ST. MARY'S RIVER
        REMEDIAL ACTION PLAN
       The St. Marys River Area of Concern
             Remedial Strategies
                   for
           Ecosystem Restoration
            STAGE2REPORT
Environment Environnement
Canada    Canada
 Ontario
MnWry ol tt» Envtronmtrt
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              ST.MARYS  RIVER
               REMEDIAL ACTION PLAN
Stage 2: Remedial Strategies for Ecosystem Restoration
                 December 2002

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                             Binational Public Advisory Council
                             St, Marys River Area of Concern
                                             14 February 2003
John Marsden
Lake Superior Coordinator and
Canadian Co-Chair, Lake Superior Binational Program Work Group
Restoration Programs Division, Environmental Conservation Branch
Environment Canada
4905 Dufferin Street, Downsview, Ontario M3H 5T4

CC:
Frank Wilson, Director
Northern Regional Office
Ontario Ministry of Environment
3rd Floor - Ste. 331
435 James St. South
Thunder Bay, ON  P7E 6S7

Art Ostaszewski
Michigan Department of Environmental Quality
P.O.  Box 30273
Lansing, Mi  48909-7773

Gary Gulezian                                  .
Director GLNPO G-17J
77 West Jackson Boulevard
Chicago, IL 60604

Jennifer Manville
RAP Coordinator
U.S.  EPA Region 5
400 Boardman Ave.
Traverse City, MI 49684

Dear Mr Marsden:

The Binational Public Advisory Council for the St Marys River Area of Concern accepts
the Stage II report attached. We're happy to see progress made on the ultimate goal of
remediating the legacy of environmental damage to the river. There is a long way to go,
but this document shows that some progress has been made.  Although there has been a
lack of resources directed from some of the government agencies toward the Remedial
Action Plan process, we are encouraged by some of the positive steps such as the upgrade
to the Sault Ste Marie, Ontario East End Sewage Treatment Plant. We look forward
especially to seeing progress on contaminated sediment management plans that
incorporate processes and problem areas across the entire St Marys River watershed.

                            650 W. EasterdayAve.
                           Crawford Hall, Room 351
                          Sault Ste. Marie, MI 49783
                   906-635-2136 • stmarysbpac@hotmail.com

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Toward these ends, we urge the agencies to give high priority to the development of the
Technical Implementation Annex. Interested people can consult our website
www.Issu.edu/bpac to review our ongoing concerns about the RAP.

Thank you for your efforts at producing the Stage II report and we look forward to
working with you and the other partner agencies on furthering the remediation process.
Regards,
Gregory Zimmerman, Chair

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                          ACKNOWLEDGEMENTS

Preparation of the Stage 2 Remedial Action Plan document has involved the dedication
and expertise of many individuals from both the Canadian and U.S. sides of the St. Marys
River.  Completion of this report would not have been possible without the commitment
of the Binational Public Advisory Council (BPAC), past and present members,
government agency representatives on the RAP team, and volunteers.

The draft document was produced by the former Lake Superior Programs Office with
contributions from the following:

       Jake Vander Wai           Formerly with Ontario Ministry of the Environment
       Ken Cullis                 Ontario Ministry of Natural Resources
       Marilee Chase              Ontario Ministry of Natural Resources
       Patrick Morash             Formerly of the Lake  Superior Programs Office
       Rod Stewart                Ontario Ministry of the Environment
       Roger Eberhardt            Michigan Department of Environmental Quality
       Jennifer Manville           US Environmental Protection Agency
       Terry Morse                US Fish and Wildlife  Service
       JimWaybrant          ,    Michigan Department of Natural Resources
       JohnKelso                 Canadian Department of Fisheries and Oceans

Grateful acknowledgements are also extended to the many technical reviewers who
provided valuable recommendations and editorial comments, and to the following
individuals who were instrumental in the preparation of the final document.

       Janette Anderson           Environment Canada
       Gail Krantzberg            International Joint Commission
       John Marsden              Environment Canada
       Ralph Jessup               Environment Canada

Thanks extended to Dr. J.R.M. Kelso of the Department of Fisheries and Oceans for his
contribution to the St. Marys River RAP with respect to the development of watershed
management plans and the habitat components of this report.

Lake Superior State University has generously provided a BPAC office that serves as a
resource centre for the St. Marys River. Reference material pertaining to the AOC and
GIS maps of the watershed are available at this location.

In memoriam of Roman Aikens we would like to acknowledge his public service and
dedication to protecting the quality of the St. Marys River.

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                                 Preface

The RAP process is dynamic, with action plans developed in response to the most current
information. This Binational St. Marys River Stage 2 Report represents a suite of
activities that will lead to the eventual delisting of the Area of Concern. The report is
considered to be a work in progress, based on current information.  In some cases, the
action plan is to acquire more refined and current information to definitively recommend
management actions to restore beneficial uses. The release of this Stage 2 Report at this
time is intended to represent a RAP milestone, by providing information to potential
implementors, to facilitate partnerships for further actions.

The RAP Implementation Annex, which will be issued subsequently to this Stage 2a
Report, will identify the roles, responsibilities, costs, and timelines for RAP
implementation.

Finally, it should be noted that the dollar sign, "$", wherever it appears in this report, will
denote "$US" when referring to funding from American sources and "$Can" when
referring to Canadian sources.

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                         TABLE OF CONTENTS

EXECUTIVE SUMMARY	 i
1.0 INTRODUCTION	 1
      1.1  Stages of the Remedial Action Plan	1
      1,2  Role of Agencies in the St. Marys River RAP	 2
      1.3  Public Involvement	 3
      1.4  Industry Participation	 6
2.0 THE ST. MARYS RIVER ECOSYSTEM 	 8
      2.1  Characteristics of the Area of Concern	8
      2.2  Socioeconomic Profile	  11
      2.3  Impaired Beneficial Uses	  15
      2.4  Point Sources of Pollution	  20
      2.5 Non-point Sources of Pollution	 23
      2.6 Exotics 	 25
3.0 GOALS AND EVALUATION CRITERIA 	 26
      3.1  Water Use Goals	  26
      3.2  Delisting Criteria	  29
4.0 POINT SOURCE POLLUTION - RESTORATION AND PROTECTION
   STRATEGIES FOR AIR AND WATER	  35
      4.1  Regulatory Programs	  36
      4.2  Restoration and Protection Measures Completed or In Progress	  38
      4.3  Restoration and Protection Actions Needed	  40
      4.4  Monitoring	 42
5.0 RESTORATION AND PROTECTION STRATEGIES FOR SEDIMENT
   AND OTHER NON-POINT SOURCES OF POLLUTION	46
      5.1 Regulatory Programs	   49
      5.2  Restoration and Protection Measures Completed or In Progress	  50
      5.3  Restoration and Protection Actions Needed	  51
      5.4  Monitoring	 56
6.0 RESTORATION AND PROTECTION STRATEGIES FOR FLORA
   AND FAUNA	61
      6.1 Regulatory Programs	   62
      6.2  Restoration and Protection Measures Completed or In Progress	  64
      6.3  Restoration and Protection Actions Needed	  67
      6.4  Monitoring	  73
7.0 REPORTING AND EDUCATION 	78
      7.1 Education Programs - On-going and Completed	 78
      7.2  On-going Reporting of AOC Activities and Monitoring	79
      7.3  Reporting and Education Actions Needed	 79
8.0 SUMMARY OF RECOMMENDATIONS	 82

REFERENCES	90
ACRONYMS	95
MEASUREMENTS AND UNITS	97

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APPENDIX 1: Contact Lists	 98
APPENDIX 2: Environmental Management Agreement Between
              Algoma Steel, Environment Canada, and the
              Ontario Ministry of the Environment	 103
                                 List of Tables

Table 2.1. Summary of impairments to Great Lakes Water Quality Agreement
           beneficial uses in the St. Marys River Area of Concern	 15
Table 2.2. Municipal point source loadings to the St. Marys River	 20
Table 2.3. Major industrial point source loadings to the St.  Marys River	 22
Table 3.1. Water use goals and delisting criteria for each beneficial
           use impairment	30
Table 4.1. Ranked contaminants of concern in the St. Marys River	  35
Table 5.1. Summary of selected areas requiring clean up  and restoration	  47
Table 6.1. Remedial options for habitat protection and conservation of the Bennett
           and West Davignon Creek system	  68
Table 6.2. Existing programs to monitor the quantity and quality of habitat capable
           of supporting flora and fauna	  74
Table 8.1 -  Summary of Recommendations to Restore the Beneficial Uses
           in the St. Marys River	  82
                                 List of Figures

Figure 2.1.  Location map of the St. Marys River Area of Concern	   10
Figure 4.1.  Air quality monitoring sites	   44

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                         EXECUTIVE SUMMARY
The St. Marys River was identified in 1985 by the International Joint Commission (IJC)
as one of 43 Areas of Concern (AOC) on the Great Lakes for which cleanup or Remedial
Action Plans (RAPs) are required.  As an international waterway, the St. Marys River
requires a cooperative effort between Canadian and U.S. Governments to coordinate the
remedial action process.  The St. Marys River is one of three binational RAPs developed
jointly between Ontario and Michigan, with Environment Canada and the Ontario
Ministry of Environment being the lead agencies responsible for its development.

Remedial action planning is a three staged process. The Stage 1 RAP for the St. Marys
River described environmental conditions and identified use impairments. The area was
originally classified as an AOC because of problems associated with phosphorus,
bacteria, oil and grease, heavy metals, trace organics, contaminated sediments, fish
consumption advisories, and impacted biota. Stage 1 was reviewed by federal, state, and
provincial agencies and the IJC.

The Stage 2 document outlines a strategy to remediate  the impaired beneficial uses and
defines a set of criteria to measure progress toward delisting the AOC.  It contains, in
addition to a large number of restoration and monitoring actions already underway,
descriptions of approximately sixty recommended actions to restore the beneficial uses.
These actions address issues such as: the control of industrial and municipal point
sources, a management program for sediment remediation, the restoration of fish and
wildlife habitat, monitoring the effectiveness of restoration activities and progress toward
delisting, and finally, the need to transfer information about the RAP to interested citizens
and communities.
A.  Impaired Beneficial Uses

The St. Marys River was designated an AOC because 9 of the 14 beneficial uses defined
by the Great Lakes Water Quality Agreement were impaired.  The following abridgment
of Table 2.1 summarizes the current status of beneficial use impairments for this area.
Ambient water quality is not recognized as a formal use impairment under the Water
Quality Agreement; however, the natural high quality water that enters the St. Marys
River from Lake Superior was established by the BPAC as the minimum water quality
standard to be achieved throughout the river system to its outflow into Lake Huron.

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Table E.I - Summary of Impairments to Great Lakes Water Quality Agreement
               Beneficial Uses in the St. Marys River Area of Concern
              (I = impaired; NI = not impaired; RFA = requires further assessment)
Beneficial Use Impairment
Restrictions on Fish and
Wildlife Consumption
(a) Restriction on fish
consumption
(b) Consumption of
wildlife
Tainting of Fish and Wildlife
Flavour
Degradation of Fish and
Wildlife Populations
(a) Dynamics of fish
populations
,,"/" "'-
(b) Body burdens offish
;;;' (c) Dynamics of wildlife
populations
(d) Body burdens of wildlife
Fish Tumours and Other
Deformities
Bird and Animal Deformities
or Reproductive Problems
Status

I
NI
NI

I
I
RFA
RFA
I
RFA
Conditions in the St. Marys River

In Ontario and Michigan, mercury and PCB contamination has resulted in
fish consumption advisories for chinook salmon, walleye, yellow perch,
longnose suckers, northern pike, channel catfish, and carp.
No AOC specific advisories are in effect. However, OMNR has issued an
advisory, throughout Ontario, against the consumption of kidneys and liver
from moose, black bear, and deer.
Tainting of fish from the St. Marys River is not common.

Populations of native fish have been reduced due to habitat alteration, over
fishing, pollution, exotic species, and stocking. The St. Marys River is also
the major contributor of sea lamprey infestation to northern Lake Huron,
which accounts for an annual mortality of 54% of adult lake trout. Zebra
mussels have also been discovered in the St. Marys River.
Evidence indicates that chemicals with hepatic mixed function oxidase
(MFO) inducing potential (eg., PAHs and PCBs) are present in the St.
Marys River below the power dam. The condition reflects localized
contamination of the sediments, water, and benthic invertebrates. The
presence of dehydroabletic acid (DHA) indicates the bioaccumulation of
resin acids as a result of exposure to the pulp mill effluent.
Extensive development on both sides of the river has resulted in the
degradation and loss of aquatic and terrestrial habitat. The potential effect
of this development on birds, mammals, and other animals has not been
well documented. Wildlife populations appear to be stable or increasing,
but assessment criteria are required.
Mercury and PCB (Aroclor) concentrations have been detected in
waterfowl breast meat, however there is no criteria for assessment. Eggs
from herring gull, black tern, and common tern nests should be analyzed.
White suckers sampled from the St. Marys River exhibited liver tumour
prevalence in excess of 9%, likely associated with exposure to chemical
contaminants, such as PAHs in contaminated sediments. Liver cancers
have also been identified in brown bullheads from Munuscong Bay.
A full assessment of bird and animal populations has not been
accomplished.

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Beneficial Use Impairment
Degradation of Benthos
(a) Dynamics of benthic
;.-••' populations
(b) Body burdens of benthic
. organisms
Restrictions on Dredging
Activities
Eutrophication or
Undesirable Algae
Restrictions on Drinking
Water Consumption or Taste
and Odour Problems
(a) Consumption
(b) Taste and odour
problems
Beach Closures
Ambient Water Quality
Degradation of Aesthetics
Added Cost to Agriculture
and Industry
Degradation of
Phytoplankton and
Zooplankton
Status

I
I
I
I

NI
NI
I
I
I
NI
NI
Conditions in the St. Marys River 7

On the Ontario side, benthic communities are moderately impaired
downstream of the Algoma Slag site. Impairment also occurs on both sides
of the Lake George Channel, within Little Lake George, and at the north
end of Lake George.
Elevated PAH levels were noted in mussels placed downstream of the
Algoma Slip and also in those exposed to sediments along the Algoma Slag
Dump shoreline. Arsenic, mercury, and PCBs have also been observed to
bioaccumulate in benthic organisms.
Sediments from navigational portions of the following sites exceed OMOE
or U.S. EPA disposal guidelines: the Algoma Slip, the Algoma Slag Dump
site, Lake George Channel, Little Lake George, northern half of Lake
George, Cannelton Industries waste site, the head of the St. Joseph and
West Neebish Channels, and Lake Munuscong.
Eutrophication and algae are an issue in the vicinity of the East End Water
Pollution Control Plant. This could be alleviated through implementation of
secondary treatment at the plant.

Treated water consumption has never been restricted in the AOC. All
drinking water obtained from surface waters requires standard treatment.
See however, section 7.3 and Action NPSM-10 in section 5.4.
Taste and odour problems have not been reported.
E. coli bacterial densities in excess of the PWQO and MWQS occur in
Ontario and Michigan waters downstream of storm sewers, combined sewer
overflows, industrial outfalls, and the East End WPCP.
Ambient water quality is not recognized as a beneficial use impairment;
however, water quality is to be reflected as a goal in the Stage 2. Water
leaving the St. Marys River should be as clean as that coming in.
Oil slicks downstream of the Algoma Slip and Terminal Basin have
occurred. Oily fibrous material mixed with woody debris anecdotally
occurs along the Ontario shoreline. Oil spills from ships or accidents that
release chemicals to the river are a threat in the AOC. Aesthetic
impairment also exists downstream of the East End WPCP.
None documented.
Open water community structure and densities reflect Lake Superior.
Ill

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  Beneficial Use Impairment
Status
Conditions in the St. Marys River
 Loss of Fish and Wildlife
 Habitat
        Significant loss of fish and wildlife habitat has occurred as a result of
        shoreline alteration, industrialization, urbanization, and shipping activities,
        particularly within and immediately above and below the St. Marys rapids.
        The unnatural flow regime resulting from the present operation of the the
        gated, flow-control structure at the head of the rapids has resulted in
        changes to the biological integrity and productive potential of the remaining
        rapids habitat. Also, specific habitats throughout the river are now
        threatened by colonization of exotic species such as purple loosestrife,
        Eurasian fish species, zebra mussels and other exotic invertebrates.
B. Public Involvement

The Binational Public Advisory Council (BPAC) was formed in 1988 to provide
informed and continuous public participation in the St. Marys River RAP.  The citizen-
based group represents interests from both Ontario and Michigan. Members work with
and advise RAP participants on key aspects of the planning process.

A number of workshops were held in support of the Stage 2 process to ensure broad
based public involvement in RAP development. As a result, the BPAC and RAP
participants developed a set of water use goals and delisting criteria for the St. Marys
River AOC.  The goals represent a wide variety of environmental principles, which must
be considered with future development along the shores of the St. Marys River, to ensure
that river water quality and the overall ecosystem are protected and enhanced for all
users. The delisting criteria will be used to guide the development of remedial actions,
preventative measures, and regulatory programs, and to direct monitoring efforts in the
AOC. These guidelines will also assist in measuring the progress towards achievement
of water use goals and alleviating use impairments.

In addition, four task teams were formed to develop strategic plans for the restoration of
impaired beneficial uses. Task team participants, including agency and BPAC
representatives, examined Point Sources of contamination, Education and Reporting
programs, Clean Up and Restoration of contaminated sediments, and Flora and Fauna
habitat issues in the AOC. The principle findings and recommendations of the task teams
have been incorporated into the Stage 2 report.

C. Industry Involvement

Algoma Steel Inc. (ASI) recently signed a three party Environmental Management
Agreement (EMA) with Environment Canada and the Ontario Ministry of Environment.
In this voluntary agreement, ASI has agreed to undertake a number of initiatives
addressing issues such as benzene and polynuclear aromatic compounds reduction,
polychlorinated biphenyl and mercury removal, blast furnace visible emissions reduction,
                                         IV

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boat slip remediation, solid waste management plans, and participation in a steel sector
wide initiative regarding the implementation of a Code of Practice.

Another major local industry, St. Marys Paper, has also demonstrated a commitment to
environmental objectives by investing $14 million in an activated sludge secondary
treatment facility. Likewise, Cannelton Industries Inc. has completed a number of clean
up activities to remediate the former tannery site.  These include the excavation of
33,000 tons of tannery waste materials and contaminated soils to off site solid waste
disposal facilities, construction of surface drainage works, a shoreline berm to prevent
erosion, and seeding and mulching to revegetate the  site.
D. Achievements

The following actions and commitments indicate clearly the high degree of determination
among stakeholders to restore the impaired beneficial uses in the St. Marys River AOC:

(1) Point Source Pollution Restoration and Protection Measures

  Algoma Steel Inc.:

  •   Commissioning of a main filtration plant in 1990, at a cost of $20 million, to
      reduce suspended solids and phenols
  •   Signing of Letter of Commitment to $45 million in environmental improvements
  •   Process improvements including basic oxygen furnace emissions project
      ($21 million), blast furnace contact water recirculation facility ($14 million),
      biological treatment plant that eliminates phenols and cyanide from coke oven
      wastes ($2 million), and fixed ammonia removal system
  •   Established air quality monitoring station to record dustfall and total suspended
      particulates
  •   Implemented street washing program for residents near coke ovens and enhanced
      dust control measures with use of dust suppressants and paving
  •   Recently signed the three party Environmental Management Agreement (EMA)
      with Environment Canada and the Ontario Ministry of Environment.

  St. Marys Paper Ltd.:

  •   Activated sludge secondary treatment facility completed in 1995, at a cost of
      approximately $14 million,  resulting in reduced BOD and suspended solid levels
  •   Installed scrubbers to eliminate particulate emissions from two boilers

  Water Pollution Control Plants:

  •    Continuous phosphorus removal system added to East End Water Pollution
      Control Plant

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  •   New sludge handling facilities added to East End Plant
  •   East End Plant now being upgraded to secondary treatment under the $60 million
      Canada-Ontario Infrastructure project described below.

 Combined Sewer Overflows:

•   Commitment of $25 million from Sault Ste. Marie, Michigan to a project that will
    eliminate combined sanitary and storm water sewers in its wastewater treatment
    system.
•   Phase A of the project has been completed ($8 million) and has resulted in the
    closing of two combined sewer overflow outfalls.
•   Phase B underway ($6.5 million) and will result in the closing of two more outfalls.
•   In 1997, the city of Sault Ste. Marie, Ontario embarked on an aggressive five year
    voluntary abatement plan to improve the existing sewage collection system. To date,
    initiatives have totaled $1.1 million.
•   Work is also under way on a $17 million program, to be completed in 2002, that will
    result in the re-routing of sewers and upgrades to two sewage pumping stations and
    sewage containment tanks.  This program is part of a new $60 million Canada-
    Ontario  Infrastructure project through which the City of Sault Ste. Marie, Ontario
    will install sewage overflow tanks, make upgrades to increase primary treatment
    capacity, add secondary treatment to the East End water pollution control plant  and
    rehabilitate sewers in areas  of high infiltration.

(2) Non Point Source Pollution Restoration  and Protection Measures

   Contaminated Sediments:

•   Pilot test of chemical injection system to treat contaminated sediments was
    completed.
•   Sault Ste. Marie, Ontario invested $1.98 million in the relocation of Trader's Metal
    to clean up  and beautify the St. Marys River waterfront.
•   Air quality monitoring program in vicinity of Algoma steel (atmospheric deposition)
•   Remediation of Cannelton Industries Superfund site

(3) Restoration and Protection  Measures for Flora and Fauna

•   St. Marys Rapids hydrology study
•   Little Rapids restoration project
•   Geozone mapping of the AOC
•   Sea lamprey control
•   Enhanced fish access to Munuscong Bay Waterfowl Sanctuary
•   Formation of St. Marys River Fisheries Task Group
                                       VI

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 £. Recommendations to Eliminate Remaining Beneficial Use Impairments

Restoring beneficial uses to the St. Marys River AOC requires a cooperative effort by
government, industry, and the public, aimed at reduction or cessation of impacts on the
ecosystem and rehabilitation of historically degraded sites.  The following table
summarizes the main recommended actions for the restoration and protection of the St.
Marys River. Note that the remediation and monitoring actions are grouped separately
and in each case are listed  in the same order in which they appear in the report.  General
reporting and education actions and management actions are listed at the end of the table.
Table E.2 - Summary of Recommended Actions for the St. Marys River AOC
    Beneficial Use
    Impairment,
         Recommendations for the Restoration of Beneficial Uses*
               and for the Associated Monitoring Activities    r
Restrictions on Fish
and Wildlife
Consumption
                                              • Remediation Actions
 Action PS-1: Virtually eliminate all persistent and bioaccumulative contaminants
 from industrial and municipal discharge.

                	Monitoring Actions	
                         Action NPSM-2: Aerial Monitoring of the Cannelton Industries Site
                         Action NPSM-3:  Biological Monitoring at the Cannelton Industries site to ensure
                         protection of the ecological food chain
                         Action FFM-3: Fish Harvest Survey
                         Action FFM-4: Continue with sport fish contaminant monitoring programs in the St.
                         Marys River and tributaries.	
Degradation of Fish
and Wildlife
Populations
                                              • Remediation Actions •
 Action PS-1: Virtually eliminate all persistent and bioaccumulative contaminants
 from industrial and municipal discharge.
 Action NPS-1: Develop a multi-agency sediment management program for the river
 to address remedial options and implement actions for contaminated sediments,
 including long-term sediment contamination studies. For details on this high priority
 action see section 5.3 of the Stage 2 Report.
Action NPS-4: Identification and Control of Contaminant Inputs from the Algoma
 Slag Dump (including stabilization of shoreline and nearshore sediments)
 Action NPS-7: Remediation for Contaminated Terrestrial and Aquatic
 Disposal Sites
 Action FF-7: Continue with St. Marys River Fishery Task Group efforts to develop a
 10 year assessment program for the river.
 Action FF-8: Continue to support sea lamprey control efforts.

               	Monitoring Actions	
                         Action PSM-6: Monitor the receiving water every three years at St. Marys Paper Ltd.
                         to document response of fish communities to improved effluent quality as mill
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    Beneficial Use
     Impairment
          Recommendations for the Restoration of Beneficial Uses*
                and for the Associated Monitoring Activities
Degradation of Fish
and Wildlife
Populations
 (continue^), ?
 upgrades and process improvements are implemented.
Action PSM-8: Monitor the Short Term Variability and Monthly Ranges of
Contaminant Discharges from Water Pollution Control Plants in the AOC
 Action NPSM-2:  Aerial Monitoring of the Cannelton Industries Site
 Action NPSM-3:  Biological Monitoring at the Cannelton Industries site to ensure
protection of the ecological food chain
Action NPSM-9:  Identify Terrestrial and Aquatic Disposal Sites Transferring
Contaminants into Waterways
Action NPSM-11: Assess the Potential Hazards Associated With Spills from
Shipping Vessels
 Action FFM-5: Complete a Canadian Wildlife Survey assessment of common tem
 and black tern populations for the entire St. Marys River.
 Action FFM-6: Analyze contaminant levels in eggs from herring gull, black tern, and
 common tern nests in the AOC.
 Action FFM-7: A monitoring program should be developed to assess change in fish
 and wildlife populations in the AOC in response to habitat enhancement efforts.	
 Fish Tumours and
Other Deformities
                                                 • Remediation Actions
 Action PS-1: Virtually eliminate all persistent and bioaccumulative contaminants
 from industrial and municipal discharge.
 Action PS-7: Continue with process improvements at industrial and municipal
 facilities.
 Action NPS-1:  Development of a Multi-Agency Sediment Management Program
 Action NPS-4:  Identification and Control of Contaminant Inputs from the Algoma
 Slag Dump (including stabilization of shoreline and nearshore sediments)
                                                 • Monitoring Actions •
                          Action NPSM-9:  Identify Terrestrial and Aquatic Disposal Sites Transferring
                          Contaminants into Waterways
                          Action FFM-1: Identify the Causes of Fish Tumours and Other Deformities
                          Which Originate Within the AOC	
Bird and Animal
Deformities or
Reproductive
Problems    ;
                        • Monitoring Actions •
 Action FFM-8: Reproductive assessments of herring gulls, black terns, and common
 terns should be done within the AOC boundary.  Deformities should be assessed in
 common terns in the St. Marys River.	
  Degradation of
     Benthos
                                                — Remediation Actions
 Action NPS-1: Develop a multi-agency sediment management program for the river
 to address remedial options and implement actions for contaminated sediments,
 including long-term sediment contamination studies. For details on this high priority
 action see section 5.3 of the Stage 2 Report.
 Action NPS-2: Conduct further studies to characterize sediment quality in high
 priority areas (ie., adjacent to Algoma Slag Dump,  portion of Little Lake George
 Channel downstream of East End WPCP, and the Algoma Slip).
 Action NPS-3: Complete sediment chemistry analysis and benthic community
 assessment as part of the St. Marys River Contaminated Sediment Zones Evaluation
 (Kauss 1999b)
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    Beneficial Use
     Impairment
          Recommendations for the Restoration of Beneficial Uses*
                and for the Associated Monitoring Activities
Degradation of
   Benthos
  (continued)
                           Action NPS-5: Algoma Steel Inc. has removed sediments from the slip during
                           maintenance dredging operations. Therefore, further sediment quality and benthic
                           community assessments should be made to determine the effectiveness of contaminant
                           removal and to determine the need for further dredging.

                                       	Monitoring Actions	
 Action PSM-1: Long-Term Water Monitoring at the Cannelton Industries Site
 Action PSM-6: Monitor the receiving water every three years at St. Marys Paper Ltd.
 to document response of benthic communities to improved effluent quality as mill
 upgrades and process improvements are implemented.
 Action NPSM-1: Monitor effluent from East End Water Pollution Control Plant for
 concentrations and loadings of persistent contaminants exceeding guidelines in Lake
 George Channel sediments.
 Action NPSM-3: Biological Monitoring at the Cannelton Industries site to ensure
protection of the ecological food chain
 Action NPSM-5: Re-sample river sediments every five years to obtain trend with
 time information.
 Action NPSM-6: Periodically conduct benthic, toxicity, and sediment chemistry
 studies in the Bellevue Marine Park area.
  Restrictions on
Dredging Activities
                                                  • Remediation Actions •
 Action NPS-1: Develop a multi-agency sediment management program for the river
 to address immediate dredging needs. For details on this high priority action see
 section 5.3 of the Stage 2 Report.
 Action NPS-S: Evaluate sediment quality and quantity in the Algoma Slip to
 determine need for further dredging.
                                                  • Monitoring Actions •
                           Action NPSM-3:  Biological Monitoring at the Cannelton Industries site to ensure
                          protection of the ecological food chain
Eutrophication or
Undesirable Algae
                                               — Remediation Actions •
Action PS-3: Upgrade East End Water Pollution Control Plant to secondary
treatment.
Action NPS-6: Control non point source pollution from agricultural activities.
                                                   • Monitoring Actions •
                           Action NPSM-8:  Monitor Non-Point Sources of Pollution in the AOC
                                               IX

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  Beneficial Use
   Impairment
         Recommendations for the Restoration of Beneficial Uses*
          ,,.,    and for the Associated Monitoring Activities ;•/
Ambient Water
   Quality
                                                • Remediation Actions •
Action PS-1: Virtually eliminate all persistent and bioaccumulative contaminants
from industrial and municipal discharge.
Action PS-2: Reduce storm water infiltration to prevent sewage bypasses.
Action PS-3: Upgrade East End Water Pollution Control Plant to secondary
treatment.
Action PS-5: Address contaminants in storm water discharge system by source
control, air quality control, and pollution prevention education programs.
Action PS-6: Continue with Clean Water Regulation (Canada) and National Pollutant
Discharge Elimination System (US) Programs for industrial dischargers.
Action PS-7: Continue with process improvements at industrial and municipal
facilities.
Action PS-8: Continued work on CSOs in Sault Ste. Marie Mich.
Action NPS-1:  Development of a Multi-Agency Sediment Management Program
Action NPS-7:  Remediation  for Contaminated Terrestrial
and Aquatic Disposal Sites
Action NPS-8:  Plan and Implement Appropriate Remediation, Protection, and
Enforcement Actions to Remove Any Potential Public Health Risks Identified by
Action NPSM-10

             	Monitoring Actions	
                         Action PSM-1: Long-Term Water Monitoring at the Cannelton Industries Site
                         Action PSM-3: Ambient Water Monitoring in the St. Marys River
                         Action PSM-7: Design and implement monitoring system for storm water.
                         Action NPSM-9:  Identify Terrestrial and Aquatic Disposal Sites Transferring
                         Contaminants into Waterways
                         Action NPSM-10: Assess Health Risks to Communities and Individuals Taking
                         Their Water From the "Down-River" Regions of the St. Marys River System
                         Action NPSM-11: Assess the Potential Hazards Associated With Spills from
                         Shipping Vessels
                                                 • Remediation Actions •
                         Action PS-2: Reduce storm water infiltration to prevent sewage bypasses.
                         Action PS-3: Upgrade East End Water Pollution Control Plant to secondary
                         treatment.
Beach Closings
                                                 • Monitoring Actions
                         Action NPSM-7: Assess potential human health risks resulting from floating
                         contaminated masses near, and downstream from, Bellevue Marine Park.

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  Beneficial Use
   Impairment
             Recommendations for the Restoration of Beneficial Uses*
                j   and for the Associated Monitoring Activities
Degradation of
  Aesthetics
                                                — Remediation Actions •
    Action PS-4: Relocate discharge pipe from East End Water Pollution Control Plant to
    deeper, faster moving water in the Lake George Channel in order to improve
    dispersion of discharge plume.
    Action PS-9: Algoma Steel to Limit Discharges from its Dekish Operation
    Action FF-9: The Algoma Slag Dump shoreline is an eyesore.  Shoreline stabilization
    and providing habitat for plant growth (eg., via soil addition) would help to soften
    and stabilize the landscape.
                                                  • Monitoring Actions •
                          Action PSM-2:  The Sault Ste. Marie, Michigan Air Quality Monitoring Project
                          Action PSM-4:  The Sault Ste. Marie, Ontario Air Quality Monitoring Project
                          Action PSM-5:  Monitoring of Paniculate Emissions at Algoma's Dekish Operation
Loss of Fish and
Wildlife Habitat
                                               • Remediation Actions •
Action NPS-6: Control non point source pollution from agricultural activities and road
   crossings on tributaries.
Action NPS-7:  Remediation for Contaminated Terrestrial and Aquatic Disposal Sites
Action FF-1: Walleye recovery in the Bar River:
    Mitigate the effects of land use practices upstream of historic walleye spawning
    grounds.
    Use stabilizing structures, contour streambanks, plant trees along the shoreline, and
    provide exclusionary fencing to restrict livestock access to river.

Action FF-2: Watershed Development Plan for Bennett and West Davignon Creeks (See
Table 6.1)
    (a) Maintain headwater reaches in natural state
    (b) Restrict development within 30m of shoreline
    (c) Plant trees in riparian zone
    (d) Restrict livestock access to stream
    (e) Assist passage of migratory salmonids by enhancing migratory pathways while
    excluding sea lamprey passage (see (n))
    (f) Create spawning and nursery habitat
    (g) Naturalize Diversion Channel
    (h) Prevent seepage of petroleum products into aquifer to protect groundwater quality
    (i) Design and implement soil remediation projects for inactive parcels of land on
    Algoma Steel property
    (j) Algoma to work with OMOE in addressing specific contamination issues
    (k) Increase habitat quality and migration pathways in Diversion Channel with
       instream modifications.
    (1) Optimize volume of flow between Diversion  Channel and Bennett and West
       Davignon Creeks
    (m) Maintain migratory pathways
    (n) Exclude passage of sea  lamprey
    (o) Adhering to buffer strip guidelines and continued restrictions on development
                                              XI

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  Beneficial Use
    Impairment
             Recommendations for the Restoration of Beneficial
                   and for the Associated Monitoring Activities
Loss of Fish and
Wildlife Habitat
  (continued)
    (p)  Provide alternative water sources for livestock
    (q)  Streambank stabilization
    (r) Construct retention ponds or man-made wetlands to reduce effects of storm water
       discharge
    (s) Continued wetland development to improve salmonid staging habitat and provide
       for waterfowl and other wildlife
    (t) Maintenance of riparian buffer zone contiguous with a forested area no less than
       1000 ha
    (u) Reforestation of inactive agricultural lands
    (v)  Tree planting along top of Diversion Channel
   (w) Enhance wetland forming off mouth of Diversion Channel

Action FF-3:  Watershed Development Plan for East Davignon and Fort Creeks etc.:
    A watershed plan similar to Action FF-2 should be developed for East Davignon and
    Fort Creeks, Root River, Crystal Creek, and the Big and Little Carp Rivers.
Action FF-4:  Munuscong River/Bay: Sedimentation Reduction
    Several key non point source pollution control projects to reduce sedimentation in the
    river and in Munuscong Bay (e.g., stabilization of eroding streambanks at Stirlingville
    Bridge site and at Pickford).
Action FF-5:  Mission Creek:
    Complete hydrogeological and waste characterization study to be completed,
    including a feasibility study for the removal of waste and restoration of the natural
    flow of the creek.

Action FF-6: Rapids Habitat: (A number of options have been presented for the
remediation of rapids habitat and associated wetlands.)
    (a) Protect remnant rapids habitat from further reduction and degradation and
       maximize the productive capacity of the rapids area
    (b) Enhance remnant rapids habitat by placing additional spawning substrate in rapids
       area
          map existing substrate, identify target fish species assemblages, and note  areas
          likely to become dewatered under differing flow conditions
   (c) Create new rapids areas elsewhere in the St. Marys River, especially in the Little
    Rapids area
          identify areas with the hydrologic and physical characteristics to support rapids
          generation
    (d)  Create alternative to rapids habitat such as artificial spawning substrate
    (e) Create wetlands downstream of Whitefish Island to connect wetland habitat to
       adjacent remnant rapids
    (f) Create new wetland/rapids complexes
   (g) Enhance habitat and water quality in tributary watersheds

Action FF-7: Fisheries Assessment:
   (a) Mortality rates for walleye, northern pike, and yellow perch require further
    assessment.
    (b) Continue with St. Marys River Fishery Task Group efforts to develop a 10 year
       assessment program for the river.
Action FF-8:  Continued Support for Sea Lamprey Control Efforts
Action FF-9:  Stabilize shoreline of Algoma slag dump to provide habitat for plants
                                              XII

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    Beneficial Use
     Impairment
             Recommendations for the Restoration of Beneficial Uses*
                   and for the Associated Monitoring Activities
Loss of Fish and
 Wildlife Habitat
   (continued)
                                                  • Monitoring Actions •
Action PSM-1: Long-Term Water Monitoring at the Cannelton Industries Site
Action NPSM-3: Biological Monitoring at the Cannelton Industries site to ensure
   protection of the ecological food chain
Action NPSM-9:  Identify Terrestrial and Aquatic Disposal Sites Transferring
   Contaminants into Waterways
Action NPSM-11: Assess the Potential Hazards Associated With Spills from
   Shipping Vessels
Action FFM-2: Continued support for the Marsh Monitoring Program
Action FFM-7: A monitoring program should be developed to assess change in fish and
   wildlife use of the AOC in response to habitat enhancement efforts.
Action FFM-9: Evaluate Influence of Water Levels and Flows on Spawning and
   Production
Action FFM-10: Determine Minimum Water Levels and Flow Rates Necessary for
   Spawning
Action FFM-11: Monitoring Water Quantity
           General Actions Relating to Reporting, Education, Human Health, and Management
    General
 Reporting and
 Education Actions
Action RE-1:  Revitalizing Public Understanding and Involvement in Remediation
              Activities
Action RE-2:  Communication of Any Identified Health Risks Resulting from Adverse
              Effects to First Nations/Native American Water Supplies or Lands
Action RE-3:  Identify, Track, and Publicize Implementation Activities Within the AOC
Action RE-4:  Raise Public Awareness of Environmental Health Concerns
Action RE-5:  Quantify the Economic Benefits of a Healthy Natural Ecosystem
Actions Relating to
Human Health
Action NPSM-10: Assess Health Risks to Communities and Individuals Taking Their
Water From the "Down-River" Regions of the St. Marys River System

Action NPSM-12: Identify Locations Within the AOC Which are Associated With
Elevated Levels of Human Health Disorders
     General    *
Management Actions
Management Action MNG-1: It is recommended that a workshop session, or series of
sessions be convened which will produce a set of precise, objectively defined delisting
criteria that are numerically quantified wherever possible, and which will provide the
necessary decision framework that will govern the delisting of each impaired beneficial
use and ultimately the delisting of the AOC itself.
                                             Xlll

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    Beneficial Use
     Impairment
              Recommendations for the Restoration of Beneficial Uses*
                    and for the Associated Monitoring Activities
     General
Management Actions
    (continued)
Management Action MNG-2: It should also be noted that monitoring activities which
track progress toward delisting must, in large measure, be determined by those very same
criteria which define the delisting process itself.  Consequently, modifications or additions
to the delisting criteria, such as those which are recommended under management action
MNG-1 will likely require corresponding changes to the monitoring activities. It is
recommended, therefore, that a workshop session, or series of sessions also be convened
to establish the necessary coordination between the overall monitoring strategy and the
revised delisting criteria resulting from Action MNG-1.
 * The recommended actions are labeled as follows:
     Action PS-n denotes the n-th point source (PS) recommended action (see section 4.3).
     Action NPS-n denotes the n-th non-point source (NFS) recommended action (see section 5.3)
     Action FF-n denotes the n-th flora and fauna (FF) recommended action (see section 6.3).
     Action RE-n denotes the n-th reporting and education action (see section 7.3).
     Action MNG-n denotes the n-th management recommended action.
Monitoring recommendations for point sources, non-point sources, and flora and fauna are denoted by Action PSM-n,
Action NPSM-n, and Action  FFM-n, respectively (see sections 4.4, 5.4, and 6.4 respectively).
                                                XIV

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                              1.0 INTRODUCTION

1.1 Stages of the Remedial Action Plan

The Great Lakes Water Quality Agreement of 1978 (GLWQA) (revised 1987), provides general
and specific water quality objectives to restore, protect, and maintain the Great Lakes Basin
Ecosystem. The agreement affirms the determination of Canadian and U.S. Governments to
adopt an ecosystem approach to planning, research, and management of the Great Lakes and
connecting channels.  As a result, participating federal, state, and provincial agencies, in
cooperation with the International Joint Commission (IJC), identified 43 degraded areas on the
Great Lakes as specific Areas of Concern (AOC), for which cleanup or Remedial Action Plans
(RAPs) are required.

The RAP program was initiated in 1985 as  a recommendation by the Great Lakes Water Quality
Board.  Eight Great Lakes states and the Province of Ontario committed themselves to
developing and implementing remedial action plans in each AOC within their political
boundaries. As an international waterway,  the St. Marys River requires a cooperative effort
between Canadian and U.S. Governments to coordinate the remedial action process. The St.
Marys River is one of three binational RAPs developed jointly between Ontario and Michigan,
with Environment Canada and the Ontario Ministry of Environment being the lead agencies
responsible for its development. The Canadian RAP program is guided by the Canada-Ontario
Agreement respecting the Great Lakes Basin Ecosystem.  The cooperation and involvement of
Environment Canada, the Ontario Ministry of Environment, the U.S. Environmental Protection
Agency, the Michigan Department of Environmental Quality, the Department of Fisheries and
Oceans  , the Ontario Ministry of Natural  Resources, and the Michigan  Department of Natural
Resources is fundamental to this procedure.

Remedial action planning is a three staged process. The Stage 1 RAP for the St. Marys River
described environmental conditions and identified use impairments. The area was originally
identified as an AOC in 1985 because of problems associated with phosphorus, bacteria, oil and
grease, heavy metals, trace organics, contaminated sediments, fish consumption advisories, and
impacted biota. Stage 1 was reviewed by federal, state, and provincial agencies and the IJC. The
Stage 2  document outlines various strategies for remediation and evaluates existing remedial
efforts.  Resolutions developed herein lay the groundwork for the third stage, which monitors the
path of remediation in the AOC, documenting progress, and updating remedial efforts. An
integral part of Stage 3 is the monitoring  effort and the means employed (eg., biological
community properties, restoration of habitat function, sediment and water chemistry sampling) to
assess ecosystem recovery.  Recognizing that the process is a dynamic  one, RAP participants
must be willing to acknowledge any deficiencies that arise at each stage and act accordingly to
modify remedial strategies.

The Great Lakes Health Effects Program (GLHEP) of Health Canada worked with RAP
participants on the integration of human health considerations into the development of all area

                                           1

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RAPs. In the U.S., the Agency for Toxic Substances and Disease Registry (ATSDR) addresses
human health effects from exposure to contaminants in the Great Lakes. The Binational
Ecosystem Objectives Working Group for Lake Superior has also produced human health
objectives and developed indicators of progress in remediating health related impairments.
These lake-wide objectives and indicators, however, are broader in scope than those of the St.
Marys River AOC.
1.2 Role of Agencies in the St. Marys River RAP

Under the protocols of the Great Lakes Water Quality Agreement, Environment Canada, the
Ontario Ministry of the Environment, the U.S. Environmental Protection Agency, and the
Michigan Department of Environmental Quality (hereafter referred to as the Four Agencies)
signed a Letter of Commitment (April 17, 1998) to the restoration of this binational AOC. This
Four-Party Agreement states that Environment Canada and the Ontario Ministry of the
Environment have the primary responsibility for the administration of the shared activities for the
St. Marys RAP.

The Four Agencies, recognizing the mutual benefits of cooperating on matters of binational
interest, agree that restoration of the boundary waters cannot be achieved independently by any
one agency and that each of the Four Agencies must be accountable to their citizens for
continued environmental improvement and protection. The Four Agencies recognize that part of
the shared accountability is to promote RAP implementation and to persuade other implementors
to undertake remedial work within the appropriate jurisdiction.  This means that the Agencies are
committed to ensuring that stakeholder and public involvement is an integral part of the RAP
process.

To delist the St. Marys River AOC, the Four Agencies have the responsibility to coordinate the
development and review of measurable and achievable delisting criteria. In addition, the
Agencies recognize the need for monitoring and surveillance efforts to track progress towards
delisting the AOC.

The active participation of all four agencies is paramount to the cleanup of this binational AOC.
This is best demonstrated by empowering local participation, facilitating implementation
activities, actively pursuing solutions to problems, defining research needs, and by recognizing
successes through the transfer of information and methodologies. The Four Agencies
acknowledge that, as  defined in the GLWQA, the federal governments have committed to
cooperate with state and provincial governments in the development and implementation of
binational RAPs.

In February of 2000, the Four Agencies finalized a "Compendium of Position Papers,"
addressing roles and responsibilities for administration, binational delisting, public involvement
and outreach, and progress reporting.

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The Administration paper establishes a management, working group, and ad hoc technical
committee structure.  This consists of a Four-Agency Management Committee, to perform
oversight and monitor RAP progress and a Technical Working Group to coordinate State,
Provincial, and Federal resources for restoration of the Areas of Concern.  In addition, Ad-Hoc
Technical Teams will be formed on an as needed basis to resolve technical issues and review
RAP documents.

The Binational Delisting paper sets out a process to delist individual beneficial use impairments
and to delist the shared Areas of Concern once restoration has occurred. The Four Agencies will
coordinate and facilitate monitoring to track site progress under this commitment.

The Public Involvement and Outreach paper outlines activities to maintain public interest in local
water quality issues.  The Four Agencies will facilitate funding and partnership opportunities to
restore the shared Areas of Concern and build broad community support for RAP
implementation.

The Progress Reporting paper describes the format, defines responsibilities,  ensures distribution,
and provides timetables for biennial progress reports to the International Joint Commission and
the public. These biennial progress reports will describe the current status of areas of concern
and progress toward achieving delisting criteria and restoring beneficial use impairments.

The St. Marys River Area of Concern, Michigan Progress Report was completed in November,
1999, and parts of that report have been used to complete this stage two document.

The Compendium of Position Papers is available from:

Michigan Department of Environmental Quality
Surface Water Quality Division
Storm Water and Remedial Action Unit
P.O. Box 30273
Lansing, MI 48909
517-241-7734

It is also available on the Internet at the following website:
http://www.on.ec.gc.ca/glimr/raps/connecting/detroit/detroit_compendl2.pdf
1.3 Public Involvement

Public participation is a critical part of the RAP process. The goal of public involvement is to
ensure that the remedial action plan responds to community needs and enjoys a high level of
support for implementation. As part of this involvement, the Binational Public Advisory Council

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(BPAC) for the St. Marys River RAP has provided the information contained in the following
sub-sections.

(A) Binational Public Advisory Council - St. Marys River

The Remedial Action Plan process began in 1985 with the identification of Areas of Concern in
the Great Lakes basin by the International Joint Commission.  As part of this process, a central
Binational Remedial Action Plan Committee was formed in 1987. The committee was
comprised of representatives from the Ontario Ministries of the Environment and Natural
Resources, the Michigan Department of Natural Resources, the United States Environmental
Protection Agency, and Environment Canada. The RAP team was charged with the development
of plans to address contaminated conditions at several of the Areas of Concern including the St.
Marys River.

Annex 2 of the Great Lakes Water Quality Agreement states that "The Parties (Canada and the
United States), in cooperation with State and Provincial governments, shall ensure that the public
is consulted in all actions undertaken pursuant to this Annex." Recognition of the importance of
this provision prompted the St. Marys River RAP Team to form the Binational Public Advisory
Council (BPAC) during the fall of 1988. The particular role of the BPAC was to provide advice
on public opinion and views regarding the remedial action plan. The charter of the BPAC called
for equal representation from both Canada and the United States for the following categories:

       •  Environment
       •  Recreation/tourism
       •  Industry/shipping/small business
       •  Labour
       •  Fisheries
       •  Municipalities
       •  Academic
       •  Elected officials
       •  Citizens at large
       •  Public health
       •  Native peoples

During the 14 years that BPAC has been in existence, there have been representatives from all
the categories listed above.  A core of long term members (referring to themselves as "die-
hards") has remained dedicated throughout that time period. A list of current BPAC members
can be found in appendix one.

The BPAC's adopted charge is as follows:

       The BPAC shall comment on and advise the RAP Team on key aspects of RAP
      preparation and implementation. This includes: the goals of the plan, problems to be

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      addressed, water uses to be restored, planning methodology, technical data, remedial
      action alternatives, plan recommendation, and plan implementation.  The goal of the
      BPAC is to arrive at a plan which both BPAC and the RAP Team can come to a
      consensus on, and for which there is broad public support and commitment.

      BPAC members shall relay relevant RAP information and decisions to members of the
      groups they represent and, where appropriate, shall seek ratification of BPAC resolutions
      by groups within their constituencies.

In addition, U.S. and Canadian BPAC members have been appointed to the Statewide Public
Advisory Council (SPAC) and the Ontario  Public Advisory Council (OPAC) respectively. These
organizations have been advocates for the collective RAPs and Public Advisory Committees.

(B) BPAC Achievements

The BPAC has met on a scheduled basis (most routinely as quarterly meetings) since 1988. The
BPAC as a group participated and helped produce the following products during the 14 years of
existence:

•  Identification of Impairments and Conditions — The BPAC assisted in identifying those
   impairments in the AOC which formed the basis of the investigations for the Stage 1 Report
   published in March 1992.  As part of that process, the BPAC participated with the RAP
   Team in public workshops and working sessions.

•  Development of Water Use Goals - The BPAC played a crucial role in the development and
   adoption of water use goals for the St. Marys River. In December of 1992, the Ontario
   Ministry of the Environment sponsored a Goals and Objectives Workshop to facilitate public
   and agency feedback.  The goals were subsequently adopted by the BPAC and form the
   desired endpoint of efforts to restore the impaired beneficial uses of the river and eventually
   to delist the river's Area of Concern status.

•  Identification of Remediation Needs and Options - Following submission of the Stage 1
   Report, an effort was made to examine  the various strategies available for remediation of the
   beneficial use impairments and to achieve the water use goals. RAP task teams were
   developed to concentrate expertise of the agencies and BPAC members to examine Point
   Sources of contamination, Education and Reporting programs, Clean Up and Restoration of
   contaminated sediments, and Flora  and Fauna habitat issues in the AOC. The resulting
   reports of the RAP task teams have  been incorporated into the Stage 2 Report and form the
   means by which the beneficial uses  can be restored and water use goals can be achieved.

•  Assessment of Community Programs and Projects - BPAC has been making efforts to
   partner with other citizen groups that strive to protect and restore the ecosystem of the St.
   Marys River and communities. As part of that effort, BPAC has been compiling and

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   updating lists of programs and projects in the region which can be supported to achieve the
   goals of the RAP. This priority list of projects has been incorporated into the Lakewide
   Management Plan (LaMP) for Lake Superior and has been presented to various agencies to
   be included in their program plans.

•  Development ofDelisting Criteria - In March 1999, a workshop was held to develop
   delisting criteria. BPAC members along with Canadian and U.S. government agencies, tribal
   and first nations, academics, industry, and St. Marys River area residents worked to define
   appropriate and concise endpoints to be achieved before the Area of Concern can be delisted.

•  Establishment of BPAC Office and Library - The BPAC was greatly encouraged and
   revitalized with the establishment of an office and library at the Gale Gleason Institute of
   Lake Superior State University. The office was organized and functions with grants through
   the U.S. Environmental Protection Agency.  Documents, photographs, and historical material
   related to the RAP process and the St. Marys River in general have been catalogued by
   student interns and are available to the public through the BPAC library. Students have also
   created and are maintaining a web site for the BPAC  and are working to consolidate
   geographical information system (GIS) maps and make them accessible to the public as well.

•  Creation of the  "Friends of the St. Marys River" - The BPAC supported the creation of a
   not-for-profit organization, the Friends of the St. Marys River.  The Friends of the  St. Marys
   River provides a local Canadian organization which can assist in the implementation of the
   Remedial Action Plan, especially for remedial works, education, promotion, and reporting.

It has become apparent throughout the Great Lakes that the most successful RAPs have not only
government support but also an active and dedicated local community to implement the plan.
The St. Marys  River BPAC has remained committed to the RAP process despite uncertain
funding, a changing political climate and government downsizing.  BPAC will continue to
provide a vital link to stakeholders and community support throughout the implementation stages
of the RAP. BPAC plans to continue forming partnerships with other watershed based groups in
the area and to encourage the formation of additional groups whose purpose is to restore and
protect watersheds in the St. Marys River system. BPAC is also planning to continue local
notification, outreach, and education of area citizens through regular meetings and the  BPAC
office.
1.4 Industry Participation

As described in section 4.2, Algoma Steel Inc. (ASI) committed itself in 1992 to $45 million in
environmental improvements to be completed by December 1996. This commitment
demonstrated the steelmaking company's resolve to support environmental projects that address
toxicity levels in process effluent, emissions control, and sediment contamination.  Since then

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ASI has continued to implement pollution abatement technology in compliance with Ministry of
Environment MISA regulations and has renewed its environmental commitment by recently
signing a three party Environmental Management Agreement (EMA) with Environment Canada
and the Ontario Ministry of the Environment.

As stated in the text  of the EMA, its objective is to clearly define a list of initiatives with
negotiated timelines for environmental activities which Algoma Steel agrees to undertake. The
activities identified in the agreement deal with issues which the three stakeholders agree are
priorities but have specific objectives which are currently beyond the compliance regime
administered by Environment Canada or the Ministry of the Environment. It is a voluntary
initiative which complements the existing regulatory process and assists Algoma Steel in
planning and prioritizing a multi year environmental program. The agreement covers the period
from the date of signing to December 31, 2005, and to this point, Algoma's financial difficulties
(see section 2.2) have not interfered with its voluntary commitments.

The EMA includes initiatives related to benzene and polynuclear aromatic compounds reduction
plans, polychlorinated biphenyl and mercury removal, blast furnace visible emissions reduction,
boat slip remediation, solid waste management plans, and participation in a steel sector wide
initiative regarding the implementation of a Code of Practice. The complete text of the
agreement is contained in Appendix 2, and may also be found on Environment Canada's Internet
site at http://www.ec.gc.ca/epa-epe/Algoma/en/index.cfm. It should also be noted that this same
website also contains the executive summaries of the semi-annual reports submitted by Algoma
to the two governments, under the terms of the EMA.

Another major local industry, St. Marys Paper, has also demonstrated a commitment to
environmental objectives by investing $14 million in an activated sludge secondary treatment
facility. Details of this may be found  in section 4.2, along with information on another initiative
designed to eliminate particulate emissions. Likewise, Cannelton Industries Inc. has completed a
number of clean up  activities to remediate the former tannery site. These include the excavation
of 33,000 tons of tannery waste materials and contaminated soils to off site solid waste disposal
facilities, construction of surface drainage works, a shoreline berm to prevent erosion, and
seeding and mulching to revegetate the site.

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                  2.0 THE ST. MARYS RIVER ECOSYSTEM

Extensive background information on the St. Marys River Area of Concern has been documented
in the Stage 1 report (St. Marys River RAP Team 1992). This section summarizes background
information that is pertinent to Stage 2 discussions, and highlights recent and additional material.
2.1 Characteristics of the Area of Concern

The St. Marys River AOC includes the area of the river which extends from Whitefish Bay
between Point Iroquois, Michigan and Gros Cap, Ontario downstream to Quebec Bay, Ontario -
Humbug Point, Ontario in the St. Joseph Channel and Hay Point, Ontario - De Tour Passage,
Michigan (Figure 2.1).  The St. Marys River is the only outlet of Lake Superior. It flows
southeasterly through several channels to Lake Huron, a distance of 100 to 120 km (63 to 75
miles) depending on which route is taken.  The elevation of the river drops a total of 6.7 m (22
feet) over this distance, with 6.1 m (20 feet) occurring at the St. Mary's Rapids. The average
flow of the river is 2,144 m3/s (75.8 x 103 cf/s).

The watershed of the St. Marys River includes all of the Lake Superior drainage basin as well as
a number of small tributaries that flow directly into the river. Michigan tributaries include the
Waiska, Charlotte, Little Munuscong, Munuscong, and Gogomain Rivers as well as several small
streams. In Ontario, the main tributaries are the Big Carp, Little Carp, Root, Garden, Echo, and
Bar Rivers and Bennett, East Davignon, West Davignon, and Fort Creeks.

Approximately 83 percent of the lands within 5 km (3 miles) of the St. Marys  River consist of
undeveloped forest and wetlands.  Extensive  areas of emergent marsh wetlands border the lower
river. Chippewa County, Michigan, for example, has 4,848 ha (11,979 acres)  of coastal wetlands
(St. Marys River RAP Team 1992). Agriculture is the second most widespread land use, with
about 10 percent of the area in farmland, hi general, agriculture is restricted because of a limited
growing season and poorly drained soils. Livestock for dairy and meat products and hay crops
are the dominant agricultural activities. Urban areas constitute about 5 percent of the land use in
the AOC.  The remainder of the area is used for rural residential, industry, commercial, and waste
disposal.

The St. Marys River is a key element in the Great Lakes-St. Lawrence Seaway. As a result,
extensive alterations to the river have been undertaken since the mid 1800s in  order to facilitate
ship navigation between Lakes Huron and Superior, enhance rail and vehicular traffic, and
provide hydroelectric power. The St. Marys River also provides domestic and industrial water
supply, fish and wildlife habitat, sport fishing, hunting and trapping opportunities, recreational
activities, and use as an effluent receiver. The river is a popular resource for recreational boating
with seven marinas located between Bruce  Mines and Sault Ste.  Marie, Ontario.

Water is withdrawn for cooling and process streams at Algoma Steel Inc. and St. Mary Paper Ltd.

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and for hydroelectric generating stations in Ontario and Michigan. The river is also a source of
drinking water for over 100,000 people. Municipal intakes are located in the upper river at Gros
Cap, Ontario and at Sherman Park, Sault Ste. Marie, Michigan's public beach. The Michigan
plant has a capacity of 22.7 x 103 m3 per day while the Ontario plant has a capacity of 40.0 x 103
m3 per day. There are also communal and private intakes along the river serving permanent  and
seasonal residences that are not connected to municipal supplies; however, there are very few
private water intakes along the Canadian side within the reaches of the St. Marys River up to and
including Lake George.

The St. Marys River watershed supports a diverse fish community within a wide range of habitat
types.  Open waters and embayments, emergent wetlands, sand and gravel beaches, and the
Rapids area provide spawning, nursery, and feeding grounds for a number of native and
introduced species. Pacific salmonine, namely pink, coho, and chinook salmon, and rainbow
trout are seasonally abundant in the river and provide  for a popular sport fishery.

Commercial fishing by Native Americans occurs in Whitefish Bay and in the upper reaches  of
the St. Marys River. Tribal commercial fishing in this area is mostly for whitefish and lake trout.
hi Ontario, commercial fishing for walleye, lake trout, lake whitefish, and perch occurs
immediately outside the AOC.  The St. Marys River also supports  a subsistence fishery
involving, but not limited to, Native Americans and First Nations Canadians who retained the
right to fish in the river through treaties made with the U.S. and Canadian governments
respectively. Utilization of the fishery will be better understood when the Fish Harvest Survey
Report is completed by the St. Marys River Fishery Task Group (see section 6.4).

At the 2000 State of the Lakes Ecosystem Conference (SOLEC 2000), the St. Marys River was
given the highest biodiversity rating in the Great Lakes.  This rating emphasizes the pressing
need to protect the River's uniquely important riparian environment and to successfully address
the problems identified in the Stage 1 report.

As described in the St. Marys River Stage 1 Report, "The St. Marys River has an abundant
supply of diverse riparian bird habitat. In fact, one hundred and eighty-six species of waterfowl,
colonial waterbirds, shorebirds, passerines and raptors inhabit the area, as residents or as
temporary inhabitants.  As well, the river is an important staging and migration corridor for
dabbling ducks, diving ducks and geese. Wetlands of the St. Marys River are part of a series of
feeding and resting areas utilized by waterfowl while migrating to and from their prairie breeding
and southern wintering areas.

The river provides breeding, nesting, and rearing habitat for mallards, common mergansers,
wood ducks, black ducks, Canada geese, common goldeneye, blue-winged teal, American
widgeon, American coot, northern pintails, ring-necked ducks, and common loons. Colonial
waterbirds nesting on the many islands and in the marshes along the banks of the river include
ring-billed gulls, common terns, double-crested cormorants, great blue herons, black terns,
herring gulls, and black-crowned night herons."

-------
 Figure 2.1
St. Marys River Remedial Action Plan
Location map of the St. Marys River Area of Concern
(liter UGLCCS 1968)
     extent ol study area

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Furthermore, "Riparian shorelines of the St. Marys River provide excellent habitat for a variety
of small mammals including beaver, otter, muskrat, mink, raccoon, American water shrew and
northern water shrew.  The most common large mammal is the white-tailed deer, even though it
is not abundant on the Ontario side of the river," (Stage 1 Report).

For additional information on the various species assemblages and habitat types the reader is
referred to the St. Marys River Stage 1 Report and its appendices.
2.2 Socioeconomic Profile

The largest communities in the AOC are Sault Ste. Marie, Ontario with a population of 85,010
(1991 census) and Sault Ste. Marie, Michigan with 15,000 residents. Although the population of
the region has remained fairly stable over the years, there has been a gradual decline during the
last decade. Both cities serve as industrial and commercial centres for a large portion of northern
Michigan and the Algoma District of Ontario. The communities of Echo Bay and the
Batchewana Rankin site and Garden River Indian Reserves are also  part of the Ontario
community (St. Marys River RAP Team 1992). In Michigan, the Bay Mills Indian Community
(-1,000 members) is located 24 km (15 miles) northwest of Sault Ste. Marie with additional
reservation land on Sugar Island. The Sault Ste. Marie Tribe (~20,000 members) has reservation
land in each of seven counties of the eastern Upper Peninsula with its largest community located
in Sault Ste. Marie, Michigan.

Algoma Steel is Canada's third largest integrated steel producer, and plays a major role in the
local and provincial economies. With 4,000 employees and 8,000 pensioners, the company's
annual wage and pension payments exceed $300 million, and it purchases more than $150
million annually in local goods and services.  Recently, however,  Algoma has experienced
significant financial setbacks, and on April 23, 2001, it announced it was initiating a
restructuring of its financial obligations and had obtained an Order for Protection under the
Companies' Creditors Arrangement Act (CCAA).

hi October, 2001 the company released a restructuring plan with its  employees, the Steel
Workers Union, investors, pension members and the City of Sault Ste. Marie. On December 22,
2001, the Government of Canada announced a loan guarantee to Algoma Steel Inc. of up to $50
million, which will provide the company with the essential financial liquidity to successfully
implement this restructuring plan. The federal government will also provide $500,000 to
establish a community economic development and  diversification strategy and will allocate an
additional $3 million for the implementation of a diversification fund for Sault Ste. Marie to
support projects, initiatives and programs. $1.7 million dollars has already been committed to 16
federal projects, under the Federal Economic Development Initiative for Northern Ontario.

St. Marys Paper Ltd. has rebounded from financial  troubles experienced in early 1990, and has

                                          11

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plans for a $25 million investment in order to adapt to changing market standards (Northern
Ontario Business 1998). Production improvements are not expected to change the mill's capacity
or increase the workforce.

A Community Development Strategy, which formed the basis for the City's Official Plan,
outlines tourism, economic, and social development opportunities for the Sault Ste. Marie,
Ontario, region. The plan includes a Waterfront Development Strategy that provides for the
revitalization of waterfront property at Bellevue Marine Park, the Plummer Hospital site, and the
Gateway Project situated between Great Lakes Power and the Station Mall property. Efforts will
be made to incorporate habitat enhancement initiatives and remediation into waterfront
development activities in these areas.

The Economic Development Corporation and the local Industrial Opportunities Committee of
Sault Ste. Marie, Ontario, have developed a resource base to attract new industry and
employment to the city (Economic Development Corporation 1997). The strategy is to
encourage diverse economic development and promote the unique natural environment and
cultural heritage of the area.  The project has the support of local government and major
employers.

In 1997, a five year Overall Economic Development Plan was completed for the eastern Upper
Peninsula of Michigan. Under this plan, the efforts of the Regional Planning and Development
Commission are directed at improving the economy of the area. Recent activities have included
such things as solid waste management, community projects, promotion of new business
opportunities, and recreation, land use, and transportation planning.  The George Kemp
Downtown Marina development and the Ashmun Bridge (extending between downtown Sault
Ste. Marie to the other side of the Edison Sault Canal) improvement project are also expected to
enhance the area and promote tourism.

Three lower St. Marys River islands were donated to the city of Sault Ste. Marie, Michigan in
1986. Funding from the city and a Coastal Zone Management grant will help to enhance
recreational opportunities, scenic viewing areas, environmental and historical interpretation, and
natural areas on the islands.

The industrial sector of the eastern Upper Peninsula has shown steady growth in the past five
years. In Chippewa County, the Sault industrial park currently has four manufacturing firms with
expansion plans underway.  Expanding operations are an indication of the healthy economy felt
throughout the region (Eastern Upper Peninsula Regional Planning & Development Commission
1997).

Capitalizing on the international market potential has increased tourism, social, and commercial
relations between the cities of Sault Ste. Marie Ontario and Michigan.  For example, an
education consortium, Binational Regional Initiative Developing Greater Education (BRIDGE),
of Lake Superior State University, Sault College, and Algoma University was formed in 1993 to
                                          12

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promote a unique, cross-border educational initiative. BRIDGE builds on the special
characteristics of the region while broadening the economic base of the two Saults to better serve
the educational and training needs of the area.  This initiative attracts interest, support, and
funding by the provincial, state, and federal governments as well as the private sector.  BRIDGE
is operated as a joint venture of a Canadian (BRIDGE Ontario) and a U.S. (BRIDGE Michigan)
nonprofit corporation.  Funding to date has come from private donations, a transition assistance
grant of $265,000  from the Ontario Ministry of Education and Training, and a $75,000 grant
from the Ontario Ministry of Northern Development and Mines.

In January 2000, the St. Marys River was formally recognized as a Canadian Heritage River
within the Canadian Heritage Rivers System (CHRS). The CHRS was established by the federal,
provincial, and territorial governments for the purpose of recognizing outstanding rivers in
Canada and ensuring future management that will protect these rivers and enhance their
significant heritage values for the long term benefit and enjoyment of all Canadians (Canadian
Heritage Rivers Board 1997).  As part of the requirements for designation as a Canadian Heritage
River, a Heritage Strategy document was produced which set out 13 objectives, 77 proposed
action items and an implementation direction for the Canadian portion of the St. Marys River.

The "Friends  of the St. Marys River," a legal non-profit corporation, is working closely with
other groups on both sides of the river to ensure commitments to the river are addressed,
including implementing the objectives and action items that were identified in the River's
Heritage Strategy document.  This organization recognizes that one of the most critical objectives
is the development of an empowered broadly based community group whose mandate would be
to pursue implementation of the Heritage Strategy, to establish short-, medium-, and long-term
goals, to monitor the progress of implementation, and to promote the St. Marys River as a pre-
eminent river in the Canadian Heritage River System. On June 6, 2001, the membership of the
Friends of the St. Marys River Board of Directors was formally ratified. At this same meeting,
the Board of Directors adopted Terms of Reference that set out the Mission, Goals and
Objectives, Membership, Committees and Financial Direction. As well, the Board passed its
first by-law that sets out specific duties  and direction including the provision of two new Sub-
committees, i.e., the Protection & Remediation and Promotion & Development Committees.

There are two important program initiatives that the Friends will support, i.e., the Great Lakes
Heritage Coast and the Remedial Action Plan for the St. Marys River. The Friends will also
consider supporting local initiatives such as those being proposed for the St. Marys River Marine
Centre and Sault Ste. Marie Legacy Landmark where heritage river themes can be presented. In
addition, the Friends of the St. Marys River will continue to assist their counterparts in Michigan
who have submitted an application for the American portion of the St. Marys River to be
nominated as  an American Heritage River. At the 4th Biennial International Water Trails
Conference held in Portland, Maine, September 7-9, 2001, the North American Water Trails
Associaltion recognized the efforts of the Friends of the St. Marys River and the St. Marys River
Heritage Water Trail received an honourable mention North American Water Trails Blue Ribbon
award.
                                          13

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Human Health

Part of the overall health of the ecosystem is the well being of the residents of the St. Marys
River AOC. To assess health vulnerabilities in each AOC, Health Canada determined that
examination of the following factors should be included in Remedial Action Plans: contaminant
levels in water, air, sediments, and biota; point and non point sources of contamination; pathways
of exposure; and health-related information, such as potential risks groups and community-raised
concerns.  Health Canada has compiled baseline information on the health status of communities
within and around the AOC (GLHEP 1998).

In 1998, Health Canada published the report Health Data and Statistics for the Population of
Sault Ste. Marie Ontario and Region which contained baseline information for the study area for
a large number of "specific health outcomes selected on the basis that they may be linked to
exposure to environmental contaminants." As explained in the report, "statistical results of
comparisons of health outcome measures between the study area and the whole of Ontario [were]
presented. Mortality, morbidity  and incidence rates as well as  birth weight information [were]
also given." No attempt, however, was made in the report to explain causal relationships
between the various contaminants in the environment and specific health disorders.
Consequently, relationships between the waters the St. Marys River and human health disorders
within the AOC cannot be inferred from this document.

Health Canada also participated in a study which assessed the lifetime health risk of skin cancer
resulting from recreational dermal exposure to water borne PAHs in the St. Marys River.  In this
study, duplicate sediment samples collected in 1992 from inshore and offshore locations at five
sites along the river, were analyzed for PAHs by Health Canada and MOE (Hussain et al., 1998).
The sites, from upstream to downstream, were the Rytac Sailing Club, Lake George Channel,
Bell Point, Squirrel Island, and Ojibway Trailer Park.  The inshore locations  were very close to
shore; the offshore locations were 15-100 m from shore.

Risk assessments were based on the assumption that an individual would swim once per day at a
maximum of 30 days per season over a maximum of 30 years during their lifetime. Estimation
of the risk from such exposure indicated that at the Rytac, Lake George Channel, and Bell Point
offshore locations, risk was higher than negligible (i.e., more than one excess cancer in a
population of one million exposed individuals). At all other sites, both inshore and offshore, risk
was well below the negligible level.

After completing this study, Health Canada informed local residents that the  risk of developing
skin cancer as a result of dermal exposure to PAHs at most locations is essentially negligible and
that the risk of swimming farther from shore (in the more heavily polluted water) could be
lowered by swimming less often and taking a shower immediately after each swim.

In the U.S., the Agency for Toxic Substances and Disease Registry (ATSDR) is required to
conduct a health assessment for every site placed on the National Priorities List under the
                                          14

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Superfund program (eg., former tannery site at Cannelton Industries Inc.). The objectives of the
health assessments are to (1) assess any current/future impacts on public health; (2) develop
health advisories/recommendations; and (3) identify actions, including studies, that are needed to
either mitigate and evaluate health effects or to prevent them from occurring. An "Interim
Preliminary Public Health Assessment" for the Cannelton Industries site was prepared by the
Michigan Department of Public Health under a cooperative agreement with the ATSDR.
2.3 Impaired Beneficial Uses

The St. Marys River was identified as an AOC because of impairment of nine of the 14
beneficial uses defined by the Great Lakes Water Quality Agreement. Table 2.1 summarizes the
current status of beneficial use impairments for this area. Ambient water quality is not
recognized as a formal use impairment under the Water Quality Agreement; however, the natural
high quality water that enters the St. Marys River from Lake Superior was established by the
BPAC as the minimum water quality standard to be achieved throughout the river system to its
outflow into Lake Huron.
Table 2.1. Summary of impairments to Great Lakes Water Quality Agreement beneficial uses in
the St. Marys River Area of Concern (I = impaired; NI = not impaired; RFA = requires further
assessment).
  Beneficial Use Impairment
Status
                Conditions in the St. Marys River
 Restrictions on Fish and
 Wildlife Consumption
   (a) Restriction on fish
      consumption
        Fish consumption advisories are currently in effect for:

        Ontario:
        -mercury: larger sized chinook salmon (>65cm), walleye (>45cm), yellow
        perch (>35cm), and longnose suckers (>30cm) in the St. Marys River
        (OMOE 1999)
        -mercury: chinook salmon (>75cm), walleye (>55cm), northern pike
        (>75cm), and channel catfish (>55cm) in the North Channel of Lake Huron
        (OMOE 1999)

        Michigan:
        -mercury: walleye (>36cm) in the St. Marys River
        -PCBs: walleye (>35cm), northern pike >66cm, and carp >15cm (MDCH)
    (b) Consumption of wildlife
 NI
Although there are no guidelines for human consumption of wildlife, the
OMNR has advised against the consumption of kidneys and liver from
moose, black bear, and deer because of high cadmium levels. This
advisory exists for the entire province of Ontario.
                                            15

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  Beneficial Use Impairment
Status
                  Conditions in the St. Marys River
Tainting of Fish and Wildlife
Flavour
  NI
Tainting of fish from the St. Marys River is not common. In the few
isolated cases that were reported, a determination could not be made as to
whether tainting was due to poor handling or other problems, either acute,
as in chemical or industrial spills, or chronic, as in long term chemical
loading (Skinkle  1992). Because the incidence of tainted fish is infrequent,
a comprehensive fish tainting evaluation has not been conducted.
Degradation of Fish and
Wildlife Populations
   (a) Dynamics offish
     populations
         The St. Marys River is the major contributor of sea lamprey infestation to
         northern Lake Huron, where parasitic lamprey account for an annual
         mortality of 54% of adult lake trout. Excessive mortality rates preclude lake
         trout rehabilitation efforts as well as other Lake Huron fishery programs
         (GLFC 1997). The sea lamprey population in the St. Marys River is
         estimated to be - 5.2 million (T. Morse, pers. comm.). Sea lamprey control
         measures are  expected to reduce lamprey populations in Lake Huron and
         northern Lake Michigan appreciably.

         Fish communities are diverse and healthy in the St.  Marys River; however,
         populations of native fish have been reduced and assemblages have
         changed due to habitat alteration, over fishing, pollution, exotic species,
         and stocking.  Zebra mussels were discovered in the Ontario waters of the
         St. Marys River in 1994.  A Lake Superior Zebra Mussel Survey (1991)
         identified the area around the canal entrance to the Parks Canada Lock as
         having the capacity to support zebra mussels.  The Ontario discovery was at
         this site as predicted (S. Greenwood, pers. comm.).  Zebra mussels had
         been found in association with the U.S. Army Corp locks in Michigan
         several years  previous.
   (b) Body burdens offish
         Hepatic mixed function oxidase (MFO) activity in white suckers sampled
         below the power dam on the St. Marys River suggests exposure to
         chemicals with MFO inducing potential (eg., PAHs and PCBs) (Smith et al.
         1990). The condition reflects localized contamination of the sediments,
         water, and benthic invertebrates.

         Most resin and fatty acids were non-detectable in white suckers collected
         downstream of St. Marys Paper Ltd.; however, the presence of
         dehydroabletic acid (DHA) indicates the bioaccumulation of resin acids as
         a result of exposure to the pulp mill effluent (Beak 1996).  Resin acid levels
         in fish tissue are expected to decline now that secondary treatment of mill
         effluent is in place.
                                                  16

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Beneficial Use Impairment
"^v" '
(c) Dynamics of wildlife
populations
(d) Body burdens of wildlife
Fish Tumours and Other
Deformities
Bird and Animal Deformities
or Reproductive Problems
Degradation of Benthos
(a) Dynamics of benthic
populations
XX*
Status
RFA
KFA
I
RFA

I
Conditions in the St. Marys River
Extensive development on both sides of the river has resulted in the
degradation and loss of aquatic and terrestrial habitat. The potential effect
of this development on birds, mammals, and other animals has not been
well documented.
Wildlife populations appear to be stable or increasing (ie., double-crested
cormorants) but assessment criteria are required. Ring-billed gull numbers
are increasing while common tern populations are decreasing due to a
decline in nesting habitat (CWS study of colonial waterbirds nesting on the
Great Lakes). In 1999, a portion of the St. Marys River was surveyed for
common terns. This survey needs to be completed including black tem
numbers in the assessment. Results can be compared with previous counts.
Mercury concentrations in waterfowl breast meat ranged from 0.12-0.46
mg/kg. Aroclor (PCB) was detected in all samples ranging from 0.002-
4.873 mg/kg however there is no criteria for assessment (CWS National
Wildlife Research Centre). Eggs from herring gull, black tern, and
common tem nests should be analyzed.
Liver tumours were identified in white suckers from industrialized sites on
the Great Lakes. The prevalence of hepatic neoplasms in excess of 5%
should be interpreted as an indicator of environmental degradation. White
suckers sampled from the St. Marys River (1985-1990) exhibited tumour
prevalence in excess of 9% (N=185). It is likely that hepatic cancers are
associated with exposure to chemical contaminants, such as PAHs in
contaminated sediments (Baumann et al. 1996). Liver cancers have also
been identified in brown bullheads from Munuscong Bay (Smith et al.
1990).
Researchers found three cross-bill common tern chicks out of 120 birds
sampled on Lime Island in 1998 (Michigan State University). No other
deformities have been noted in wildlife along the St. Marys River; however,
a full assessment of bird and animal populations has not been
accomplished. Reproductive assessments of herring gulls, black terns, and
common terns should be done within the AOC boundary. Deformities
should be assessed in common terns inhabiting the St. Marys River.

Benthic community health on the Michigan side of the AOC appears to be
good; however detailed studies are necessary to confirm this. In localized
areas on the Ontario side, benthic communities are moderately impaired
downstream of the Algoma Slag site to a distance of ~4 km. Impairment
also occurs on both sides of the Lake George Channel, within Little Lake
George, and at the north end of Lake George. In the vicinity of Bellevue
Marine Park, surficial sediment samples collected in Sept., 1995 indicate
reduced levels of metals, nutrients, oil and grease, and PAHs compared to
levels measured in 1985. Since 1985, sediments in this area have had a
relatively diverse benthic fauna and these changes are likely associated with
reduced surficial sediment contamination (Kilgour and Morton 1998).
17

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Beneficial Use Impairment
(b) Body burdens of benthic
organisms
Restrictions on Dredging
Activities
Eutrophication or
Undesirable Algae
Restrictions on Drinking
Water Consumption or Taste
and Odour Problems
; (a) Consumption
(b) Taste and odour
problems
Beach Closures
Ambient Water Quality
Status
I
I
I

NI
NI
I
I
Conditions in the St. Marys River
Arsenic, mercury, and PCBs tend to bioaccumulate in benthic organisms.
Caged mussels placed downstream of the Algoma Slip acquired the highest
total PAH levels when compared to low total PAH levels in mussels placed
upstream of the Algoma Slip and near the Michigan shore. The effects of
these contaminants on benthic organisms are not known. Elevated PAH
levels were also noted in mussels exposed to sediments along the Algoma
Slag Dump shoreline (Kauss 1999a).
Contaminated dredged spoils from the Algoma Slip must be disposed of in
an approved waste disposal site. Sediments from navigational portions of
the following sites have had contaminant levels that exceeded OMOE or
U.S. EPA guidelines for the disposal of contaminated sediment: adjacent to
the Algoma Slag Dump site along the Ontario shore; both sides of Lake
George Channel; Little Lake George; northern half of Lake George;
Michigan shore adjacent to Cannelton Industries waste site; the head of the
St. Joseph and West Neebish Channels; and Lake Munuscong.
Eutrophication and algae continue to be an issue in the vicinity of the East
End Water Pollution Control Plant. Conditions in embayments and in slow
moving parts of the river downstream from the WPCP have not been
documented. Ultimately this could be alleviated through implementation of
secondary treatment at the plant.

Treated water consumption has never been restricted in the AOC. All
drinking water obtained from surface waters requires standard treatment.
See however, section 7.3 and Action NPSM-10 in section 5.4.
Taste and odour problems have not been reported.
E. coli bacterial densities in excess of the PWQO and MWQS occur in
Ontario and Michigan waters downstream of storm sewers, combined sewer
overflows, industrial outfalls, and the East End WPCP.
Ambient water quality is not recognized as a beneficial use impairment;
however, water quality is to be reflected as a goal in the Stage 2. Water
leaving the St. Marys River should be as clean as that coming in.
18

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  Beneficial Use Impairment
Status
                  Conditions in the St. Marys River
Degradation of Aesthetics
         Recently, both municipalities have been increasing access and development
         along the waterfront. Further projects should be encouraged as long as this
         development proceeds within the context of protecting and enhancing the
         natural environment of the river.  Oil slicks downstream of the Algoma Slip
         and Terminal Basin have occurred; however, no complaints have been
         received since March 1990.  Oily fibrous material mixed with woody debris
         anecdotally occurs along the Ontario shoreline. Periodic spills have also
         been reported.  Given the extensive use of the river for transport, oil spills
         from ships or accidents that release chemicals to the river are a threat in the
         AOC.  Aesthetic impairment also exists downstream of the East End Water
         Pollution Control Plant.  Floating scum periodically occurs along the north
         shore of Sugar Island and the Ontario shoreline of Lake George Channel,
         downstream from the East End Plant.
Added Cost to Agriculture
and Industry
 NI
None documented.
Degradation of
Phytoplankton and
Zooplankton
 NI
Open water community structure and densities reflect Lake Superior.
Phytoplankton and zooplankton populations, however, have not been
documented in the nearshore areas of the St. Marys River.
Loss of Fish and Wildlife
Habitat
          Significant loss offish and wildlife habitat has occurred as a result of
          shoreline alteration, industrialization, urbanization, and shipping activities,
          particularly within and immediately above and below the St. Marys rapids.
          The unnatural flow regime resulting from the present operation of the
          Compensating Works -the gated, flow-control structure at the head of the
          rapids- has resulted in changes to the biological integrity and productive
          potential of the remaining rapids habitat (Edsall and Gannon 1993).
          Changes in flow through the gates result in higher flow for a period of time
          and then reduction back to a guaranteed minimum flow. Rapid fluctuations
          in water levels when gates are opened further and then closed, as well as
          timing relative to critical life stages offish and invertebrates are a concern.
          A total rapids area of 29.68 ha is separated by an 800 m long concrete
          berm.  Flow over the 6.25 ha rapids area north of the berm is supplied by
          gate #1 and flow over the 23.43 ha rapids south of the berm is supplied by
          the other 15 gates. While agreements on water use have guaranteed
          minimum amounts of water for the rapids it is a significant change in flow
          that existed pre 1985 that has resulted in both a reduction in size of the
          rapids habitat and a reduction in discharge over the rapids.

          Specific habitats throughout the river are now threatened by colonization of
          exotic species such as  purple loosestrife, Eurasian fish species (ruffe and
          gobie), and zebra mussels and other exotic invertebrates.
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2.4 Point Sources of Pollution

Main point sources of pollution to the St. Marys River AOC include effluent from two major
industrial facilities representing the iron and steel (Algoma Steel Inc.) and the pulp and paper
sectors (St. Marys Paper Ltd.); two municipal Water Pollution Control Plants (East and West
End plants) in Ontario; and a Waste Water Treatment Plant in Michigan.

Although the East End Water Pollution Control Plant will shortly be upgraded to a secondary
facility, as described below, it has until now been a primary treatment facility. It provides
chemical treatment for phosphorus removal and receives effluent from residential, commercial,
and small industrial users. The plant services a population of approximately 64,800 and
discharges to the St. Marys River in the Lake George Channel. The West End plant is a


Table 2.2. Municipal point source loadings to the St. Marys River. Values for East and West
End Water Pollution Control Plants (WPCP) based on yearly average for 1999 (Ontario Clean
Water Agency). Loadings for the Michigan Waste Water Treatment Plant (WWTP) based on
average monthly effluent data for 1997 (R. Eberhardt, pers. comm.).

Cadmium (ug/1)
Copper (|ig/l)
Zinc (ug/1)
Chlorine (ug/1)
Phosphorus (mg/1)
Phenols (ug/1)
Ammonia (kg/d)
Faecal Coliform (#/100 ml)
Total Coliform (#/100 ml)
E. coli (#/100 ml)
BOD5(mg/l)
Total Suspended Solids (mg/1)
Average Daily Flow (m3/d)
Discharge
limitsf
-
-
-
-
1.0 mg/1
-
-
-
-
-
25 mg/1
25 mg/1
-
East End WPCP
1.0**
17**
136**
-
0.61
-
373.11*
101-160000*
488
4-17300
43.01
21.14
34,720
West End WPCP
1.0**
10**
30**
-
0.56
3.25
9.59.
101-5400*
1001-100000*
6-2300
5.82
7.47
10,501
Michigan
WWTP
<10
<10
33
0.23
0.52
-
-
57
-
-
4.23
8.15
11,356
tMinistry of the Environment discharge limits for regulated parameters in the operation of sewage treatment
facilities.
*Values from Point Source Task Team Report 1994.  Information not available in 1999.
**Metals analysis for East and West End WPCPs from Sewer Water Inspection Program, 1998.
.Higher than normal ammonia levels were experienced in the fall and early winter 1999 but annual averages were
within guidelines.
                                            20

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secondary treatment facility utilizing a conventional activated sludge process with continuous
phosphorus removal. Effluent is discharged to the St. Marys River at Leigh Bay above the
rapids.  The plant services a primarily residential area with a population of about  16,200. The
Waste Water Treatment Plant in Sault Ste. Marie, Michigan is a secondary treatment facility
with phosphorus removal.  This plant also discharges to the river and serves a population of
15,000. Table 2.2 summarizes the loadings of conventional contaminants from each facility.

There are no combined sewers in the city of Sault Ste. Marie, Ontario.  However, several
sanitary to storm sewer overflows exist in the central older part of the city. Consequently, the
hydraulic capacity of the East End Water Pollution Control Plant (ie., 54,550 m3/d) is exceeded
during periods of high flow, resulting in the bypass of untreated sewage directly to the St. Marys
River,  hi an effort to prevent further overloading, the Ministry of the Environment imposed a
development restriction in  1989 on new housing in the  city's east end.  In addition, the City of
Sault Ste. Marie, Ontario adopted a five year plan to reduce storm water infiltration to the East
End plant.  To date, work has been completed on a sewer diversion to the West End plant from
the Fort Creek subdivision at an approximate cost of $300,000.  Work is also under way on a
$17 million program that will result in the re-routing of sewers and upgrades to two sewage
pumping stations and sewage containment tanks.  When this program has been completed in the
fall of 2002, there will be no more raw sewage by-passes into the storm water collection system.

These and other improvements to the City's wastewater treatment system are being supported
under the Canada-Ontario Infrastructure Program through a new joint project, announced
December 18, 2001. Through this project, the City of Sault Ste. Marie will install the sewage
overflow tanks, make upgrades to increase primary treatment capacity, add secondary treatment
to the East End water pollution control plant and rehabilitate sewers in areas of high infiltration.
The Government of Canada through Industry Canada and the Government of Ontario through
SuperBuild will each contribute up to $20,181,333 to the project, and the City of Sault Ste. Marie
will invest the balance, bringing the total project cost to $60,544,000. All of the improvements
implemented through this project are expected to be completed by March 2006.

Unlike Sault Ste. Marie, Ontario, approximately 85% of the sewer system for the city of Sault
Ste. Marie, Michigan consists of combined stormwater and sanitary sewers, and part of this
system has the potential to  overflow untreated sewage to the St. Marys River under certain high
flow conditions.  To control these combined sewer overflows (CSOs),  the City of Sault Ste.
Marie, Michigan plans to separate the stormwater and sanitary sewers.  The plan will result in
the elimination or treatment of combined sewage discharges containing raw sewage. While this
is a long-term plan, the City has already made several improvements  that have resulted in the
closure  of the four worst CSOs. Overflow now occurs only rarely in  severe runoff events.

St. Marys Paper Ltd. is a mechanical pulp mill that uses groundwood pulp, purchased bleach
kraft pulp, and filler (Beak 1996). The mill has three paper machines in operation: two produce
super-calendared paper for catalogues and advertising material; a third machine produces
newsprint.  Process water is drawn from the St. Marys River upstream of the mill. Effluent is
discharged to the St. Marys River through a submerged diffuser at an average flow rate of

                                          21

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27,325 m3/d.  Table 2.3 summarizes the loadings of conventional contaminants from St. Marys
Paper Ltd. It should be noted that these loadings are well below the regulated discharge limits.
Table 2.3. Major industrial point source loadings to the St. Marys River Area of Concern.
Municipal Industrial Strategy for Abatement (MISA) upper limit discharge quality for regulated
parameters included for comparison.

Heavy metals (kg/d):
Lead
Zinc
Cyanide (kg/d)
Phosphorus (kg/d)
Phenols (kg/d)
Ammonia (kg/d)
BOD5 (kg/d)
Total Solids (kg/d)
Benzene (kg/d)
Benzo(a) pyrene (kg/d)
Naphthalene (kg/d)
Oil and grease (mg/1)
Flow (m3/d)
Discharge
Limit1
-
-
110
0.267
-
3235
5084
-
-
-
-
-
St. Marys Paper Ltd.f
1998
-
-
22.127
0.0015528
-
340.99
1111.3
-
-
-
-
31,496
1999
-
-
15.211
0.0019539
-
372.19
1142.9
-
-
-
-
30,150
Discharge
Limit1
11.3
22.5
16.4
-
1.45
219
-
2380
0.143
0.166
0.389
15.0,
-
Algoma Steel Inc.*
1998
2.9438
18.360
12.756
-
0.35597
73.518

696.54
0.1116
0.12852
0.12563
0.232
258,816
1999
2.5141
6.0622
5.5772
-
0.4442
81.803
-
468.59
0.10224
0.02182
0.00111
2.046
224,092
t MISA Compliance Report, 1998 (average values for Jan. to Dec. 1998; average values for Jan. to Sept. 1999).
Upper limit for discharge quality effective Jan.l, 1998.
*MISA Compliance Report, 1998 and 1999 (average values for Jan. - Dec. 1998 and 1999).  Includes process
effluent discharge to the St. Marys River from main filtration plant, bar & strip lagoon, and #1 and #2 tube mills.
Upper limit for discharge quality effective Apr. 13, 1998.
»No loading limit for oil and grease.  Recorded value is the maximum concentration limit.
* Discharge must be non-toxic to rainbow trout and Daphnia magna.


Algoma Steel Inc. began making rails for Canadian and American railways at the start of the
twentieth century.  It is now a fully integrated operation producing flat rolled products.
Processing includes coke, iron, and steel making operations, hot forming, and finishing. Process
                                             22

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water is drawn from the St. Marys River and wastewater is discharged directly to the river from
the main filtration plant, the bar and strip lagoon, and #1 and #2 tube mills. Contaminant
loadings for all point source discharges from Algoma Steel have been summarized in Table 2.3,
and are well below regulated discharge limits.


2.5 Non-point Sources of Pollution

Algoma Slag Site

The Algoma Steel slag site has been identified as a potential source of chemical constituents
(i.e., PAHs, volatile organics, metals, phenols, cyanide, ammonia, and acid) to the groundwater
(Beak 1990). In 1989, a network of monitoring wells was established in the Algoma landfill by
the Ministry of the Environment, and a program was initiated to monitor groundwater quality of
the landfill site. A study was completed to determine if the disposal site is a source of toxic
seepage to the river via groundwater contamination.  Results indicated that deeper groundwater
was not affected by shallow, site-affected groundwater, and that groundwater from beneath the
slag site does not migrate towards the city water supply wells (Beak  1990). However, during the
study period the site contributed 15% of the benzene, toluene, and xylene load and 32% of the
PAH load to the river (Beak 1990).  To address this problem, a one million dollar coal tar
collection system was installed in 1990 by Algoma Steel at Bennett Creek.

Following the initial groundwater study, the monitoring program was assumed by Algoma  and
was repeated on a two-year cycle, up to and including 1997.  The findings of these subsequent
groundwater studies, indicated an improving trend in water quality and little or no impact on the
St. Mary's River water quality. Algoma Steel then determined that a two-year cycle was not
further warranted and that a four-year cycle for the groundwater study would be undertaken,
beginning in 2001 and then repeated in 2005. The findings of the  2001 groundwater study  were
reported in the February, 2002 semi-annual report, as required under the three party
Environmental Management Agreement (see Action NPS-4 in section 5.3). The executive
summary of this report may be found on the Internet, at the URL given in section 1.4.

Algoma continues with its initiatives to reduce the overall load of material sent to the landfill and
is actively involved in programs for paper, cardboard and wood that divert these materials from
the landfill and send them for recycling. Of these three commodities, an estimated total annual
average of approximately  160,000 kilograms  is diverted out of the  landfill. Furthermore, Algoma
also recycles an average 500,000 tonnes of steel each year, minimizing the amount getting to
landfill.

Sault Ste. Marie Ontario Landfill

An environmental assessment (1988) of the Sault Ste. Marie landfill  (Ontario) identified an on-
site leachate plume flowing towards the Root River, a tributary of the St. Marys River. A
landfill leachate collection and transmission system was installed (1998), and collected leachate

                                          23

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is now directed by force-main to the West End STP for treatment.  The landfill has a negligible
impact on the surface waters of the St. Marys River (Beak 1993).

Sediments

A sediment survey was conducted in the St. Marys River to determine the extent of
contamination and the potential impacts of contaminated sediments on the aquatic ecosystem of
the AOC. hi 1992, samples were collected from eight sites extending from the former tannery
dump site (i.e., Cannelton Industries Inc.) downstream to Lake George. An additional survey
(1995) concentrated on the Bellevue Marine Park area. All samples were surficial ponar grabs.

Toxicity tests performed in 1992 indicated that sediments from the Algoma Slip elicited the
greatest effect on benthic organisms followed by samples collected from Bellevue Marine Park
(Bedard and Petro 1997).

Chromium sediment concentrations (2,600 ug/g) in Tannery Bay exceeded the Provincial
Sediment Quality Guidelines (PSQG) severe effects level (110 ug/g). Total PAH sediment
levels ranged from 0.8 to 291 ug/g, well below the severe effects level (10,000 ug/g) (Arthur
and Kauss 1999). The higher total PAH levels were associated with benthic invertebrate growth
impairment; however, PAH levels in samples collected in 1995 were insufficient in explaining
this result (Bedard and Petro  1997).

Wood fibres and detritus produced unsuitable benthic habitat in the vicinity of Bellevue Marine
Park and up river to the Clergue Generating Station.  This latter site was not sampled as part of
the benthic study; however, wood fibres and detritus were observed during dredging operations
(S. Greenwood, pers.  comm.). Growth impairment of mayfly (Hexagenia limbata) and
chironomid (Chironomus tentans) larvae was associated with oil-based substances retained
within the organic materials (Bedard and Petro 1997). Levels of PAHs, nutrients, and most
metals were in excess of PSQG lowest effect levels; however, concentrations were reduced from
1985 values (Kilgour and Morton  1998).

Sediments containing elevated PAH levels have been dredged from the Algoma boat slip and
confined within an approved disposal facility (i.e., 20,000 m3 of dredgate) (RAP update info., R.
Stewart OMOE). The  slip serves as a docking area for commercial vessels and continues to
receive contaminant inputs from ASI (30" and 60" Blast Furnace sewers) and two tributary
creeks (East Davignon and Bennett).

Adjacent to the Cannelton Industries Inc. site is Tannery Bay, located on the south shore of the
St. Marys River. The site operated as a sawmill and tannery for many years, and waste products
were disposed or migrated offshore and settled in the river sediments. Remedial investigation
work has indicated that sediments contain organic material contaminated with chromium,
mercury, lead, cadmium, and arsenic. A detailed investigation of sediments in 1995 determined
that the river currents continue to deposit layers of clean sediment over the contaminated
                                          24

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organic material. The U.S. EPA approved a remedy for site clean up that included leaving the
contaminated sediments in place, capped by the layer of clean sediments. A biomonitoring
program will be on-going to determine that the selected remedy is protective.
2.6 Exotics

The invasion of aquatic habitats by nonindigenous, or exotic, species poses a serious and
continuing threat to native ecosystems of the Great Lakes region. Since these aquatic nuisance
species (ANS) often have no natural predators in their new environment, their populations can
expand dramatically to the point where they out-compete native species for food and habitat, and
in some cases even displace them entirely.

One such exotic species which poses a particularly serious threat to the Great Lakes is the sea
lamprey, which accounts for 54% of adult lake trout mortality in Lake Huron. The St. Marys
River is the largest contributor of sea lamprey to northern Lake Huron, with lamprey populations
estimated to be higher in Lake Huron than in all other Great Lakes combined (GLFC 1997). The
preferred spawning habitat  for sea lamprey in the St. Marys River is similar to that of salmonid
species. Therefore, spawning habitat rehabilitation efforts to augment fish populations should
coincide with enhanced sea lamprey control measures.

In addition to the sea lamprey, there are a number of other aquatic nuisance species which also
threaten the integrity of the Lake Superior aquatic ecosystems. Among these are the alewife, the
Eurasian water milfoil, purple loosestrife, rainbow smelt, round goby, ruffe, and zebra mussel.
Descriptions of these ANS  may be  found in the Lake Superior Lakewide Management Plan
(LaMP) on the Internet at www.epa.gov/glnpo/lakesuperior/lamp2000/index.html.

Since it is virtually impossible to eradicate an ANS once it has invaded a new habitat, it is
generally agreed that prevention is the best means of control. This explains why such emphasis is
placed on restricting and regulating ballast water discharges.  Unintentional introductions of
exotic species into the Great Lakes have occurred primarily through the transport of ballast water
carried in ships engaging in international trade. In fact, nearly a third of the nonindigenous
organisms found in the Great Lakes have been introduced since the opening of the St. Lawrence
Seaway in 1959.

hi both the United States and Canada, there are a few regulations governing ballast water in the
Great Lakes. The U.S. Coast Guard, for example, established both regulations and guidelines for
the control of ANS in 1996, which established mandatory reporting and sampling procedures for
all vessels to help limit the  further introduction of ANS through ballast water. The Canadian
Coast Guard,  likewise, has  had guidelines in place since 1989 and works in conjunction with the
Department of Fisheries and Oceans, the Marine Safety Branch of Transport Canada, and the
U.S. Coast Guard to ensure that ballast water guidelines are being met (L. Superior LaMP, 2000).
                                          25

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                 3.0 GOALS AND EVALUATION CRITERIA

3.1 Water Use Goals

One of the first directives facing the BPAC was the determination of a common vision for the
future state of the St. Marys River AOC which would clearly identify locally defined water use
goals and also represent regional environmental priorities.  The subsequent challenge was to
select from among a range of remedial actions those which, when implemented, would not only
restore the impaired beneficial uses, but also support these more general water use goals
important to the local community. The inclusion of these locally defined objectives in the Stage
2 report is an essential prerequisite to achieving broad local support for implementation.

Through a series of public workshops, the Binational Public Advisory Council and the Remedial
Action Plan Team developed a set of water use goals for the St. Marys River AOC.  The goals
represent a wide variety of environmental principles, which must be considered with future
development along the shores of the St. Marys River, to ensure that river water quality and the
overall ecosystem are protected and enhanced for all users of the river.  The water use goals
were designed to address specific beneficial use impairments in the AOC.

The following water use goals were adopted by the BPAC in November 1990:

Aesthetics

      Aesthetically pleasing

       • Remedial actions shall not detract from the aesthetic quality of the Area of Concern.

      Balance between natural shoreline and human use

       • The river shall be available for compatible multi-use activities which do not exceed
         the carrying capacity of the river system or to the exclusion of recreational activities.
      • Waterfront development shall require public notice and consultation and an
         environmental impact assessment.
      • Sustainable development shall be consistent with goals set forth.

      Public access

      • Public access to and along the river for recreation should be increased, improved, and
        maintained.

Recreation and Shipping

      Recreation
      • Commercial and recreational vessels must be subject to speed regulation.

                                         26

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       Navigation

       • All vessels must be operated by licensed operators trained to protect water quality
         consistent with the water use goals and regulation.
       • There shall be no winter navigation.

Sources of Contaminants

       Spills

       • An adequate spills prevention program and proper recovery equipment shall be
         established and maintained.

       Point Sources

       • Industrial/commercial wastes shall not be treated in domestic sewage plants.
       • Programs shall be established to collect and treat domestic and industrial/commercial
         waste oils and hazardous chemicals.
       • Municipal and private sewage treatment effluents from operational and closed sites
         shall be sufficiently treated to satisfy the water use goals.
       • Costs or mitigation of negative impacts shall be borne by the party responsible for the
         impact.
       • There should be zero discharge of materials and substances by way of water, land,
         and air. These materials are those which are considered to be:

                Toxic: a substance which can cause death, disease, behavioural abnormalities,
                cancer, genetic mutations, physiological or reproductive malfunctions or
                physical deformities in any organism or its offspring, or which can become
                poisonous after concentration in the food chain or in combination with other
                substances;

                Persistent: any toxic substance with a half-life (in water) of greater than eight
                weeks;

                Bioaccumulative: the uptake and retention of substances by an organism from
                both its environment (ie., directly from the water) and its food;

                Bioconcentrated: the ability of an organism to concentrate substances within
                its body at concentrations greater than it's surrounding environment or food;

                Mutagenic: a substance or physical agent that can cause changes in one or
                more hereditary features by modifying genes. Ionizing radiation is a mutagen;
                                           27

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                Teratogenic: a substance capable of causing changes to the developing fetus;

                Carcinogenic: a substance or physical agent that can cause cancer in humans
                (eg., asbestos, bischloromethyl ether (B.C.M.E.), and beta-napthylamine);

          and/or may cause adverse effects to the health of the biota, especially fish, animals,
          and humans.

       Non-point Sources

       •  Hazardous wastes found in closed land based waste disposal or storage sites shall be
          rendered safe, harmless, and healthful to meet the water use goals.
       •  Stormwater runoff and landfill leachate effluents from operational and closed sites
          shall be sufficiently treated to satisfy the water use goals.
       •  Runoff from non-point sources resulting from land management practices in the Area
          of Concern shall not compromise the ecosystem and shall meet our water use goals.

       Sediments

       •  Sediments in the watershed shall be rendered safe, harmless, and healthful to meet the
          water use goals.
       •  Future dredging to enlarge the St. Marys River main shipping channels shall require
          an environmental impact assessment  and specifically assess alteration of flows,
          sedimentation, and impact on recreation in downstream channels.
       •  Dredging in the Area of Concern shall meet the water quality goals and address bank
          stability and wildlife habitat.
Exotics
       •  The intentional introduction of new species of plants and animals will require an
          environmental impact assessment.
       •  Undesirable exotic species shall be controlled or eliminated to meet the water use
          goals.
Human Health
          The water shall be safe, drinkable with standard treatment, and healthful for humans.
          The water shall be safe for wholebody contact (eg., swimming).
          Water shall be free from unnatural colour, odour, taste, turbidity, and heat.
          There shall be no further unnatural diversion in or out of the Great Lakes Basin -
          particularly Lake Superior as it affects the St. Marys River.
          Discharge water from the generation of power and for cooling shall meet our water
          quality goals.

                                          28

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Ecosystem Health
          Migratory and indigenous fish and wildlife habitat (natural and enhanced) shall be
          provided and protected, including wetlands, nesting sites, and other ecologically
          sensitive areas.
          Existing fish and wildlife habitat of the St. Marys River ecosystem shall be retained
          and protected from contamination or development.
          The water shall be safe and healthful for the benthic community, migrating and
          indigenous wildlife, and native species of fish.
Monitoring
          An integrated state of the art air, water, and sediment monitoring system shall be
          established, maintained, and updated in perpetuity.
          The results of all activity undertaken in all goals shall be made public.
          A funded committee be established to monitor and ensure that these goals are
          implemented.
3.2 Delisting Criteria

The delisting criteria presented in Table 3.1 were developed for each beneficial use impairment
and, collectively, will provide a decision framework for delisting the St. Marys River AOC.  The
criteria will be used to guide the development of remedial actions, preventative measures,
regulatory programs, and to direct monitoring efforts.  In addition, they will assist in measuring
progress towards achievement of water use goals and alleviating use impairments. It is
recognized, however, that many of the delisting criteria in Table 3.1 are open to subjective
interpretation, something that could cause problems when it comes time to delist.

Management Action MNG-1: It is recommended, therefore, that a workshop session, or series
of sessions be convened which will produce a set of precise, objectively defined delisting criteria
that are numerically quantified wherever possible,  and which will provide the necessary decision
framework that will govern the delisting of each impaired beneficial use and ultimately the
delisting of the AOC itself.  These criteria, furthermore, should be developed and reviewed in
accordance with the principals set forth in Chapter 2 of the Four Agency Compendium of
Position Papers  (see section 1.2).

Management Action MNG-2: It should also be noted that monitoring activities which track
progress toward delisting must, in large measure, be determined by those very same criteria
which define the delisting process itself. Consequently, modifications or additions to the
delisting criteria, such as those which are recommended under management action MNG-1, will
                                           29

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Table 3.1.  St. Marys River Area of Concern Water Use Goals and Delisting Criteria for each Beneficial Use Impairment.
  Beneficial Use Impairment
     Water Use Goals
                      Delisting Criteria
Restrictions on fish and wildlife
consumption
Sources of Contaminants (point
and non point sources, air
deposition)
Ecosystem Health
Human Health
No locally derived fish and wildlife consumption advisories as determined by
 the most stringent standards, objectives or guidelines.
Degradation offish and wildlife
populations
Sources of Contaminants (spills,
point and non point sources,
sediments)
Exotics
Ecosystem Health
Concentrations of persistent toxic substances in fish and wildlife will be below
 no observable adverse effect concentration (NOAEC) for reproductive,
 population, and teratogenic effects.  Effects will be the same as control
 populations from unaffected areas which may include Lakes Superior and
 Huron.
Delisting criteria for sea lamprey control should be guided by Sea Lamprey
 Control Centre goals and objectives for control of lamprey on the St. Marys
 River.
A St. Marys fisheries management plan, compatible with both the Lake Huron
 Binational Initiative and the Lake Superior Lakewide Management Plan, should
 be developed to protect, enhance, and restore habitat, fish communities, and
 native species. The plan should provide guidelines for the control of exotic
 species.  The guiding principle should provide for sustainable use of this
 resource founded upon self-sustaining fish populations.
Wildlife management plans for resident and migratory species.
Fish rumours and other deformities
Sources of Contaminants (spills,
point and non point sources,
sediments)
Ecosystem Health
Concentrations of persistent toxic substances in fish and wildlife will be below
no observable adverse effect concentration (NOAEC) for reproductive,
population, and teratogenic effects.  Effects will be the same as control
populations from unaffected areas which may include Lakes Superior and
Huron.
Bird and animal deformities or
reproductive problems
Sources of Contaminants (spills,
point and non point sources,
sediments)
Ecosystem Health
Concentrations of persistent toxic substances in fish and wildlife will be below
no observable adverse effect concentration (NOAEC) for reproductive,
population, and teratogenic effects.  Effects will be the same as control
populations from unaffected areas which may include Lakes Superior and
Huron.
                                                                     30

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Degradation of benthos
Sources of Contaminants (spills,
point and non point sources,
sediments}
Exotics
Ecosystem Health
Due to frequent disruption of benthic communities within navigational channels,
 as a consequence of ship traffic (includes adjacent areas that may be affected by
 ship traffic through bow waves, etc.) and navigational dredging, emphasis is
 placed on demonstrating the absence of acute and chronic toxic effects of
 sediment-associated contaminants and on demonstrating bioassay end points
 comparable to controls.
Benthic community structure outside the shipping channel is not significantly
 different from control sites of comparable physical and chemical characteristics
 (ie., shallow, silty sand, substrates with no oxygen limitations). When benthic
 macroinvertebrate community structure does not significantly diverge from
 unimpacted sites of comparable physical and chemical characteristics.
 Populations of mesotrophic species such as mayfly (Hexagenia), fingernail clam
 (Pisidium), and oligochaetes (Ilyodrilus templetoni and Spirosperma ferox) are
 present where suitable substrates are located, and historical data indicates that
 these organisms are native to the area.
In the absence of community structure data, this use may be considered restored
 when toxicity of sediment-associated contaminants is not significantly higher
 than controls. Resident fauna does not have elevated contaminant levels relative
 to unimpacted areas.
Restrictions on dredging
Sources of Contaminants
(sediments)
When contaminants in dredged sediment do not exceed the standards, criteria, or
 guidelines that permit open water disposal.  These levels are based on sediment
 concentrations associated with compounds identified within this AOC from
 local point or non point sources, and not based on contributions of new
 atmospheric deposition of compounds.
                                                                       31

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Eutrophication and undesirable algae   Sources of Contaminants (point
                                     and non point sources)
                                     Ecosystem Health
                                         All embayment waters have persistent total phosphorus concentrations of <20
                                          ug/1, a secchi disc transparency of > 1.2 m, dissolved oxygen at saturation,
                                          chlorophyll concentration of <10 ug/1, and unionized ammonia O.02  ug/1.
                                         Phosphorus load from East End Water Pollution Control Plant <1 mg/1 with a
                                          consideration of seasonal variability in receiving water sensitivity.  All plants to
                                          consistently meet Certificate of Approval limits or MI permit system limits.
                                         Any failure to meet these targets must not be attributable to cultural
                                          eutrophication (ie., nutrient inputs from human sources such as sewage).
                                         Conditions above to be maintained for at least five years prior to delisting.
                                         Mean monthly values for delisting targets should be met throughout the river,
                                          with sampling points representative of different river reaches and in proximity
                                          to known significant sources.
Ambient water quality
Human Health
Recreation and Shipping
(navigation)
Water should be substantially free from the presence of organisms that may
produce human diseases and infections as a result of human activity.
Consideration should be given to the effects of diversions, impoundments, and
fluctuating water levels. (Note: all drinking water obtained from surface waters
requires standard treatment).
Iron, phenols and ammonia need to be within applicable standard for finished
drinking water.
Beach closings
Human Health
Aesthetics (public access)
For officially designated or commonly used full-body water contact beaches, the
 daily geometric mean should not exceed regulatory standards for parameters
 measured and be free from public health advisories and beach closures due to
 sewage discharges from any source for a period of two years.
Water should be substantially free from the presence of toxic algae or
 contaminated sediments, which result from human activities and which threaten
 human health through dermal exposure.  Also free from bacteria, fungi, or
 viruses that may produce enteric disorders or eye, ear, nose, throat, and skin
 infections.
                                                                        32

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Degradation of aesthetics
Aesthetics (aesthetically
pleasing, natural balance,
public access)
When the waters are devoid of any substance that produces a persistent
 objectionable deposit, unnatural colour, turbidity, or odour (eg., oil slick,
 surface scum).
Oil and petrochemicals should not be present in concentrations that can be
 detected as visible film, sheen or discolouration on the surface, detected by
 odour, or form deposits on shorelines and bottom sediments.
To address turbidity, waters should be free from substances attributable to
 municipal, industrial or other discharges resulting from human activity that will
 settle to form putrescent or otherwise objectionable sludge deposits.
Persistence to be defined as in eutrophication, in terms of spatial and temporal
 scales.
Degradation of phytoplankton and
zooplankton
Sources of Contaminants (spills,
point and non point sources,
sediments)
Exotics
Ecosystem Health
Ambient water quality meets applicable guidelines for the protection of aquatic
 life.
Delisting targets are met for eutrophication or undesirable algae.
Loss offish and wildlife habitat
Ecosystem Health
Sources of Contaminants
(sediments, exotics)
Delisting shall not occur until appropriate planning has been undertaken on an
 ongoing basis by local, state or provincial, and federal governments. Plans shall
 ensure no net loss of existing habitat.  Where possible, they should address
 restoration of lost habitat and rehabilitation of degraded habitat.  Water quality
 guidelines for fish and wildlife requirements will also be addressed in these
 plans.
Watershed management planning should be completed through the establishment
 of a Watershed Council. Plans should include the same goals as listed above.
Agreements related to water flow regimes on the St. Marys River linked to fish
 and wildlife needs will be negotiated and adhered to.
Control programs as  identified in Fish & Wildlife Management Procedures and
 Practices should be established for the protection and maintenance of habitat
 from invasion and colonization of exotic species.
Ambient air quality
Sources of Contaminants (point
sources)
Local sources of air emissions should be at levels that meet the most restrictive
 regulatory standards for human health. (Note: ambient air quality is not
 recognized as a formal use impairment).
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likely require corresponding changes to the monitoring activities. It is recommended, therefore,
that a workshop session, or series of sessions also be convened to establish the necessary
coordination between the overall monitoring strategy and the revised delisting criteria resulting
from Action MNG-1. The resulting changes to the monitoring strategy, furthermore, should be
carried out in accordance with the principals set forth in Chapter 2 of the Four Agency
Compendium of Position Papers (see section 1.2).

Recognizing the close connection between monitoring and delisting, the two series of workshops
should be closely coordinated and attended by the same people, i.e., experts designated by the
Four Agencies, BPAC members, First Nations representatives, those involved in managing RAP
related activities, and any other interested stakeholders who may wish to attend.

The documentation from the two series of workshops should be included in a "Stage 2 Update,"
along with the revised delisting criteria, as part of the Stage 2 Implementation Annex.
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4.0 POINT SOURCE POLLUTION - RESTORATION AND PROTECTION
                     STRATEGIES FOR AIR AND WATER

The primary focus of the Point Source Task Team was to prioritize and identify sources of
pollutants, and to recommend remedial actions for point source discharges not currently
effectively addressed by control programs in place. The task team defined point source
discharges as either pipes or tributaries leading to the St. Marys River.  Objectives addressed by
the group were to apply and enforce the most stringent standards to all point source discharges
to the AOC via air, land, and water; and to make progress towards the implementation of best
available technology for the treatment of municipal sewage and industrial waste (including
separation of storm and sanitary sewers).

Using a facilitated workshop process, the task team completed the following activities:
       •     Ranked contaminants of concern in the St. Marys River based on impaired
             beneficial uses and RAP objectives (Table 4.1).
       •     Reviewed point source discharges for guidelines that had been exceeded and
             prepared a table of current point source loadings to the St. Marys River for
             contaminants of concern (see Tables 2.2 and 2.3).
       •     Reviewed current controls and standards for point sources (sec. 4.1).
       •     Developed draft recommendations for point source discharges (sec. 4.3).

The findings of the task team indicate that industrial (Algoma Steel Inc., St. Marys Paper Ltd.)
and municipal (Ontario Water Pollution Control Plants, Michigan Waste Water Treatment
Plant) point source discharges contribute significant loadings of contaminants to the St. Marys
River AOC, even though (with one exception) they are meeting their regulated discharge limits,
as shown by Tables 2.2 and 2.3. Nine beneficial use impairments have been associated with
point source loadings: degradation of benthos, dredging restrictions, ambient water quality,
aesthetic impairment, fish consumption advisories, eutrophication, fish tumours, beach closings,
and degradation of fish habitat.


Table 4.1. Ranked contaminants of concern in the St. Marys River based on impaired beneficial
uses and RAP objectives (Point Source Task Team 1994).
          Contaminant of Concern
Beneficial Use Impairment(s) Associated with
              Contaminants
 1. Polycyclic aromatic hydrocarbons (PAHs)
     degradation of benthos
     restrictions on dredging activities
     beach closings
     fish tumours and other deformities
     degradation of fish and wildlife populations
     ambient water quality
                                         35

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          Contaminant of Concern
Beneficial Use Impairment(s) Associated with
               Contaminants
 2. Heavy metals (cadmium, copper, chromium,
 iron, lead, manganese, nickel, zinc)
 3. Oil and grease



 4. Cyanide



 5. Mercury

 6. Phosphorus



 7. Benzene, toluene, and xylene (BTX)




 8. Phenols


 9. Arsenic

 10.  Ammonia

 11.  Bacteria



 12.  Polychlorinated biphenyls
 13.  Biochemical oxygen demand (BOD)
 14.  Solids
      degradation of benthos
      restrictions on dredging activities
      ambient water quality

      degradation of benthos
      restrictions on dredging activities
      degradation of aesthetics

      degradation of benthos
      restrictions on dredging activities
      ambient water quality

      restrictions on fish consumption

      restrictions on dredging activities
      eutrophication or undesirable algae
      ambient water quality

      degradation of benthos
      restrictions on dredging activities
      ambient water quality
      fish tumours and other deformities

      degradation of benthos
      ambient water quality

      degradation of benthos

      ambient water quality

      restrictions on dredging activities*
      ambient water quality
      beach closings

      degradation of benthos
      restrictions on dredging activities
      degradation of fish and wildlife populations
      restrictions on fish consumption

      ambient water quality
      loss of fish habitat

      degradation of aesthetics
      ambient water quality
* Provincial dredging regulations do not include restrictions related to bacteria.


4.1 Regulatory Programs

A number of regulatory programs, guidelines, and agreements are in place or under development
                                             36

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at the Federal, State, and Provincial levels to maintain and enhance the environmental quality of
the St. Marys River. These regulations and policies are outlined below.

Ontario and Canada

Point source discharges from Algoma Steel Inc. and St. Marys Paper Ltd. are under regulation
by the Municipal Industrial Strategy for Abatement (MISA). MISA is a regulatory-based
program under the Ontario Environmental Protection Act to control toxic contaminants in
industrial and municipal effluents, initially, through a regulatory component to enforce
technology-based effluent limits.  The program allows the Province to enforce a minimum
pollution control requirement based on the implementation of Best Available Technology
Economically Achievable (BATEA). As treatment technologies advance, the minimum
requirements are adjusted, working towards the goal of virtual elimination of persistent toxic
contaminants. This is consistent with the policies stated in the Great Lakes Water Quality
Agreement as amended in 1987.

St Marys Paper Ltd is also regulated under the Pulp and Paper Effluent Regulations and is
therefore required to conduct environmental effects monitoring (EEM).  In 1992, Environment
Canada and the Department of Fisheries and Oceans put forth an amendment to the Pulp and
Paper Effluent Regulations under the Fisheries Act that requires all mills to conduct
environmental effects monitoring. EEM monitoring will provide a description of the biological
quality of the mill's receiving water.  The receiving water will be monitored every three years to
document temporal and spatial responses of benthic and fisheries communities to improved
effluent quality, as mill upgrades and process improvements are implemented. EEM monitoring
assesses the adequacy of effluent regulations for protecting fish, habitat, and the beneficial uses
of the fisheries resource. Pulp and paper effluent regulations set limits for the discharge of total
suspended solids, biochemical oxygen demand, and acute lethality in mill effluent.

The federal Fisheries Act provides for the protection offish, fish habitat, and human use offish
by prohibiting the discharge of deleterious  substances to Canadian waters frequented by fish.  A
deleterious substance is defined as any substance or water that has been processed or changed
which, if added to the system, would degrade the quality of the water such that it is rendered
harmful to fish or fish habitat.

Michigan and the United States

Point source discharges to Michigan surface waters are regulated by the National Pollution
Discharge Elimination System (NPDES). The United States Environmental Protection Agency
(U.S. EPA) has delegated the responsibility to issue surface water discharge permits to the
Michigan Department of Natural Resources under the authority of the federal Clean  Water Act.
The U.S. EPA has also delegated regulation of most air pollution point sources to the state of
Michigan under the Clean Air Act. The EPA retains regulation of point sources on Tribal Lands
in the St. Marys River watershed.
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As a non-regulatory measure, the U.S. EPA Office of Water encourages all citizens to learn
about their water resources and supports volunteer monitoring programs.  The data produced by
the volunteer programs is used to characterize watersheds, screen for water quality problems,
and measure baseline conditions and trends.
4.2 Restoration and Protection Measures Completed or In Progress

Combined Sewer Overflows

The city of Sault Ste. Marie, Michigan has made a $25 million commitment to eliminating the
combined sanitary and stormwater sewers in its wastewater treatment system. The project is
split up into two phases, with phase A completed at a cost of $8 million and resulting in the
closure of two combined sewer overflow outfalls. Phase B is presently under way and will
result in the closure of two more outfalls ($6.5 million).  There are seven outfalls remaining to
be closed. Expected completion date for the project is -2020, including improvements to street
and water utilities. This work is funded by the citizens of Sault Ste. Marie, Michigan through
increased sewer rates.

hi 1997, the city of Sault Ste. Marie, Ontario embarked on an aggressive five year voluntary
abatement plan to improve the existing sewage collection system. Furthermore, as described in
section 2.4, additional improvements to the City's wastewater treatment system will be
supported under the Canada-Ontario Infrastructure Program through a new joint project which
will install sewage overflow tanks, make upgrades to increase primary treatment capacity, add
secondary treatment to the East End water pollution control plant and rehabilitate sewers in
areas of high infiltration.

Algoma Steel Inc. (ASI)

Algoma Steel Inc.'s  main filtration plant, treating 320,000 m3/d of effluent, was commissioned
in 1990 at an approximate cost of $20 million. Significant reductions in suspended solids, from
4,000 kg/d to 251 kg/d, and phenols, from 250 kg/d to 5 kg/d, were realized.

The restructuring of ASI in 1992 included a Letter of Commitment to $45 million in
environmental improvements to be completed by December 1996.  The agreement demonstrates
the steelmaking company's commitment to environmental projects that address toxicity levels in
process effluent, emissions control, and sediment contamination. ASI will continue to
implement pollution abatement technology in compliance with Ministry of Environment MISA
regulations.

hi April 1998, ASI completed construction of a basic oxygen furnace emissions project ($21
million) and a blast furnace contact water recirculation facility ($14 million). The latter project
eliminates discharge from the blast furnace scrubber by recycling the water back to the gas
                                          38

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cleaning plant.  The procedure reduces ammonia and cyanide levels in the bar and strip lagoon
effluent. ASI has also replaced its existing phenol removal system with a biological treatment
plant ($2 million) that eliminates both phenols and cyanide from coke oven wastes. Coke-
making process water has been treated for fixed ammonia removal since 1996.

ASI initiated an air quality assessment program in 1994 to identify sources of particulates
associated with the northwest corner of the plant. As a result, the company established an air
quality monitoring station to record dustfall and total suspended particulates from the steel
plant. An OMOE monitoring station records emissions of polycyclic aromatic hydrocarbons
(PAHs) and volatile organic compounds. ASI has also implemented a street washing program
for residents near the coke ovens and enhanced dust control measures with the use of dust
suppressants and paving.  Further efforts are required to reduce emissions from the steel making
process.

Construction of a Direct Strip Production Complex (DSPC) was  completed in 1997. The new
mill streamlines hot rolled strip production by transforming liquid steel directly into coiled
product using a continuous process. Ninety seven percent of process water is recycled through a
state-of-the-art water treatment plant at the DSPC facility. Minor blowdown volumes are routed
to the main filtration plant for treatment.

In addition, Algoma Steel has recently renewed its environmental commitment by signing a
three party Environmental Management Agreement (EMA) with  Environment Canada and the
Ontario Ministry of Environment (see section 1.4 and appendix 2).

St. Marys Paper Ltd.

An activated sludge secondary treatment facility (~$14 million) was completed in 1995 resulting
in a reduction in biochemical oxygen demand (BOD), from 4,630 to 411  kg/d, and suspended
solids, from 2,368 to  1,148 kg/d. The facility meets all provincial and federal effluent
regulations.  St. Marys Paper has also installed scrubbers (1990) to eliminate particulate
emissions from two boilers.

Water Pollution Control Plants

A continuous phosphorus removal system was added to the East End treatment facility in 1989,
resulting in total phosphorus levels below the  1.0 mg/1 requirement (GLWQA 1987). New
sludge handling facilities were also added to the treatment plant at this time to improve the
efficiency of chlorination procedures and to significantly reduce bacterial levels in the discharge.
Despite these improvements, BOD levels still exceed the OMOE secondary effluent guideline of
25 mg/1, and elevated bacterial numbers are present (see Table  2.2). These problems, however,
will be addressed by the recently announced upgrades described in section 2.4, which will be
implemented under the Canada-Ontario Infrastructure Program.
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 The West End plant continues to meet average annual effluent limits for BOD, suspended
 solids, and phosphorus. Effluent from the Michigan Wastewater Treatment Plant complies with
 National Pollutant Discharge Elimination System (NPDES) permit limits and monitoring
 requirements.
 4.3 Restoration and Protection Actions Needed

 In addition to the restoration and protection measures described above, which are either
 completed or ongoing, there are a number of other actions which have been recommended to
 minimize the effects of point source (PS) discharges to the St. Marys River.  Descriptions of
 these actions are given below, along with lists of proposed implementing agencies and partners
 (see list of acronyms at the end of this report). Note that these lists are only proposals and do
 not constitute commitments on behalf of those organizations included within them. The actual
 role to be played by the organizations and the type and  extent of their support (which could
 range, for example, from major funding initiatives to the provision of scientific advice upon
 request) will be delineated in the implementation annex.

Action PS-1: Virtual Elimination
Implementing Organizations: EC, USEPA, OMOE, MDEQ, MDNR, DFO, Industry, SSMO,
SSMM
Virtually eliminate all persistent and bioaccumulative contaminants from industrial and
municipal discharge. In this context, it should be noted that the three party EMA signed by ASI,
EC, and OMOE includes among its objectives "the reduction or elimination of specific
substances which are found to be persistent, bioaccumulative and toxic in the environment and
appear in appendix 2 of the 1994 Canada-Ontario Agreement as Tier I and Tier II substances."
Also included among the EMA objectives is "the reduction or elimination of air discharges in the
form of visible and gaseous emissions, which exceed or are inconsistent with existing or
proposed limits or guidelines or are the subject of pollution reports to OMOE."

Action PS-2: Reduce Stormwater Infiltration at East End WPCP
Implementing Organizations: SSMO, 1C, OMOE
With funding provided by the Canada-Ontario Infrastructure Program and the City of Sault Ste.
Marie Ontario, as described in section 2.4, storm water  infiltration to the East End WPCP
collection system will be reduced to prevent sewage bypasses during periods of high runoff. As
recommended in the study by Kauss and Nettleton (1999), the influence of heavy rainfall events
on treatment plant discharge quality and loadings will be minimized through plant capacity
expansion and temporary containment of storm water runoff until proper treatment can be
effected.

Action PS-3: Upgrade East End WPCP to Secondary Treatment
Implementing Organizations: SSMO, 1C, OMOE
The upgrading of the East End WPCP to secondary treatment will be supported under the


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Canada-Ontario Infrastructure Program through the new joint project described in section 2.4.
This upgrade, which was recommended by the Point Source Task Team (1994), will decrease the
impact of the WPCP on the river and could prevent localized algal blooms, sediment
contamination, and public beach closings on Sugar Island.

A study which examined the financial requirements of replacing the East End plant with an
upgraded secondary treatment facility (Zegarac and Muir 2000) determined that the City of Sault
Ste. Marie would benefit from the practice of full-cost pricing of their water, wastewater and
storm water services. According to the study, if prices were to reflect the full cost of these
services (including construction, maintenance and renovation), there would be adequate funding
to upgrade sanitary sewers and treatment plants and to make capital expenditures to help solve
the problems in the East End WPCP drainage area. At the same time, the shift to full-cost
recovery would promote economic efficiency and better communicate the additional costs
associated with  increased demand, while lifting the burden on general revenues.

Action PS-4: Relocate Discharge Pipe at East End WPCP
Implementing Organizations: SSMO, 1C, OMOE
The East End WPCP discharge pipe should be relocated to deeper, faster moving water in the
Lake George Channel in order to improve the dispersion of the discharge plume (Kauss and
Nettleton 1999).

Action PS-5: Contaminant Source Control
Implementing Organizations: SSMO, SSMM, EC, OMOE, USEPA, MDEQ, MDNR, Industry
Contaminants in storm water discharge systems (U.S. and Canada) should be addressed by
source control, air quality control, and pollution prevention education programs for business,
industry, and the public (Point Source Task Team 1994).

Action PS-6: Continue with Canadian and U.S. Regulatory Programs for Industrial Dischargers
Implementing Organizations: EC, DFO, OMOE, MDEQ
Canadian regulatory programs (e.g., Fisheries Act, Pulp and Paper Regulations, and MISA) and
U.S. programs such as NPDES provide sufficient point source control for the steel mill, paper
mill, and the U.S. waste water treatment system under present plans. Plans should be re-
evaluated every five years for effectiveness (Point  Source Task Team 1994).

Action PS-7: Encourage Major Point Source Dischargers to Continue Process Improvements
Implementing Organizations: EC, OMOE, MDEQ, MDNR, SSMO, SSMM
The major industries and municipalities serving as point source dischargers to the AOC should
be encouraged to continue with voluntary process improvements. Post-implementation
monitoring will  provide the necessary information to determine whether process modifications
continue to have a positive effect in the St. Marys River.
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Action PS-8: Continued Work on CSOs in Sault Ste. Marie Mich.
Implementing Organizations: SSMM, MDEQ
Continued work will be needed on the CSOs in the Sault, Michigan wastewater system.

Action PS-9: Algoma Steel to Limit Discharges from its Dekish Operation
Implementing Organizations: Algoma Steel, OMOE
Algoma Steel has signed a Program Approval with the OMOE to limit discharges from its
Dekish operation, which is an uncontrolled source of particulates associated with iron making.
The program approval is to have the company effect some form of positive control of this source.
Full implementation of controls at this operation is targeted for June 2002.
 4.4 Monitoring

 The following point source monitoring (PSM) actions, some of which are ongoing, have been
 recommended to obtain baseline information, measure compliance, and to assess the
 effectiveness of remedial actions. Lists of the proposed implementing agencies and partners are
 given beneath the title of each recommended action (see list of acronyms). Note that these lists
 are only proposals and do not constitute commitments on behalf of those organizations included
 within them. The actual role to be played by the organizations and the type and extent of their
 support (which could range, for example, from major funding initiatives to the provision of
 scientific advice upon request) will be delineated in the implementation annex.

 Action PSM-1: Long-Term  Water Monitoring at the Cannelton Industries Site
 Implementing Organizations: USEPA
 Upon completion of the remedial action at the Cannelton Industries Superfund site, water
 quality monitoring was initiated to determine the effectiveness of the remedial action.
 Groundwater and surface water were sampled twice in the first year for the following
 parameters: arsenic, cadmium, chromium IH, chromium VI, lead, mercury, total organic carbon,
 and hardness. Groundwater samples were all below federal standards.  Some of the surface
 water samples exceeded federal standards. The next round of sampling will be completed in
 2003.  During the required 5-year review of the site, which will be conducted in 2004,
 modifications to the water quality monitoring plan will be evaluated.

 Action PSM-2: The Sault Ste. Marie, Michigan Air Quality Monitoring Project
 Implementing Organizations: EC, OMOE, MDEQ, Inter-Tribal Council of Michigan, USEPA
 This is a joint effort undertaken by Environment Canada, Ontario Ministry of the Environment,
 Michigan Department of Environmental Quality, Inter-Tribal Council of Michigan, and the U.S.
 Environmental Protection Agency to deploy an air quality monitoring network in the Sault Ste.
 Marie  area. The project is in response to citizen complaints about orange-brown haze and
 particulate  deposition caused by emissions from Algoma Steel Inc. The network consists of 2
 sites in Michigan and 6 sites in Ontario. In 2001, the two sites in Michigan were established at
 Lake Superior State University and Bahweting School (Figure 4.1). The equipment at these
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sites includes: two PM2.5 filter-based (FRM) monitors and 1 speciation monitor used to
determine ions (sulfate, nitrate, ammonium potassium), elemental/organic carbon, and trace
elements including toxic metals.  This equipment is operated by the Inter-Tribal Council of
Michigan, with laboratory support from Michigan Department of Environmental Quality.  In
addition, the Ontario Ministry of the Environment also operates one continuous mass monitor.
Action PSM-3:  Ambient Water Monitoring in the St. Marys River
Implementing Organizations: MDEQ
The Michigan Department of Environmental Quality is now monitoring ambient water in the St.
Marys River for a number of parameters, including conventional pollutants, metals, and
pesticides.
Action PSM-4: The Sault Ste. Marie, Ontario Air Quality Monitoring Program
Implementing Organizations: OMOE, Algoma Steel
The Ontario Ministry of Environment established an air quality monitoring program in Sault
Ste. Marie, Ontario in the mid 1970s. An air quality index station (Merrifield School, Figure
4.1) records outdoor concentrations of pollutants (sulphur dioxide, total reduced sulphur,
coefficient-of-haze, nitrogen oxides, particulate matter, polycyclic aromatic hydrocarbons,
volatile organic carbons, and dustfall) that may adversely affect human health, animal life,
vegetation, and the use and enjoyment of property.  On an annual basis, the Air Quality Index
(AQI) in Sault Ste. Marie is good to very good 97% of the time. Elevated levels of particulate,
total reduced sulphur, and ozone are the pollutants responsible for the approximately 220 hours
of moderate to poor air quality recorded annually since 1991.

Particulate matter, total suspended solids, polycyclic aromatic hydrocarbons (PAHs), volatile
organic carbons, and dustfall are currently being measured at the Bonney Street site in the west
end of the city (Figure 4.1).  Elevated PAH and particulate levels are a concern in this area.  Both
contaminants are associated with diverse urban sources (eg., vehicle exhaust, wood burning
stoves, barbeques); however, a substantial contribution can be attributed to Algoma Steel Inc.
operations.

Reports summarizing non-compliance with Ambient Air Quality Criteria (AAQC) and
identifying long-term (1979-1994) air quality trends in Sault Ste. Marie, Ontario have been
produced (Olivier and Potvin 1996; Clara and Racette 1996). Quarterly reports on air quality
have been issued since 1998. Data from air quality and meteorology instruments are
supplemented by vegetation, soil, and snow sampling studies.  In general, there has been a trend
of improving air quality in Sault Ste. Marie, Ontario from 1987 to 1994 (Clara and Racette
1996). Ambient concentrations of sulphur dioxide and nitrogen dioxide are well below
provincial AAQC. There are occasional excursions above the AAQC for total reduced sulphur,
ozone, inhalable particulate matter, and total suspended particles. While Algoma is to be
                                           43

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   ALGOMA
     STEEL
      INC.
Figure 4.1. Air quality monitoring sites, Sault Ste. Marie.
71015
71042
71043
71045
Station No.                Location
                 Spadina/Young St.        71046
                 Bonney Street            71068
                 Wilding/Wallace          71080
                 73 Adelaide St.           71081
                                                    Station No.
       Location
Fairview Ave.
Merrifield School
Lake Superior State
Balweting School

-------
commended for improvements that have been realized over the years, further efforts to
characterize the risk to the community at these levels is required, including source identification
and emission reduction (Clara and Racette 1996).

Recognizing this, ASI, in the three party Environmental Management Agreement with EC and
OMOE (see section 1.4), has committed itself to (a) the reduction or elimination of air discharges
in the form of visible and gaseous emissions (including PAHs and benzene), which exceed or are
inconsistent with existing or proposed limits or guidelines or are the subject of pollution reports
to OMOE,  (b) continued discussions on developing an air quality monitoring partnership with
the OMOE, and (c) participation in the discussion and resolution of local trans-boundary air
issues between Sault Ste. Marie Ontario and Sault Ste. Marie Michigan.

Action PSM-5: Monitoring of Paniculate Emissions at Algoma 's Dekish Operation
Implementing Organizations: OMOE, Algoma Steel
As previously mentioned in section 4.3 under Action PS-9, Algoma Steel has signed a Program
Approval with the OMOE to limit discharges from its Dekish operation, which is an
uncontrolled source of particulates associated with iron making.  The purpose of this is to have
the company achieve positive control of these emissions, and this will presumably require some
sort of monitoring. Full implementation is targeted for June 2002.

Action PSM-6: Monitor Receiving Water at St. Marys Paper
Implementing Organizations: St. Marys Paper Ltd., DFO,  EC
Under the EEM program, monitor the receiving water every three years at St. Marys Paper Ltd.
and document response of fish and benthic communities to improved effluent quality as mill
upgrades and process improvements are implemented.

Action PSM-7: Monitoring System for Stormwater
Implementing Organizations: SSMO, SSMM, SSMRCA, EC, OMOE, MDEQ,  MDNR
A monitoring system should be designed and implemented  for storm water, including flows and
concentrations of pollutants of concern (Point Source Task  Team 1994).

Action PSM-8: Monitoring Study to Examine the Short Term Variability and Monthly Ranges
of Contaminant Discharges from Water Pollution Control Plants in the AOC
Implementing Organizations: SSMO, SSMM, EC, OMOE, USEPA, MDEQ, MDNR
Since temporal averaging can mask large levels of short term variability in time sequenced data,
it follows that monthly averages of contaminant discharges  from WPCPs provide an incomplete
basis on which to assess environmental impacts. Studies should, therefore, be carried out which
would monitor contaminant loadings from the water pollution control plants at time scales
sufficiently small to detect any short term elevations which  could pose a hazard to human health
or the environment. These studies should record the short term maxima and the monthly ranges
of contaminant discharges, in addition to the monthly averages, which are already being
computed, and report on any anomalous, hazardous elevations that are observed.
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5.0 RESTORATION AND PROTECTION STRATEGIES FOR SEDIMENT
AND OTHER NON-POINT SOURCES OF POLLUTION

Non-point sources of pollution are diffuse inputs that reach the AOC from multiple points of
origin via natural and anthropogenic delivery mechanisms. These include such things as
atmospheric deposition (see sec. 4.4), intermittent stormwater discharges, groundwater
migration, spills from shipping vessels, and contaminated sediments. The very nature of non-
point source pollutant loads makes assessment of their magnitude and impacts difficult.

Navigation (Spills from Shipping Vessels)
The Canadian locks did not operate between 1987 and 1998 because of structural wall failures.
Following reconstruction and restoration in 1997-98 the lock opened to recreational and small
vessel use in 1999. The majority of river traffic passes through the American locks, with vessels
carrying crude oil, grain, steel, coal, petroleum products, and iron ore between Lake Superior
and industrial centres on the lower Great Lakes.  Spills from shipping vessels can be a
significant source of contamination to the river system.

Contaminated Sediments
The Clean Up and Restoration Task Team's efforts were directed at contaminated sediment
remediation in the AOC. The team prioritized 13 contaminated sites for remediation (Table 5.1)
and developed a list of sediment monitoring programs (sec. 5.4). The sites extended from Point
aux Pins Bay, downstream to Lake George in Ontario waters, and from Tannery Bay to upper
Lake Nicolet in Michigan waters. Recommendations for remedial actions at specific locations,
however, were not completed by the task team.

A sediment survey was conducted by the Ontario Ministry of the Environment in 1992 as part of
a continuing program of environmental monitoring of the St. Marys River. The purpose of the
survey was to update and enhance the Ministry's database on inorganic and organic
contaminants in surficial sediments collected from selected locations in the river and to
determine if sediment contaminant levels were still associated with benthic community
impairment (Arthur and Kauss 1999). Benthic invertebrates are appropriate biological
indicators as they are directly associated with contaminants in sediments through their feeding
and behavioral activities. Some areas of the AOC continue to support benthic communities
reflective of organic enrichment, contaminated sediments, and habitat loss from dredging
activities.

Sediment samples were collected from the Algoma Slip to determine sediment quality, toxicity,
and degree of impairment to benthic invertebrates.  Results indicated that sediments were
marginally to significantly polluted with  elevated levels of inorganics, metals, solvent
extractables (oil and grease), and PAHs (Pope and Kauss 1995).  Severe benthic community
impairment was also evident within the slip. The absence of pollution-intolerant species (eg.,
Hexagenia) reflects the toxic  nature of the sediments relative to the upstream control site in
Pointe aux Pins Bay (Pope and Kauss 1995).  The number of pollution-tolerant invertebrates

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was also low.  Algoma Steel has since removed sediments from the slip during maintenance
dredging operations; however, further sediment quality and benthic community assessments
should be made to determine the effectiveness of contaminant removal (Pope and Kauss 1995).

Table 5.1.  Summary of selected St. Marys River areas requiring clean up and restoration as determined
by surficial sediment quality data (Clean Up and Restoration Task Team 1994). The potential for re-
contamination is reflected in the upstream to downstream order of the site listings. Site ranking is based
on the number of contaminants exceeding Provincial Sediment Quality Guideline (PSQG) lowest (LEL)
and severe effect levels (SEL) at each location.
Location
Point aux Pins Bay, ON
Algoma Slag Dump, ON
Algoma Slip, ON
Bellevue Marine Park area, ON«
East End Water Pollution Control
Plant/Lake George Channel, ON and MI
Bells Point, ON
Little Lake George, ON
Squirrel Island, ON
Ojibiway Trailer Park beach, ON
Lake George, ON and MI
Cannelton Dump, MI
Sault Ste. Marie, MI
Lake Nicolet, MI
# of contaminants
exceeding PSQG LEL
3
29
30
30
29
18
28
0
0
24
8
18
8
# of contaminants
exceeding PSQG SEL
0
5
3
6
1
2
0
0
0
1
1
1
1
Rank*
11
3
1
2
4
7
5
12
13
6
A
B
C
* Michigan and Ontario sites were ranked separately as alpha and numerical values respectively.
 «The site around the old government dock (now Purvis Marine dock) is very contaminated with wood waste and oil
 and grease (S. Greenwood, pers. comm.). At one time there was an oil and gas storage tank farm at the dock area
 and oil tankers still dock to discharge fuel into a pipeline.  Therefore, the Bellevue Park site encompasses the river
 bed up to and including the dredged channel into the government dock.
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Sediment and benthic invertebrate samples were also collected from the Bellevue Marine Park
area of the St. Marys River as part of this ongoing aquatic environmental assessment program
(Kilgour and Morton 1998). The primary objectives were to determine the spatial variation in
benthic community composition in the river and to ascertain whether distribution was affected
by sediment characteristics (ie., contaminants, particle size, etc.). The study also examined the
change in community composition between 1968 and 1995 to determine if benthic communities
reflected or suggested improvements in water and sediment quality.

Results indicated that sediments in this area are still significantly contaminated with metals, oil
and grease, petroleum hydrocarbons (TPHs), PAHs, and nutrients. Although there have been
improvements in sediment chemistry and benthic community composition since 1987,
concentrations of metals, nutrients, and PAHs are still in excess of Provincial Sediment Quality
Guideline lowest effect limits (Kilgour and Morton 1998). Variation in benthic community
composition was associated with variation in metals, nutrients, oil and grease, and physical
sediment conditions (ie., percentage of silt and very coarse-fine sand) (Kilgour and Morton
1998). Consequently, the benthos remains impaired relative to pristine reference locations (eg.,
Pointe aux Pins Bay).

According to Murphy (2000), there are places in the Bellevue Marine Park region where
contaminated sediments are meters deep.  Although it is possible that a surface cap of less toxic
sediment is forming, it is also likely that the production of gases in deeper sediments will at
times continue to lift masses of wood fibre and oil to the surface. In fact, such masses, up to
500L in volume and containing volatile naphthalene, have been observed floating in the area
(Murphy, 2000).  Furthermore, it is not clear that the risks posed by dermal exposure to these
floating masses have been thoroughly assessed.  Hypersensitive/ allergic reactions from minor
exposure to these types of sediments can be very serious. Skin irritations were observed by
Environment Canada staff sampling these sediments in the Sault, and two  serious hypersensitive
responses occurred with similar contamination in Hamilton Harbour. It is suggested, therefore,
that local health authorities determine if the recreational activities (e.g., swimming, boating,
windsurfing) in the region of the Bellevue Marine Park,  and downstream from it, are likely to
bring members of the public into dermal contact with these  contaminated floating masses, and if
so, to determine the health risks posed by such contact. If these risks are significant, it is
recommended that the local health authorities take whatever actions are necessary to protect the
public.

Sediments near the Algoma Slag Dump, a disposal site covering approximately 400 ha above
the St. Marys Falls, were also sampled as part of the sediment contamination and biological
monitoring assessment program. Sediments at many sampling locations contained elevated
concentrations of organic  carbon, arsenic, cyanide, several heavy metals, and PAHs (Kauss
1999a).  Contaminant levels were generally higher at the sampling locations near the Algoma
Slip area. Arsenic, cadmium, chromium, copper, iron, lead, manganese, nickel, zinc, PAHs, and
total organic carbon concentrations exceeded respective Provincial Sediment Quality Guideline
lowest effect levels at the  majority of stations sampled (Kauss 1999a). Arsenic, iron,
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manganese, zinc, and total organic carbon also exceeded severe effect levels at some locations.
In addition, levels of available cyanide were above the provincial guideline for open water
disposal of dredged material at most stations (Kauss 1999a). Elevated PAH levels were also
noted in caged mussels exposed to sediments along the shoreline (Kauss 1999a).

In 1989, the U.S. EPA examined the extent and nature of sediment contamination at the
Cannelton Industries site. The results indicated that soil, sediment, and tannery wastes at the
site contained chromium, cadmium, lead, arsenic, and mercury. As a result, the site was added
to the National Priorities List, a list of sites that are eligible for study and cleanup assistance
under the Superfund program.
5.1 Regulatory and Other Programs

Ontario and Canada

In Canada, the Federal Fisheries Act is the most significant Federal Statute for the protection of
fish habitat from chemical pollution. The habitat protection provisions of the Act provide for
the protection offish and fish habitat from disruptive and destructive activities and require no
net loss of productive capacity offish habitat.  The Act provides comprehensive powers to
protect fish, fish habitat, and human use offish by prohibiting the deposition of harmful
substances in water where fish are found or on lands that drain into these waters. The Act is
legally enforceable when an impact on fish or fish habitat can be shown, and is administered by
the federal Department of Fisheries and Oceans and by Environment Canada.

The focus of the revised (1999) Canadian Environmental Protection Act (CEP A) is pollution
prevention and protection of the environment and human health in order to contribute to
sustainable development. The federal Departments of Environment and Health have
responsibilities under this legislation.  Enforcement officers may issue an environmental
protection compliance order to prevent a violation from occurring, to put an  immediate stop to a
CEPA violation, or to require action to be taken to correct a violation.  The compliance order is
designed to restore an alleged offender to compliance with the Act as quickly as possible.

In Ontario, Provincial Sediment Quality Guidelines for Open Water Disposal of Dredged Spoils
have been established for the protection of aquatic life and to address the significance of
sediment contaminants in-situ.  This policy is specially designed for disposal of contaminated
sediments where dredging is proposed.

The Ontario Water Resources Act and the Environmental Protection Act provide limited
controls for urban and rural/agricultural runoff. Stormwater Quality Guidelines, developed
jointly by the Ontario Ministries of the Environment and Natural Resources, address the need
for stormwater quality management.  These guidelines apply to new developments only.
Stormwater drainage plans and management practices are encouraged through  the Ontario
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Drainage Management Program with funds for municipal stormwater abatement provided
through the Ministry of the Environment's Pollution Control Planning Program.

Michigan and the United States
The Non-point Source Management Program was established by the 1987 Clean Water Act
Amendments. The program provides states and tribes with grants to implement non-point source
pollution control measures described in approved pollution management plans.

The U.S. Environmental Protection Agency (EPA) is implementing a national initiative, the
Clean Water Action Plan, in cooperation with the U.S. Department of Agriculture. The plan
takes a cooperative approach to restoring and protecting water quality where federal, state,
tribal, and local governments work with interested  stakeholders to (1) identify watersheds not
meeting clean water goals, and (2) work cooperatively to focus resources and implement
effective strategies to alleviate watershed problems.

The Michigan Department of Environmental Quality is  administering funds from the Clean
Michigan Initiative to restore and protect land and water in Michigan.
5.2 Restoration and Protection Measures Completed or In Progress

Navigation:  The U.S. Army Corps of Engineers regularly samples the main navigation channel
for contaminants before maintenance dredging operations.  No recent problems with
contamination have been found in the channel.

Chemical Injection Treatment of Contaminated Sediments: A chemical injection system was
developed as part of a pilot test to treat contaminated sediments in the St. Marys River. The
system was designed to enhance the biodegradation of some organic contaminants by treating
the sediment in situ with ferric chloride or calcium nitrate.  Laboratory and field studies
indicated that ferric chloride injection reduced acute toxicity of sediments by about 75% (Zarull
and Allan 1994). This system has been used successfully in Salem, Mass. (Babin et al. 2001)
and Hong Kong (Babin et al.  1999) to remediate sediments. Two new full-scale projects are
beginning in Detroit and Shing Mun River, China but whether it is effective or less expensive
than other methods is very site specific (Murphy et al. 1995,1999).

Traders Metal Site: The city of Sault Ste. Marie, Ontario, invested $1.98 million to relocate
Trader's Metal from Queen Street to Yates Avenue (January 1995) in an effort to clean up and
beautify the  St. Marys River waterfront.  The move complements the construction of Bondar
Park and the extensive waterfront boardwalk system between the park and the Traders Metal
site, which has been redeveloped for a casino.  Trader's Metal is working with the OMOE
District Office on decommissioning the site. Relocation of Trader's Metal will reduce
contaminant inputs to Fort Creek and ultimately to the St. Marys River.
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Soil Contamination From Atmospheric Deposition:  An ongoing air quality monitoring program
(OMOE) in the vicinity of Algoma Steel Inc. indicated elevated levels of PAH in the air.
Consequently, the deposition of PAH to the terrestrial environment was assessed in 1980 and re-
examined in 1997. In 1980, several PAH compounds exceeded background levels for soils with
concentrations decreasing with distance from the steel plant and with soil depth (Mcllveen
1998). PAH levels were significantly lower in the 1997 sediment collection. The investigation
concluded that PAH compounds are being deposited on and accumulated by soil and vegetation
in the residential community adjacent to Algoma Steel (Mcllveen 1998).  Additional sampling is
required to determine the extent and severity of soil PAH contamination.

The Cannelton Industries Site: The U.S. EPA issued a unilateral administrative order in
January, 1998, directing Cannelton Industries Inc. to remediate the former tannery site. During
June-October 1999, the following clean up activities were conducted at the site:
       •  excavation of 33,000 tons of tannery waste materials and contaminated soils to off
          site solid waste disposal facilities
       •  back filling and regrading as needed to stabilize the site
       •  construction of surface drainage works and shoreline berm to prevent erosion
       •  seeding and mulching to revegetate the site.
The U.S. EPA will conduct long term monitoring to verify that the site is not a threat to human
health and the environment. Deed restrictions will limit future use consistent with wetland
protection regulations.

As previously described in section 2.5, the contamination at the Cannelton Industries site also
includes offshore sediments in Tannery Bay which contain historical deposits of organic
material contaminated with chromium, mercury, lead, cadmium, and arsenic. However, since
the river currents,  except during low water levels, continue to deposit layers of clean sediment
over the contaminated organic material, the U.S. EPA approved a natural remedy that would
leave  the contaminated sediments in place, allowing natural processes to gradually bury them
with layers of clean sediment.  Long term monitoring, however, will be required to verify that
erosion processes  during the low water periods are not reversing the natural recovery processes
which occur during the high water periods (see Action NPSM-2).  hi addition, a long term
biomonitoring program (see Action NPSM-3) will be needed to measure the biological uptake
levels of the contaminants in the sediments. If these monitoring programs reveal that "natural
remediation" is not having the desired results, then additional remediation will be needed.
5.3 Restoration and Protection Actions Needed for Non-Point Sources (NPS)

Besides the ongoing and completed measures described in the previous section, a number of
additional restoration and protection actions have also been recommended to minimize the
effects of non-point sources (NPS) on the St. Marys River.  Recommendations have also been
made for a number of pre-implementation, base-line assessment actions essential to the planning
and execution of these restoration measures. Although these assessment activities have strong

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monitoring components, they are also essential prerequisites for the sediment remediation
activities described below, and for this reason have been included in this section rather than the
next one. Descriptions of all these remediation and assessment actions are given below, along
with lists of the proposed implementing agencies and partners (see list of acronyms at the end of
this report). Note that these lists are only proposals and do not constitute commitments on
behalf of those organizations included within them. The actual role to be played by the
organizations and the type and extent of their support (which could range, for example, from
major funding initiatives to the provision of scientific advice upon request) will be delineated in
the implementation annex.

Action NPS-1: Development of a Multi-Agency Sediment Management Program
Implementing Organizations: EC, OMOE, Industry, SSMRCA, and those listed under Action
NPSM-4
The most important of all the non-point source remediation activities is the development and
implementation of a Multi-Agency Sediment Management Program for the St. Marys River
system. This would be a long term program which would include the wide scope of planning,
remediation, and monitoring activities described in the following list, many of which are
touched on elsewhere in this report.  It should be noted that this list includes a number of
recommendations contained in the IJC's 1998 status assessment, and several that were identified
by the Clean Up and Restoration Task Team as described in section 5.4.

a) The sediment mapping in the St Marys River system should be continued until all significant
   zones of contaminated sediment, including those in the "down river regions," have been
   included in the survey.   Once these zones have all been located and identified, they should
   each be characterized, if they haven't already, by determining their spatial distribution and by
   identifying and quantifying the contaminants within them.  The  identification would be done
   using the most current benthic, toxicity, and sediment chemistry studies (see Actions NPS-2
   and NPS-3 below). The zones should also be ranked on the basis of toxicity and/or
   degradation of benthos.
b) Using the monitoring data described above, develop a consistent, scientifically defensible,
   and publicly acceptable decision-making framework that will identify remediation options
   and provide a logical basis to guide community-based management decisions on sediment
   remediation within the AOC (Krantzberg,  1998). This framework would contain, for
   example, the decision criteria used in identifying which zones require remediation and which
   remediation options are most appropriate for each zone. It would also provide the logical
  justification for these criteria and identify all of the data requirements needed for their
   application, thereby guiding decision making  and providing the  public with the means to
   understand and participate in the management process. Using available data, the framework
   would identify the  range of remediation and disposal options for each site  and would identify
   what additional information is needed to choose between them.  Then, once this information
   has been obtained, it would guide the final selection of the most appropriate option (e.g.,
   dredging, in situ treatment, capping, etc.).
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c) Once the final options have been selected in consultation with the public, implementation
   would be carried out with agency support and would be guided by precisely defined,
   numerically quantified objectives developed by the sediment management teams and
   incorporated into the delisting criteria (see management Action MNG-1).  These objectives
   would define the completion-point for both implementation and ultimate remediation, and
   would be the focus of appropriate monitoring activities, as described under item (h) below.

d) To prevent additional  accumulation of contaminants, and also their re-accumulation
   following remediation, it would be necessary to implement, prior to sediment remediation, a
   strategy to identify and control all major point and non-point sources of contaminant loadings
   to sediments within the St. Marys River system.

e) The identification of contaminant sources, as described in item (d), would require a
   monitoring program that would track water and sediment quality at stations above, at, and
   below major dischargers, with the downstream limit for stations extending to the point of
   near-background conditions (1JC, 1998).  It would also require the monitoring of any non-
   point sources (and tributaries) which may be contributing contaminants to the waterways
   within the AOC. The control measures, referred to in item (d), for point and non-point
   sources would include process upgrades at industrial and municipal facilities, cooperative
   environmental management agreements between industry and government, enforcement of
   government regulations, and the measures described below under Action NPS-6.

f) There would also be a requirement to  monitor and control any resuspension of contaminants
   that may occur during sediment remediation activities (see Action NPSM-4c) or during the
   dredging of navigation channels (see Action NPSM-4d).

g) Atmospheric inputs of persistent toxic substances to the waters and basin of the River would
   also need to be tracked (IJC, 1998;  see also Action NPSM-4a).

h) Appropriate monitoring of remediation, both short-term and long-term, would be a vital
   component of the sediment management program. The short term monitoring would track
   progress toward the immediate implementation objectives, whereas the long term monitoring
   would track ecosystem response to the remediation and control measures and the ultimate
   effectiveness (or ineffectiveness) of these measures in meeting the delisting criteria. These
   monitoring activities,  therefore, would provide the necessary information for adaptive
   management decisions on any changes or additions which may be required in the remediation
   strategy in order that it meet its designated goals.

i) The management program should also incorporate the benefits afforded by advancing
   technology. Thus, for  example, remedial actions previously considered necessary but
   unrealistic, should be  initiated once new technology makes them feasible, provided the
   necessity of these actions is still supported by current monitoring data and decision criteria.
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j) All the above monitoring and remediation activities, furthermore, should be fully coordinated
   with those of the Lake Superior LaMP (IJC, 1998) and those of the various RAP task teams.
   Furthermore, since Lake Huron is downstream from the St. Marys River, they should also be
   coordinated with those of the Lake Huron Binational Initiative.

Primary responsibility for Action NPS-1 is to be shared jointly by Environment Canada and the
Ontario Ministry of the Environment, with the cooperation of local industry.
Action NPS-2: Further Characterize Several High Priority Areas
Implementing Organizations: EC, OMOE, industry
While there is a significant amount of information about sediment quality in a number of areas,
there still remains a requirement to further characterize several high priority areas including the
area adjacent to the slag dump, the East End Water Pollution Control Plant, the Algoma Slip,
and Little Lake George. It is hoped that the information necessary to carry out this
characterization of high priority areas will be provided by the study described below in Action
NPS-3.  These two actions are consistent with the recommendations of the Clean Up and
Restoration Task Team and will provide important information for the successful completion of
Action NPS-1 a.
Action NPS-3:  Completion of the St. Marys River Contaminated Sediment Zones Evaluation
Implementing Organizations: EC, OMOE
A St. Marys River Contaminated Sediment Zones Evaluation (Kauss 1999b) was conducted (fall
of 1999) to determine the extent and severity of sediment contamination from the Algoma Slag
Dump, Algoma Slip, and a portion of the Lake George Channel downstream of the East End
Water Pollution Control Plant. The Point aux Pins Bay area was also sampled.  Benthic
invertebrates were also sampled at these locations. Sediment chemical analysis is  under way,
and support has been provided by the Government of Canada's Great Lakes Sustainability Fund
for the analysis of the benthic samples and an interpretive report, the draft version  of which was
completed in September 2001. The final version of this report should receive high priority so as
to make further recommendations for sediment remediation. The culmination of this study is an
important prerequisite to the successful completion of Action NPS-1 a.

Action NPS-4: Identification and Control of Contaminants from the Algoma Slag Dump
Implementing Organizations: Algoma Steel, EC, OMOE
It is extremely important that contaminants originating from the Algoma Slag dump be
identified and controlled to prevent continuing adverse impacts on the St. Marys River AOC.

a) In an effort to identify and quantify the impacts resulting from groundwater seepage, ASI has
   made a commitment in the three party EMA to continue a program of monitoring the landfill
   site to assess trends in groundwater quality. The groundwater monitoring will be conducted


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   on a four-year cycle commencing in 2001 and again in 2005. The results of the monitoring
   will be included in the first semi-annual report following completion of the studies as
   required in section 7.1 of the EMA. ASI has also committed to continue its efforts to reduce
   the overall load of material sent to the landfill for disposal and to develop and implement a
   suitable long-term plan for the waste disposal site describing its site operations and closure.
   The plan will be submitted to OMOE and EC as part of the February 1, 2002 semi-annual
   report. The executive summary of this, and other semi-annual reports, may be found on the
   Internet at the URL provided in section 1.4.

b) It is also necessary to minimize the impact of contaminated sediments adjacent to the landfill
   site. Although actions were taken in 1993 to stabilize the shoreline along the slag dump, there
   is relatively little shoreline stability in some areas.  It is therefore recommended that action be
   taken, wherever necessary, to stabilize the shoreline and nearshore sediments of the slag
   dump (see Eberhardt, 2000).  See also Action FF-9.
Action NPS-5: Evaluation ofAlgoma Slip Sediment and Implementation of Clean-up
Implementing Organizations: Algoma Steel, EC, OMOE
The Algoma Slip sediment quality and quantity needs to be evaluated from an environmental
perspective and remediated as required.  This need is addressed in the three party EMA signed
by ASI, EC, and OMOE, which includes among its objectives "the de-listing of the 'beneficial
use impairment' associated with the ASI boat slip as identified in the Stage 1 report for the
Remedial Action Plan (RAP) for the St Marys River." To achieve this, Algoma has agreed to:
(a) assess sediment contamination and submit a clean-up plan to OMOE in its Feb 1, 2001 semi-
annual report, and (b) complete the clean-up and submit a summary report to OMOE in its first
semi-annual report following completion of the work (see the Internet site provided in section
1.4).
Action NPS-6: Control of Agricultural and Other Non-point Sources of Pollution
Implementing Organizations: EC, USEPA, AAFC, OMAFRA, OMOE, MDEQ, Local Farming
                           Community
As recommended under monitoring Action NPSM-8, comprehensive studies should be carried
out within the AOC to monitor agricultural runoff and other non-point sources of pollution such
as road runoff into tributaries.  Using the results of these studies, suitable measures  to control
these non point sources should be designed and implemented (see also actions FF-1 and FF-4).
Examples of such control measures, might include, for example (depending on the results of
Action NPSM-8):
       a) limiting livestock access to surface waters,
       b) proper management of manure piles and milkhouse waste disposal systems,
       c) restoring and stabilizing stream banks to reduce erosion,
       d) extending buffer strips along drainage ditches and streams, and
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       e) providing education and financial support to farmers to facilitate the implementation
          of these and other proper farm management practices.

Suitable criteria controlling and implementing these measures will need to be developed.

Action NPS-7: Remediation for Contaminated Terrestrial and Aquatic Disposal Sites
Implementing Organizations: EC, USEPA, OMOE, MDEQ, HC, Local Health Authorities
If the monitoring initiated under Actions NPSM-9 and NPSM-12 determines that contaminated
terrestrial or aquatic disposal sites within the AOC (i.e., those not already adequately covered by
previous site-specific recommendations) are a danger to public health or the health of the
ecosystem, then appropriate reporting and remedial actions should be taken to alert the public
and rectify the situation. Measures should be taken to ensure that all hazardous contaminants
are properly isolated and disposed of in a manner which is harmless to human health and the
environment. Where appropriate, aquatic disposal sites, should they be found to exist,  would be
remediated under the sediment management program described in Action NPS-1. Enforcement
measures should also be initiated wherever warranted.

Action NPS-8: Plan and Implement Appropriate Remediation, Protection, and Enforcement
Actions to Remove Any Potential Public Health Risks Identified by Action NPSM-10
Implementing Organizations: EC, USEPA, OMOE, MDEQ, HC, Local Health Authorities
If the information obtained from monitoring action NPSM-10 confirms the existence of real or
potential health risks to the smaller communities taking their water from the "down-river"
regions of the St. Marys River system, then appropriate remediation, protection, and
enforcement actions should be implemented to rectify the situation.  These actions would
include, but would not be limited by, those related actions described elsewhere in this Stage 2
Report. If it is determined, on the basis of information provided by  Action NPSM-10, that those
actions are insufficient, then additional remediation, protection and  enforcement actions should
be planned and implemented as required.
5.4 Monitoring

The following non-point source monitoring (NPSM) actions have been recommended to assess
the need for new remedial actions and the effectiveness of those actions already under way. A
list of the proposed implementing agencies and partners is given beneath the title of each
recommended action (see the list of acronyms at the end of this report). Note that these lists are
only proposals and do not constitute commitments on behalf of those organizations included
within them. The actual role to be played by the organizations and the type and extent of their
support (which could range, for example, from major funding initiatives to the provision of
scientific advice upon request) will be delineated in the implementation annex.

Action NPSM-1: Monitoring East End WPCP and Identification of Upstream Sources
Implementing Organizations: EC, OMOE, SSMO

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Further evaluation of the East End Water Pollution Control Plant effluent is required to
determine concentrations and loadings of persistent contaminants exceeding guidelines in Lake
George Channel sediments.  In addition, the relative contribution of upstream sources, including
point and non point sources, and their loadings to sediment contamination in Lake George
Channel and Little Lake George should be investigated (Kauss and Nettleton 1999).  The
information provided by this action should be regarded as contributory to Action NPSM-10.
Action NPSM-2: Aerial Monitoring of the Cannelton Industries Site
Implementing Organizations:  USEPA
In 1998, Cannelton Industries submitted a report entitled "Stability of Tannery Bay Sediments",
which will provide a baseline for monitoring whether sediment erosion is occurring at the site.
hi preparation for the required 5-year site review, aerial photographs will be reviewed to
determine any changes to the shoreline, hi addition, site monitoring will include visual
inspection of the bay  from a boat. Elevations of the top of sediment will be measured at several
established locations  to exclude changes in surface elevation of sediment over time.
Action NPSM-3: Biological Monitoring at the Cannelton Industries Site to Ensure Protection
of the Ecological Food Chain
Implementing Organizations:  USEPA
Biological monitoring of the sediments in Tannery Bay will also be conducted to ensure that the
natural remedial processes described earlier (i.e., capping with clean sediment) are having the
desired effect and will provide the necessary degree of protection to the ecological food chain.
A biological monitoring program has been implemented at Cannelton Industries site, to evaluate
the bioavailability of site contaminants to aquatic organisms and wildlife. A baseline study in
Tannery Bay using caged clams was completed in 1997 by the National Oceanic and
Atmospheric Administration. A second round of biological monitoring was conducted in 2000,
and a third round is scheduled for 2003.  Sampling results will be used during the required 5-
year site review, to determine whether the site remedy continues to provide adequate protection
for human health and the environment.

Action NPSM-4: Task Team Monitoring Recommendations
Implementing Organizations: Listed below, or where indicated.
a) Continue with data collection at air quality monitoring network. [See Actions PSM-2, 4, 5]
b) Determine disposal options for dredged material following Provincial Sediment Quality
   Guidelines for Open Water Disposal of Dredged Spoils.  [EC, OMOE (See Action NPS-1)]
c) Monitor change and impacts of remedial activities. [EC, OMOE (See Action NPS-1)]
d) Establish monitoring program for potential dredging and sediment dispersal within
   navigation channels.  [USACOE, TC, MDEQ, EC, OMOE (See Action NPS-1)]

Action NPSM-5: Re-sampling of River Sediments to obtain Trend Information
Implementing Organizations: EC,  USEPA,OMOE, MDEQ, USACOE

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As part of the long term monitoring program described under Action NPS-l(h), re-sampling of
river sediments should be carried out systematically to obtain trend information on sediment
quality and benthic community status.  The period for re-sampling should be adjusted in
accordance with the number and magnitude of remedial actions which have taken place since
the last sampling time. It has also been recommended that future surficial sediment quality
surveys near the Algoma slag dump should incorporate benthic community assessment (Kauss
1999a).
Action NPSM-6: Benthic, Toxicity, and Sediment Chemistry Studies at Bellevue Marine Park
Implementing Organizations: EC, OMOE
Benthic, toxicity, and sediment chemistry studies using core samples should be continued in the
Bellevue Marine Park area and at reference locations to confirm and document further
improvements in water and sediment quality (see also Action NPSM-7). If improvements
continue to occur, then further remediation may not be necessary (Kilgour and Morton 1998).
Action NPSM-7: Assess Potential Health Risks Resulting from Floating Contaminated Masses
Implementing Organizations: Local health authorities, HC
Determine if the recreational activities (e.g., swimming, boating) in the region of the Bellevue
Park, and downstream, have a significant potential to expose members of the public to dermal
contact with floating contaminated masses.  If so, determine the health risks posed by such
contact. If these risks are significant, take whatever actions are necessary to protect the public.
Action NPSM-8: Monitor Non-Point Sources of Pollution in theAOC
Implementing Organizations: EC, USEPA, MDEQ, OMOE, OMAFRA
Comprehensive studies should be carried out within the AOC to monitor agricultural runoff and
other non-point sources of pollution such as stream bank erosion and runoff into tributaries at
road crossings. Particular emphasis should be given to those regions of the AOC for which there
is a shortage of data. The study should also identify and alert the public to any potential public
health hazards which may result from these sources.
Action NPSM-9: Identify Terrestrial and Aquatic Disposal Sites Transferring Contaminants
into Waterways
Implementing Organizations: EC, USEPA, MDEQ, OMOE, HC
Monitoring should be carried out to identify any terrestrial or aquatic sites (legal and illegal)
which have been used for the disposal of contaminated or hazardous material and which may
have been leaching or otherwise transferring contaminants into the streams, rivers, lakes, and
groundwater within the AOC (see also Action FF-5). Should such sites be found to exist, the
contents of the sites, and the offending contaminants within them, should be identified and their
impacts assessed. If any of these sites are found to pose a real or potential hazard to public

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health or to the ecosystem, the public should be alerted to the nature and magnitude of these
hazards and appropriate remediation and enforcement actions should be taken as described
under Action NPS-7.
Action NPSM-10: Assess Health Risks to Communities and Individuals Taking Their Water
From the "Down-River" Regions of the St. Marys River System
Implementing Organizations: INAC, USEPA, MDEQ, OMOE, HC
The drinking water supplies to Sault Ste. Marie, Ontario and Sault Ste. Marie, Michigan are not
impaired, since they originate either from aquifers or from the unpolluted upstream region of the
St. Marys River near Lake Superior. Some small communities, however, take their water from
regions of the river system which are downstream from the various point and non-point sources
of contaminants within the AOC. Monitoring should therefore be carried out to determine if
these downstream communities are at risk due to water borne contaminants. In particular, it
should be determined if the contaminated sediments located in these "down-river" regions of the
St. Marys River system (e.g., Lake George) pose a potential health risk to the communities
taking water from these parts of the River. Furthermore, it should be determined if there has
been any disposal of contaminated soils and other materials within this part of the river system
which could also pose such a risk (see Action NPSM-9). If any of the above mentioned health
risks are confirmed, then the public should be alerted to these risks and informed of the causes
(see Actions RE-2 and RE-4), and appropriate remediation, protection, and enforcement  actions
should be implemented to rectify the situation (e.g., see remedial actions described in sections
4.3  and 5.3).
Action NPSM-11: Assess the Potential Hazards Associated With Spills from Shipping Vessels
Implementing Organizations: EC, DFO, USEPA, USFWS, MDEQ, OMOE, HC, TC
Studies should be carried out by the agencies, if they have not already done so, to examine the
historical frequency and nature of significant spills from shipping vessels within the AOC, and
to determine the likelihood of major spills occurring in the future. An assessment should also
be made of the potential health and environmental impacts of a major spill, should it occur, and
of the adequacy of the existing prevention and response measures in protecting the public and
the environment.  The public should also be informed of those cargoes which pose the greatest
risk by virtue of their toxicity, bulk, and frequency of shipment. If studies such as these have
already been carried out by the agencies, they should be made available to the public.
Action NPSM-12: Identify Locations Within the AOC Which are Associated With Elevated
Levels of Human Health Disorders
Implementing Organizations: HC, USEPA, MDEQ, OMOE, Local Health Authorities
Studies should be carried out in those regions of the AOC which are near confirmed or potential
sources of hazardous contaminants (e.g., landfills and other disposal sites, abandoned industrial
sites, or sites identified under Action NPSM-9), in order to determine if those who have lived or
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worked in these regions are manifesting elevated levels of health disorders known to be
associated with present or past exposure to toxic substances. The studies should identify
statistical or causal relationships between any observed region-specific health anomalies and the
contaminants known to have been present.  Should such relationships be discovered, then,
depending on their degree of statistical significance, appropriate measures should be initiated
(see Action NPS-7) to address any real or potential public health hazards which might exist.
Wherever warranted, these measures would include (a) restricting public use of the identified
source areas, and (b) ensuring that all contaminants in these areas are properly isolated and
disposed of in a manner which is harmless to human health and the environment. Furthermore,
the results of the above mentioned studies should be made readily accessible to the public and
the local medical community.
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      6.0 RESTORATION AND PROTECTION STRATEGIES FOR
                               FLORA AND FAUNA

The St. Marys River watershed, wetlands, and riparian areas provide habitat for a number of fish
and wildlife species.  While much of the river is unaffected by human influence, other portions
are heavily impaired. Fish spawning and rearing habitat, as well as wildlife staging areas, have
been lost with the construction of navigational structures, hydropower generation, dredging, and
filling activities. Three categories of habitat loss and degradation are predominant in the AOC:
loss of rapids habitat, loss of wetlands, and urban/agricultural degradation of tributary streams.
Beneficial use impairments associated with this loss include degradation offish and wildlife
populations, consumption restrictions, bird and animal deformities or reproductive problems,
and degradation of benthos.

The fish community of the St. Marys River is influenced by cold, oligotrophic Lake Superior
waters that funnel through the dredged shipping channels. Native and exotic cold water and
warm/cool water fish species coexist within the river system.  Commercially important species,
such as whitefish, sturgeon, lake trout, and walleye, are no longer as abundant as they once were
in this river system (Bray 1993). Populations have been impaired by overfishing, introduction
of exotics, accumulation of toxic chemicals, water level fluctuations, and habitat destruction
through shoreline alteration, dredging, and development, including agricultural development
along tributaries.  Invasive exotic species found within the St. Marys River in the past five years
include zebra mussels, three spined stickleback,  spiny water flea, and alewives. The size and
extent of these populations is not yet known; however, their presence has been associated with
the Michigan and Ontario locks.

The St. Marys River is the major contributor of sea lamprey infestation to northern Lake Huron,
where parasitic  lamprey account for an annual mortality of 54% of adult lake trout. Excessive
mortality rates preclude lake trout rehabilitation efforts as well as other Lake Huron fishery
programs (GLFC  1997). The sea lamprey population in the St. Marys River is estimated to be ~
5.2 million (T. Morse, pers. comm.). Sea lamprey control measures are expected to reduce
lamprey populations in Lake Huron and northern Lake Michigan appreciably.

The St. Marys Rapids area supports a productive fishery with excellent recreational fishing
opportunities. Construction of shipping and power canals have decreased the area of the rapids
by at least 50%  from their natural state (Bray 1993). The development has caused a reduction in
total discharge in the rapids area by at least 80%, along with an increase in temporal variability
in flows (Bray 1993). Together, this results in an intermittent dewatering of portions of the
remnant rapids.  In addition, the Little Rapids-Sugar Island and East Neebish Rapids areas have
been lost as a result of navigational dredging. Construction of a causeway culvert system has
reduced flow significantly through the Little Rapids.

Loss of wetland habitat in the St. Marys River, from industrial and urban expansion, has been
most severe along the shoreline of Sault Ste. Marie, Ontario, downstream of the rapids (Bray

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1993). Wetland areas offer warmer water temperatures and greater nutrient availability,
improving the overall productivity of the system. The effect of loss offish habitat in the St.
Marys River may be increased by the destruction of wetland habitat in close proximity to the
rapids area (Bray 1993).

Destruction of the rapids and wetland habitat along the Sault Ste. Marie waterfront has been
extensive and, for the most part, permanent. The infilling of wetlands for urban development
constrains opportunities for restoration as these areas cannot be returned to healthy, productive
habitat. Similarly, losses to the St. Marys Rapids, in excess of 50 ha, are largely unrecoverable.
For this reason, remedial options for aquatic habitat should include: enhancement of remnant
rapids habitat or creation of new rapids or similar habitat; enhancement or creation of wetlands
in association with the remnant rapids or tributaries to the St. Marys River; and, rehabilitation of
tributary streams (Flora and Fauna Task Team Report 1994). Nevertheless, implementation of
some or all of these options will only partially compensate for historic losses to aquatic habitat
in the AOC.
6.1 Regulatory programs

Ontario and Canada
Fisheries Act: As previously described in section 5.1, this Act is the most significant Federal
Statute for the protection of fish habitat from chemical pollution. The habitat protection
provisions of the Act provide for the protection offish and fish habitat from disruptive and
destructive activities and require no net loss of productive capacity offish habitat. The Act
provides comprehensive powers to protect fish, fish habitat, and human use offish by
prohibiting the deposition of harmful substances in water where fish are found or on lands that
drain into these waters. The Act is legally enforceable when an impact on fish or fish habitat
can be shown, and is administered by the federal Department of Fisheries and Oceans and by
Environment Canada.

Federal Food and Drug Act: authorizes Health Canada to establish tolerances for chemical
substances in fish and fishery products intended for human consumption.  These criteria have
been adopted by the Province of Ontario. The Guide to Eating Ontario Sport Fish gives
consumption advice for sport fish from Ontario waters and is published every other year by the
Ministry of the Environment in cooperation with the Ministry of Natural Resources. The Sport
Fish Contaminant Monitoring Program provides information for this guide.

Public Lands Act: restricts activities on or adjacent to crown land.  Anyone wishing to work
along a  shoreline requires an approved work permit. Permits are reviewed by the OMNR,
OMOE, Conservation Authorities, and Transport Canada.

Beds of Navigable Waters Act: a Provincial Act that can be used to restrict alterations to water
courses.
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Planning Act: a Provincial statute giving the Ministry of Municipal Affairs the jurisdiction over
Municipal Land Use Planning in Ontario.  The Act provides an opportunity for organized
Municipalities to produce Official Plans, create bylaws, and approve severances, among other
things. Section three of the Act allows the Province to incorporate Policy Statements that relate
to matters of resource management (eg., Wetlands Policy Statement).

Conservation Authorities Act: flood and fill regulations promulgated under this  act are used by
Conservation Authorities to control or restrict development in the channel and flood plain. The
Sault Ste. Marie Region Conservation Authority issues permits to authorize works within flood
plains, particularly along the St. Marys River.

Canadian Environmental Protection Act: As previously described in section 5.1, the focus of
the revised (1999) CEPA is pollution  prevention and protection of the environment and human
health in order to contribute to sustainable development. The federal Departments of
Environment and Health have responsibilities under this legislation.  Enforcement officers may
issue an environmental protection compliance order to prevent a violation from  occurring, to put
an immediate stop to a CEPA violation, or to require action to be taken to correct a violation.
The compliance order is designed to restore an alleged offender to compliance with the Act as
quickly as possible.

Michigan and the  United States
Clean Water Act: this federal Act regulates the discharge of dredged or other fill material into
navigable waters and their adjacent wetlands.

Wetland Protection part of Michigan Act 451: provides for the preservation, management,
protection, and use of wetland resources. Under this act, the Michigan Department of
Environmental Quality requires a permit to alter wetlands and provides penalties for illegal
wetland alteration.  It also establishes  a permit program to regulate some activities in wetlands
that are above the ordinary high water marks of lakes and streams. The Act establishes a state
policy to protect the public against the loss of wetlands; however, most normal agricultural and
silvicultural activities are exempted from permit requirements.

Inland Lakes and Streams part of Michigan Act 451: requires a permit for dredging, filling, and
construction activities in inland lakes  and streams and associated wetlands below the ordinary
high water mark.

Great Lakes Submerged Lands part of Michigan Act 451: requires a permit for construction
activities in the Great Lakes including the bays and harbours on bottomlands and in the water.
Projects proposed in or near coastal wetlands are usually denied a permit unless  the activity is
necessary to exercise a riparian right of access, such as an open pile dock.

Shorelands Protection and Management part of Michigan Act 451: defines and regulates some
construction in high risk erosion areas, flood areas, and  environmental areas adjacent to the
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Great Lakes and connecting waterways. Also provides for the designation of Environmental
Areas necessary for the preservation and maintenance of fish and wildlife.

Soil Erosion and Sedimentation Control part of Michigan Act 451: requires permit based on soil
erosion control plan for earth change activities that disturb one or more acre or are within 500 ft
of a lake or stream.

Environmental Protection part of Michigan Act 451: requires a finding of no pollution or
destruction of the air, water, or other natural resources by all permitting and licensing agencies,
unless there are no feasible and prudent alternatives.  The Act provides for citizen-based
lawsuits against any individual, company, or government entity in order to protect the air, water,
and other natural resources.
6.2 Restoration and Protection Measures Completed or In Progress

St. Marys Rapids Hydrology Study:
A hydrological study (Environmental Hydraulics Group 1995) estimated the gains in Rapids
habitat that would result from various incremental increases in minimum flow volumes through
the gates at the Compensating Works. Under normal flow conditions (ie., one gate open half
way), it has been estimated that 90% of the Rapids south of the berm would be watered. The
entire area would be submerged for flows greater than two gate openings. Field tests have been
proposed to supplement this hydraulic analysis.  Repairs to the 16 gates have been completed.
The Lake Superior Board of Control did a flow study to confirm model predictions and calibrate
flow for specific gate openings in August 1999.  Results of this study are pending.

The Ontario Ministry of Natural Resources has been working with the agency responsible for
ordering flow changes since 1994 to mitigate effects by supplying appropriate timing for water
level fluctuations (ie., take into account critical life stages for fish and invertebrates) and
expressing concern with flood/drought scenarios (S.  Greenwood, pers. comm.).

Little Rapids Restoration Project:
The Little Rapids at the head of Sugar Island have been occluded by shipping channel
construction and the building of the causeway between the Sugar Island ferry terminal and the
island proper.  The potential for reestablishing a portion of the Little Rapids area by installing a
series of culverts through the Sugar Island causeway was examined by U.S. participants
(MDNR) in the RAP process (Acres International Corporation 1997).  It is anticipated that the
resumption of water flow through the Little Rapids area would provide up to 28 ha of additional
rapids habitat.

Pre-construction assessment of the substrate and fish community in the Little Rapids area has
been completed.  White and redhorse suckers, carp, northern pike, and perch were captured
above and below the causeway (J. Waybrant, pers. comm.). Whitefish and steelhead trout were
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found in the areas of higher flow around the Sugar Island ferry dock. This initial assessment
suggests that increasing the flow in the Little Rapids would enhance the fishery in this area.
Additional surveys are required.

Geozone mapping:
The Flora and Fauna Task Team endeavored to provide options for the protection of existing
fish and wildlife habitat and to encourage the rehabilitation of degraded sites.  To complete this
task, the team developed a series of maps that partition the St. Marys River into manageable
geographic units or geozones. Shoreline features, level of industrial or urban development, and
characteristics of the river, such as rapids, channels, and lakes, define each of the 12 geozones.
Significant habitat types (ie., biozones) that support flora and fauna populations have also been
identified and located  on natural feature, biologically sensitive, and human influence overlays.
The idea is to rank biozones based on their importance to maintaining the watershed of the AOC
and their contribution  to the natural functioning of the ecosystem. From this, monitoring
systems and protection priorities can be established to guide remedial efforts.

Sea Lamprey Control:
Researchers at Clarkson University developed a model to predict the movement and dispersal of
the lampricide TFM in the St. Marys River under a range of flow conditions. The model
suggested that a TFM  treatment would only be effective in the north channel of the River and
not in the Lake Nicolet portion.  A rhodamine dye study was conducted to validate the transport
model. The harmless  dye was applied to the river from the railway bridge upstream of the Great
Lakes Power generating station. The dye study confirmed the model predictions. TFM applied
under similar flow conditions would  be effective in portions of the north channel, resulting in a
35% reduction in the River's sea lamprey population (Schleen 1997). Furthermore, the cost of
treating the St. Marys  River with TFM would exceed the annual budget for lampricide
application in the entire Great Lakes  basin (Schleen 1997). Alternatively, treatments with
granular Bayluscide, a bottom toxicant that would target 'hot spots' or areas of high larval
density, would be more efficient and  cost effective for treatment of the St. Marys River (Schleen
1997).

Consequently, 81 hectares of the river were treated with granular Bayluscide (aerial helicopter
application) in 1998, followed by a much larger treatment  of 760 hectares in 1999. In the plots
treated, an estimated 88% of the larvae present were removed (determined by larval assessments
before and after the treatments). The combined treatments targeted about 51% of the estimated
5 million larvae in the river, resulting in an estimated 45% removal.  The Bayluscide treatment
appeared to have minimal impacts on non-target organisms.

The Great Lakes Fishery Commission encourages integrated control  and development of
alternate (non chemical) lamprey control strategies in an effort to reduce dependence on
lampricides. In the St. Marys River watershed, barrier darns, constructed on the Big Carp and
Echo Rivers, prevent the upstream migration of spawning phase sea lamprey into these
tributaries. Traps in the St. Marys River remove spawning lamprey and supply males for the
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 sterile male-release program. After sterilization, male lamprey are released into the St. Marys
 River (sterile males have been released into the St. Marys River since 1991).  Studies indicate
 that sterile males compete as aggressively as untreated males, wasting the spawning potential of
 female sea lamprey. The number of larvae produced in streams that have a sterile male
 population is reduced (Schleen et al. 1998). hi 1999, traps at the Great Lakes Power and the
 USCOE hydroelectric facilities (both of which have recently undergone improvements), trapped
 56% of the estimated 20,000 spawners in the river.  In 1999, over 26,000 sterile males were
 released, resulting in an estimated 4.7:1 ratio of sterile:normal males.  Together the integrated
 trapping and sterile male releases is estimated to have reduced the theoretical reproductive
 potential by 92%.

The focus of efforts on the river will now be on further enhancement of alternative control
efforts and full implementation of the St. Marys River assessment plan.  The requirement for
future granular Bayluscide treatments will be determined by assessment results.  The focus will
now move to the lake and the observation of the predicted reduction in fish damage beginning in
2000 and reductions in spawning abundance in the St. Marys beginning in 2001.

 Enhanced fish access:
 The Michigan Department of Natural Resources recently bulldozed openings  into the
 Munuscong Bay Waterfowl Sanctuary dyke, allowing free water and fish movement into the
 rich emergent wetland matrix, unattainable by many fish since 1963 (S. Greenwood, pers.
 comm.).

 St. Marys River Fisheries Task Group:
 The St. Marys River Fisheries Task Group,  established under the authority of the Lake Huron
 Technical Committee of the Lake Huron Committee, Great Lakes Fishery Commission, is a
 multi-agency organization with representatives from Michigan, Ontario, Bay Mills Tribe,
 Chippewa/Ottawa Treaty Fishery Management Authority, and First Nations. The role of the
 Task Group is to identify data needs and develop an assessment plan that will give resource
 management agencies the information they need to work towards sustainable fisheries (see, for
 example, monitoring actions FFM-9, 10, and 11 in section 6.4).  The Task Group conducted a
 fish harvest survey of the entire St. Marys River from Whitefish Bay, Lake Superior to Detour
 Passage, Lake Huron and around St. Joseph Island including Potagannissing Bay. Harvest
 information was collected from May to October 1999 for the open water and from January to
 March 2000 for the ice fishery. Results of this study are pending.

Wetland Monitoring at the Cannelton Industries Site'.
The Cannelton Industries site includes a sizable wetland area that borders the St. Marys River.
In order to evaluate the potential for future releases to the wetland area, a monitoring study was
carried out by the Michigan State University prior to the remediation actions described earlier.
The results of the study, will be used to develop long term monitoring and management
requirements for the area.
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6.3 Restoration and Protection Actions Needed

The following actions have been recommended to restore and protect the flora and fauna (FF) of
the St. Marys River ecosystems. A list of proposed implementing agencies and partners is given
beneath the title of each recommended action (see list of acronyms at the end of this report).
Note that these lists are only proposals and do not constitute commitments on behalf of those
organizations included within them. The actual role to be played by the organizations and the
type and extent of their support (which could range, for example, from major funding initiatives
to the provision of  scientific advice upon request) will be delineated in the implementation
annex.

Action FF-1: Bar  River Habitat Project
Implementing Organizations: EC, OMOE, OMNR, OMAFRA, AAFC
It may be possible to contribute to the recovery of the Bar River walleye spawning stock by
mitigating the effects of land use practices (primarily agricultural) upstream of historic spawning
grounds. Ceiling (1998) provided a description of land use practices along the river, identifying
sites prone to erosion, agricultural run off, and sites where livestock have direct access to the
stream.  Remedial options include placement of stabilizing structures, contouring stream banks,
installation of exclusionary fencing, and tree planting.

Approximately 6,900 white cedar seedlings would be required to replant the river bank (ie., one
tree every two metres, two rows deep, for 6.9 km of stream bank) (Ceiling 1998). Exclusionary
fencing would have to be constructed in areas where livestock have access to  the river.
Alternate watering  sources for livestock would also be required.

There are two sections of the Bar River that have been altered, likely to accommodate increased
crop production. These straightened areas with steep banks and no vegetation are highly
susceptible to erosion and elevated water temperatures. Remediation would require contouring
and stabilization of the stream banks and up slope planting of trees (Ceiling 1998).

Action FF-2: Watershed Development Plan for Bennett and West Davignon Creeks
Implementing Organizations: EC, DFO, AAFC, OMOE,  OMNR, OMAFRA, ASI, SSMRCA,
Local Groups
The Bennett and West Davignon Creek system empties into the St. Marys River at the Algoma
Steel boat slip. A Diversion Channel accepts flood waters from both creeks.  A small rural
tributary, Leigh's Bay Creek,  empties into the Diversion Channel.  The Watershed Development
Plan (1998) for this system identifies specific remedial options to address habitat components
and outlines preventative measures required to protect this northern Ontario watershed. This
watershed development plan addresses urban, rural, and industrial  development and is a
proactive approach  to the application of pollution prevention concepts in Lake Superior.
However, since this draft plan has not been submitted for public comments and has not been
approved by any of the stakeholders, it will be necessary for the implementing organizations, in
consultation with stakeholders, to review and revise it as required prior to implementation.


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Table 6.1. Remedial options for habitat protection and conservation of the upper, middle, and lower sections of the Bennett and West Davignon Creek system
(see Action FF-2) as outlined in the Watershed Development Plan. Information required is listed in italics.	
                             Uplands section of the creek system
                             upstream from the Precambrian Shield
                                           Middle section from point where flows are
                                           divided between the natural stream channels
                                           and the Diversion Channel upstream to the
                                           edge of the Precambrian shield      .. •...,,.
                                            Lower section of watershed includes flow-managed
                                            reaches of both creeks, the Diversion Channel, and
                                            Leigh Bay
Fish Habitat Enhancement
and Rehabilitation
no enhancement or rehabilitation opportunities
identified

(a) maintenance of headwater reaches in a
natural state is encouraged
(b) restrict new development within 30m of
shoreline
(c) tree planting in riparian zone
(d) restricting livestock access to stream
         -requires funding source to defray
         costs to landowners
(e) assist passage of migratory salmonids (eg.,
jumping pools below weirs, boulder placement,
refuge creation)
(f) create spawning and nursery habitat for non-
jumping fish between estuary and furthest
downstream weir in the Diversion Channel
(g) naturalization of Diversion Channel
         -stream survey to assess migratory
         pathways, weir design, jumping pools, and
         resting areas
         -habitat and fish community usage study in
         the Diversion Channel from furthest
         downstream weir to the estuary
Groundwater Quality
Protection and
Conservation
no specific protective measures advised as
development is restricted in this area
(h) prevent seepage of petroleum products
from aggregate extraction operations into the
aquifer to protect groundwater quality
 (i) cooperation between Algoma Steel and the OMOE
 in designing and implementing soil remediation
 projects for inactive parcels of land
 (j) Algoma Steel to continue to work with OMOE in
 addressing specific contamination issues as required
 (eg., phenolic seepage into downstream portion of the
 combined channel)
         -requires assessment of soil and
         groundwater contaminant levels on Algoma
         Steel property
Surface Water Quantity
Rehabilitation
-maintenance of natural stream hydrology
-maintenance of natural stream hydrology
 (k) increase habitat quality and migration pathways in
 Diversion Channel with instream modifications
 (1) review of weir and culvert design with respect to
 flow volumes between Diversion Channel and
 Bennett and West Davignon Creeks to optimize use of
 allocated flows
 (m) maintain migratory pathways
 (n) exclude passage of sea lamprey
         -definition of seasonal distribution of flow
         volumes prior to  water reallocation and
	redesign of water management structures
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Table 6.1 continued
Surface Water Quality
Enhancement and
Rehabilitation
(o) protection of natural water quality by
adhering to buffer strip guidelines and
continued restrictions on development
(c) tree planting to enhance riparian buffer
zone
(d) restrict livestock access to stream
(p) provide alternative water sources for
livestock
(q) streambank stabilization
         -identify current land use practices,
         livestock access points, streambank
         erosion, and parcels of inactive
         agricultural land
(r)  reduce elevated bacteria and phosphorus levels
between storm sewer pipe and the receiving water
course through construction of retention ponds or
man-made wetlands
(s) continued wetland development to improve
salmonid staging habitat and provide for waterfowl
and other wildlife
         -options assume that water quality
         impairments upstream from Algoma Steel
         are the result of elevated iron, phosphorus,
         and bacteria levels; therefore, water quality
         sampling is required in the Diversion
         Channel and Mid and Upland sections of
         the Bennett and West Davignon Creeks	
Wildlife and Terrestrial
Habitat Issues
(t) maintenance of riparian buffer zone
contiguous with a forested area of no less than
1,000 ha
(u) reforestation of inactive agricultural lands
         -a guide outlining existing
         reforestation programs and
         strategies for owners of inactive
         agricultural land
(v) tree planting along top of Diversion Channel to
improve aesthetic values and augment songbird
habitat
Wetland Enhancement
(w) enhancement of wetland forming off the mouth of the Diversion Channel including contouring the shoreline of the estuary and planting semi-aquatic
vegetation
         -list of appropriate species for planting
         -identify areas of shoreline in need of contouring
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Table 6.1 provides a summary of the potential remedial options included in the plan. The lower
section of the watershed includes the flow-managed reaches of both creeks, the Diversion
Channel, and Leigh Bay. The middle section extends from the point where flows are divided
between the natural stream channels and the Diversion Channel upstream to the edge of the
Precambrian Shield. The uplands section of the creek system continues upstream from the
Shield.

Action FF-3: Watershed Development Plan for the East Davignon and Fort Creeks etc.
Implementing Organizations: EC, DFO, AAFC, OMOE, OMNR, OMAFRA, ASI, SSMRCA,
Local Groups
A watershed plan similar to Action FF-2 should be developed for the East Davignon and Fort
Creeks, which also pass through urban and industrial lands (P. Kauss, pers. comm.). Sub-
watershed plans should also be developed for Root River, Crystal Creek, and the Big and Little
Carp Rivers, subject to the acquisition of funding.

Action FF-4: Sedimentation Reduction in the Munuscong River/Bay:
Implementing Organizations: MDEQ, MDNR
The Munuscong River is in need of several key non point source pollution control projects to
reduce sedimentation in the river and in Munuscong Bay. The Stirlingville Bridge site and
further upstream at Pickford are two examples where eroding streambanks need stabilization.

Action FF-5: Characterization/Feasibility Study for Waste Removal in Mission Creek:
Implementing Organizations: MDEQ, USEPA
Mission Creek in Sault Ste. Marie, Michigan, has been identified by local residents as having
been a waste dump for many years. The creek still contains a great amount of household waste,
appliances, cars,  containers, and what appears to be waste from former local industries including
the Union Carbide operations. Citizens are requesting that a complete hydrogeological and
waste characterization study be completed including a feasibility study for the removal of waste
and restoration of the natural  flow of the creek (see also Actions NPS-7 and NPSM-9).

Action FF-6: Remediation of Rapids Habitat
Implementing Organizations: DFO, EC, OMNR, TC, MDEQ, USFWS,  USACOE
The Flora and Fauna Task Team examined a number of options for the remediation of rapids
habitat and associated wetlands. The options listed below were designed to restore and
rehabilitate habitat in order to enhance fish and wildlife populations in the AOC. The
implementing organizations will examine all of these options and decide which should be
implemented.

(a)     Protection of remnant rapids habitat
       This option encompasses both the protection of remnant habitat  from further reduction
       and degradation as well as the maximization of the productive capacity of the rapids
       area. In essence, this is a water quantity issue.
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       Water use demands in the rapids area have been prioritized by the International Joint
       Commission (1978) as follows: (1) shipping (ie., lock operation); (2) protection of rapids
       fishery; and (3) other approved uses including hydroelectric power generation. A berm
       was constructed in 1985 to prevent intermittent dewatering of the rapids.  While the
       structure is largely effective, dewatering of portions of the rapids still occurs.  A
       preliminary assessment of the extent of dewatering has been completed (see Rapids
       Hydrology Study above); however, the impact of dewatering on the biotic community
       remains to be examined.

       Fisheries assessment using conventional netting in the rapids area is recognized as being
       either extremely difficult or impossible.  A series of controlled angling efforts would,
       however, identify use of rapids habitat by larger fish.  Conventional sampling gear could
       then be used in the shallow waters around the edge of the rapids to provide information
       on forage fish and the young of some predator species.

(b)     Physical enhancement of remnant rapids habitat
       Berm construction represents the first attempt to enhance the remnant rapids habitat.
       The berm maintains a minimum level of flow along the southern shore of Whitefish
       Island, an area believed to contain some of the best fish spawning habitat in the rapids.
       The area also supports a highly productive benthic invertebrate community. The option
       requires the placement of additional substrate to potentially increase the size and
       productive capacity of the remnant rapids.

       Preliminary assessment would involve mapping existing substrate composition,
       identifying target fish species assemblages, and noting areas likely to become dewatered
       under differing water supply scenarios. This information could then be used to guide
       substrate placement strategies.

(c)     Creation of new rapids areas in  the St. Marys River
       An alternative to enhancing or enlarging the remnant rapids would be to augment rapids
       elsewhere in the St. Marys River (eg., Little Rapids restoration). Areas in the river or its
       tributaries, which have the hydrologic and physical characteristics required to support
       rapids regeneration, need to be identified. Vertical drop, substrate type, streambank
       characteristics, the potential for ice scouring, and flow velocities are factors that must be
       accounted for at each site. Artificial rapids would have to be designed to incorporate sea
       lamprey control mechanisms.

(d)     Creation of alternatives to rapids habitat
       A variety of methods are available to either create artificial spawning substrate or to
       cleanse existing habitat in order to enhance fishery production.  Artificial substrate
       would have to have similar characteristics to a rapids area. A self-cleaning substrate
       system involves directing water into a bed of distribution pipes underlying a man made
       spawning bed, creating an upwelling through the bed. The self-cleaning system is
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       applicable to areas with high fine sediment deposition.

(e)    Creation of wetlands in association with existing rapids
       Wetland creation downstream of Whitefish Island would connect wetland habitat to the
       adjacent remnant rapids. The option would involve depositing suitable fill in the area
       between Whitefish Island and the channel leading to the former Canadian navigation
       lock. Placement of boulders and rock rubble as a buffer against the fast current of the
       rapids would protect the site from erosion. A number of small channels could be
       constructed between the rapids and the new wetland to direct drifting larval fish into the
       wetland area.

(f)     Creation of new wetlands/rapids complexes
       It may be possible to create a simulated rapids area in the Great Lakes Power tailrace just
       upstream from Fort Creek in Sault Ste. Marie, Ontario. Clean rock fill could be added to
       deflect most of the existing current away from the mouth of Fort Creek while the
       remainder of the flow would be directed over the top of the structure. Wetland features
       could be incorporated into the design.

       A series of islands and shoals extending along a band of shallow water on the north
       shore of Sugar Island can also be considered for wetland development. Riffle habitat
       could be created by placing boulder/rubble obstructions to  concentrate river flows over
       suitable gravel/cobble substrates. The lee of these boulder barriers might then
       accommodate wetland development.

(g)    Enhance habitat and water quality in tributary watersheds
       Creating or enhancing wetlands in selected areas of tributary streams would provide a
       range offish and wildlife habitats and would reduce sediment and nutrient inputs to the
       St. Marys River.  Tributary streams provide spawning and  nursery habitat for
       anadromous fish species, forage  fish production, and linkages to terrestrial inland
       habitats.  Removing barriers or impediments to migration,  such as low head barrier
       dams, would also enhance fish production in tributary streams.

(h)    Do nothing
       The Flora and Fauna Task Team recognize that this  option will maintain or increase
       dependence on hatcheries and stocking programs to  enhance fish populations in the St.
       Marys River.

Action FF-7: Develop a 10 Year Fisheries Assessment Program for the River
Implementing Organizations:  DFO, GLFC, OMNR,  USFWS, SMRFTG, ITFAP
Netting survey results (1995) indicated an estimated 51% mortality rate for walleye in the St.
Marys River (Fielder and Waybrant 1998). Northern pike and yellow perch also appeared to be
experiencing very high mortality rates.  High mortality rates for these species, combined with
slow growth rate as a result of the cold, oligotrophic Lake Superior water, and a short growing
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season, should be cause for concern and requires further assessment. Therefore, the St. Marys
River Fishery Task Group (SMRFTG) should continue its efforts to develop a 10 year
assessment program for the river.

Action FF-8: Continued Support for Sea Lamprey Control Efforts
Implementing Organizations: DFO, EC, OMNR, GLFC, USFWS, ITFAP
For a description of these efforts, see section 6.2.

Action FF-9: Stabilize Shoreline of the Algoma Slag Dump to Provide Habitat for Plants
Implementing Organizations: Algoma Steel, EC, OMOE, SSMRCA
Materials have been deposited over the years along the shoreline of the Algoma Slag Dump to
extend the dump and, in the process, encroach upon the St. Marys River. Although actions were
taken in 1993 to stabilize the shoreline along the slag dump, there is relatively little shoreline
stability in some areas and poor habitat for plant growth. Stabilizing these areas and providing a
more hospitable habitat for plants (eg., via soil addition) is required.
6.4 Monitoring - The Flora and Fauna Monitoring (FFM) Actions

The following flora and fauna monitoring (FFM) actions have been recommended to provide
baseline information, identify factors contributing to impairments, and to assess the
effectiveness of the remedial actions. This section also contains a number of monitoring actions
and studies recommended by the St. Marys River Fishery Task Group (SMRFTG) to identify
data needs and develop an assessment plan that will give resource management agencies the
information they need to work towards sustainable fisheries (see actions FFM-9, 10, and 11). A
list of proposed implementing agencies and partners is given beneath the title of each
recommended action (see the list of acronyms at the end of this report). Note that these lists are
only proposals and do not constitute commitments on behalf of those organizations included
within them. The actual role to be played by the organizations and the type and extent of their
support (which could range, for example, from major funding initiatives to the provision of
scientific advice upon request) will be delineated in the implementation annex.

In addition, the Flora and Fauna Task Team (1994) compiled a list of existing monitoring
programs for the St. Marys River AOC which are shown in Table 6.2.

Action FFM-1: Identify the Causes of Fish Tumours and Other Deformities Which Originate
Within the AOC
Implementing Organizations: DFO, USFWS, SMRFTG
Studies should be  carried out, along with any monitoring which may be required, to positively
identify which contaminants originating within the AOC are contributing to Fish Tumours and
Other Deformities. Particular emphasis should be given to those contaminants already
suspected of contributing to the problem (i.e., PAHs in sediments) and to the causes of
deformities which have been observed in Munuscong Bay.

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   Action FFM-2:  Marsh Monitoring Program
   Implementing Organizations: EC-CWS, EC-GLSF, USGLPF
   A Marsh Monitoring Program was established to provide baseline information on marsh bird and
   amphibian populations and their habitat.  This is a cooperative project with the involvement of
   the Long Point Bird Observatory,  Canadian Wildlife Service, Great Lakes Sustainability Fund,
   Table 6.2.  Existing programs to monitor the quantity and quality of habitat capable of
   supporting flora and fauna populations in the St. Marys River AOC (see list of acronyms at the
   end of this  table).
             Goal
       Monitoring Program (responsible agency)
Fish and Wildlife Habitat:
        -to protect fish and wildlife
        habitat from
        contamination,
        development, loss, and
        dredging
        -to ensure no net loss of
        wetlands
        -maintain water quality
        standards
Conduct overflights to detect changes in environmental areas (MDNR)
 and land use (ASCS). The USACOE agreed to maintain an aerial
 photographic database of the river and to update the photos every five
 years (D. Fielder, pers. comm.).
erosion control (surveyors for Province  of Ontario)
storm water and flooding control (SSMRCA, OMNR, SSMO)
sediment transport (SSMRCA, OMNR)
sewage and water quality control (AHU, OMOE)
shoreline alterations (OMNR, SSMO-DSMP)
shoreline alterations within the city (SSMRCA)

detecting changes in wetlands (USFWS, NOAA, MDNR, USCG,
 USACOE, local groups, universities)
wetland evaluations (OMNR, MDEQ)
Marsh Monitoring Program (CWS, USGLPF)
municipal plan review - upgrade to re-zone lands for long term protection
 (OMNR)
all shoreline alterations (OMNR, MDEQ)
landowner agreements for long term protection (OMNR)

water levels (USACOE) and flow rates (LSBC)
river monitoring (OMOE, MDEQ)
Benthic Community:
       -to maintain a diverse and
       appropriate benthic
       community for the area
OMOE has been sampling sediments and associated benthic invertebrate
 communities for many years and will continue to do so, given the
 resources (P. Kauss, pers. comm.).
Fish Community:
       -reduce incidence of
       defects and reproductive
       problems (compare to
       control)

       -eliminate advisories and
       reduce contaminant levels
Native fish contaminant trends (MDEQ)
Sport fish contaminant levels (OMOE)
Juvenile (young of the year) fish have been sampled and analyzed by the
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            Goal
      Monitoring Program (responsible agency)
       -sustain populations
       -sustain diversity
OMOE's Biomonitoring Section. Additional collections have been made
in recent years as part of the Great Lakes Nearshore and Tributary
Sampling program (OMOE).
Sport fish creel/CAN-AM Derby (OMNR)
Creel survey, 1999-2000 (MDNR, OMNR, Bay Mills Tribe, COTFMA,
First Nations)
Gill net survey, 1995 (MDNR, OMNR, Bay Mills Tribe)
Bait and commercial fish harvest (OMNR)
Fish spawning study (USFWS, NOAA, MDNR, USCG, USACOE, local
groups, universities)
St. Marys River Fishery Task Group has been set up to develop a 10 year
assessment program for the river.
No monitoring program identified
Wildlife Community:
       -decrease in populations of
       exotics
       -prevention of             •
       introductions and spread of  •
       exotics
Purple loosestrife inventory/education (OMNR)
Sea lamprey ammocoete abundance (DFO, USFWS, GLFC)
Sea lamprey adult assessment and trapping (DFO, USFWS)
Sea lamprey flyovers, habitat identification (DFO, USFWS)
Sea lamprey mark and recapture program (DFO, USFWS, ITFAP)
Model of river flow for chemical treatment (GLFC - Lake Huron
Technical Committee)
Check for vegetation such as loosestrife (SSMRCA)
Check for zebra mussels and river ruffe (OMNR, MDNR)

AHU
ASCS
SSMRCA
COTFMA
CWS
DFO
GLFC
ITFAP
LSBC
MDEQ

Algoma Health Unit
Algotna Soil Conservation Service
Sault Ste. Marie Region Conservation Authority
Chippewa/Ottawa Treaty Fishery Management Authority
Canadian Wildlife Service
Department of Fisheries and Oceans
Great Lakes Fishery Commission
Inter-tribal Fisheries and Assessment Program
Lake Superior Board of Control
Michigan Department of Environmental Quality

MDNR
MSU
NOAA
OMOE
OMNR
SSMO
SSMO-DSMP
USACOE
USCG
USFWS
USGLPF
Michigan Department of Natural Resources
Michigan State University
National Oceanic and Atmospheric Administration
Ontario Ministry of the Environment
Ontario Ministry of Natural Resources
City of Sault Ste. Marie, Ontario
Sault Ste. Marie District Shoreline Management Plan
U.S. Army Corps of Engineers
U.S. Coast Guard
U.S. Fish and Wildlife Service
U.S. Great Lakes Protection Fund
  and the U.S. Great Lakes Protection Fund.  The program is coordinated by the Long Point Bird
  Observatory and implemented by volunteers. Marsh monitoring surveys were conducted in the
  St. Marys River AOC from 1994 to 1996. Study sites were located in the St. Marys River marsh
  (Echo Bay and Pumpkin Point) on the Canadian side of the river, and at Lake Nicolet Marsh and
  Munuscong Lake Wildlife Management Unit Marsh in Michigan.  The study concluded that the
  AOC supports healthy marsh bird and amphibian populations; however, efforts should be made
  to rehabilitate marsh habitat and to continue with these surveys in order to properly address
  habitat loss in the St. Marys River watershed.
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Action FFM-3: The Fish Harvest Survey
Implementing Organizations: SMRFTG
The first Fish Harvest Survey was completed in 1999-2000 as a cooperative effort by provincial,
state, and native fisheries management agencies in Ontario and Michigan. The goal was to
determine the total fish extraction from the St. Marys River by all sources (ie., angling,
commercial and subsistence fishing).

Action FFM-4: The Fish Contaminant Monitoring Programs
Implementing Organizations: MDEQ, OMOE, OMNR
The Michigan Department of Environmental Quality and the Ontario Ministry of the
Environment will continue with Fish Contaminant Monitoring Programs in the St. Marys River
and tributaries. Results are used to determine consumption advisories in the AOC.

Action FFM-5: The CWS Surveys of the Common and Black Tern Populations
Implementing Organizations: EC-CWS
Complete  a Canadian Wildlife Survey assessment of common tern and black tern populations for
the entire St. Marys River.

Action FFM-6: Analysis of Contaminant Levels in Eggs
Implementing Organizations: EC-CWS, USFWS
Analyze contaminant levels in eggs from herring gull,  black tern, and common tern nests in the
AOC. This should include an evaluation of the contaminant levels in eggs from sites near highly
contaminated areas such as the Algoma slag dump, or  wherever bird deformities have been
observed.

Action FFM-7: Monitoring of Population Changes Due to Habitat Enhancement
Implementing Organizations: EC, USFWS, OMNR, MDEQ
A monitoring program should be  developed to assess change in fish and wildlife populations in
the AOC in response to habitat enhancement efforts.

Action FFM-8: Reproductive Assessments of Gulls and Terns
Implementing Organizations: EC-CWS, USFWS
Reproductive assessments of herring gulls, black terns, and common terns should be done within
the AOC boundary. Deformities should be assessed in common terns in the St. Marys River.

Action FFM-9: Evaluate Influence of Water Levels and Flows on Spawning and Production
Implementing Organizations: DFO, OMNR, USFWS,  SMRFTG
Design and implement studies to evaluate the influence of water levels and flow rates on
spawning and fish production in the St. Marys River and St. Marys Rapids.

Action FFM-10: Determine Minimum Water Levels and Flow Rates Necessary for Spawning
Implementing Organizations: DFO, OMNR, USFWS,  SMRFTG
Design and implement a study to determine minimum  water levels and flow rates necessary for


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spring and fall spawning fish species in the St. Marys River and St. Marys Rapids.

Action FFM-11: Monitoring Water Quantity
Implementing Organizations: DFO, OMNR, USFWS, SMRFTG
As a connecting channel, water levels in the St. Marys River reflect the water supply from Lake
Superior as regulated by the International Lake Superior Board of Control.  The Board's
approach has been to attempt to "balance the levels of Lakes Superior and Michigan-Huron about
their mean levels, giving consideration to their natural ranges."  (IJC 2001). Fisheries concerns
in the St. Marys Rapids were recognized in 1990 with adoption of the current Lake Superior
regulation plan, Plan 1977'A. This marked a considerable improvement in ensuring sufficient
water for some critical life processes over the long term.  However, issues remain around short
and medium term flow alterations in the rapids, for maintenance and study purposes and water
level changes affecting riparian, wetland and littoral habitats in the lower river. The International
Lake Superior Board of Control of the International Joint Commission could contribute to
addressing these fisheries concerns  through their expertise in regulating water levels in the Great
Lakes.
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                      7.0 REPORTING AND EDUCATION

The mandate of the Education and Reporting Task Team was to develop a plan for the
coordination and dissemination of information relating to the St. Marys River.  To achieve this
goal, the task team developed plans for a resource centre (St. Marys River Centre) and
established a Friends of the St. Marys River organization that would be eligible for funding.
This non-profit, grass roots organization has been involved in clean-up activities along the
shores of the St. Marys River, promotion of the River as a Heritage Water Trail, establishing a
public library to house documents concerning the AOC, and participating in the St. Marys River
Celebration.  These activities are designed to educate the public on environmental issues and
increase the sense of public responsibility and stewardship for remediation of the  AOC.
7.1 Education Programs - On-going and Completed

Storm Drain Marking Program:
The Yellow Fish Road Storm Drain Marking Program was developed in Canada to increase
public awareness and knowledge about protecting fish habitat in urban streams. The program
educated the public on proper methods for disposal of hazardous household materials by
stressing the linkage between storm drains and adjacent waterways. The local Yellow Fish Road
program in Sault Ste. Marie, Ontario was initiated by the environmental advocacy group, Clean
North.  During the summers of 1994 and 1995, students from local schools used yellow fish
symbols to mark 3,400 storm drains that discharge to the St. Marys River and its tributaries, a
level of participation unequaled anywhere else in Canada.  Students in Sault Ste. Marie,
Michigan, also participated in a similar project by stenciling a message beside storm drains
indicating that anything going into the drainage system will be discharged to the St. Marys River
and could pose a hazard to the aquatic ecosystem.

Waterfront Development Plan:
The City of Sault Ste. Marie, Ontario, has completed a number of development projects
designed to enhance waterfront properties, attract residents and tourists to the area, and increase
public awareness of ecologically sound designs while realizing a direct cost-savings for the
municipality. Development has been guided by a Waterfront Development Strategy, adopted by
the City in 1988.

Environmental Platform:
The Munuscong River Watershed Association (MRWA), in partnership with the Sault Area
Community Foundation, Pickford High School, Michigan State University Extension, Bay Mills
Indian Community, Chippewa County Soil Conservation Office, and Americorp, has received
funding to construct an educational platform on the Munuscong River next to Pickford High
School. The majority of the funding will be used to build a 50 ft by 100 ft outdoor classroom to
accommodate over 400 students. Bird feeders, weather station equipment, and water quality
measuring devices will be purchased for use at the site. Bi-weekly monitoring will continue at


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 seven MRWA test sites on the Munuscong River.  The balance of the grant money was used to
 sponsor an Eastern Upper Peninsula Environmental Conference in October 1999. Funding was
 provided by Michigan's Leam and Serve program.

 Wetland Observation Platform:
 The Sault Ste. Marie High School in Michigan constructed a platform on the school grounds
 that allows for the observation of a functioning wetland and pond on the school property. The
 platform provides opportunities to educate students on wetland flora and fauna, the ecological
 importance of functioning wetlands, and to foster ecological stewardship in the area's future
 leaders.
 7.2 On-going Reporting of Area of Concern Activities and Monitoring

 The Binational Public Advisory Council established an office at Lake Superior State University
 in 1998 to serve as a resource centre for the St. Marys River. Documents related to the AOC
 and maps of the watershed will be housed in this office.
 7.3 Reporting and Education Actions Needed

It is important that information about government and industry successes and developments be
transferred in a reader-friendly manner to interested citizens, agencies, and elected officials. In
particular, the flow of information across the border needs to be enhanced. These points were
emphasized by the IJC in its site assessment of the St. Marys River AOC, and are addressed by
Actions RE-1 and RE-3, which have been taken, in large measure, directly from the IJC report.

 The IJC also identified the Native American/First Nation population as the most impacted group
 within the AOC, and pointed out that their lands "continue to be affected by the release of raw
 sewage during wet weather flow conditions."  Furthermore, it expressed  concern over what
 appears to be a lack of specific outreach programs directed to these people. This concern is
 addressed by Action RE-2 which has also been taken, with some modification, from the IJC
 report.

 A list of proposed implementing agencies and partners is given beneath the title of each
 recommended action (see the list of acronyms at the end of this report). Note that these lists are
 only proposals and do not constitute commitments on behalf of those organizations included
 within them. The actual role to be played by the organizations and the type and extent of their
 support will be delineated in the implementation annex.
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 Action RE-1: Revitalizing Public Understanding and Involvement in Remediation Activities
 Implementing Organizations:  EC, OMOE, USEPA, MDEQ
 Give immediate priority to revitalizing public involvement in the implementation of the
 remediation activities in the AOC, with a view to generating and sustaining community
 understanding and support for the goals of AOC restoration.  The Four Agencies will
 accomplish this by demonstrating their strong commitment to the principals set forth in Chapter
 Three of the Four Party Compendium of Position Papers (see section 1.2).

 Action RE-2: Communication of Any Identified Health Risks Resulting from Adverse
             Effects to First Nation/Native American Water Supplies or Lands
 Implementing Organizations:  EC, OMOE, USEPA, MDEQ, INAC
 (a) Any health risks identified by Action NPSM-10 resulting from adverse effects to First
 Nation/Native American water supplies or lands should be communicated without delay to the
 affected communities. Impacts should be used as further justification for controlling excess
 flows and upgrading the East End WPCP.
 (b) The four responsible agencies should utilize  existing First Nation/Native American outreach
 programs  at Lake Superior State University or other institutions to better communicate with
 communities on both sides of the U.S./Canadian border. Efforts should also be made to
 improve direct channels of communication with the general membership of these communities.

Action RE-3: Identify, Track, and Publicize Implementation Activities Within the AOC
Implementing Organizations: EC,  OMOE, USEPA, MDEQ
Implementation activities within the AOC and their specific benefits should be clearly identified,
tracked, and publicized with particular attention to the information needs of industry and citizens.
This effort might well be linked with an ongoing initiative such as the Bi-national Regional
Initiative Developing Greater Education (BRIDGE, see section 2.2).

Action RE-4: Raise Public Awareness of Environmental Health Concerns
Implementing Organizations: HC, EC, USEPA, MDEQ
Remediation that addresses beneficial use impairments should also address health-related issues.
The RAP process can be used to raise public awareness of environmental health concerns,
reduce human exposure to potentially harmful contaminants, and increase public support for
remediation.  See for example Action NPSM-10.

Action RE-5: Quantify the Economic Benefits of a Healthy Natural Ecosystem
Implementing Organizations: EC,  OMOE, MDEQ
Future development in the commercial, industrial, or tourism sectors requires careful planning
and sustainable solutions to eliminate any potential environmental impacts on the beneficial uses
of the AOC. While the natural environment provides opportunities and challenges for the growth
of the St. Marys River community on both sides of the border, contamination problems could
resurface from economic, urban, or industrial growth and development. Therefore, any efforts
made to quantify linkages between the economic development capacity of this area and the
restoration, enhancement, and protection of the natural ecosystem would be beneficial to the
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RAP process.
Actions Described in Previous Chapters Involving Public Participation and Education

Furthermore, in addition to the activities described above, there are a number of other
recommended actions described previously in this report which also involve public participation
and education. These are briefly summarized below:

1.  The pollution prevention education programs for business, industry, and the public described
   in Action PS-5.
2.  Items (d) and (u) listed in Table 6.1, which focused on:
       •  the involvement of landowners in activities that would restrict livestock access to
          streams
       •  the reforestation of inactive agricultural lands by distributing a guide outlining existing
          reforestation programs and strategies to owners of inactive agricultural land
3.  The "no net loss" landowner agreements mentioned in Table 6.2, that will ensure long term
   protection of wetlands
4.  The Marsh Monitoring Program described under Action FFM-2, coordinated by the Long
   Point Bird Observatory and implemented by volunteers.
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             8.0 SUMMARY OF RECOMMENDATIONS FOR THE
     RESTORATION AND PROTECTION OF THE ST. MARYS RIVER
The following table summarizes the main recommendations to restore the impaired beneficial
uses in the St. Marys River AOC.  Note that the remediation and monitoring actions are listed
separately in the same order in which they appear in the Stage 2 Report. General reporting and
education actions and management actions are listed at the end of the table.

Table 8.1 - Summary of Recommendations to Restore the Beneficial Uses in the St. Marys River
  Beneficial Use
   Impairment
    Recommendations for the Restoration of Beneficial Uses*
           and for the Associated Monitoring Activities
                                             • Remediation Actions
Restrictions on Fish
and Wildlife
Consumption
 Action PS-1: Virtually eliminate all persistent and bioaccumulative contaminants
 from industrial and municipal discharge.

                	•- Monitoring Actions	

 Action NPSM-2: Aerial Monitoring of the Cannelton Industries Site
Action NPSM-3:  Biological Monitoring at the Cannelton Industries site to ensure
 protection of the ecological food chain
 Action FFM-3:  Fish Harvest Survey
 Action FFM-4: Continue with sport fish contaminant monitoring programs in the St.
 Marys River and tributaries.	
Degradation of Fish
and Wildlife
Populations
              ————— Remediation Actions	

 Action PS-1: Virtually eliminate all persistent and bioaccumulative contaminants
 from industrial and municipal discharge.
 Action NPS-1: Develop a multi-agency sediment management program for the river
 to address remedial options and implement actions for contaminated sediments,
 including long-term sediment contamination studies. For details on this high priority
 action see section 5.3 of the Stage 2 Report.
Action NPS-4: Identification and Control of Contaminant Inputs from the Algoma
 Slag Dump (including stabilization of shoreline and nearshore sediments)
 Action NPS-7: Remediation for Contaminated Terrestrial and Aquatic
 Disposal Sites
 Action FF-7: Continue with St. Marys River Fishery Task Group efforts to develop a
 10 year assessment program for the river.
 Action FF-8: Continue to support sea lamprey control efforts.

               	Monitoring Actions	
                         Action PSM-6: Monitor the receiving water every three years at St. Marys Paper Ltd.
                         to document response of fish communities to improved effluent quality as mill
                         upgrades and process improvements are implemented.	
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  Beneficial Use
   Impairment
    Recommendations for the Restoration of Beneficial Uses*
            and for the Associated Monitoring Activities
Degradation of Fish
   and Wildlife
   Populations
    (continued)
Action PSM-8: Monitor the Short Term Variability and Monthly Ranges of
Contaminant Discharges from Water Pollution Control Plants in the AOC
 Action NPSM-2: Aerial Monitoring of the Cannelton Industries Site
 Action NPSM-3: Biological Monitoring at the Cannelton Industries site to ensure
protection of the ecological food chain
Action NPSM-9:  Identify Terrestrial and Aquatic Disposal Sites Transferring
Contaminants into Waterways
Action NPSM-11: Assess the Potential Hazards Associated With Spills from
Shipping Vessels
 Action FFM-5: Complete  a Canadian Wildlife Survey assessment of common tern
 and black tern populations  for the entire St. Marys River.
 Action FFM-6: Analyze contaminant levels in eggs from herring gull, black tern, and
 common tern nests in the AOC.
 Action FFM-7: A monitoring program should be developed to assess change in fish
 and wildlife populations in the AOC in response to habitat enhancement efforts.	
 Fish Tumours and
Other Deformities
                                                 Remediation Actions
 Action PS-1: Virtually eliminate all persistent and bioaccumulative contaminants
 from industrial and municipal discharge.
 Action PS-7: Continue with process improvements at industrial and municipal
 facilities.
 Action NPS-1:  Development of a Multi-Agency Sediment Management Program
 Action NPS-4:  Identification and Control of Contaminant Inputs from the Algoma
 Slag Dump (including stabilization of shoreline and nearshore sediments)
                                                 • Monitoring Actions •
                          Action NPSM-9: Identify Terrestrial and Aquatic Disposal Sites Transferring
                          Contaminants into Waterways
                          Action FFM-1:  Identify the Causes of Fish Tumours and Other Deformities
                          Which Originate Within the AOC	
 Bird and Animal
  Deformities or
  Reproductive
    Problems
                        Monitoring Actions •
 Action FFM-8: Reproductive assessments of herring gulls, black terns, and common
 terns should be done within the AOC boundary. Deformities should be assessed in
 common terns in the St. Marys River.
  Degradation of
     Benthos
                                                 • Remediation Actions •
 Action NPS-1: Develop a multi-agency sediment management program for the river
 to address remedial options and implement actions for contaminated sediments,
 including long-term sediment contamination studies. For details on this high priority
 action see section 5.3 of the Stage 2 Report.
 Action NPS-2: Conduct further studies to characterize sediment quality in high
 priority areas (ie., adjacent to Algoma Slag Dump, portion of Little Lake George
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  Beneficial Use
    Impairment
    Recommendations for the Restoration of Beneficial Uses*
           and for the Associated Monitoring Activities  f ? /-'
                           Channel downstream of East End WPCP, and the Algoma Slip).
                           Action NPS-3: Complete sediment chemistry analysis and benthic community
                           assessment as part of the St. Marys River Contaminated Sediment Zones Evaluation
                           (Kauss 1999b)
                           Action NPS-5: Algoma Steel Inc. has removed sediments from the slip during
                           maintenance dredging operations. Therefore, further sediment quality and benthic
                           community assessments should be made to determine the effectiveness of contaminant
                           removal and to determine the need for further dredging.
  Degradation of
    Benthos
   (continued)
                                                 • Monitoring Actions •
 Action PSM-1: Long-Term Water Monitoring at the Cannelton Industries Site
 Action PSM-6: Monitor the receiving water every three years at St. Marys Paper Ltd.
 to document response of benthic communities to improved effluent quality as mill
 upgrades and process improvements are implemented.
 Action NPSM-1: Monitor effluent from East End Water Pollution Control Plant for
 concentrations and loadings of persistent contaminants exceeding guidelines in Lake
 George Channel sediments.
 Action NPSM-3:  Biological Monitoring at the Cannelton Industries site to ensure
protection of the ecological food chain
 Action NPSM-5: Re-sample river sediments every five years to obtain trend with
 time information.
 Action NPSM-6: Periodically conduct benthic, toxicity, and sediment chemistry
 studies in the Bellevue Marine Park area.
  Restrictions on
Dredging Activities
                                                 • Remediation Actions •
 Action NPS-1: Develop a multi-agency sediment management program for the river
 to address immediate dredging needs. For details on this high priority action see
 section 5.3 of the Stage 2 Report.
 Action NPS-5: Evaluate sediment quality and quantity in the Algoma Slip to
 determine need for further dredging.
                                                 • Monitoring Actions
                           Action NPSM-3: Biological Monitoring at the Cannelton Industries site to ensure
                          protection of the ecological food chain
Eutrophication or
Undesirable Algae
                                                • Remediation Actions •
Action PS-3: Upgrade East End Water Pollution Control Plant to secondary
treatment.
Action NPS-6: Control non point source pollution from agricultural activities.
                                                 84

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  Beneficial Use
   Impairment
    Recommendations for the Restoration of Beneficial Uses*
           and for the Associated Monitoring Activities » ^*
Eutrophication or
Undesirable Algae
   (continued)
                    • Monitoring Actions •
Action NPSM-8: Monitor Non-Point Sources of Pollution in the AOC
 Ambient Water
    Quality
                                                • Remediation Actions •
Action PS-1: Virtually eliminate all persistent and bioaccumulative contaminants
from industrial and municipal discharge.
Action PS-2: Reduce storm water infiltration to prevent sewage bypasses.
Action PS-3: Upgrade East End Water Pollution Control Plant to secondary
treatment.
Action PS-5: Address contaminants in storm water discharge system by source
control, air quality control, and pollution prevention education programs.
Action PS-6: Continue with Clean Water Regulation (Canada)  and National Pollutant
Discharge Elimination System (US) Programs for industrial dischargers.
Action PS-7: Continue with process improvements at industrial and municipal
facilities.
Action PS-8: Continued work on CSOs in Sault Ste. Marie Mich.
Action NPS-1: Development of a Multi-Agency Sediment Management Program
Action NPS-7: Remediation for Contaminated Terrestrial
and Aquatic Disposal Sites
Action NPS-8: Plan and Implement Appropriate Remediation, Protection, and
Enforcement Actions to Remove Any Potential Public Health Risks Identified by
Action NPSM-10
                                                 • Monitoring Actions •
                          Action PSM-1: Long-Term Water Monitoring at the Cannelton Industries Site
                          Action PSM-3: Ambient Water Monitoring in the St. Marys River
                          Action PSM-7: Design and implement monitoring system for storm water.
                          Action NPSM-9:  Identify Terrestrial and Aquatic Disposal Sites Transferring
                          Contaminants into Waterways
                          Action NPSM-10: Assess Health Risks to Communities and Individuals Taking
                          Their Water From the "Down-River" Regions of the St. Marys River System
                          Action NPSM-11: Assess the Potential  Hazards Associated With Spills from
                         Shipping Vessels
  Beach Closings
                                                 • Remediation Actions •
                          Action PS-2: Reduce storm water infiltration to prevent sewage bypasses.
                          Action PS-3: Upgrade East End Water Pollution Control Plant to secondary
                          treatment.
                                                 85

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 Beneficial Use
  Impairment
       Recommendations for the Restoration of Beneficial Uses*

               and for the Associated Monitoring Activities ,-; '*
                                            ffr       tU'*T'-V-    ^" ^ S     1V7 .>
Beach Closings
  (continued)
                           • Monitoring Actions •
                          Action NPSM-7:  Assess potential human health risks resulting from floating
                          sediment near, and downstream from, Bellevue Marine Park.
Degradation of
  Aesthetics
                                                 • Remediation Actions
    Action PS-4: Relocate discharge pipe from East End Water Pollution Control Plant to
    deeper, faster moving water in the Lake George Channel in order to improve
    dispersion of discharge plume.
    Action PS-9: Algoma Steel to Limit Discharges from its Dekish Operation
    Action FF-9: The Algoma Slag Dump shoreline is an eyesore.  Shoreline stabilization
    and providing habitat for plant growth (eg., via soil addition) would help to soften
    and stabilize the landscape.
                                                  • Monitoring Actions •
                          Action PSM-2: The Sault Ste. Marie, Michigan Air Quality Monitoring Project
                          Action PSM-4: The Sault Ste. Marie, Ontario Air Quality Monitoring Project
                          Action PSM-5: Monitoring of Particulate Emissions at Algoma's Dekish Operation
Loss of Fish and
Wildlife Habitat
                                               • Remediation Actions •
Action NPS-6: Control non point source pollution from agricultural activities and road
   crossings on tributaries.
Action NPS-7:  Remediation for Contaminated Terrestrial and Aquatic Disposal Sites
Action FF-1: Walleye recovery in the Bar River:
    Mitigate the effects of land use practices upstream of historic walleye spawning
    grounds.
    Use stabilizing structures, contour streambanks, plant trees along the shoreline, and
    provide exclusionary fencing to restrict livestock access to river.

Action FF-2: Watershed Development Plan for Bennett and West Davignon Creeks (See
Table 6.1)
    (a) Maintain headwater reaches in natural state
    (b) Restrict development within 30m of shoreline
    (c) Plant trees in riparian zone
    (d) Restrict livestock access to stream
    (e) Assist passage of migratory salmonids by enhancing migratory pathways while
      excluding sea lamprey passage (see (n))
    (f) Create spawning and nursery habitat
    (g) Naturalize Diversion Channel
    (h) Prevent seepage of petroleum products into aquifer to protect groundwater quality
    (i) Design and implement soil remediation projects for inactive parcels of land on
       Algoma Steel property
    (j) Algoma to work with OMQE in addressing specific contamination issues	
                                                 86

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 Beneficial Use
  Impairment
       Recommendations for the Restoration of Beneficial Uses*
               and for the Associated Monitoring Activities
Loss of Fish and
Wildlife Habitat
  (continued)
    (k) Increase habitat quality and migration pathways in Diversion Channel with
       instream modifications.
    (1) Optimize volume of flow between Diversion Channel and Bennett and West
       Davignon Creeks
    (m) Maintain migratory pathways
    (n) Exclude passage of sea lamprey
    (o) Adhering to buffer strip guidelines and continued restrictions on development
    (p) Provide alternative water sources for livestock
    (q) Streambank stabilization
    (r) Construct retention ponds or man-made wetlands to reduce effects of storm water
          discharge
    (s) Continued wetland development to improve salmonid staging habitat and provide
       for waterfowl and other wildlife
    (t) Maintenance of riparian buffer zone contiguous with a forested area no less than
       1000 ha
    (u) Reforestation of inactive agricultural lands
    (v) Tree planting along top of Diversion Channel
    (w) Enhance wetland forming off mouth of Diversion Channel

Action FF-3:  Watershed Development Plan for East Davignon and Fort Creeks etc. :
    Watershed plans similar to Action FF-2 should be developed for East Davignon and
    Fort Creeks, Root River, Crystal Creek, and the Big and Little Carp Rivers.
 Action FF-4:  Munuscong River/Bay:
 Several key non point source pollution control projects to reduce sedimentation in the
    river and in Munuscong Bay (e.g., stabilization of eroding streambanks at Srirlingville
    Bridge site and at Pickford).
 Action FF-5:  Mission Creek:
    Complete hydrogeological and waste characterization study to be completed,
    including a  feasibility study for the removal of waste and restoration of the natural
    flow of the creek.

Action FF-6:  Rapids Habitat: (A number of options have been presented for the
remediation of rapids habitat and associated wetlands.)
    (a) Protect remnant rapids habitat from further reduction and degradation and
       maximize the productive capacity of the rapids area
    (b) Enhance remnant rapids habitat by placing additional spawning substrate in rapids
       area
          map existing  substrate, identify target fish species assemblages, and note areas
          likely to become dewatered under differing flow conditions
    (c) Create new rapids areas elsewhere in the St. Marys River, especially in the Little
      Rapids area
          identify areas with the hydrologic and physical characteristics to support rapids
          generation
    (d) Create alternative to rapids habitat such as artificial spawning substrate
    (e) Create wetlands downstream of Whitefish Island to connect wetland habitat to
       adjacent remnant rapids
    (f) Create new wetland/rapids complexes
    (g) Enhance habitat and water quality in tributary watersheds
                                                  87

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  Beneficial Use
   Impairment
       Recommendations for the Restoration of Beneficial Uses*
               and for the Associated Monitoring Activities
 Loss of Fish and
 Wildlife Habitat
   (continued)
                      Action FF-7:  Fisheries Assessment:
                         (a) Mortality rates for walleye, northern pike, and yellow perch require further
                             assessment.
                          (b) Continue with St. Marys River Fishery Task Group efforts to develop a 10 year
                             assessment program for the river.
                      Action FF-8: Continued Support for Sea Lamprey Control Efforts
                      Action FF-9: Stabilize shoreline of Algoma slag dump to provide habitat for plants
                           • Monitoring Actions •
                      Action PSM-1: Long-Term Water Monitoring at the Cannelton Industries Site
                      Action NPSM-3: Biological Monitoring at the Cannelton Industries site to ensure
                         protection of the ecological food chain
                      Action NPSM-9: Identify Terrestrial and Aquatic Disposal Sites Transferring
                         Contaminants into Waterways
                      Action NPSM-11: Assess the Potential Hazards Associated With Spills from
                         Shipping Vessels
                      Action FFM-2:  Continued support for the Marsh Monitoring Program
                      Action FFM-7: A monitoring program should be developed to assess change in fish and
                         wildlife use of the AOC in response to habitat enhancement efforts.
                      Action FFM-9: Evaluate Influence of Water Levels and Flows on Spawning and
                         Production
                      Action FFM-10: Determine Minimum Water Levels and Flow Rates Necessary for
                         Spawning
                      Action FFM-11: Monitoring Water Quantity	
          General Actions Relating to Reporting, Education, Human Health, and Management
   General
 Reporting and
Education Actions
Action RE-1: Revitalizing Public Understanding and Involvement in Remediation
             Activities
Action RE-2: Communication of Any Identified Health Risks Resulting from Adverse
             Effects to First Nations/Native American Water Supplies or Lands
Action RE-3: Identify, Track, and Publicize Implementation Activities Within the AOC
Action RE-4: Raise Public Awareness of Environmental Health Concerns
Action RE-5: Quantify the Economic Benefits of a Healthy Natural Ecosystem
Actions Relating to
Human Health
Action NPSM-10:  Assess Health Risks to Communities and Individuals Taking Their
Water From the "Down-River" Regions of the St. Marys River System

Action NPSM-12:  Identify Locations Within the AOC Which are Associated With
Elevated Levels of Human Health Disorders
                                                88

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           General Actions Relating to Reporting, Education, Human Health, and Management
     General
Management Actions
Management Action MNG-1: It is recommended that a workshop session, or series of
sessions be convened which will produce a set of precise, objectively defined delisting
criteria that are numerically quantified wherever possible, and which will provide the
necessary decision framework that will govern the delisting of each impaired beneficial
use and ultimately the delisting of the AOC itself.

Management Action MNG-2: It should also be noted that monitoring activities which
track progress toward delisting must, in large measure, be determined by those very same
criteria which define the delisting process itself. Consequently, modifications or additions
to the delisting criteria, such as those which are recommended under management action
MNG-1 will likely require corresponding changes to the monitoring activities.  It is
recommended, therefore, that a workshop session, or series of sessions also be convened
to establish the necessary coordination between the overall monitoring strategy and the
revised delisting criteria resulting from Action MNG-1.
 * The recommended actions are labeled as follows:
     Action PS-n denotes the n-th point source (PS) recommended action (see section 4.3).
     Action NPS-n denotes the n-th non-point source (NFS) recommended action (see section 5.3)
     Action FF-n denotes the n-th flora and fauna (FF) recommended action (see section 6.3).
     Action RE-n denotes the n-th reporting and education action (see section 7.3).
     Action MNG-n denotes the n-th management recommended action.
Monitoring recommendations for point sources, non-point sources, and flora and fauna are denoted by Action PSM-n, Action
NPSM-n, and Action FFM-n, respectively (see sections 4.4, 5.4, and 6.4 respectively).
                                                    89

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Arthur, A., and P.B. Kauss.  1999.  Sediment and Benthic community Assessment of the St.
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Babin, J., T.P. Murphy, and J.T. Lynn.  1999. In situ sediment treatment in Kai Tak Nullah to
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Baumann, P.C., I.R. Smith, and C.D. Metcalfe.  1996.  Linkages between chemical
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Beak Consultants Limited. 1990.  Slag disposal site investigation at Algoma Steel Corporation,
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Beak Consultants Limited. 1993.  St. Marys River AOC Technical Options Study Interim
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Beak Consultants Limited. 1996.  First Cycle Environmental Effects  Monitoring Study Report.
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Bedard, D., and S. Petro.  1997. Laboratory Sediment Bioassay Report on St. Marys River
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Bray, K.E. 1993. Changes to fish habitat of the St. Marys River: a retrospective analysis.
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Clara, R., and  D.J. Racette.  1996.  Air Quality in Ontario, Sault Ste. Marie, 1993-94. Ministry
       of the Environment.

Clean Up and  Restoration Task Team. 1994. St. Marys River Area of Concern Stage 2 RAP
       Report, September 1994.
                                          90

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Duffy, W.E., and T.R. Batterson. 1987. The St. Marys River, Michigan: an ecological profile.
      USFWS Biological Report 85(7.10).  138pp.

Eberhardt, R. 2000. Technical review comments on the draft version of the St. Marys River
      Remedial Action Plan.

Economic Development Corporation. 1997.  Sault Ste. Marie Economic Development
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Edsall, T.A., and I.E. Gannon. 1993. A Profile of St. Marys River. MICHU-SG-93-700
      Michigan Sea Grant College Program. Ann Arbor, Michigan.  20 pp.
      Environmental Hydraulics Group. 1995. St. Marys Rapids Hydrology Study.  Prepared
      for the St. Marys River RAP Team. 49 pp.

Fielder, D.G., and J.R. Waybrant. 1998. Fish population surveys of St. Marys River, 1975-95,
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      Fisheries Research Report No. 2048.  10 pp.

Flora and Fauna Task Team.  1994. Flora and Fauna Liter-agency Monitoring Plan. St. Marys
      River Area of Concern Stage 2 RAP Report, April 1994.

Gelling, W.D.  1998. Bar River Habitat Project. Great Lakes Clean Up Fund Program Report.
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Great Lakes Fishery Commission (GLFC). 1997. GLFC program requirements and cost
      estimates for fiscal year 1998. Submitted to the Governments of Canada and the United
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Great Lakes Health Effects Program. 1998. St. Marys River Area of Concern: Health Data and
      Statistics for the Population of Sault Ste. Marie (Ontario) and Region (1986-1992).  A
      Technical Report for the RAP community.  35 pp.

Hussain, M., J. Rae, A. Oilman, and P. Kauss.  1998.  Lifetime Health Risk Assessment from
      Exposure of Recreational Users to Polycyclic Aromatic Hydrocarbons. Archives of
      Environmental Contamination and Toxicology. 35, 527-531.

International Joint Commission (IJC). 1998.  Status Assessment for the St. Marys River AOC.
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Kauss, P.B.  1999a. Algoma Slag Dump (St. Marys River) Nearshore Sediment Quality and
      Contaminant Bioavailability Study. Technical Report, March 31, 1999.  Ontario
                                         91

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       Ministry of the Environment. 70pp.

Kauss, P.B. 1999b. St. Marys River Contaminated Sediment Zones Evaluation. Project
       description, June 9, 1999. Ontario Ministry of the Environment.  22pp.
Kauss, P.B., and P.C. Nettleton. 1999. Impact of Sault Ste. Marie East End Wastewater
       Treatment Plant Discharge on Lake George Channel (St. Marys River) Waters - 1989.
       Technical Report, March 31, 1999. Ontario Ministry of the Environment. 58pp.

Kilgour, B., and W. Morton. 1998. 1995 Survey of St. Marys River Benthos in the Vicinity of
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Krantzberg, G. 1998. Presentation to the COA RAP Steering Committee in conjunction with
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Mcllveen, W.D. 1998. Phytotoxicology 1997 Investigation: Algoma Steel - Sault Ste. Marie.
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Muller, P.,  and M. Hussain.  1994.  Lifetime Health Risk Assessment from Exposure of
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Murphy, T., A. 2000. Technical review comments on the draft version of the St. Marys River
       Remedial Action Plan.

Murphy, T., A. Moller, and H. Brouwer.  1995. In situ treatment of Hamilton Habour sediment.
       Journal of Aquatic Ecosystem Health 4: 195-203.

Murphy, T.P., A. Lawson, M. Kumagai, and J. Babin. 1999. Review of Canadian Experiences in
       Sediment Treatment. Aquatic Ecosystem Health & Management 2:419-434.

Northern Ontario Business Magazine, March 1998 issue.

Olivier, L., and R. Potvin. 1996. Air quality assessment studies for the City of Sault Ste. Marie,
       1979-1992. Ministry of the Environment.

Ontario Ministry of the Environment. 1999.  Guide to Eating Ontario Sport Fish. Queen's
       Printer for Ontario, Toronto, Ontario.  197 pp.

Point Source Task Team.  1994. St. Marys River Area of Concern Stage 2 RAP Report, January
       1995.
                                         92

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Pope, R.J., and P.B. Kauss. 1995. Algoma Slip Sediment Quality and Benthic Invertebrate
       Community Assessment. Prepared for Ontario Ministry of Environment.

Scleen, L.P.  1997. Dye study proves only limited effectiveness of TFM for a St. Marys River
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Scleen, L.P., RJ. Young, and G.T. Klar.  1998.  Integrated management of sea lampreys in Lake
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       Ontario, March 17-18, 1998. 19 pp.

Skinkle, C. 1992. St. Marys River Remedial Action Plan Tainted Fish Survey.  Ontario
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Smith, I.R., C. Portt, and D.A. Rokosh.  1990. Induced levels of hepatic mixed function
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St. Marys River Area of Concern, Michigan Progress Report. November, 1999.  Michigan
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       Bennett and West Davignon Creeks Watershed.  19pp.

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Zegarac, M., and T. Muir. 2000. City of Sault Ste. Marie Water Pollution Control Plant
       Financing Study.  Prepared for the City of Sault Ste. Marie, Ontario. 25 pp.
                                         93

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Personal Communication:

R. Eberhardt, Ph.D., Environmental Quality Analyst, Surface Water Quality Division, Michigan
       Department of Environmental Quality, Lansing, MI.

S. Greenwood, Management Biologist, Huron Superior Management Unit, Ontario Ministry of
       Natural Resources, Sault Ste. Marie, Ontario.

P. Kauss, Ph.D., Senior Environmental Scientist, Surface Water Section, Environmental
       Monitoring and Reporting Branch, Ministry of the Environment, Etobicoke, Ontario.

T. Morse, Treatment Supervisor for Sea Lamprey Control, U.S. Fish and Wildlife Service,
       Marquette, MI.

J. Waybrant, Michigan Department of Natural Resources, Newberry, MI.
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                                   Acronyms

AAFC        Agriculture and Agri-Food Canada
AHU        Algoma Health Unit
AOC        Area of Concern
ASCS        Algoma Soil Conservation Service
ASI          Algoma Steel Inc.
ATSDR      Agency for Toxic Substances and Disease Registry
BATEA      Best Available Technology Economically Achievable
BOD        Biochemical oxygen demand
BPAC        Binational Public Advisory Council
BRIDGE     Binational Regional Initiative Developing Greater Education
CA          Conservation Authority
CHRS        Canadian Heritage River System
COTFMA    Chippewa/Ottawa Treaty Fishery Management Authority
CSO        Combined sewer overflow
CWS        Canadian Wildlife Service
DHA        Dehydroabletic acid
DFO        Department of Fisheries and Oceans
DSPC        Direct Strip Production Complex
EEM        Environmental Effects Monitoring
EC          Environment Canada
EPA        (U. S.) Environmental Protection Agency
GLFC        Great Lakes Fishery Commission
GLHEP      Great Lakes Health Effects Program
GLSF        Great Lakes Sustainability Fund
GLWQA     Great Lakes Water Quality Agreement
HC          Health Canada
1C           Industry Canada
LTC          International Joint Commission
INAC        Indian and Northern Affairs Canada
ITFAP       Inter-Tribal Fisheries Assessment Program
LaMP        Lakewide Management Plan
LSBC        Lake Superior Board of Control
OMAFRA    Ontario Ministry of Agriculture Farming and Rural Affairs
OMNR      Ontario Ministry of Natural Resources
OMOE      Ontario Ministry of the Environment (also designated as MOE)
MISA        Municipal Industrial Strategy for Abatement
MDEQ      Michigan Department of Environmental Quality
MDNR      Michigan Department of Natural Resources
MFO        Mixed function oxidase
MOE        Ontario Ministry of the Environment (also designated as OMOE)
MSU        Michigan State University
                                        95

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MRWA       Munuscong River Watershed Association
NOAA        (U. S.) National Oceanic and Atmospheric Administration
NOAEC       No observable adverse effect concentration
NPDES       National Pollution Discharge Elimination System
PAH          Polycyclic aromatic hydrocarbons
PCB          Polychlorinated biphenyls
PSQG         Provincial Sediment Quality Guidelines
RAP          Remedial Action Plan
SMRFTG     St. Marys River Fisheries Task Group
SSM          Sault Ste. Marie
SSMM        City of Sault Ste. Marie, Michigan
SSMO        City of Sault Ste. Marie, Ontario
SSMRCA     Sault Ste. Marie Region Conservation Authority
TC           Transport Canada
TFM          3-trifluoromethyl-4-nitrophenol
TPH          Petroleum hydrocarbons
USACOE     U. S. A.  Core of Engineers
USCG        U.S. Coast Guard
USEPA       United States Environmental Protection Agency
USFWS       U. S. Fish and Wildlife Service
USGLPF      U. S. Great Lakes Protection Fund
WPCP        Water Pollution Control Plant
WWTP       Waste Water Treatment Plant
                                        96

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                             Measurements and Units

mg/1           = milligrams per litre                  = parts per million (ppm)*
mg/kg         = milligrams per kilogram              = parts per million (ppm)
(o,g/l           = micrograms per litre                 = parts per billion (ppb)*
|ig/g           = micrograms per gram                = parts per million (ppm)
kg/d           = kilograms per day
m3/d           = cubic metres per day
#/l 00ml        = number per 100 millilitre
m3/s           = cubic metres per second
cf7s            = cubic feet per second
*How small is small?
One part per million:
= one inch in  16 miles;
= one minute  in two years;
= one bad apple in 2,000 barrels;
= one ounce in 31 tonnes of potato chips.

One part per billion:
= one inch in  16,000 miles;
= one second  in 32 years;
= one bad apple in 2 million barrels;
= a pinch of salt in 10 tonnes of potato chips.

At what point are chemicals perceived? Table salt in water becomes somewhat unpalatable at
one part per thousand; swimmers can detect chlorine in a pool at one part per million; and
sensitive noses can detect the odour of fuel oil at one part per billion.
                                          97

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               APPENDIX 1 - CONTACT LISTS
(A) St. Marys River Binational Public Advisory Council Members for 2001-2002
                (Note that Council positions change yearly)
Name / Affiliation
John Bain
Tourism
Marilyn Burton
Environmental
John Campbell
Tourism & Recreation
Patrick Egan
Shoreline Property Owner
Kara Flannigan
Public Health
Donald Maries
Environmental
1st Vice - Chan-
Martin McPherson
Environmental
Mike Ripley
Tribal Fisheries
2nd Vice Chair
Phone / Fax / e-mail ! ';f
(705) 253-8683
bain@soonet.ca
(906) 635-5594
(906)635-1581 office
(906) 632-4255 office fax
(906) 437-5526
FAX 437-5262
pegan@up.net
(705) 759-5286
FAX 759-1 534
kmf@canada.com
(705) 254-6344 home
donald.marles@sympatico.ca
(705) 256-7579
(906) 632-0072
FAX 632-1 141
mripley@northernway.net
Address
1 6 Willow Ave.
Sault Ste. Marie, ON
P6B 5A9
1004 Bingham Ave.
Sault Ste. Marie, MI
49783
Eastern Upper Peninsula
Planning, 542 Ashmun
P.O. Box 520
Sault Ste. Marie, MI
49783
23806 Lakeshore Dr.
Brimley, MI
49715
Algoma Health Unit,
Civic Centre,
99 Foster Drive
Sault Ste. Marie, ON
P6A 5X6
69 Broadview Drive
Sault Ste. Marie, ON
P6C 5Z4
120 Church Street, Apt #2
Sault Ste. Marie, ON
PSA 5H5
Inter-Tribal Fisheries and
Assessment Program
179 West 3 Mile Road
Sault Ste. Marie, MI
49783
                                  98

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Name / Affiliation

Walter Sarich
Labour, Local 1425
Carpenters & Joiners
Mary Rossiter
Shoreline Property Owner
James Dukes
Shoreline Property Owner
Greg Zimmerman
Education
Chair for 2002-2003
Barbara Keller
Research
Joan Aikens
Citizen
Louis A. Quinlan
River Transport
Joseph Gallagher
Environmental
Phone / Fax / e-mail
* ',„*""''" - ,- '*.x*>>i Jx<: , ~
(705) 256-5393
(705)253-2458 home
dukesjr@soonet.ca
(705)253-2458 home
dukesjr@soonet.ca
(906) 635-2470
(906)635-2111
gzimmennan@lakers.lssu.edu
(906) 635-2438
FAX (906) 635-21 11
bkeller@gw.lssu.edu
(705)246-3417
(705) 945-8418
FAX 945-0908
louquinlan@sympatico.ca
(906)253-1763
joseph_p_gallagher@hotmail.com
Address
-- *• . •'-** «-< *. ff* j- • . *,. --" .
940 Queen St. E.
Sault Ste. Marie, ON
P6A 2C1
1031 Queen Street, E.
Sault Ste. Marie, ON
P6A 2C2
1031 Queen Street E.
Sault Ste. Marie, ON
P6A 2C2
Gale Gleason Institute
Lake Superior State University
Sault Ste. Marie
MI 49783
Lake Superior University
650 W. Easterday Ave
Sault Ste. Marie, MI
49783
1772 F & G Line
R.R.#2
Richards Landing, ON
POR 1JO
150 Churchill Blvd.
P.O. Box 20032
Sault Ste. Marie, ON
P6A 6W3
921 Cedar St.
Sault Ste. Marie, MI
49783
The e-mail address for the St. Marys River BPAC is:  stmarysbpac@hotmail.com
                                   99

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(B) Former BPAC Members Who Contributed to the Stage 2 Report
Name / Affiliation 7 ;
'•-•*«•*• ••••• A.,,., •",.--,• .,4i-i'Jfe
Roman Aikens
Mimicipal
Marvin Besteman
Elected Official
William Cryderman
Environmental
Jarl Hiltunen
Environmental
Verna Lawrence
Elected Official
Jim Moreau
Municipal Employee
Gladys Wallwork
Environmental
Terry LeBouef
Academia
Phone / Fax / e-mail : ;
'{" \'::;v '^f '^^"t \ , , ^^.'-«- if^A^^^^^j"'^'''^-
(705)246-3417
(906) 478 - 5412

(906) 632-7067
(906) 632-3293
vlawr@sault.com
(906)632-3531
(705) 779-3098
(705) 759-9350
Address . . ft|:
^^f'-^f'^^jy^^^-^j '&SNV *&K9g&^g4gg^&kgA«^^^£'>^p*
Township of St. Joseph
R.R.#2
Richards Landing, ON
FOR 1JO
R.R. #1, Box 772
Rudyard,MI 49780
Dafter Township
Route 1, Box 48
Dafter, MI 49724
Sugar Island, Box 335
Sault Ste. Marie, MI 49783
1006 Easterday Ave.
Sault Ste. Marie, Mi 49783
City of Sault Ste. Marie
325 Court St.
Sault Ste. Marie, MI 49783
Sault Naturalists
506 Townline
Sault Ste. Marie, ON
P6A 6K4.
Separate School Board
170Birchwood
Sault Ste. Marie, ON
P6A 5R8
                            100

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               (C ) Agency Representatives and Other Participants
  Name / Affiliation
  Phone / Fax / e-mail
       Address
John Marsden
Lake Superior Coordinator
Environment Canada
(416) 739-4759
FAX (416) 739-4404
john.marsden@ec.gc.ca
Environment Canada
4905 Dufferin Street
Downsview, ON M3H 5T4
Dr. Roger Eberhardt
Michigan Department of
Environmental Quality
(517)335-1119
FAX 373-2040
EBERHARR@state.mi.us
Michigan Department of
Environmental Quality
P.O. Box 30273
Lansing, MI 48909
Arthur Ostaszewski
Aquatic Biologist
Michigan Department of
Environmental Quality
(517)335-1119
OSTASZEA@michigan.gov
Michigan Deptartment of
Environmental Quality
Surface Water Quality Div.
P.O. Box 30273
Lansing, MI 48909-7773
Rick Hobrla
Michigan Deptartment of
Environmental Quality
(517)335-4173
HOBRLAR@michigan.gov
Michigan Deptartment of
Environmental Quality
Surface Water Quality Division
525 West Allegan
P.O. Box 30273
Lansing, MI 48933
Jennifer Manville
RAP Coordinator
U.S. Environmental Protection
Agency
(231)922-4769
FAX 922-4499
Manville.Jennifer@epamail.epa.gov
U.S. EPA Region 5
Governmental Center
400 Boardman Avenue
Traverse City, MI 49684
Marilee Chase
Ontario Ministry of Natural
Resources
(807)475-1371
Fax (807) 473-3024
marilee.chase@mnr.gov.on.ca
Lake Superior Management
Unit, Ontario MNR
435 James St. S., Suite 22le
Thunder Bay, ON P7B 6S8
Sue Greenwood
Ontario Ministry of Natural
Resources
(705) 253-8288
Fax 253-9099
susan.greenwood@mnr.gov.on.ca
Huron Superior Management
Unit, Ontario MNR
1235 Queen St. East
Sault Ste. Mane, ON P6A 2E5
Al Wright
Reporter
(705) 946-8538
FAX 946-1860
al.wright@sympatico.ca
4 Valhalla Place
Sault Sainte Marie, ON
P6A 5Z1
                                            101

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  Name / Affiliation
Rod Stewart
Ontario Ministry of the
Environment
  Phone / Fax / e-mail
(705)541-2173
Rod.Stewart@ene.gov.on.ca
       Address
Ontario Ministry of
Environment
70 Foster Drive
Sault Ste. Marie, ON P6A 6V4
Robert Purdon
Regional Program Coordinator
Ontario Ministry of the
Environment
(807)475-1733
Rob.Purdon@ene.gov.on.ca
Ontario Ministry of the
Environment
435 James St. S., Suite 331
Thunder Bay, ON P7E 6S7
Doug Geiling
Department of Fisheries and
Oceans Canada
(705) 942-2848
Fax 941-3025
GeilingD@DFO-MPO.GC.CA
Department of Fisheries and
Oceans Canada
GLLFAS
Canal Post Office
Sault Ste. Marie, ON
P6A IPO
                                           102

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                APPENDIX 2:
 ENVIRONMENTAL MANAGEMENT AGREEMENT

                    between

                Algoma Steel Inc.

                      and

     Her Majesty the Queen in Right of Canada,
  as represented by the Minister of Environment (EC)

                      and

     Her Majesty the Queen in Right of Ontario,
as represented by the Minister of the Environment (MOE)
                      103

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                ENVIRONMENTAL MANAGEMENT AGREEMENT

                                       between                        .

                                  Algoma Steel Inc.

                                         and

                      Her Majesty the Queen in Right of Canada,
                  as represented by the Minister of Environment (EC)

                                         and

                      Her Majesty the Queen in Right of Ontario,
                as represented by the Minister of the Environment (MOE)

Section 1 - Definitions

1.1   In this document,

1.1.1  ASI means the steelworks located in Sault Ste. Marie owned by Algoma Steel Inc.

1.1.2  CEP A means the Canadian Environmental Protection Act S. C. 1999 c. 33 and as amended
      from time to time.

1.1.3  contaminant means any solid, liquid, gas, odour, heat, vibration, radiation or combination
      of any of them resulting directly or indirectly from human activities that may cause an
      adverse effect.

1.1.4  Director(s) means the Regional Director of the MOE Northern Region and/or the Regional
      Director of EC Ontario Region.

1.1.5  EBR registry means the Environmental Bill of Rights registry administered by the MOE
      (www.ene.gov.on.ca).

1.1.6  EMA means the signed three-party Environmental Management Agreement.

1.1.7  EPA means the Environmental Protection Act R.S.O. 1990 c. E.I9 administered by the
      Ontario Ministry of the Environment and as amended from time to time.

1.1.8  Green Lane means  the EC internet  environmental page (www.cciw.ca/green-lane/or-
      home.htmlj.P^// means the group of 17 polynuclear aromatic hydrocarbons as listed in
      appendix  1.

1.1.9  the parties means ASI, EC and MOE.

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Section 2 -  Introduction and Background

2.1    Introduction

The development of several inter-governmental agreements and initiatives over the past few
decades have resulted in an opportunity for the parties to this document to negotiate an
Environmental Management Agreement (£M4),\vhich advances several environmental issues at
Algoma Steel Inc (ASP). This EMA is a voluntary initiative designed to complement the existing
regulatory process. It provides a mechanism for AS1 to commit to environmental initiatives that
exceed existing regulatory requirements while taking into consideration the criteria and
principles embodied in the Voluntary Non-Regulatory Initiatives (VNRI) document of November
 1997.  The VNR1 document was developed by the New Directions Group, which has multi-
stakeholder membership and is comprised of representatives from government, industry and
environmental non-governmental organizations and was used as guidance in completing this
EMA.

A key goal of this EMA is to bring together several federal and provincial objectives in one
concise document and provide one window through which ASJ can deal with government
agencies. Progress towards reduction or elimination of the "beneficial use impairments"(as
defined in the Canada-US Water Quality Agreement) and pollution incident reports are important
objectives considered in the development of this EMA.

Under Annex 2 of the  1987 Protocol to the 1978 Canada- U.S. Water Quality Agreement, an
Area of Concern (where the impairment of beneficial uses of a geographic area has been realized)
was established for the St. Mary's River in 1988. This led to the development of a Remedial
 Action Plan led by the Ontario Ministry of the Environment with support from Environment
 Canada and other federal departments and the formation of a Binational Public Advisory
 Council. Criteria for the delisting (as defined in the Canada-US Water quality Agreement) of the
 "beneficial use impairments" have been completed in the development of the Remedial Action
 Plan Stage 2 document.

 An Air Quality Committee formed pursuant to the United States-Canada Air Quality Agreement
 between Canada and the United States, requested in 1997, that a bi-national multi-stakeholder
 consultation be undertaken to evaluate complaints from Michigan residents regarding trans-
 boundary pollution from Sault Ste. Marie, Ontario. An ongoing consultation and monitoring
 partnership between federal, state, provincial and tribal stakeholders has been developed to
 address this issue.

 This EMA hopes to further the goals of the 1994 Canada-Ontario Agreement, Great Lakes Water
- Quality Agreement, Remedial Action Plan, United States-Canada Air Quality Agreement and
 other government programs, and align them with the environmental initiatives which the parties
 agree are current priorities.

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The EMA is also consistent with ASl's policy on reducing the impact of its operations on the
overall environment and adjacent residential areas. All parties agree that the establishment of a
list of environmental projects, with appropriate time lines in a clearly defined plan, is beneficial
to all stakeholders and provides a clear path to realizing the goals and mandates of the parties
who are signatories to this agreement.  The draft EMA was presented at a public meeting held in
Sault Ste. Marie on May 18, 2000, and posted on the MOE Environmental Bill of Rights
Registry and the Green Lane internet site for a 30 day period ending June 30, 2000.

2.2    Background

ASI is  an  integrated  steel producer, with annual production of finished steel products of
approximately 2.1 million tonnes. It is located on an 810 hectare parcel of land, which includes a 328
hectare non-hazardous landfill site (MOE Certificate of Approval #A560101). Finished products
include plate, strip and cold rolled steel.  The facility is operated with three cokemaking batteries,
one operational blast furnace, one basic oxygen steel plant and a variety of finishing mills, including
a recently completed direct strip production complex.

Environmental improvements over the last decade have  resulted in ASI currently achieving full
compliance with Ontario Regulation 214/95 (MISA) at its eleven control points, which discharge
to the St. Mary's River. Major environmental upgrades to reduce and treat waste streams at ,457over
the past decade include the  installation of a main wastewater treatment plant, blast furnace
wastewater recirculation system, pH control of process wastewater discharges from the Bar and Strip
Lagoon, fixed ammonia removal, biological treatment of phenol in cokemaking wastewater and
secondary emission controls for visible emissions from the steelmaking operation. A commitment
to address particulate emissions from the Ironmaking dekishing operations was provided to MOE
in a Program Approval issued in November  1998. Controls on this source will be fully implemented
by September 2002. Over the past ten years, ASI has committed approximately $100 Million for
capital environmental facilities.

Regarding  climate change issues, ASI has made changes to its processes, incorporating direct strip
casting and rolling technology. This addition of the newest steel processing technology, along with
reductions  in the amount and types of fuel used, advancements in fuel burner technology and a
change to its iron ore source has resulted in significant reductions in the production of greenhouse
gases. Between 1990 and 2000, ,457 will realize a 6.5% reduction in carbon dioxide(C02) emissions.
ASI has increased the use of natural gas in new and refurbished facilities and thereby reduced its
reliance on heavy.fuels.

ASI has been actively upgrading  electrical equipment to newer, more energy efficient types that has
resulted in  net energy savings. This commitment will continue with future improvements planned
for equipment upgrades and energy use monitoring.

ASI  is  a  participant  in   the  Voluntary   Challenge  Registry  (VCR), the  Accelerated
Reduction/Elimination of Toxics (ARET) Program, the Ontario Anti-Smog Action Plan and is a
signatory to the Canadian Steel Producers' Association (CSPA), Statement of Commitment and
Actions.

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ASI sponsors a used oil collection day, twice per year, in Sault Ste. Marie, as a public service to
collect and recover waste oil from the community. Since beginning this program in 1991, ASI has
collected approximately 74,000 litres of waste oil from the public. Waste oils collected both on and
off site are processed into waste derived fuel and utilized by ASI as a fuel source, reducing the need
to purchase virgin fuel. Within the operations, a program has also begun to directly recycle oil at
the mill source.  This approach will be expanded wherever possible and maintenance programs will
ensure that the volume used is minimized

ASI believes that the commitments contained in the Agreement represent realistic and achievable
goals and, wherever possible, ASI will work toward improving the timetable and the levels of
reduction.

Section 3 -  Goals and Objectives

3.1    Goals and Objectives are as follows:

       the reduction or  elimination of specific substances which  are found  to  be  persistent,
       bioaccumulative and toxic in the environment and appear in appendix 2 of the 1994 Canada-
       Ontario Agreement as Tier I and Tier II substances (appendix 2 attached),

       the reduction or elimination of air discharges in the form of visible and gaseous emissions*
       which exceed or are inconsistent with existing or proposed limits or guidelines or are the
       subject of pollution reports to MOE,

       improved management of solid waste and contaminated sediments,

       continued discussions on developing an air quality monitoring partnership with the MOE,

       the de-listing of  the "beneficial use impairment" associated with the ASI boat slip as
       identified in the Stage 1 report for the Remedial Action Plan (RAP) for the St Marys River,

       participation in the discussion and resolution of local trans-boundary air issues between Sault
       Ste. Marie Ontario and Sault Ste. Marie Michigan,

       enhancement of pollution prevention planning initiatives, such as raw products substitution,
       new technology applications and energy or water use reduction programs, and,

       continued participation in other  steel sector initiatives and other  voluntary programs as
       outlined below:
              •   Strategic Options Process for the Steel Sector (SOP)
              •   Accelerated Reduction/Elimination of Toxics Program (ARET)
              •   Voluntary  Challenge Registry for Climate Change (VCR)
              •   Anti-Smog Action Plan (ASAP)
              •   Canadian Steel Producers Association Best Practices Manuals

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Section 4 - Activities
4.1    The following schedule outlines the activities which ASI agrees to undertake to assist in
       achieving the goals and objectives outlined in Section 3.1. Items in the following table are
       further described in Sections 4.1.1 to 4.1.9.

                                          TABLE 4
Project
1 . Benzene Air Emissions Reduction ( 1 993
base year emission rate of 432.6 grams/tonne of
Coke produced)
2. PAH Air Emissions Reduction (1993 base
year emissions of 21.3 grams/tonne of Coke
produced)
3. Blast Furnace Visible Emissions
4. Annual Cokemaking Plans
5. PCB Destruction
6. ASI Boat Slip
7. ASI Landfill
8. Mercury Recycling
9. Environmental Code of Practice for
Integrated Steel Mills
ASI Commitment / Time
a) 50% Reduction by December 3 1 , 2000 (2 1 6 g/t).
b) 75% Reduction by December 3 1, 2003 (108 g/t).
c) 85% Reduction by December 31, 2005 (57.3 g/t).
a) 20% Reduction by December 31, 2000 (17g/t).
b) 54% Reduction by December 31, 2005 (9.8 g/t).
a) Study / experiment with flame system.
b) Maximize the efficiency of flame suppression.
c) Report the findings in the Feb 1, 2001 semi-annual
report.
a) develop annual Cokemaking Environmental Plans.
b) include the plan in the February 1 semi-annual
reports.
a) In storage PCBs to be destroyed by Dec. 31, 2005.
a) Assess sediment contamination and submit clean-up
plan to MOE in the Feb 1, 2001 semi-annual report.
b) Complete clean-up and submit summary report to
MOE in the first semi-annual report following
completion of the work.
a) Continue groundwater monitoring program and
submit results to MOE on a four-year cycle (2001 &
2005).
b) Develop and submit a Closure Plan to MOE in the
Feb 1, 2002, semi-annual report.
Recycle all in-storage Mercury by Dec. 31, 2001.
a) Complete a review of the code by Dec. 31, 2000.
b) Develop an implementation strategy by June 30,
2001.
c) Provide an annual progress report on the
implementation of the code.
 4.1.1  Benzene Air Emissions Reduction (Cokemaking)

       For the purposes of this Agreement, the 1993 base year for Benzene air emissions from ASI
       is reported to be 432 grams/tonne coke production.
       ASI has reduced total benzene loadings by approximately 27% since 1993. These reductions
       are a result of shutting down an older phenol plant in 1997 and replacing this facility with
       a biological waste treatment system. Benzene discharge levels were reduced in 1995 by
       loading and shipping of light oil by rail, rather than by ship, as was previously the case.

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      In addition to the above noted achievements, ASI will continue to reduce benzene air
      emissions over the period from 2000 to 2005. The reductions will occur in steps, with a
      reduction of 50% being achieved by December 31,2000(216 g/t); 75% being achieved by
      December 31, 2003(108  g/t); and further reductions to 85% (of the 1993  base year) by
      December 31, 2005. It is anticipated that the above reductions will be attained by the use of
      a technology referred to as "gas blanketing", whereby the volatiles such as benzene are
      prevented from gaining access to the atmosphere by use of an inert gas and a system to carry
      the resulting mixture to coke oven gas lines to be used as a fuel.  The emission reductions
      associated with the Benzene control program will be verified using third party auditing and
      the results of these audits will be reported in the following semi-annual report as identified
      in section 7.1.

      Good management practices will continue to be applied to the cokemaking process to reduce
      emissions from this source. ASI will make every effort to improve on the above schedule.

4.1.2  PAH Air Emissions Reduction (Cokemaking)

      For the purposes of this Agreement, the 1993 base year for PAH air emissions rate from ASI
      is reported to be 21.3 grams/tonne of coke produced from the three batteries.

      PAH emissions are reduced by the use of good operating and maintenance practices on the
      coke oven batteries. ASI lias made significant reductions in the level ofPAHs as a result of
      adopting these practices and the application of annual cokemaking plans over the past 10
      years.

      ASI'will reduce  PAH air emissions  in steps,  with a reduction of 20% being achieved by
      December 31,2000(17g/t); and 54% being achieved by December 31,2005(9.8 g/t) from the
      base year.

      These reduction levels will satisfy the  1996 Strategic Options Report objectives and are
      equivalent to the reductions committed to in the CSPA Statement of Commitment and
      Actions.

      Measurement of PAH emission levels to monitor progress towards the  above  goals, will
      occur  by the use of the  observation and  calculation methods developed by the CSPA,
      Environment Committee. The emission  reductions associated  with the PAH reduction
      program will be verified  using third party auditing and the results of these  audits will be
      reported in the following semi-annual report as identified in section 7.1.

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       The measurement of ambient levels ofPAHs will continue to assist in measuring progress
       in meeting these reduction targets.

4.1.3   Blast Furnace Visible Emissions

       j4SY will continue to apply flame technology to enhance the control of visible emissions from
       this source.  ASI will set up a study team to further develop and maximize this control
       method. A flame emission control system is presently in use on the #7 Blast Furnace.

       The present system while meeting its original purpose, was recognized by ASI as being less
       than optimally efficient. The design of the flame suppression system will be changed to
       enhance the blanketing  and dispersion characteristics of the flame. This will allow more
       efficient displacement of oxygen at the interface of molten iron and air and thereby reduce
       the formation of fugitive particulate emissions of iron oxide.

       ASI believes there is opportunity to better understand the technical aspects of the application
       and thereby develop a very practical and innovative technology. It is expected that the flame
       suppression equipment  will be installed  in mid-2000.  The  results of this study will be
       provided to MOE and EC in the February 1, 2001 semi-annual progress report.

       In the event that the flame suppression trial does not produce satisfactory results, ASI will
       continue to pursue alternative methods to reduce Blast Furnace visible emissions. All
       activities arising from this effort will be reported in each semi annual progress report.

4.1.4  Annual Cokemaking Plans

       ASI will provide the MOE and EC with annual Cokemaking Plans included in each February
       1 semi-annual report as outlined in section 7.1. The purpose of these plans  is to provide
       continuous improvement to the coke oven batteries and  to reduce emissions over time,
       through the application  of proactive maintenance techniques.

       Annual Cokemaking Plans have been provided to the MOE for a number of years and have
       proven to be a valuable  tool in reducing emissions from the batteries. ASI will continue to
       implement these plans  to reduce both visible and PAH emissions in accordance with the
       ongoing commitments made in the annual plans.

4.1.5  PCB Destruction
       ASFs holdings of waste Polychlorinated Biphenyls (PCBs) and equipment are contained in
       secure storage that currently meets both provincial and federal legislation.

       An inventory of ASFs total  PCB holdings as of December 31, 1999, is attached as Appendix
       . 3. The amount recorded in the report represents the current stored inventory for the purposes
       of this agreement. ASI will eliminate a volume of PCB's equivalent to the stored inventory

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      by December 31, 2005. Elimination of PCB's will begin no later than December 31, 2001.
      ASI will make every reasonable effort to eliminate all PCBs and equipment from usage.

4.1.6  ASI Boat Slip

      The ASI boat slip was last dredged in 1995. At that time approximately 11,500 cubic metres
      of dredge materials from the Slip were disposed of in the ASI waste disposal site.  ASI will
      sample and analyze the sediments  for Contaminants above Provincial Sediment Quality
      Guidelines, in accordance with the same terms of reference used in the 1993 study of Slip
      sediment   quality.   The  results  of this  monitoring  plan  along with  appropriate
      recommendations for any remedial work will be provided to MOE and EC for their review
      and comment as part of the February 1,  2001, semi-annual report.  If remedial work is
      required, this would be completed during the 2001 work season and a summary report on the
      clean-up activities will be provided to MOE and EC in the first semi annual report following
      the completion of the clean-up activities.

4.1.7  ASI Landfill

      ASI commits to continue a program of monitoring of the landfill site to assess trends in
       groundwater quality. The groundwater monitoring will be conducted on a four-year cycle
       commencing in 2001 and again in 2005. The results of the monitoring will be included in
       the first semi-annual report following completion of the studies as required in section 7.1.

      ASI commits to continue to make efforts to reduce the overall load of material sent to the
       landfill for disposal.

      ASI will commit to develop and implement a suitable long-term plan for the waste disposal
       site describing its site operations and closure. The plan will be submitted to MOE and EC
       as part of the February 1, 2002, semi-annual report.

4.1.8   Mercury Recycling

       Elemental  mercury has  a  number of uses  in industry,  including  electrical switching
       components.  As a result of taking this equipment out of service, ASI has accumulated an
       inventory  of mercury that is being stored in steel vaults.  ASI will  have  removed, by a
       licensed waste contractor, all stored mercury by December 31, 2001. The details of this
       program, including total Mercury  recovered, will be provided in the first semi-annual
       progress report subsequent to completion of the work.

4.1.9   Environmental Code of Practice

       EC has developed an Environmental Code of Practice  for Integrated Steel Mills as an
       outcome of the Strategic Options Process (SOP) for the Steel Manufacturing Sector. The
       Code is designed to identify the minimum environmental performance standard  for new
       integrated  steel mills and to provide a set of voluntary environmental performance goals for

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      existing facilities.

      ASI will continue to participate in the SOP and supports the principle of enhanced voluntary
      initiatives for the purpose of advancing environmental protection in Ontario and Canada.
      ASI will;
             i   Conduct a thorough review of the Code to determine:
                 -   ASPs current level of achievement with regard to each recommendation in
                    the Code;
                    which of the Code recommendations are achievable with the current
                    equipment at ASI',
                    what limitations there are in achieving any of the Code recommendations.
                    This review will be completed by December 31, 2000.

             ii   Develop  an  Implementation  Strategy  which will  prioritize  the  Code
                 recommendations into a schedule that is in step with ASfs other environmental
                 initiatives and commitments.  This will include an implementation timeline for
                 the  Code recommendations  that are deemed to be  achievable within the
                 timeframe of this EMA. This Implementation Strategy will be completed by June
                 30,2001.                                      .

             iii  Provide an annual progress report to the MOE and EC, which is consistent with
                 the reporting method developed by the CSPA. In the absence of such a reporting
                 method,  the progress will  be reported in a  manner  consistent  with the
                 requirements set out in Section 7.
Section 5  - General
5.1     Any request by ASI to change a requirement in this Agreement shall be made in writing to
       the MOE and EC with reasons for the request, at least 30 days prior to any specified date for
       meeting that requirement.  Details of this request will be subject to assessment and/or
       verification by the Director(s) and may require posting on the EBR registry and Green Lane
       internet site.

5.2     The requirements of this Agreement are undertaken on a voluntary basis and currently exceed
       regulatory requirements.  Compliance with this Agreement does not relieve ASI from:

       5.2.1   complying with any applicable order, statute, regulation, municipal, provincial or
              federal requirements; and
       5.2.2   obtaining any approvals, such as certificates of approval or consents, required by
              law.

5.3     Nothing in this Agreement shall be interpreted as preventing the MOE or EC from issuing

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       orders against ASI, taking any other steps to bring about compliance by ASI or to prosecuting
       ASI for any non-compliance, including anything related to this Agreement.

5.4    Nothing in this Agreement shall be interpreted as preventing the MOE or EC from proposing
       and implementing new legislation or new policies, including that which is related to matters
       covered by this Agreement.

5.5    In the event any party to this Agreement is, in the opinion of the Director(s), rendered unable
       to perform or comply with any commitments herein because of

       5.5.1   natural phenomenon of an  exceptional, inevitable or irresistible  nature, or
              insurrections, or

       5.5.2   strikes, lockouts or other industrial disturbances, or

       5.5.3   inability to obtain materials or equipment for reasons beyond the control of ASI, or

       5.5.4   any other cause whether similar to or different from the foregoing beyond the
              reasonable control of the parties,

       the commitments herein, to the extent that they are affected by the circumstances in 5.5.1
       through 5.5.4 above, may be modified in a manner mutually agreed upon by the parties.

       ASI must notify the MOE and EC immediately of any of the circumstances  in 5.5  and
       provide details that demonstrate that no practical alternatives are feasible in order to meet the
       commitments.   ASI shall  provide a written explanation for its failure  to meet  the
       commitments herein, and such explanation shall be in a format suitable for posting on the
       EBR registry and the Green Lane.

5.6    This Agreement shall be in force from the date of signing to December 31, 2005.

5.7    Termination of this Agreement can be initiated by any of the parties at any time. Notice of
       intent to terminate this Agreement, along with an appropriate rationale, shall be provided to
       the other parties no  less than 30 days prior to the date of termination. The rationale will be
       posted on the EBR registry and the Green Lane .

5.8    This agreement shall not be legally binding and shall not give rise to any rights or obligations
       and shall not be enforceable in any court of law.
                                            10

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Section 6- Public Consultation

6.1    Two (2) members representing the broader public participated on an advisory committee
       which evaluated and commented on matters relating to the development of the draft EMA.
       The Terms of Reference for this committee, which have been agreed to by the parties, are
       appended to this EMA as appendix 4.
Section 7 - Reporting

7.1    ASI shall provide semi-annual progress reports to the Director of Northern Region of MOE
       and the Regional Director of EC, Ontario Region in a format acceptable to the Director(s).
       The reports will detail all activities associated with the advancement of the goals  and
       objectives identified in Section 3 of this EMA and shall include, but not be limited to, the
       following:

       7.1.1  A discussion of the status of activities as they relate to completion dates specified in
              Section 4.

       7.1.2  A discussion of the impact of work completed as it relates to reductions of emissions
              or other progress towards the goals and objectives agreed to in Section 3.

       7.1.3  A full accounting of issues that occurred which have resulted in ASI not being able
              to maintain the progress on and completion of activities set out in Section 4.

       7.1.4  Facility wide emission  inventories, which  will include an  assessment  of the primary
              pollutants [oxides of nitrogen (NOx), oxides of  sulphur (SOx), Volatile  Organic
              Compounds (VOCs), total suspended particulate (TSP) Carbon Monoxide (CO)]  and
              Carbon Dioxide (CO2) will be produced and submitted with the appropriate semi-annual
              report for the calendar years 2000, 2003 and 2005. The TSP evaluation will  include a
              reporting of the fine particulate matter (PM10,2.5).

 7.2    Semi-annual progress reports shall be provided to MOE and EC by August 1st and February 1s1 in
       each year that this Agreement is in effect.

 7.3    The first semi-annual progress  report  will be due  by  February 1,  2001, and will summarize
       activities including all matters set  out in this Agreement.

 7.4    Progress reports  submitted by  ASI pursuant  to 7.1 are public and will be subject to public
       distribution. The semi-annual reports will include an executive summary. Information regarding
       the progress reports will be posted on the EBR registry and the Green Lane.

 7.5    On site assessment associated with progress and completion of projects identified in this Agreement
       will be the responsibility of the MOE.
                                           11

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Signed:
                   Algoma Steel Inc.
                                                               Date:  I
Signed:
                          .ad——
               :r Majesty the Queen in Right of Ontario as
               presented by the Minister of the Environment.
Date:
In I
                                                                               OQ
Signed:
             He^ Majesty the Queen in Right of Canada as
             Represented by the Minister of the Environment.
                                                               Date:
                                        12

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                                   APPENDIX 1

The following list identifies 18 polynuclear aromatic hydrocarbons (PAHs) which are routinely
analyzed to assess PAH release into the environment. This list represents the significant
compounds studied by Algoma Steel Inc. in assessing the boat slip remediation conducted in
1993. This list contains the 16 compounds which the Ministry of the Environment laboratory has
approved analytical methods for and includes Benzo (j) Fluoranthene, Fluorene and perylene.
      Acenaphthene

      Acenaphthylene

      Anthracene

      Benzo (a) Anthracene

      Benzo (a) Pyrene

      Benzo (b) Fluoranthene

      Benzo (ghi) Perylene

      Benzo (j) Fluoranthene

      Benzo (k) Fluoranthene

      Chrysene

      Dibenzo (a,h) Anthracene

      Fluoranthene

      Fluorene

      Indeno (1,2,3-cd) Pyrene.

      Naphthalene

      Perylene

      Phenanthrene

      Pyrene

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                                     APPENDIX 2
         Canada Ontario Agreement respecting the Great Lakes Basin Ecosystem

Tier 1 substances:                               Tier II substances:
The Tier 1 listing includes the 11 critical
pollutants identified by the International Joint
Commission, plus critical pollutants identified
in the Niagara River and Lake Ontario Toxic
Management Plans and the Lake Superior
Binational Program. Tier  1 pollutants are
targeted for virtual elimination by adopting the
philosophy of zero discharge for local or direct
sources, and by encouraging similar actions
binationally and globally in order to eliminate
distant sources or long-range transport as inputs
to the Great Lakes Basin.

       Aldrin/dieldrin

       Benzo(a)pyrene

       Chlordane

       DDT
       Hexachlorobenzene

       Alkyl-lead

       Mercury

       Mirex

       Octachlorostyrene

       PCBs

       PCCD (dioxins)

       PCDF (furans)

       Toxaphene
Tier II compounds include substances
identified by science-based screening
methodologies or Lakewide Management
Plans. These substances have the potential for
causing widespread impacts, or have already
caused local adverse impacts on the Great
Lakes environment.

       Anthracene
       Cadmium
       1,4-dichlorobenzene
       3,3'-dichlorobenzidine
       Dinitropyrene
       Hexachlorocyclohexane
       4,4"-methylenebis(2-chloraniline)

       Pentachlorophenpl
       Tributyl tin
Plus 17 PAH's as a group, including but not
limited to:

       Benz(a)anthracene
       Benzo(b)fluoranthene
       Benzo(g,h,i)perylene

       Perylene
       Phenanthrene

Tier II will be updated periodically, on the
basis of sound science, to ensure emerging
contaminant issues are addressed as
information becomes available. Persistent,
bioaccumulative and toxic substances may be
elevated from the Tier II listing through a
weight-of-evidence approach, and through a
process of stakeholder consultation.

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I .PCS Site Identification
            APPENDIX 3
PCB site no.
          503 85 A016
             WASTE CLASS 243 D
2 PCB Holder
name of company holdng PCB
Algoma Steel Inc.
Contact Person
Craig Knight
Signature
Tel no
(705)945-3149
3.PCB Site Location
Queen Street West
Sault Ste. Marie Ontario
Northeastern Region
^.Corporate Name and Address of Holder
Sault Ste. Marie, Ont
5. The generator Registration Number associated with this PCB waste
storage site must be entered here.	•	
                               ON0393200
6. Date Survey Completed
                   December 31, 1999
7. Liquids
a. bulk liquid
b. transformers
c. total liquid in transformers
high Level (over 10000 ppm)
Litres
9,260.87
No. of transformers
67
Litres
24,583.544
low level (50-1 0000 ppm)
Litres
10,379.69
No. of transformers
4
Litres
215.5
8. Solids
Capacitors
a. Ballasts
b. other capacitors
c. total weight other capacitors/large
cap./other equip.
No. of Drums
3
No. of Capacitors
63 Barrels
Kg.
548.1
Soil/Gravel
d. soil and gravel
e. Total weight not in drums
No. of Drums
Kg.
3200
No. of Drums
KB.
Olher Solids
f. clothing
g.total weight
No. of Drums
46 (1 empty)
Kg-
No. of Drums
32
Kg.

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                                     APPENDIX 4

                 ASI HARMONIZATION PILOT ADVISORY COMMITTEE

                                 TERMS Of REFERENCE
Membership  Membership is to be comprised of two representatives from the public. Other stake-
              holders who will participate in meetings of this advisory committee include
              representatives from ASI, EPB-OR and MOE ("the parties" as defined in section 1 of
              the agreement)

              Nomination of the 2 members from the public shall be based on their ability to
              represent the broadest constituency. Factors considered for nominee selection  include; a
              history of public involvement/experience/knovvledge, commitment and ability to
              represent and report to the public and, knowledge in the workings of ASI, EPB-OR and
              MOE. Appointment of public members to this committee will be by consensus
              agreement of the parties.

Purpose      This committee is established to provide advice to the parties, on matters related to the
              development of a voluntary environmental plan for ASI. The advisory committee will
              provide assistance to the parties by;

              •      ensuring timely and accurate distribution of information to all stakeholders in
                     relation to the development and finalization of the Environmental Management
                     Agreement (EMA)

              •      reviewing and providing comment to the project coordinator on issues related
                     to completion of steps identified in the detailed work plan

              •      reviewing and providing comment to the project coordinator on relative
                     priorities of projects as they are being negotiated in the EMA

              •      reviewing and commenting on the action items  or project list identified in the
                     EMA

              •      receiving contacts and reviewing information from individuals, groups, other
                     parties or agencies having a interest in this EMA

Chair         The chair will be the project coordinator for the term of the pilot program work plan.
              The chair will be responsible for arranging an agenda and producing minutes for each
              meeting.

Meetings      Meetings will be called by the chair as necessary. The duration of this committee is
              expected not to exceed six months or until a final EMA is completed.

Reporting     Members are encouraged to provide a two way flow of information between their
              respective associates and this committee. Information arising from business of this
              committee is public and will be distributed to other affected parties as required. This
              will be the responsibility of the committee chair.

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