WQS. By the conclusion of FY '88, they will
revise WQS as determined necessary. They will develop and implement
antidegradation procedures by the end of FY '87.
2. Develop Procedures to Implement "Free From" Toxics Standards (1986-1987)
The States of Illinois, Indiana and Wisconsin will develop detailed
procedures for translating narrative WQS's which specify that State
waters shall be free from toxic substances in toxic amounts into
water quality based effluent limitations by the end of FY '87, or as
soon thereafter as specified in program plan commitments. It is
recommended that the States detail the procedures to be used to
calculate water quality based effluent limits to protect aquatic life,
human health and wildlife. Explicit procedures facilitate the calcula-
tion of appropriate effluent limits and enhance their defensibility.
It may be advisable to develop these procedures in cooperation with
technical representatives from the public, private and environmental
sectors. Region V recommends this approach as a useful means of
responding to concerns and minimizing later challenges.
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3. Review/Revise Pollutants of Concern List (1986 and thereafter, as
needed)
Throughout 1986 Region V, GLNPO and the States will review water
quality and other environmental data for pollutants based on
monitoring results in order to refine the Lake Michigan Pollutants
of Concern (POC) List. An update with possible revisions will be
contained in the End of Year Report to be available in December of
1986.
4. Incorporate POC Effluent Limits into Permits (1986-1989)
The States will control direct and tributary point sources of POC's
by incorporating into permits the more restrictive of Best Available
Technology or edge of mixing zone water quality based effluent limits
by the end of fiscal year 1989. The Region and the States have
agreed to reopen and modify permits as information becomes available,
e.g. through pre-treatment program needs and monitoring networks.
Special emphasis will-be placed on dischargers to the lake and its
tributaries. Limits for toxicants other than POC's should be
incorporated at the same time, where data obtained from biomonitoring,
chemical scans, process reviews or other appropriate sources indicate
that limits are needed. The 1989 deadline means that approximately
three-fifths of the Lake Michigan and tributary dischargers' permits
will be reviewed, and modified as necessary, on their normal 5-year
reissuance schedule. Permits for the high priority dischargers among
the remaining two-fifths will have to be reviewed, and modified as
as necessary, on an accelerated schedule. However, it is anticipated
that the number of permits requiring accelerated schedule reviews will
be small.
5. Conduct Screening Surveys to Identify POC Sources (1986-1988)
Using areas of sediment deposition and resident fish species as
indicators of toxic pollutant problems, GLNPO will screen tributary
mouths and nearshore areas and will evaluate atmospheric deposition
data to locate pollutant sources requiring more detailed study.
Current monitoring efforts are summarized in Appendix C.
6. Expand Modelling Capability for Lake Michigan (1987-1991)
Region V, GLNPO and the States will cooperatively assess the adequacy
of current modelling techniques, identify modelling shortfalls and
develop improved modelling techniques for Lake Michigan.
7. Monitor to Estimate Loadings (1988, Plus)
Based on the results of the screening surveys (element 5, above), GLNPO
with State assistance, will revise monitoring strategies and initiate
monitoring for tributary loads, sediment release, atmospheric deposition
and other sources of toxicants to estimate total loadings. If tributary
and nearshore monitoring reveal significant loadings, Region V and
GLNPO will develop a more detailed point and nonpoint source monitoring
plan. Additional monitoring data will be obtained through both permittee
monitoring and supplemental monitoring, as appropriate.
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7
8. Calculate Total Point Source Loadings (1989-1990)
Region V, GLNPO, and the States will calculate total loadings to the
lake from point sources after the more restrictive of BAT or WQ-based
effluent limits are imposed. They will also determine the likelihood
that significant loadings from other sources exist by comparing total
loading estimates with point source loading data.
9. Calculate Total Nonpoint Source Loadings (1990, Plus)
Region V, GLNPO and the States will calculate loading estimates for
pollutants with significant sources other than point sources.
10. Calculate Total Lake Loadings (1990-1991)
Region V, GLNPO, and the States-will calculate total lake loading
estimates for POC's and develop a mass balance for Lake Michigan,
insofar as data allow.
11. Calculate Relationship Between Total Loadings and Nearshore
and Open Water Quality (1992T
Using refined mathematical models or other appropriate methods,
Region V and GLNPO in cooperation with the States will, by the end
of FY '92, determine the relationship between tributary
and in-place pollutant load reductions and harbor and nearshore
Lake Michigan water quality, and between total loading and open Lake
Michigan water quality. Currently available models are briefly
described in Appendix D.
12. Determine if Water Quality is Protected by Current Toxicant
Control "Measures (
Region V, GLNPO and the States will determine if the toxicant control
measures in place are adequate to ensure that Lake Michigan water
quality is, and will continue to be, protective of public health and
the envi ronment.
Phase II
1. Develop Total Lake Load Reduction Plans (1994-1995)
If it is determined that point source controls are insufficient to
protect public health and the environment, it may be that conservative
toxicants are accumulating, or that nonpoint source or air deposition
are the responsible sources. Whatever the cause, Region V, GLNPO and
the States will develop total Lake load reduction plans for appropriate
toxic pollutants. In developing these plans, due recognition will be
given to the relative contributions of the various sources and the
effectiveness with which source reductions can be instituted to achieve
water quality goals in the Lake.
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8
2. Implement Total Lake Load Reduction Plans (1996, Plus)
The precise mechanism for development and subsequent implementation
of total Lake load reduction plans is, as yet, undetermined, but it
is likely that the plans will consist of a mix of controls for point
sources, nonpoint sources, and air deposition. Plans would include
provisions for Region V and the States to revise ambient and source
compliance monitoring as necessary to assess the effectiveness of the
total Lake load reduction plan in reducing the loadings and concentra-
tions of POC's.
E. FISCAL YEAR 1986 AND 1987 ACTION STEPS
Listed below are specific action steps for the States and Region V
for fiscal years 1986 and 1987. The action steps set forth below
were derived from the Strategy Implementation (Section .D) and the
Present Mechanism for Point Source Toxic Pollutant Control
(Appendix B). Deta'ils for implementing the State action steps for
FY '87 will be negotiated in each State as a part of the annual
program planning process.
State Action Steps for Fiscal Year 1986
Action steps 1-3 are Strategy-specific; steps 4-8 address toxicant
control in. general.
1. The States will review water quality and other environmental data
for substances on the Lake Michigan Pollutants of Concern List
and will recommend changes to the List, where appropriate.
2. The States will identify the highest priority dischargers for
imposition of appropriate effluent limits for POC's based upon
an analysis of treatment, technologies, manufacturing processes,
effluent characteristics and proximity to the Lake. The States
will then schedule permit issuance/reissuance such that all high
priority dischargers have appropriate effluent limitations for
POC's by the end of FY '89.
3. The States will develop/retain information for inclusion in the
End of Year Report and will assist Region V in the preparation
of this Report.
4. The States will initiate Remedial Action Plan development for the
IJC AOC's in Lake Michigan, in accordance with State commitments
to the IJC Water Quality Board and with agreements reached with
Region V and GLNPO.
5. The States will complete the Lake Michigan monitoring identified
in their FY '86 Program Plans, and identify additional monitoring
activities needed for subsequent Fiscal Years.
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6. The States will monitor Lake Michigan basin point sources for
compliance with toxicant effluent limitations and take enforce-
ment action, as needed.
7. The States will review the water quality criteria and antidegrad-
ation portions of their existing WQS. They will complete any
related tasks presently identified in their FY '86 Water Pollution
Control Program Plans. The States will then list any additional
tasks and timeframes, as determined necessary to complete adequate
revisions of their WQS.
8. The States of Illinois, Indiana and Wisconsin will complete the
development of detailed procedures for translating narrative "free
from toxic substances in toxic amounts" WQS language into water
quality based effluent limitations which are presently identified
for completion in their FY '86 Program Plans. These States will
then schedule any additional tasks necessary to complete develop-
ment and institute implementation of effluent limitation
procedures by the' end of FY '87 or as specified in program plan
commitments.
Region V and GLNPO Action Steps for Fiscal Year ^986 •-
Action Steps 1-5 are Strategy-specific; steps 6-10 address toxicant
control in general.
1. Region V and GLNPO will review water quality and other environmental
data for the substances on the Lake Michigan Pollutants of Concern
List. The Region and GLNPO will recommend revisions to the List,
as appropriate, based on this review.
2. Region V and GLNPO, in conjunction with the States, will develop a
list of necessary environmental monitoring activities, including
identification of data gaps, recommended timeframes and responsible
parties. Development of the list will be coordinated with the States,
3. Region V and GLNPO, in conjunction with the States, will develop a
list of necessary modelling activities, including recommended
timeframes and responsible parties. Development of the list will
be coordinated with the States.
4. GLNPO will begin to apply the mass balance approach in Green Bay.
This is part of an ongoing commitment to pilot special studies to
provide information needed to develop appropriate management and long
term monitoring plans for toxic pollutants entering the Lake Michigan
ecosystem.
5. Region V and GLNPO will develop/retain information for inclusion
in the End of Year Report and will develop this Report in
cooperation with the States.
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10
6. Region V will support states in developing appropriate State
Specific guidance relating to procedures for translating narrative
"free from toxic substances in toxic amounts" WQS language into
water quality-based effluent limitations, for utilization in the
FY '87 Program Planning Process negotiations with Illinois,
Indiana and Wisconsin.
7. Region V will follow-up the results of point source compliance
monitoring, if necessary, to ensure compliance with applicable
NPDES permits.
8. Region V, in coordination with the States, will complete'development
of a biomonitoring strategy and will identify the highest priority
Lake Michigan dischargers for inclusion of biomonitoring require-
ments within their permits.
9. Region V will continue"to'work with the States and the Army Corps
of Engineers to assess the effectiveness and environmental impacts
of confined disposal facilities. Results of activities will be
reported annually in the End of Year Report. - - - ..
10. Region V and GLNPO will assist the States in FY '86 activities
necessary to produce Remedial Action Plans.
State Action Steps for Fiscal Year 1987
Action steps 1-4 are Strategy-specific; steps 5-7 address toxicant
control in general.
1. The States will issue/reissue permits to the high priority
dischargers, in accordance with the list described above in
the FY '86 State Action Steps, and with the results of the FY '87
Program Planning Process negotiations.
2. The States will conduct monitoring for Lake Michigan specified
in their FY '87 Program Plans as necessary to implement the
Strategy.
3. The States will continue Lake Michigan basin point source compliance
monitoring and enforcement, as necessary.
4. The States will develop/retain information for inclusion in the
second End of Year Report and will assist Region V in the preparation
of this Report.
5. The States will complete development and begin implementation
of Remedial Action Plans for Lake Michigan AOC's, in accordance
with program plan commitments, with continuing Region V and GLNPO
support.
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6. The States of Illinois, Indiana and Wisconsin will complete any
steps necessary to adopt water quality-based effluent limitation
procedures, and will begin implementation of those procedures as
soon as possible thereafter, in accordance with program plan
commitments.
7. The States will continue the WQS revision process to ensure
adequate protection of Lake Michigan by the end of FY '88.
Region V and GLNPO Action Steps for Fiscal Year 1987
Action steps 1-4 are Strategy-specific; steps 5-7 address toxicant
control in general.
1. Region V and GLNPO will undertake Lake monitoring activities
identified for FY '87 by the FY '86 Region V Action Steps." 'Region V
and GLNPO will also track and assess the activities of other parties
responsible for Lake monitoring. This information will be made avail-
able to the States.
2. Region V and GLNPO will accomplish the FY '87 modeling activities
identified for FY '87 by the FY '86 Region V Action Steps. The results
of these activities will be made available to the States.
3. GLNPO will decide on the type of sampler to be used for toxic
pollutant monitoring' of atmospheric deposition, and GLNPO will also
initiate steps to place the first of these samplers at a station in
Green Bay. Additional samplers will be placed on the Lake if
funds are available.
4. Region V and GLNPO will draft the FY '86 End of Year Report; by
December 1986 and will complete the Report in cooperation with the
States. Region V and GLNPO will also develop/retain information
necessary to produce the FY '87 Report.
5. Region V and GLNPO will complete FY '87 activities necessary to
produce Remedial Action Plans, in accordance with agreements reached
with the States.
6. Region V will continue working with the Army Corps of Engineers
to bring the study on Confined Disposal Facilities to a satisfactory
conclusion. The results will be made available to the States.
In addition, Region V, in coordination with the States, will
complete an In-Place Pollutant Strategy.
7. Region V will evaluate the results of point source compliance
monitoring, to ensure compliance with applicable permits and take
enforcement action as needed.
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APPENDIX A
POLLUTANTS FOR WHICH TMDL CALCULATIONS MAY BE REQUIRED
Polychlorinated Biphenyls (PCB's)
PCB's are highly persistent, highly bioaccumulative and highly toxic
pollutants. Present levels in some commercial and sport fish species
are believed to constitute a threat to the public health and thus have
damaged the Lake Michigan fisheries. PCB's are still in use for elec-
trical purposes pending replacement, and there appears to be recycling
of the pollutant to the Lake from contaminated sediments and the
atmosphere.
The 1985 Great Lakes Water Quality Board Report noted that all samples of
resident fish collected from 30 major harbors and tributaries between 1981
and 1984, contained fish which ex-ceeded the IJC Agreement water quality
objective of 0.1 mg/kg total PCB. Extremely high concentrations of PCB
(up to 790 mg/kg) were also reported in fish from the lower Sheboygan
River. Elevated PCB concentrations (10-30 mg/kg) also were noted in fish
samples from White Lake and the Kinnickinnic, Milwaukee,-St. Joseph,
Kalamazoo and Fox Rivers.
Chlorinated Benzenes, Hexachlorobenzene, Hexachlorocyclohexane,
Polycyclic Aromatic Hydrocarbons (PAH's), Polychlorinated Dibenzofurans
(PCDF's), and 2,3,7,8-Tetrachlorodibenzo-p^Dioxin (2,3,7,8-TCDD)
These pollutants have been detected in fish flesh at some locations
within Lake Michigan. The IJC referred to these substances as "emerging
problems" in its 1983 Great Lakes Water Quality Board Report. In addition,
the 1985 Great Lakes Water Quality Board Report noted dibenzofurans in the
Grand Calumet River and the Indiana Harbor and Ship Canal. Elevated levels
of 2,3,7,8-TCDD were found in a fish caught off Saugatuck, Michigan and in
the eggs of a Green Bay colony o'f Forster's terns, as reported in the 1985
Water Quality Report.
PCDF's were noted in Lake Trout (Saugatuck), Common Carp (Waukegan), and
Large Mouth Bass (Waukegan) in the Surveillance Appendix to the 1983 Great
Lakes Water Quality Board Report. In this regard it should also be noted
that PCDF's frequently occur as trace contaminants of PCB's. Therefore,
where PCB's are found, PCDF's are also likely to be present. PAH's have
been found in sediments from a number of Lake Michigan locations, primarily
outside of harbors and river mouths. Sources include atmospheric deposition
of combustion products, coke production and petroleum refining. Chlorinated
benzenes, especially the tetra- and penta-isomers, were found in Fox River
"" fish and sediments. Hexachlorobenzene (HCB) was found in fish from the
Sheboygan River, Milwaukee River, Menominee River and the Kinnickinnic
River, as well as fish from the open waters of Lake Michigan. The atmo-
sphere is likely to be the most significant source of the higher chlorinated
benzenes, dibenzofurans and dioxin detected in fish from the open waters
of the lake, while elevated tributary mouth and nearshore levels are more
likely to be attributable to point sources.
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APPENDIX A - Continued
Selenium and Silver
Concentrations of total selenium in Lake Michigan water have been reported
to be as high as 4.5 ug/1, and Lake concentrations of dissolved selenium as
high as 3.7 ug/1 have also been reported (Trace Metal Concentrations in the
Offshore Waters of Lakes Erie and Michigan, Ronald Rossmann; 1984). Rossmann
further notes that dissolved selenium appears to be increasing at the rate
of 0.252 ug/l/Y, while no trend is apparent for total selenium concentrations,
fc Ambient values for this metal do not currently violate State WQS or the USEPA
recommended water quality criterion of 10 ug/1. The IJC objective of 1 ug/1
is being violated, however.
Lake Michigan concentrations of silver have been reported at-widely varying
levels, but they appear to cluster between 1 and 3 ug/1. Rossmann's work
(Op. Cit.) is the most recent determination and reports mean concentrations
for dissolved and total silver of 0.053 and 0.061 ug/1 respectively.
These latter concentrations are well below current Illinois aRd Indiana WQ
criteria of 30 and 50 ug/1-, but they are near the 0.1 ug/1 level as recom-
mended by the IJC and USEPA for the protection of aquatic life. In addi-
tion, elevated sediment concentrations of silver have been reported in
STORET at various Lake Michigan stations. Atmospheric deposition of fly
ash could be a significant source of both selenium and silver in the open
waters of the lake.
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APPENDIX B
THE PRESENT MECHANISM FOR POINT SOURCE TOXIC POLLUTANT CONTROL
The Clean Water Act provides for a national goal, where attainable, of
water quality suitable for maintenance/enhancement of well balanced fish
and aquatic life populations as well as recreation on and in the water.
To ensure compliance with this goal, the Act provides both technology-based
* and water quality-based requirements. Both of these requirements are
enforceable through discharger-specific permits as the major component of
the National Pollutant Discharge Elimination System (NPDES).
The applicable technology-based requirement for industrial dischargers of
toxic pollutants is Best Available Treatment (BAT). BAT is individually
defined for classes of dischargers identified in the,Clean Water Act
taking the industry-wide availability of treatment technologies and economic
achievability into consideration. The analogous technology-based require-
ment for municipalities is secondary treatment plus compliance with
applicable Pretreatment Program requirements.' If effluent limitations
derived from the application of technology-based guidelines are found to be
inadequate to implement applicable WQS at the edge of a defined mixing
zone, the additional increment of treatment as judged necessary to meet
these standards in the receiving waters must be provided by the discharger.
At a minimum of once every three years, states are required to review, and
thereafter revise as determined necessary, WQS for their surface waters.
The WQS embody specific environmental goals to be attained, and provide the
basis for developing enforceable effluent limits for NPDES permits.
Antidegradation policy is an integral part of water quality standards and
is, therefore, to be implemented in the permit issuance/reissuance process.
At present, none of the Lake Michigan State antidegradation programs fully
meet the requirements of 40 CFR 131.12. Region V considers adequate
policies and procedures to be hfgh priority items for immediate development
and implementation.
A summary of the toxic pollutant control portions of the WQS for the Lake
Michigan States is presented below.
Ill inois
Any substance toxic to aquatic life shall not exceed one-tenth of the
96-hour median tolerance level (96-hr. MTL) for native fish or essential
fish food organisms. Detailed procedures necessary to apply the foregoing
general requirement to specific dischargers are in preparation, but are
— not yet available for use.
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APPENDIX B - Continued
Indiana
Concentrations of toxic substances shall not exceed one-tenth of the 96-hour
median lethal concentration (LCsg) for important indigenous aquatic
species and those artificially propagated by the Indiana Department of
Natural Resources. More stringent application factors can be used when
justified on the basis of available evidence and approved by the Board,
after public notice and the opportunity for a public hearing.
Organic contaminants which can be demonstrated to be persistent, to have a
* tendency to bioconcentrate in aquatic biota, and are likely to be toxic on
the basis of available scientific evidence, will be limited as determined
by the Department of Environmental Management after public notice and the
opportunity for a hearing.
Selenium is not to exceed 10 ug/1 at any time, and silver is not to exceed
50 ug/1 at any time.
Detailed procedures necessary to-apply the foregoing general 'requirements
to specific dischargers are in preparation, but are not yet available for
use.
Michigan
Toxic substances are not to be present in the waters of the State at levels
which are, or which may become, injurious to the public health, safety,
welfare; plant and animal life; or the designated uses of those waters.
Allowable levels of toxic substances shall be determined by the Commission
using appropriate scientific data.
For purposes of developing water quality based effluent limits for the
NPDES permit program, allowable levels of toxic substances in the surface
waters, after mixing with the receiving water, will be determined by
applying an adequate margin of safety to the "maximum acceptable toxicant
concentration" (MATC), "no observable adverse effects level" (NOAEL), or
other appropriate effect end points, based on knowledge of the behavior
of the toxic substance, the characteristics of the receiving water, and
the organisms to be protected. In addition, the discharge of nonthres-
hold carcinogens must not create a level of risk to the public health
greater than 1 in 100,000 in the surface water after mixing with the
receiving water. In addition, the Commission may require a greater degree
of protection where determined necessary to comply with the applicable
antidegradation provisos.
Michigan has adequate procedures to apply the State's WQS requirements
to specific dischargers.
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APPENDIX B - Continued
Wisconsin
Waters of the State are to be free from substances in concentrations
which are found to be of public health significance. In addition,
substances must not be present at any location in amounts which are
acutely harmful to animal, plant or aquatic life. Furthermore,
concentrations of substances are not permitted that, alone or in com-
bination with other materials present, are toxic to fish or other
aquatic life based on current scientific information.
Wisconsin has historically incorporated effluent limits for some toxic
substances in industrial permits and has initiated actions to do the
same for municipal permits. The detailed procedures for translating
the narrative water quality standards into effluent limits are being
formalized, but are not yet available.
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APPENDIX C
MONITORING
In any given year, there is a substantial amount of monitoring of sediments
and harbors, open water, fish, waste water effluents and air deposistion
in and around Lake Michigan. Agencies which undertake one or more types
of the aforementioned monitoring activities include Region V, GLNPO, the
States bordering the Lake, universities/colleges, water supply utilities,
and the U.S. Fish and Wildlife Service. Though much useful information on
the Lake and its contaminants has been gathered, efforts to date have not
always focused on those initiatives necessary to control/reduce toxic
pollutant loadings to the Lake. The Region and the States are currently
developing monitoring strategies that will address this situation.
Because identification of in-place pollutants as major remaining sources
of contaminants, and the availability of analytical capability to allow the
measurement of toxic organics, are both relatively recent developments,
only a very limited and disjointed data base exists for organic contaminant
levels in sediments. To ftll the void, GLNPO has embarked on a multi-year
effort to determine the level of toxic substances in Great Lakes river and
harbor sediments.
Open lake monitoring to provide basic limnology data (chemical and biological)
and to evaluate nutrient trends in Lake Michigan is conducted by the Great
Lakes National Program Office. The Chicago and Milwaukee MSD's also conduct
extensive nearshore and open lake monitoring to evaluate water quality
trends near these cities' water supply intakes, and the University of
Wisconsin is investigating the use of Milwaukee and Chicago water supply
intakes as representative of open lake waters and to assess the structure
and function of long-term biological change in lake primary production.
These activities will have to be reviewed, and restructured if determined
necessary, to assure that such activities are sufficient to support the
development of whole Lake loading estimates.
The Great Lakes National Program Office's Great Lakes Fish Monitoring
Program (GLFMP) has, since its inception in 1980, been a coordinated effort
by numerous State and Federal agencies to monitor several aspects of the
fish contaminant problem in the Great Lakes. Some states also conduct
their own fish contaminant monitoring programs.
The broad areas that are or will be addressed by GLNPO and the States in
these monitoring programs include 1) trend monitoring in the open lake;
2) detection of emerging problems in harbors and tributary mouths;
3) monitoring potential human exposure; 4) monitoring local trends in
problem compounds as identified in # 3; and 5) monitoring indicators of
ecosystem and fishery health. No significant changes in fish monitoring
activities appear necessary at this time other than possible adjustment of
priorities as necessary to support implementation of the Lake Michigan
Toxic Pollutant Control/Reduction Strategy.
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APPENDIX C - Continued
The Great Lakes National Program Office presently operates an atmospheric
deposition monitoring network consisting of seven (7) sites in and around
Lake Michigan. This network, which is part of the Great Lakes Atmospheric
Deposition (GLAD) Network, collects precipitation samples that are analyzed
in the USEPA Region V laboratory for selected nutrients and metals. Some
States also operate air deposition monitoring stations over and above the
GLAD Network. At the present time, however, none of the potential TMDL
e pollutants are sampled in air monitoring activities. As a first step to
- remedy this monitoring deficiency, GLNPO awarded a 2-year research grant
' in the Spring of 1985 to the University of Minnesota to evaluate five
different types of precipitation samplers for assessing the atmospheric
inputs of trace organic compounds. When a decision on the type of sampler
to be used for toxic pollutant monitoring has been made a master atmospheric
deposition monitoring station will be installed near Green Bay to assess
the potential loading of toxic pollutants of concern.
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APPENDIX D
MODELLING
Mathematical modelling and trend monitoring are important tools in
the implementation of the mass balance approach. Once a mass balance
budget has been calculated for each pollutant of concern, the long
term effects of various source reduction strategies on water quality
of the lake can be simulated using best estimates of the transport and
fate of toxic pollutants. If mathematical modelling reveals that water
quality will remain or become degraded at the present or projected
toxic pollutant loading rate from all sources, load reduction efforts
can be directed to the sources most amenable to control and clean-up
efforts.
A number of mathematical models of toxic substances transport
and fate have been developed for quantitatively relating loading
rates to concentration profiles in aquatic ecosystems. Existing
generic models include the Simplified Lake and Stream Analysis
(SLSA) modelling framework, developed by HydroQual Inc. of Mahwah,
New Jersey, which treats the lake-as a well-stirred reactor ir> both
steady state or time-dependent modes. Aquatic fate processes taken
into account include partitioning between water and particles,
particle settling and resuspension, chemical and photochemical
reaction, volatilization and sedimentation. Similar to SLSA is
USEPA's EXAMS II model, a microcomputer-implementable version of the
EXAMS model developed by Larry Burns and co-workers at US EPA's
Athens, Georgia research laboratory. It divides the water column
and sediment into (25)- compartments, each of which is treated as a
well-stirred reactor which can exchange matter with its nearest
neighbors, according to a specified flow regime. EXAMS II does
not, however, allow inputs for particle settling, sedimentation or
resuspension rates. Although SLSA and EXAMS II are similar,
in that they both assume instantaneous equilibrium between water and
particles, only EXAMS II contains a biological component for modelling
bioaccumulation.
SERATRA, developed by Yasuo Onishi of Battelle Northwest in Richland,
Washington, is a fully dynamic, time-dependent toxic pollutant trans-
port and fate model which allows for vertical and lateral mixing
without compartmentalizing the environment by solving fundamental flow,
momentum and energy equations. Rather than assuming instantaneous
equilibrium partitioning between water and sediment particles, SERATRA
employs rate equations based on adsorption/desorption kinetics.
SERATRA omits a biological component.
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APPENDIX D - Continued
Other models developed for specific Great Lakes applications
incorporate many of the same features as SLSA, EXAMS II or
SERATRA. These models probably could be adapted for use at a number
of locations within Lake Michigan. For example, toxics models for
Great Lakes embayments include the Saginaw Bay PCB model developed
by USEPA's Large Lakes Research Station (LLRS), which includes an
empirically-based, wind-driven hydrodynamics component, and a cell
*. model developed by LimnoTech, Inc. of Ann Arbor, Michigan. With
regard to a specific area within Lake Michigan, Canale and Auer
have developed a model of Green Bay nutrient dynamics which may
also have application to the Bay's problems involving toxics trans-
port and fate.
Toxics models developed for the open waters of the Great Lakes which
may very well have utility for Lake Michigan include Manhattan
College's WASTOX, presently being, adapted to the IBM PC-AT under
contract to LLRS. This model includes a biological component which
accounts for food chain-driven bioaccumulation. A general version
of WASTOX is now available for utilization on an IBM PC-AT from EPA's
Environmental Research Laboratory, Athens, Georgia. In addition,
Thomann and DiToro have applied a simplified whole lake model of
toxic substances fate to PCB accumulation in Lake Michigan.
Overall, it appears that reasonable progress is being made to develop
modelling techniques which will ultimately be sufficient to help decision
makers understand the relative effectiveness of various control scenarios
and to assess the likely impacts of ongoing programs. In order to assure
continued progress at a rate sufficient for strategy implementation
purposes, EPA will have to systematically assess modelling capabilities,
identify shortfalls which potentially prevent development of estimates
for whole Lake loadings and concentrations, define the steps necessary
to remedy shortfalls and find the resources necessary to complete
modelling tasks on a timely basis.
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