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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                                   4

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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                                  11

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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