DRAFT DELIBERATIVE COPY
DO NOT QUOTE, CITE OR RELEASE
United States Response to Recommendations in
the International Joint Commission's Ninth Biennial Report
on Great Lakes Water Quality
United States Department of State
and
United States Environmental Protection Agency
Great Lakes National Program Office
Chicago, Illinois
June 1999
DRAFT DELIBERATIVE COPY
DO NOT QUOTE, CITE OR RELEASE
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
INTRODUCTION
The United States (U.S.) compliments the International Joint Commission (the Commission or "IJC")
on the release of its Ninth Biennial Report on Great Lakes Water Quality. It contains thoughtful
recommendations for actions by the U.S. and Canada (the Parties).
The Parties have made significant efforts and expenditures to address adverse environmental
impacts and to mitigating or reversing the subsequent effects. The Parties take pride in their
cooperative efforts in working toward proactive solutions to avoid new impacts and to protect the
Great Lakes Ecosystem from degradation. The U.S. wishes to assure the Commission of its firm
commitment to continue these efforts.
The Commission's Ninth Biennial Report, as in reports past, stresses the need to continue the
Parties' efforts in reducing and virtually eliminating, persistent toxics from the Great Lakes. In
addition, the Commission has increased its focus on the potential impacts of radioactive
substances. The U.S. remains committed to this effort, and along with our Canadian partners, is
actively engaged in national, binational, regional, and global efforts to address persistent organic
toxic pollutants, be they from air emissions, from nonpoint sources, or from traditional point
sources. The U.S. feels that this multilevel approach will increase the pace of toxics reduction in the
Great Lakes and within the international community.
The Commission has once again expressed concern over the way in which reductions in government
funding may affect Agreement activities. The U.S. is aware of the need for vigilance and innovation
to protect and to more efficiently use limited resources. We take very seriously our responsibility to
protect the citizens we represent. The U.S. commitment to the Great Lakes remains firm and
undiminished. We are actively engaged in insuring that the needs of the Great Lakes are well met
through the efficient use of all resources. The development of SOLEC indicators, for example, will
help to target monitoring resources.
It is important to note that this response, while highlighting a small selection of representative
activities, reflects the wide universe of programs being undertaken by the large number of U.S.
Great Lakes partners. These partners include Federal, State, Tribal and local agencies as well as
public, private and non-profit businesses and organizations. This vast array creates a synergy which
has led to the significant environmental improvements in the Great Lakes Basin.
The U.S. feels that it is important to strongly reiterate that there are a variety of stressors impacting
the Great Lakes ecosystem. We recognize and are addressing the impacts of toxic substances
through a variety of existing and new, innovative efforts. But there is also an equally important
need to address other areas of vital importance to the health of the Great Lakes. These include, but
are not limited to, the protection and restoration of important habitats; enhancing biodiversity;
controlling the impacts of exotic species and limiting future introductions; and promoting
sustainable patterns of development. The breadth and magnitude of the stressors impacting the
Great Lakes both argues for and bolsters the ecosystem approach to research and management of
the Basin which forms the cornerstone of our efforts. The U.S. encourages the IJC to make
recommendations as to how the Parties can make further progress in furthering the adoption and
full implementation of the ecosystem approach.
Page 1 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
On behalf of the entire U.S. Great Lakes community, the U.S. Department of State and the U.S.
Environmental Protection Agency (EPA) are pleased to present this Nation's response to the
Commission's Ninth Biennial Report on Great Lakes Water Quality.
Page 2 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
CONTAMINATED SEDIMENTS
1. Governments provide detailed work plans, schedules and benchmarks to complete
sediment remediation projects in the eight Areas of Concern for which remediation
decisions have been made but action is pending.
2. Governments make sediment remediation and management decisions for the 31 Areas
of Concern that remain under assessment, and provide detailed work plans, schedules
and benchmarks to initiate and complete sediment remediation.
The United States Great Lakes Program is strongly committed to managing and, where
recommended and as opportunities arise, remediating Great Lakes contaminated sediments in all
Areas of Concern (AOC) and in other priority areas of the Basin which do not have AOC status.
Through the Assessment and Remediation of Contaminated Sediments Program, as well as
innovative sediment remediation activities undertaken by the EPA, the U.S. Army Corps of Engineers
(USAGE), and the eight Great Lakes States, the Basin has long been recognized as a leading forum
for sediment management and remediation. Indeed, the U.S. continues to refine its understanding
of the issues involved in making these types of decisions and is committed to making them with full
public participation.
To date, many resources have been applied to remediate sediments in the Basin which have led to
large amount of contaminated sediments being removed from the environment, including recent or
ongoing removals of approximately 600,000 cubic yards (cy) at the following sites:
* 8,000 cy of PCB-contaminated sediment (56,000 Ibs. of PCBs) from the Unnamed Tributary
of the Ottawa River, Ohio; completed in June 1998, achieving a clean up of 5-10 ppm
residual PCBs;
* 28,000 cy of PCB-contaminated sediment (45,000 Ibs. of PCBs) from the Ford Monroe site
on the River Raisin, Ml; completed in the summer of 1997, achieving a clean up of 3-5 ppm
residual PCBs;
> 72,000 cy of PCB-contaminated sediment (2,700 Ibs. of PCBs) from the Manistique River
and Harbor, Ml from 1995 -1998, thus far achieving the clean up goal of less than 10 ppm;
an additional 45,000 cy will be removed during the Summer of 1999;
» 63,000 cy out of a total 103,000 cy of PCB-contaminated sediment (10,000 Ibs. PCBs total)
from Bryant Mill Pond, Kalamazoo River, Ml; to be completed April 1999; thus far achieving
0.1 - 0.6 ppm residual PCBs;
» 450,000 cy of PCB-contaminated sediment and soil (300,000 Ibs. of PCBs) from the Willow
Run Creek, Huron River, Ml; achieving the 1 ppm clean up goal for sediment.
* The USAGE is moving forward with a Comprehensive Dredge Material Management Plan for
Waukegan Harbor. Currently the plan calls for dredging 250,000 cy of polluted material by
2002. A critical component of the plan is securing an acceptable site for a confined
disposal facility.
Page 3 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
Many of these and similar efforts have been highlighted in EPA reports which cover remedial
activities achieved through a number of partnerships with federal, state and tribal agencies. These
reports include "MovingMud"a synopsis of EPA's Great Lakes National Program Office's (GLNPO)
sediment grants program; and "RealizingRemediation, "a summary of 33 past or current sediment
remediation projects, led by either EPA or by a state environmental agency.
For the six U.S. AOCs for which remediation decisions have been made, substantial progress has
been achieved, or will be made in the near future, to address contaminated sediments. Working
through the established Remedial Action Plan (RAP) programs in each AOC, site-specific solutions to
sediment problems were devised and have been or will be implemented. Most of these
remediation decisions have moved toward the implementation phase. The U.S. will also highlight
these activities through website postings and other technology transfer venues in order to promote
successful cleanup actions within and outside of the Basin.
For the remaining U.S. AOCs where sediment contamination is being assessed, those U.S. federal
and state agencies with the legal authorities to develop plans and take action in remediating these
sites are working in close cooperation with the RAP processes to develop the detailed work plans,
schedules and benchmarks needed to complete sediment remediation and other important
projects. The local RAP programs are best able to set schedules for implementing these actions.
They provide a context of which actions are needed to restore beneficial use impairments, generate
local support for these actions, and report on progress. The U.S. will follow this decision-making
process as we work towards remediating these sites. Centralized decision-making could have the
unfortunate result of undermining locally-driven processes, while creating expectations which may
not accommodate local concerns. This is further complicated because meaningful deadlines need
guaranteed resources to undertake these complicated and oftentimes expensive projects. As we
have seen in a number of large-scale remediation (such as the Unnamed Tributary to the Ottawa
River), private sector funding can play a vital role. It would be difficult at best to incorporate such
an important funding source, which may arise on an ad hoc basis, into schedules and workplans.
We agree with the IJC's own findings regarding the impediments to progress in this area. The White
Paper on Contaminated Sediments (written by the Sediment Priority Action Committee, or SEDPAC,
formed under the auspices of the IJC) correctly highlights the following reasons for the slow pace of
cleanups: limited funding and resources; regulatory complexity; lack of a decision-making
framework; limited corporate involvement; insufficient research and technology development; and
limited public and local support. The relative importance of these obstacles varies from site to site,
and differs in the U.S. and Canada.
The EPA published a document entitled, EPA's Contaminated Sediment Management Strategy in
April 1998 (EPA-823-R-98-001), describing goals, policies, and how we intend to accomplish these
goals for managing the problem of contaminated sediment and actions that EPA intends to take to
accomplish those goals. This EPA nationwide strategy specifically notes the importance of meeting
the goals of the Lakewide Management Plans (LaMPs) and RAPs (page 56). The stated goal for
active remediation and natural attenuation projects, outlined in this strategy is, "...to achieve
sediments that pose no acute or chronic toxicity to aquatic life and wildlife, and no significant risk to
human health and the environment". In the U.S., the specific framework utilized to achieve this
goal will vary, depending on the governmental program used to achieve it. The U.S. does not feel
Page 4 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
that the development of detailed work plans, schedules and benchmarks, prepared outside of the
context of the RAPs and governmental programs utilized to achieve RAP goals, is the best use of
resources.
We do recognize the importance of deadlines but we feel that this is the purview of each RAP
process as they work to define these goals with local stakeholders and those federal and state
agencies which implement the remedial activities. We would question the value of developing and
submitting such schedules to a third party external to the RAP process. It should also be noted that
there is the possibility that some RAPs may determine that sediment remediation is not practicable
and that natural processes should be allowed to remediate the pollution once sources are
controlled. We will make every effort to ensure that RAPs articulate schedules and deadlines when
they are established.
On April 7, 1997, the United States and Canada signed " The Great Lakes Binational Toxics Strategy:
Canada-United States Strategy for the Virtual Elimination of Persistent Toxic Substances in the Great
Lakes (BNS). A goal was agreed to by both Governments for contaminated sediments to "Complete
or be well advanced in remediation of priority sites with contaminated bottom sediments in the
Great Lakes Basin by 2006." We believe that the United States will achieve this goal. As part of our
commitment to this goal we will track and report progress achieved.
AIR POLLUTION
3. Governments accelerate development of integrated, binational programs, including
common benchmarks and schedules, to reduce and eliminate specific sources of toxic
and persistent toxic substances to the atmosphere, including sources outside the Great
Lakes basin.
The reduction and elimination of specific sources of toxic and persistent toxic substances to the
atmosphere, including sources outside the Great Lakes basin, is essential. Studies have shown that
atmospheric deposition is a major pathway for toxic contaminants in the Great Lakes, including from
sources outside the basin. The U.S. is accelerating the development of integrated programs and as
a result of these efforts, there are an increasing number of activities to address emissions of toxic
substances. The following are some of the ongoing regulatory and voluntary initiatives that will
reduce atmospheric deposition of toxic substances to the Great Lakes.
Binational Toxics Strategy
EPA and Environment Canada, in collaboration with other stakeholders, are implementing the Great
Lakes Binational Toxics Strategy: Canada-United States Strategy for the Virtual Elimination of
Persistent Toxic Substances in the Great Lakes (BNS). A number of actions are now occurring to
achieve the use and release reduction goals for the substances targeted by the BNS:
dioxins/furans, mercury, PCBs, hexachlorobenzene, benzo(a)pyrene, alkyl lead, octachlorostyrene,
and a number of canceled or restricted pesticides. Now two years into the implementation of the
BNS, some of the progress that has been made includes:
Page 5 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
Agreements have been entered into with the American Hospital Association to eliminate
mercury from hospital waste; three northwest Indiana steel mills to reduce their use of
mercury; and the chlor-alkali industry to reduce mercury use by 50 percent from 1990-1995
levels.
Clean Sweeps have been conducted which have included BTS banned pesticides.
We have confirmed that there is no longer use of alkyl-lead in automotive gasoline.
An assessment of the long-range transport contributions of toxic substances to the Great
Lakes is being conducted.
A wide number of stakeholders, including industrial and environmental groups, are
participating in implementing the BNS and are designing additional actions to assist in
meeting the Strategy's goals.
PBT Strategy
EPA has developed a draft national toxics reduction plan, the draft Persistent, Bioaccumulative and
Toxic (PBT) Strategy. The PBT Strategy will use a coordinated effort among all national and regional
programs for the reduction of PBT substances in the environment. Action Plans are being
developed for each PBT substance or group of substances and should be available by December
1999. An action plan for mercury has already been drafted and is currently under revision, taking
into account those recommendations obtained during the public comment period. And work is
ongoing for identifying additional PBT substances for action. The PBT Strategy will assist in
obtaining out of basin reductions of persistent toxic substances.
Regulations/Guidance
EPA published final rules which apply to certain municipal solid waste incinerators (large units,
meaning those with a combustion capacity greater than 250 tons of municipal waster per day) that
include new requirements for emission limitation to control chlorinated dioxins, mercury, particulate
matter and carbon monoxide, and plans to finalize rules for medical waste incinerators. EPA is also
in the process of finalizing rules for hazardous waste combustors that will reduce emissions of toxic
pollutants. The combined effect of federal, state, and voluntary private section initiatives will result
in a 75 percent or greater reduction in total dioxin releases to air between a!987 and 2006.
The use of leaded gasoline in on-road vehicles is prohibited under Clean Air Act regulations. As a
result, the use of leaded gas in on-road vehicles has been virtually eliminated. In 1998, EPA issued
a notice that it was planning to include "Gasoline Distribution Stage I Aviation" in a listing under
Section 112(c)(6) of the Clean Air Act that would place aviation gasoline, a source of alkyl lead, on a
schedule for the development of Maximum Achievable Control Technology (MACT) regulations.
Page 6 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
As a result of the Synthetic Organic Chemical Manufacturing Industry Hazardous Organic National
Emission Standards for Hazardous Air Pollutants (NESHAP), there has been about a 90% reduction
in hexachlorobenzene (HOB) air emissions since 1990. A proposed air toxic standard for pesticide
active ingredients will further reduce HOB emissions.
EPA is conducting research on treatment options for mercury wastes, taking into account air
emissions from such treatment. The Agency is collecting data on air emissions during treatment of
mercury-containing wastes and will be publishing an Notice of Proposed Rulemaking concerning
potential revision of the land disposal restrictions for mercury containing waste.
The Administrator of EPA must make a finding as to whether regulation of mercury is appropriate
and necessary by the end of the year 2000. In order to assure that this finding and any subsequent
decisions regarding mercury are based on the best scientific information EPA is undertaking a
number of inquiries, including:
Using the information gathering authority under the Clean Air Act EPA is requiring all coal
fired power plants of greater than 25MW to report the mercury content of their coal and a
sample of the plants to do actual stack testing. Emissions factors generated from the stack
test results will allow EPA to calculate mercury emissions estimates for each coal fired plant.
This effort will provide the best inventory of mercury emissions from electric power plants
and will provide data on the species in which mercury is emitted. The species of mercury
emissions is important because different species behave differently in transport and
because mercury control technology effectiveness varies by species. The first quarter
reports on the mercury in coal were due to EPA on May 15 and the EPA will publish the
results on its web-site shortly. This information collection will continue through 1999.
Conducting a two-phase research program to develop more cost effective technologies to
control mercury emissions from coal-fired electric power generating plants. The first phase
includes activities prior to December 2000, when the Administrator will make a finding. This
phase emphasizes evaluation and small scale piloting of technologies for mercury control
and includes engineering and economic studies. The second phase will consist of three to
five large scale pilots of promising technologies that will be conducted with the Department
of Energy and the Electric Power Research Institute and will be partnered with industry.
These large scale pilots will focus on several primary types of plant configurations.
EPA is funding a review of recent mercury health research by the National Academy of
Sciences. This review which is about to begin and expected to take a year will assure that
EPA has the very latest information from emerging health studies concerning mercury.
In addition to these efforts other EPA research activities concerning mercury include those that will
improve our understanding of mercury transport and fate in the environment and human exposure
to mercury.
International Efforts
Internationally, efforts include a legally-binding protocol on persistent organic pollutants (POPs)
negotiated in February 1998 by members of the United Nations Economic Commission for Europe
Page 7 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
under the Convention on Long-Range Transboundary Air Pollution (LRTAP). The objective of the
LRTAP protocol is to control, reduce or eliminate releases of persistent, organic pollutants, including
the substances targeted by the BNS. In June 1998, 55 member countries signed the LRTAP
protocol. A second pact signed by the member countries will reduce emissions of lead, cadmium
and mercury below 1990 levels and phase out unleaded gasoline. EPA is also working on possible
new U.S. legislation for import and export requirements for hazardous and other wastes under the
Basel Convention.
Under the United Nations Environment Program, a global Persistent Organic Pollutant (POPs) treaty
is presently being negotiated. The goal is to complete agreement on the first 12 POPs chemicals
and on the criteria for selecting additional chemicals by the end of the year 2000.
The U.S., Canada and Mexico, under the authority of the North American Agreement on
Environmental Cooperation, and under the auspices of the Commission for Environmental
Cooperation have developed North American Regional Action Plans for mercury, PCBs, DDT, and
chlordane. These four action plans on persistent and toxic substances represents the common
desire of these three countries to address national and regional concerns associated with the sound
management of chemicals.
4. Governments develop and communicate to the public, by December 31, 2000, a
comprehensive strategy for altering established energy production and use patterns to
achieve reductions in mercury and nitrogen oxide emissions.
In the broadest context, the goals and strategies of the most recent national energy strategy
(Comprehensive National Energy Strategy, April 1998; DOE/S-1024;
http://www.hr.doe.gov/nesp/cnes.htm) communicates the U.S. approach to addressing
environmental issues in energy production and use. This approach provides a market-based energy
strategy for the simultaneous pursuit of various national goals, such as improving energy efficiency,
expanding the portfolio of clean energy sources, and promoting environmentally protective energy
production and use. In the more focused context of pursuing emission reduction goals in the U.S.,
EPA has generally preferred flexibility in selecting cost-effective compliance options rather than
prescribing any particular means to achieve those reductions. Thus, development of a separate
"strategy for altering established energy production and use patterns" as recommended by the IJC is
neither necessary nor the ideal approach for the U.S.
However, EPA is fostering actions to reduce harmful emissions that may result in changes in energy
production and use patterns. In addition, there are several voluntary programs managed by EPA
and other agencies which encourage more efficient production and use of electricity, such as the
Green Lights and Energy Star Programs, and the new Combined Heat and Power Challenge.
Several activities are underway to address emissions of nitrogen oxides (NOx) and mercury, and to
track emissions changes that may result from restructuring of the power generating industry. In
2000, implementation of the second phase of NOx emission reductions under the Acid Rain
Program will reduce these emissions from utility boilers by two million tons. Actual NOx emissions
are monitored at all major U.S. power plants by continuous and other monitoring systems, and this
data is available to the public.
Page 8 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
Following the adoption of an open transmission access rule (Order 888) by the Federal Energy
Regulatory Commission (FERC) in May 1996, EPA, in conjunction with FERC and the Department of
Energy, embarked on developing a data system for tracking possible emissions increases related to
electricity industry restructuring. This has evolved into the Emissions and Generation Resource
Integrated Database (E-GRID), which will be released by EPA in the near future. In a single public
database, E-GRID will contain data collected by various agencies, including emissions profiles and
resource mixes for all power plants, electric generating companies, and regions of the U.S. power
grid. E-GRID will provide data necessary for policy and regulatory development in areas such as
output-based emission standards, renewable portfolio standards, and emissions disclosure to
consumers. And in September 1998, EPA called for a reduction in NOx emissions by 1.1 million
tons annually in 22 eastern states. EPA expects this action to mitigate ozone transport problems
associated with power generation.
Regarding mercury emissions, EPA has established emission standards (for new units) and emission
guidelines (to be implemented by states for existing units) for municipal waste combustors and
medical waste incinerators (the latter is referred to as the hospital/medical/infectious waste
incinerator final rule because it covers both hospital waste and medical infectious waste). When
fully implemented, these rules will reduce mercury emissions from municipal waste sources by
about 90 percent, and from medical incinerators by 95 percent. And in the very near future, EPA
will issue a standard for hazardous air pollutants, including mercury, from hazardous waste
combustion facilities. Work is underway to develop standards for several categories of combustion
units and for chlor-alkali plants. Coal-burning electric utilities are the highest remaining source
category in the U.S., and the EPA will issue a determination in December 2000 whether regulation
of air toxics emissions, including mercury, from utilities is appropriate and necessary to protect
public health. During this period, EPA will collect, and increase public access to, data on mercury
emissions from power plants, and together with the Department of Energy will support the
development and commercialization of cost-effective control technologies for mercury emissions.
Efforts are underway to continue to report and communicate with the public on progress made in all
of these areas.
AGRICULTURAL PRACTICES
5. Governments adopt the following agricultural and land-use goals and targets:
to place at least 55 per cent of the Great Lakes basin row-crop acreage into
conservation tillage by 2002;
to increase buffer-strip mileage in the Great Lakes basin by at least 30 per cent by
2002 [1998 baseline]; and
to reduce herbicide loads to the Great Lakes by at least 30 per cent by 2005.
The U.S. fully endorses the goals and targets of this recommendation and hopes to be able to
exceed these very important goals regarding the state of environmental conservation and pollution
reduction programs being implemented in the Great Lakes Basin. Many of the goals have been
incorporated into the strategic plans of various implementing agencies through the U.S.
Page 9 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
Government Performance and Results Act (GPRA).
The IJC is correct in highlighting how conservation practices such as conservation tillage and buffer
strips serve to reduce the loads of herbicides and pesticides to the surface and groundwater of the
Basin. In addition, innovative and important programs such as USDA's Conservation Reserve
Program (CRP), National Conservation Buffer Initiative, and Environment Quality Incentive Program
(EQIP) provide a "systems approach" for addressing agricultural nonpoint source pollution to the
Great Lakes. This approach aims for an end-product from which a "healthy land" is constructed,
which promotes sustainable production of food and fiber products while maintaining environmental
quality and a strong natural resource base.
In addition, EPA has several standing programs (e.g., Section 319 nonpoint source pollution control,
National Pollutant Discharge Elimination System (NPDES) permitting, State Revolving Fund) to
address soil erosion and sedimentation in the Basin, as well as numerous groundwater protection
activities. Overall government strategies are being coordinated under the Administration's Clean
Water Action Plan which will help achieve substantial reductions in nonpoint source pollution
through the setting of national goals which are coupled with on-the-ground activities at the
watershed level. This approach will allow nationwide goals to be tailored to the needs of a specific
watershed.
Responses to the three specific recommendations are listed below:
As reported in the Great Lakes Commission's April 1996 report entitled "An Agricultural Profile in
the Great Lakes Basin: Characteristics and Trends in Production, Land-use and Environmental Impacts, "
conservation tillage is rapidly becoming the primary cultivation practice in the Basin, affecting as
much as 70 percent of the total acreage in many counties, and 48 percent basinwide. The report
further states that most of southern Michigan, northern Ohio, and Indiana report conservation
tillage in excess of 60 percent (based on 1992 U.S. Agriculture Census). In the intervening years,
conservation tillage levels continue to increase. Nationally, the USDA goal for acreage under
conservation tillage is 50 percent of cropped acres by the year 2002. Conservation tillage can
reduce soil erosion by 50 to 90 percent compared to conventional tillage. As a corollary to
conservation tillage, more than 800,000 acres of highly erodible farmland in the Basin were
enrolled in the CRP Program, substantially reducing soil erosion and runoff. These practices can
also lead to sharply reduced levels of nutrient and herbicide runoff. The U.S. will continue to
strongly promote the implementation of these and other conservation programs throughout the
Great Lakes Basin.
The use of buffer strips is another important tool for limiting runoff and associated pollutants from
agricultural lands in the Basin. The 1996 Farm Bill created a major new opportunity to prevent
pollution and restore watersheds through a focused effort to put conservation buffers in place in
very rural watershed in this country. USDA's unprecedented National Conservation Buffer Initiative
is set to install conservation buffers along two million of the nation's 3.5 million riparian miles by
2002. Conservation buffers are strips of vegetation along the margins of farm fields, streams,
creeks, and lakes which intercept runoff water, nutrients, and pesticides before they can drain into
waterways. USDA will reserve four million acres from the CRP for the establishment of conservation
buffers. A baseline is currently being developed so that success on this goal can be tracked.
Page 10 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
The U.S. fully recognizes the need to further reduce the loadings of pesticides and herbicides to the
Great Lakes. Although over 120 pesticide actives ingredients are used in the Basin, the top five
herbicides alone (atrazine, metolachlor, cyanazine, acetochlor and alachlor) account for about 53
percent of the total volume, and are primarily applied in the southern Lake Michigan and western
Lake Ontario basins. Nonpoint source control programs are being coupled with toxic reduction
programs to achieve lower levels of herbicide use in the Basin. The previously cited "Agricultural
Profile"has highlighted a general decline in pesticide applications for the period 1981/82-1991/92
which is in a large part due to lower application rates for existing substances, as well as new
generation pesticides which are applied at much lower rates. Conservation tillage programs are
helping to reduce the use of herbicides. Chemicals are being specifically designed for the
conservation tillage market which allow for much lower application levels, which leads to reduced
runoff.
Under EPA's Agricultural Stewardship Program, the Agency hopes to place 75 percent of agricultural
lands under Integrated Pest Management (IPM) which will help to further reduce the use of
herbicides and the attendant potential for polluted runoff to the Lakes. Under the EQIP Program,
NRCS has the ability to cost-share IPM implementation activities.
A 1998 preliminary U.S. Department of Agriculture sponsored report entitled "Twenty-Five Year
Trend in the Potential for Environmental Risk from Pesticide Leaching and Runoff from Farm Fields "
highlighted environmental indicators of the potential for pesticide leaching and runoff from farm
fields. The report showed that the potential risk to drinking water through runoff in recent years
was only about 30 percent of the 1972 level, with the greatest decreases occurring in the Midwest
East Regions )which include the Great Lakes.
AOCSAND LAMPS
6. Governments implement the eight recommendations presented in the Commission's
report, Beacons of Light, that deal with human health, public-private partnerships,
funding and staffing, public participation, information transfer, quantification of
environmental benefits and public advisory council funding.
The U.S. remains committed to fully implementing the RAP Program at the 26 U.S. and five
binational AOCs. In all AOCs, active and meaningful involvement of all stakeholders, including
public, private, and governmental entities, is essential for achieving the restoration of beneficial
uses. We applaud the IJC's continuing efforts to review and analyze the RAP process to help the
Parties identify successful, efficient, and cost-effective strategies. In addition, the IJC is playing a
key role by helping the Parties disseminate important information regarding these strategies. The
report, Beacons of Light, is but one example of this type of value-added work. The in-depth reviews
of selected AOCs over the last biennium has also helped the Parties to better target their efforts.
This continuing complementary relationship between the Parties and IJC bodes well for future RAP
implementation and restoration activities.
The U.S. responses to specific recommendations contained in Beacons of Light are presented below.
Page 11 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
Human Health Considerations
IJC recommends that human health information being developed for LaMPs be incorporated as
appropriate into the RAP development process. This information should provide considerable
justification for many needed remedial actions in various AOCs and should especially be
disseminated within AOCs which have susceptible populations consuming sport-caught fish.
The LaMP programs and the AOCs located within the associated lake basin coordinate activities and
share information on a continuing basis. In the U.S., the LaMP Program Managers also have the
responsibility to track RAP progress. Through these parallel and complementary roles, these
managers can insure that LaMP-related human health information is incorporated into the RAP
decision-making process.
It also needs to be recognized that human health issues from a Great Lakes and/or lakewide
perspective might differ from the more localized RAP perspective. Many of the RAP processes are
already fully aware of human health issues which may be impacting susceptible local populations.
Some RAPs are also much farther along than the LaMPs; should the LaMPs adopt additional human
health issues, it may be difficult to incorporate these issues into the RAPs. While we agree that
human health is an important topic under both programs, the RAPs and LaMPs cannot address all
health issues and must therefore focus on those specifically related to water quality. LaMPs and
RAPs consider drinking water restrictions, consumption advisories and beach closings. These three
impairment indicators are the most direct indicators of potential human health threats and are
included in all LaMPs and RAPs. Many of these concerns are due to sediments contaminated with
past discharges of toxic substances. As these sources and point source discharges are either being
controlled or remediated, the U.S. will continue to actively address nonpoint and atmospheric
sources of toxic substances that can impact human health. Through the RAP and LaMP Programs,
the BNS, and other pollution prevention and control programs, the U.S. Great Lakes Program's goal
is to identify, prevent and remediate threats to human health.
The Agency for Toxic Substances and Disease Registry (ATSDR) has been very proactive in sharing
the research findings from its Great Lakes Human Health Effects Research Program (GLHHERP).
ATSDR GLHHERP is designed to investigate the potential for short- and long-term health effects
from consumption of contaminated Great Lakes fish. This research in being conducted in
susceptible populations including Native Americans, sport anglers, pregnant women, fetuses,
children, the urban poor, and the elderly because of their elevated exposures or physiologic
sensitivity to these contaminants. ATSDR has and currently participates in a number of LaMPs and
RAPs meetings, workshops, and committees to share the human health findings with these groups
and discuss the public health implications of these findings.
Public-Private Partnerships
The U.S. Environmental Protection Agency and the states of Indiana and Ohio cooperatively
compile lessons learned from the Ashtabula and Grand Calumet partnerships and disseminate
the information to other AOCs. IJC recommends that this successful strategy be looked at
carefully by both Federal Governments for application in other AOCs.
Page 12 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
The U.S. RAP partners throughout the Basin are looking at ways to improve the dissemination of
successful RAP partnerships. EPA is funding the Great Lakes Commission to develop and maintain
an Internet site containing information on all 26 U.S. and five binational AOCs. Information will be
added on a regular basis to highlight activities that are transferable to any number of AOCs.
The unique situation in the Ashtabula River AOC (the Ashtabula Partnership) and in the Grand
Calumet region are prime examples of the success which can be derived through the innovative use
of public-private partnerships. The U.S. strongly supports such efforts and is actively promoting
them throughout the Basin. The U.S. will confer with Great Lakes Commission staff regarding a
special Internet posting on the AOC website which highlights the achievements of these two RAPs.
These highlight pages will serve as models for future RAP highlight postings.
Funding and Staffing
IJC recommends that the Parties undertake a transparent planning activity aimed at identifying
resources available annually for RAP planning and implementation activities as well as
resources still required to restore beneficial uses in the 42 AOCs within the Great Lakes basin.
Inter alia, this information should be used to balance between planning and implementation
activities.
IJC recommends that the Parties and jurisdiction determine both the minimal and optimal
levels of support necessary to complete planning and implementation of each AOCs restoration
activities.
The U.S. is actively engaged at the federal, state, and local levels in attempting to identify priority
actions and the associated funding required to implement these activities. This includes supporting
remedial projects, securing core funding for coordinating the RAP process, maintaining institutional
history, and funding nongovernmental organizations so they can be fully engaged. EPA Lake Team
Managers have initiated a process by which they are meeting with both governmental and
nongovernmental stakeholders to identify priority activities and those resources which are available
and/or could be used to leverage additional funding in order to meet the needs of the AOC.
The eight Great Lakes States also conducted Unified Watershed Assessments (UWAs) under the
terms of the Administration's Clean Water Action Plan (CWAP). The UWAs identified those priority
watersheds in need of some level of restoration. The majority of Great Lakes watersheds which
contain an AOC were listed as priorities under the UWAs. This makes them eligible for additional
funds which will are being made available under the CWAP.
The IJC's request for the Parties to identify in an expedited manner the resource levels necessary to
restore each AOC does not fully recognize the inherent robustness of the RAP process whereby all
stakeholders are equal partners in identifying such needs. The added transaction times required to
make these decisions can lead to better priority setting and implementation. Steady progress is
being made in every AOC.
Page 13 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
Public Participation
IJC recommends more resources be mobilized by the Parties and jurisdictions in order to
enhance public participation efforts. In order to increase public awareness of and participation
in AOC restoration efforts, low-cost or no-cost means of reaching and influencing the public
should be better utilized.
The U.S. is dedicated to the concept of community-based environmental protection as exemplified
by the high levels of public involvement in the RAP program. RAP Public Advisory Committees
(PACs) are vital components of the RAP process. This has long been recognized by the U.S. and is
supported by financial and technical resources so that these citizens can fill these important
voluntary roles.
The U.S. also recognizes that more resources would enhance the public participation process. But
this need must be balanced against the equally important needs of planning, coordination, and
implementation. The levels of resources available for direct public participation through the PACs
are reviewed on an annual basis to determine if changes are needed. The U.S. is also actively
implementing other types of public outreach (Internet websites, public talks, press releases, annual
and biennial Great Lakes ecosystem reports) as cost-effective methods of reaching out to and
informing the public. We will continue to use these avenues and to identify new ones in order to
increase public participation in the RAP process.
Information Transfer
IJC recommends greater use of available technology to enhance public participation efforts and
improve the transfer of information and technology to and between AOCs. Efforts similar to the
U.S. EPA web site for nonprofit organizations are needed. Increased private sector participation
could be instrumental in carrying out this activity. Publishing RAP documents and other
publications on web sites would provide a cost-effective means of sharing advances in
remediation strategy and technology.
The U.S. fully supports this recommendation and has several activities already being implemented
which will help meet these laudable goals. As mentioned previously, EPA has partnered with the
Great Lakes Commission to create and maintain a website for the 26 U.S. and five binational AOCs.
This site includes fact sheets on each AOC, RAP status, use impairment restoration progress, and
electronic versions of RAP documents and newsletters. In addition, contact persons at the PAC,
state and federal levels are included. This site will be updated on a regular schedule as well as on
an ad hoc basis as events warrant. The U.S. encourages the IJC and all other interested parties to
visit the site at:
www.epa.gov/glnpo/aoc/
Some states, such as Ohio, also maintain their own AOC websites which contain detailed RAP
information updated on a regular basis. This website is located at:
http://chagrin.epa.state.oh.us/programs/rap/rap.html
Page 14 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
Quantification of Environmental Benefits
The reduction in risk to human health achieved under the Superfund Program in the Waukegan
Harbor AOC has not received optimal public exposure. IJC recommends additional effort be
devoted to properly informing citizens and politicians of this notable success.
The U.S. is proud of the coordinated actions which led to the removal of almost 1,000,000 pounds
of RGBs from the Waukegan Harbor AOC. RGBs are one of the compounds largely responsible for
fish consumption advisories in the Great Lakes. This removed mass represented the largest single
source of RGBs to the Great Lakes. This significant environmental improvement was covered by the
local media and was highlighted in numerous reports from both EPA and Illinois EPA as well as the
Waukegan Harbor Citizen Advisory Group (GAG). In addition, the work of the GAG and the
associated governmental partners in achieving this unprecedented cleanup was recognized at the
State of the Lakes Ecosystem Conference awards event in October 1998. The U.S. agrees that such
important success stories should be given a high level of public exposure. We will explore
additional methods for publicizing the reductions in risk to human health achieved under the
Superfund Program at this and other sites.
In addition Waukegan Harbor is one of the highlighted ports of call for an educational boat tour in
1999. The tour, Making Lake Michigan Great, is a partnership with the Lake Michigan Forum and
Grand Valley State University in cooperation with the Waukegan Harbor Citizens' Advisory Group
(GAG). Also the GAG has established its own home page on the Internet to announce
environmental progress being made at the harbor.
In a related activity, EPA is partially funding a Northeast-Midwest Institute study to analyze the
economic benefits related to the cleanup of contaminated sediments in areas such as the
Waukegan Harbor AOC.
PAC Funding
The Muskegon Lake Public Advisory Council example of aggressive fund-raising serves to show
that many PACs could be more effective in seeking outside funding. IJC recommends that
inter-PAC transfer of information concerning funding sources and techniques be promoted.
As mentioned previously, EPA has set up a RAP website where information can be shared amongst
PACs. In addition, EPA Lake Team Managers track progress on all AOCs within their respective lake
basins. This affords them a unique opportunity to promote the cross-fertilization of ideas among
PACs regarding funding techniques and sources as well as other technical information.
EPA did produce a series of funding documents for RAPs which describe a variety of funding
opportunities ranging from foundation grants to incorporation. These are still available from EPA's
Great Lakes National Program Office (GLNPO). GLNPO is also developing a funding guidance
document which will identify funding opportunities from both public and private sector sources.
The U.S. encourages and supports annual statewide PAC meetings where PAC representatives from
each AOC in a given state can spend a day discussing common problems and sharing important
information.
Page 15 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
The U.S. will continue to develop and promote innovative and effective methods to promote these
and other methods of information sharing throughout the Great Lakes Basin.
7. Governments review the current environmental status and programs in place to address
environmental issues in the Lake St. Clair and the St. Joseph River areas, and report
this information to the Commission, so that the Commission may direct the Great Lakes
Water Quality Board to advise on their possible designation as Areas of Concern under
the Agreement.
The states of Michigan and Indiana have undertaken thorough reviews of the environmental status
and programs in place in both Lake St. Clair and the St. Joseph River areas. Based on their
findings, the U.S. does not believe that either of these areas need to be nominated for AOC status.
This information will be made available to the Water Quality Board for their information and review.
BACKGROUND - ST. JOSEPH RIVER
The St. Joseph River starts in Michigan near Albion, flows generally southwesterly through South
Bend, Indiana, and then turns northwest to empty into Lake Michigan at Benton Harbor. Potential
impairments to beneficial uses were evaluated in 1985 by the Michigan Department of Natural
Resources when the AOC program originated. It was determined then that the St. Joseph River was
not an AOC. Since that time, no new beneficial use impairments have been identified.
ISSUES
RGBs: There is a consumption advisory for PCB contamination for carp, smallmouth bass, and
walleye on various reaches of the river, but these are no more than are found on other
tributaries to Lake Michigan. Results of a caged fish study conducted in 1997 by the Michigan
Department of Environmental Quality (MDEQ) showed RGBs accumulating in fish, but at much
lower levels than found in most AOCs where RGBs are a major problem.
Atrazine: New information available from the 1993-1995 Lake Michigan Mass Balance Study
indicates that the St. Joseph River has high concentrations of the corn herbicide atrazine during
certain times of the year. Atrazine loads to Lake Michigan from the St. Joseph River are the
highest of all Lake Michigan tributaries. These levels may be of concern to the Lake Michigan
LaMP effort, but are not known to be impairing any beneficial uses in the river or Lake Michigan
at this time. Moreover, the Lake Michigan Mass Balance Study has not detected any
bioaccumulation in fish. If any atrazine-specific problems arise within the river system, they can
be addressed by specific programs, including nonpoint source pollution controls, pollution
prevention programs, or placement on the MDEQ's 303(d) list with subsequent Total Mass Daily
Load (TMDL) development. The river does not need to be an AOC to effectively address the
atrazine issue. The river also does not need to be an AOC to receive attention from the MDEQ,
as regulatory programs and monitoring programs are now being applied to the St. Joseph River.
Public Involvement
The Friends of the St. Joe River Association is a grass-roots citizen group that is working on local
environmental problems in the river. The MDEQ - Plainwell District office responds to needs of this
group. The president of the Friends of the St. Joe River Association is on the Lake Michigan Forum
for the Lake Michigan LaMP.
Page 16 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
Summary
The St. Joseph River has the usual suite of water quality problems for rivers in the Great Lakes
Basin and these are being addressed by current programs. Atrazine levels may be of concern, but
these also can be addressed through available programs. However, we do not believe that the river
has the severity of problems that would qualify for AOC status; further, identifying it as an AOC
would be of no added value to the efforts to restore and protect the river.
BACKGROUND - LAKE ST. CLAIR
Lake St. Clair serves as a link in the chain of connecting channels between Lake Huron and Lake
Erie. Lake St. Clair is shallow (6.5 meter maximum natural depth) and has a short retention time
(5-7 days) compared to most lakes. Ninety-seven percent or more of the inflow to Lake St. Clair
comes from the St. Clair River. Other tributaries include the Clinton River in Michigan, and the
Thames and Sydenham Rivers in Ontario. Both the St. Clair River and the Clinton River are currently
designated as AOCs with RAPs in development.
Issues
The U.S.-Canada Upper Great Lakes Connecting Channels Study (UGLCCS) of 1988 detailed the
results of intensive binational study of nutrients, toxic chemicals and other environmental concerns
for Lake St. Clair. Since 1994, weather patterns and inputs of nutrients and bacteria (from
combined sewer overflows and nonpoint sources) have combined to yield frequent beach closings
and extensive mats of aquatic vegetation which hamper boating and produce strong odors when
they decompose. Macomb County, Michigan in particular, has suffered economic impacts due to
these conditions.
PUBLIC INVOLVEMENT
A Macomb County "Blue Ribbon" Commission was established locally to study Lake St. Clair issues
and make recommendations for their resolution. The Commission and its deliberations received a
significant amount of press regionally and it continues to gain respect and attention at the state,
provincial, and federal levels of government.
The Commission specifically declined to recommend designating Lake St. Clair as an AOC after
careful deliberations.
Each of the tributary AOCs (the St. Clair and Clinton Rivers) also have active public groups involved
in water quality/environmental issues through the RAP program. There are also several other
"watershed" and "friends of" organizations located within the Lake St. Clair watershed.
More recently, State and regional officials and environmentalists have agreed to create a watershed
organization to establish goals to address environmental problems in Lake St. Clair. The
organization, called the Lake St. Clair Lakewide Management Plan will allow for further public-
private partnerships for improving the Lake. By giving Lake St. Clair a management identity apart
from existing RAPs and LaMPs, more focus and will be brought on those decisions needed to
improve environmental conditions.
Page 17 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
The Lake St. Clair fish community has
actually improved over the past few years.
Native predator fish species, including
muskellunge, smallmouth and largemouth
bass, northern pike, and yellow perch offer
some of the best fishing in the world. For
instance, the yellow perch fishery, as
evidenced by the charter fishery, has seen
dramatic increases in total catch and catch
per angler hour since the early 1990's years
(see figure, information from Michigan
Department of Natural Resources). There
has also been a tremendous increase in the
number, size, and catch per effort of
muskellunge. These positive indicators are
often overlooked when assessing the state
of Lake St. Clair.
Michigan Lake St. Clair Charter
12 -i
10
o
§ 8
* 6 -
i-» 4 -
O
2
0
Fishery - Yellow Perch
n n n n
o i- CN cr> M-
O> O) O) O) O)
O) O) O) O) O)
Year
in
0)
0)
CD
0)
0)
Summary
Lake St. Clair has certain water quality problems and environmental issues which are common to
the region. In Michigan, these are being addressed by baseline Michigan Department of
Environmental Quality programs including the AOC program. Implementation of the
recommendations from the two tributary RAPs and the Blue Ribbon Commission would resolve most
of the issues for Lake St. Clair. Identifying Lake St. Clair as an AOC would be of no added value for
the Lake.
It should be noted that habitat issues for Lake St. Clair may benefit to some extent from binational
cooperation. However, the AOC program would not be the most efficient program to address these
issues. Efforts through the locally initiated Lake St.. Clair Lakewide Management Plan, the Great
Lakes Fishery Commission (GLFC), the North American Waterfowl Management Plan, the Ramsar
Convention, and/or the Great Lakes Wetlands Policy Consortium are possible alternatives.
SCIENCE AND RESEARCH
8. Public and private sectors
fund research that expands understanding about the incidence of endocrine disruption
in humans and wildlife;
conduct programs to measure and establish the concentration of endocrine-disrupting
chemicals in human tissues and fluids; and
investigate endocrine-disrupting capability of chemical mixtures.
EPA is actively reviewing information indicating the possibility of adverse impacts on human health
and the environment associated with exposure to chemicals or environmental agents that act as
endocrine disrupters. At the present time, there is little agreement on the extent of the problem.
Page 18 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
Based on the current state of the science, the Agency considers endocrine disruption to be a
mechanism of action potentially leading to other outcomes (for example, carcinogenic, reproductive,
or developmental effects), routinely considered in reaching regulatory decisions. EPA thinks that
identification of environmental agents that cause adverse effects as a result of endocrine
disruption, as well as enhancement of our understanding of how these agents exert their effects,
will improve the U.S.'s ability to reduce or prevent risks, particularly to children and vulnerable
ecosystems.
Therefore the Agency has developed a two part strategy for dealing with endocrine disrupters: (1)
research to understand the basic science and inform the process of risk assessment; and (2)
screening and testing to identify chemicals that act as endocrine disrupters and the effects they
cause.
EPA is setting forth a screening program for determining which pesticide chemicals and other
substances may have an effect in humans that is similar to an effect produced by a naturally
occurring estrogen or other endocrine effects. The Food Quality Protection Act (FQPA) and the
amendments to the Safe Drinking Water Act (SDWA), both of which were passed in the summer of
1996, require the Agency to develop a screening and testing strategy for endocrine disrupters by
August 1998, implement screening and testing by August 1999, and report progress to Congress by
August 2000.
In developing the Endocrine Disrupter Screening Program, EPA is adopting the recommendations of
the Endocrine Disrupter Screening and Testing Advisory Committee (EDSTAC), a panel comprised of
representatives from a cross-section of public and private organizations, including the Agency for
Toxic Substances and Disease Registry (ATSDR). Initially, the Endocrine Disrupter Screening
Program will focus on estrogenic, androgenic, and thyroid hormone effects. These three hormone
systems are presently the most studied of the approximately 50 known vertebrate hormones. In
vitroand in wVotest systems to examine estrogen, androgen, and thyroid effects exist, and are
currently the most amenable for regulatory use. Further, inclusion of estrogen, androgen, and
thyroid effects will cover aspects of reproduction, development, and growth. As more scientific
information becomes available, EPA will consider expanding the scope of the Endocrine Disrupter
Screening Program to other hormones. For now, however, the estrogen, androgen, and thyroid
hormone effects and test systems represent a scientifically reasonable focus.
In addition, the White House Office of Science and Technology Policy's Committee on Environment
and Natural Resources created an Endocrine Disrupter Workgroup in 1996 consisting of
representatives of the federal agencies that have a scientific mission. Chaired by EPA and the
National Institute of Environmental Health Sciences, the workgroup was tasked with developing and
coordinating a federal research program to measure and understand the human and ecological
consequences of exposures to endocrine disrupting chemicals. The approach taken by this group
includes the development of a federal research inventory, identification of research gaps,
facilitation of coordination across the federal government, and initiation of outreach efforts to public
interest and private sector groups.
EPA's Region 5 office and Great Lakes National Program Office have taken a great interest in the
endocrine disrupting potential of alkylphenols and akylphenol polyethoxylates, chemicals that are
discharged by various industries and municipalities into Great Lakes Basin waterways. Studies are
now being done by these offices to better establish the levels of these chemicals in fish and the
quantities being discharged by municipal effluents. Studies are also being initiated to quantify the
Page 19 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
cumulative effects on fish of estrogenic disrupters in municipal effluents, with special emphasis on
synthetic and natural hormones and alkylphenols, because of their documented persistence.
In addition, ATSDR's Great Lakes Human Health Effects Research Program is characterizing
exposure to the 11 "critical pollutants" identified by the IJC in susceptible populations. These
eleven pollutants include chemicals, i.e., dioxins, furans, RGBs, mirex, and DDT which have been
identified as endocrine disrupters. Research findings from ATSDR's Great Lakes program indicate
neurobehavioral deficits in newborns exposed in utero, and disturbances in reproductive
parameters in women who consumed contaminated Great Lakes fish.
Several Great Lakes States are implementing programs to address potential endocrine disrupting
substances. Ohio, for example, has several Lake Erie-related projects underway for measuring
chemicals that have been associated with endocrine disruption. Great Lakes States are presently
coordinating fish contaminant monitoring programs through the Council of Great Lakes Governors
and USEPA. Additional parameters are routinely added to the monitoring regime as needed.
9. Governments actively participate in the work of the Communications Task Force under
the Council of Great Lakes Research Managers.
The U.S. strongly supports the need for timely and useful scientific information being made
available to policymakers so that informed decisions can be made regarding Great Lakes issues.
The U.S. and Canada have recently held the third biennial State of the Lakes Ecosystem Conference
(SOLEC) where policymakers were invited to presentations by pre-eminent researchers on a variety
of topics regarding the health and future of the Great Lakes ecosystem. SOLEC has proven to be
enormously successful in disseminating important Great Lakes information in easily understood
reports and Internet postings. In the years between SOLECs, State of the Great Lakes reports are
prepared and widely distributed. In addition, both the U.S. and Canada are firmly committed to the
timely release of information via the Internet and other outlets.
One of these important outlets is the proposed Communications Task Force (CTF). The CTF would
involve a communications specialist from each agency or department represented on the Council. It
would be their responsibility to explain their agency's research activities to the general public and
elected officials. These explanations should include the results of their work, but their discussions
should be much broader than simply results. It is equally and possibly more important to explain
research needs, priorities, and capabilities, and to involve these audiences in the process to identify
these needs and set these priorities. Explanations should be tailored to the particular audience and
presented as concisely as possible.
Some of the important duties of the CTF would be to include the Great Lakes education community
so that research results can be taken into the schools of the region; to make use of the latest
technology to disseminate information while including traditional means to reach all audiences; and
to involve the private sector and the media. At the most recent IJC Biennial Forum, a number of
media representatives came forward to express their interest in helping the CTF disseminate this
kind of information and to develop products that are write-ups of research "stories." The CTF must
also insure that its work is complementary to, and not duplicative of, other outreach activities which
each agency is already undertaking.
In March 1999 the CTF held a Great Lakes Communicators Workshop in cooperation with the IJC,
the Great Lakes Fishery Commission, and the Great Lakes Commission. As an outcome of this
Page 20 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
workshop, a subsequent electronic network of Great Lakes communicators and educators was
established.
10. Governments support the development and application of models to assist in the
testing, evaluation and implementation of ecosystem indicators, monitoring strategies,
and management strategies for water quality, contaminants, fisheries and other
ecosystem issues.
The U.S. strongly supports this recommendation and will briefly describe a number of modeling and
ecosystem indicator development activities being undertaken both domestically and binationally
with our Canadian partners.
Modeling provides researchers the ability to make qualified predictions about future states of a
given ecosystem. Based on model findings, decision makers are given the best available data to
assist in their actions. The U.S. notes that the IJC understands the utility of using models and have
implemented them on Lake Erie, through the completed Lake Erie Ecological Modeling Project. One
of the major modeling tools the Parties are currently using in the Great Lakes is mass balance
modeling.
Mass balance modeling is based on the principles of conservation of mass and energy; the amount
of pollutants entering a lake must equal the amount of pollutants leaving, remaining, or chemically
changed in the lake. A model incorporating the processes and activities that affect the transport
and distribution of a chemical within the lake can be developed by collecting environmental data
and using these data to help mathematically describe the critical rates and exchanges between the
various ecosystem components. The model then becomes a valuable tool enabling resource
managers to design cost-effective strategies for reducing toxic loads and minimizing human and
ecosystem health risks. The development of draft ecosystem objectives for wildlife, habitat, aquatic
communities, human health, and environmental stewardship has provided direction and a basis for
establishing targets, or ecosystem indicators, as a means to check on the effectiveness of remedial
activities.
There are major examples of mass balance models in the Great Lakes Basin:
1. The Green Bay Mass Balance Study was conducted in 1989-90 to pilot the technique of
mass balance analysis in understanding the sources and effects of toxic pollutants in the
Great Lakes food chain. The study, headed by EPA's Great Lakes National Program Office
(GLNPO) and the Wisconsin Department of Natural Resources, had many participants from
the federal, state, interagency, and academic communities. The study focused on four
representative chemicals or chemical classes: PCBs, dieldrin, cadmium, and lead.
2. The Lake Michigan Mass Balance began in 1994 and will be concluded in 2000. The four
major chemicals being studied are mercury, PCBs, atrazine (an agricultural herbicide), and
trans-nonachlor (a pesticide). The Lake Michigan Mass Balance is helping us understand
how these chemicals are entering the Lake and what happens to them as they move
through the ecosystem. This study will identify relative pollutant loads from rivers, air
deposition, and sediment resuspension, and will allow us to predict the benefits associated
with reducing loads.
3. The continued enhancement of Lake Ontario mass balance models.
Page 21 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
In addition to the use of mass balance models, the Great Lakes Fishery Commission relies quite
heavily on models and has supported development of quite a few over the years, including an
integrated pest management approach to sea lamprey management (IMSL) and Sustainability of
Intensively Managed Lake Ecosystem (SIMPLE) for Lakes Ontario, Michigan and Huron.
Models need to collect the necessary information in order to make predictions about ecosystem
responses. The State of the Lakes Ecosystem Conference (SOLEC) Indicators Development process
is establishing a consistent, easily understood suite of indicators that will objectively represent the
state of major ecosystem components across all Great Lakes basins, on which to report progress on
biennially, and upon which the Parties can be assessed regarding achievement of the purpose of
the Agreement. The acceptance and use of a core set of indicators can also drive data collection
activities throughout the Basin.
The SOLEC indicators list is meant to be an umbrella of overarching indicators. These indicators will
provide a general overview of conditions in the Lakes. In relation to the overarching set, additional
geographic area indicators will be LaMP and RAP indicators. These will most likely form the basis of
the indicator set, supplemented with indicators from other sources such as the GLFC, SOLEC 94 or
96, the IJC, etc. The SOLEC indicator list was discussed at the October 1998 conference and is now
being modified as necessary to produce an indicator list that is mutually acceptable to as many
stakeholders as possible.
In support of the development of indicators for the Great Lakes, EPA's Office of Research and
Development has an active research program in the Great Lakes Basin. This research is designed to
continue to solidify the scientific underpinnings of suggested indicators by studying the
relationships between critical biological communities and processes in the nearshore areas of the
Lakes. A substantial effort is also underway to improve our understanding of components of the
Great Lakes for which there is little past information. For example, ongoing research on the
interactions and processes within Great Lakes coastal wetlands will help establish scientifically
sound indicators that can be used to monitor the condition of these vital ecosystems.
In addition to research on indicators for the Great Lakes themselves, EPA is also studying the
watersheds and landscapes within the Great Lakes Basin. One purpose of this research is to
improve our understanding of the impact of changes in tributary water quality and quantity on the
Lakes. Indicators of landscape patterns and land use are being explored as a means of rapidly and
remotely predicting the ecological condition of tributaries, wetlands, and other water bodies within
the Basin. These indicators include those currently being developed and tested in research
underway in other geographic regions of the Nation as well as those specifically being developed
within the Great Lakes.
ATSDR, in support of the development of indicators for SOLEC, participates on the SOLEC steering
committee and shares findings from its Great Lakes Human Health Effects Research Program to be
used in the development of human health indicators.
The development of mass balance models and their coordination with monitoring strategies based
in part on the SOLEC indicators development process provides an opportunity to enhance our ability
to assess the health of the Great Lakes system.
Page 22 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
11. Governments identify surveillance and monitoring programs essential to track
contaminant loadings to and concentration trends for each of the Great Lakes; provide
assurances to the Commission and the public that these programs will be maintained;
and provide on a timely basis data and information to quantify load reductions and
ecosystem improvements.
The U.S. remains strongly committed to fully meeting the monitoring and surveillance needs
required to be able to track and report on the health of the Great Lakes. The Great Lakes program
has developed and implemented some of the most innovative and important ecosystem monitoring
plans and programs being used today..
The demand for high quality, relevant data concerning the health of various components of the
Great Lakes ecosystem has been escalating rapidly for the past decade or so. The U.S. and Canada
have spent billions of dollars and uncounted hours attempting to reverse the effects of cultural
eutrophication, toxic chemical pollution, over-fishing, habitat destruction, introduced species, etc.
Environmental management agencies are being asked to demonstrate that past programs have
been successful and that the success of future or continuing programs will be commensurate with
the resources expended. At the same time, in both countries, the amount of taxpayers dollars being
devoted to Great Lakes environmental issues is decreasing. The demand for high quality data,
while operating with limited resources, is forcing environmental and natural resource agencies to be
more selective and more efficient in the collection and analysis of data.
The most efficient data collection efforts will be those that are cost-effective and relevant to
multiple users. An understanding by stakeholders about what information is necessary and
sufficient to characterize the state of Great Lakes ecosystem health through the use of indicators,
and to measure progress toward ecosystem goals would facilitate efficient monitoring and reporting
programs. An agreed upon set of Great Lakes indicators will help agencies and programs
responsible for monitoring environmental conditions to target their monitoring resources in the most
efficient manner, and to help policymakers makes the decisions which will be of benefit to all
inhabitants of the Basin.
In support of these goals, the U.S. is aligning its monitoring activities around the needs of the
resource. To this end, the LaMPs will be developing strategic monitoring plans for their respective
lakes which will lead to more efficient data collection. At the basinwide level, monitoring programs
such as GLNPO's open lake trend monitoring program, Integrated Atmospheric Deposition Network
(IADN), the Great Lakes Research Vessels Database, and those programs which will support the
BNS, will focus their data collection efforts on those binationally agreed upon toxic contaminants
which are having the largest impact on the Lakes.
The development of indicators through the SOLEC Indicators Development Process can also greatly
improve coordination between monitoring programs. By reaching agreement on this suite of
indicators, monitoring programs throughout the Great Lakes Basin will be able to align their
activities accordingly, which will allow for better reporting on the status of the Great Lakes and to
more informed decision-making. It will also allow these programs to identify what monitoring is
"necessary and sufficient;" identify any additional monitoring required for reporting on the
indicators; and identify monitoring activities which collect data which may no longer be needed to
support the selected indicators.
Page 23 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
The IJC's report is unclear as to whether the IJC believes that monitoring of biota for persistent toxic
substances is a victim of monitoring budget cuts. As mentioned earlier, GLNPO is maintaining its
program of monitoring lake trout, walleye (on Lake Erie), and salmon for persistent toxic
substances. The list of chemicals to be analyzed for will be expanded in fiscal year 1999. This
program helps to provide much of the data needed to track contaminant loadings as indicated by
their levels in fish tissue, the principal route of human exposure. There is also an indication that
state monitoring budgets are on the increase. New York State serves as an example. There have
been no cut backs in New York's routine monitoring programs due to budget cuts from 1993-1997.
In fact, the number of times the routine programs monitor the tributaries had actually increased.
Environmental monitoring has been accelerated on all fronts with numerous small tributaries,
sewage treatment systems, waste sites and other potential contaminant sources targeted with
specialized sampling programs designed to locate sources of persistent toxic substances. In
addition, biomonitoring has been expanded to several tributaries that had never been sampled
before. Special sediment projects were also conducted in a number of tributaries.
The U.S. is also fully committed to collecting and analyzing this data in the most expeditious manner
and reporting findings through a variety of outlets, including Internet postings, professional
conferences such as SOLEC and IAGLR, through journal articles, and through regular reports such
as the Biennial Progress Report, the Great Lakes Report to Congress, and the State of the Great Lakes
reports.
While resources for surveillance and monitoring throughout the Basin have been impacted to some
degree, the U.S. remains confident that it will be able to continue to collect and report on those
indicators, both for toxic contaminants and for non-chemical stressors such as habitat and wetlands
loss, biodiversity, and exotic species, which will help guide future Great Lakes policies. Through the
co-development of indicators and other planning processes, the Parties are achieving better levels
of efficiencies in their surveillance and monitoring programs.
PERSISTENT TOXIC SUBSTANCES
12. Governments adopt a three-part strategy relating to: existing commercial operations,
including manufacture, import, use and release into the environment; present day
combustion facilities; and the legacy of dioxin-like substances from past human
activities. Further, Governments adopt and report on a schedule outlining appropriate
measures to be taken.
The U.S., through its combined federal, state and local pollution abatement programs, has made
major progress in addressing dioxin releases to the environment and will continue to achieve even
greater reduction through the implementation of a variety of actions, including the Binational Toxics
Strategy. Environmental levels of dioxins have been in decline since the early 1970s. This decline
coincides with the major strengthening of U.S. environmental programs. Dioxin reductions have
come about in part from broad combinations of programs designed to improve combustion and
more effectively manage chemicals and wastes. It is also the result of more recent efforts directed
specifically at dioxin as our understanding of the sources has improved. The U.S. recognizes that
efforts to reduce dioxin exposure are not yet completed and more needs to be done. Additionally,
as our understanding of dioxin sources, exposure pathways, and dioxin toxicology improves,
programs will have to respond accordingly.
Page 24 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
The U.S. government has taken action to eliminate, or significantly reduce, releases of dioxin-like
compounds associated with the manufacture and use of a number of chemical products. These
include: eliminating the U.S. manufacture and import of 2,4,5-T, Hexachlorophene, and RGBs; the
elimination of lead from virtually all gasoline sold in the U.S.; and major reductions in the dioxin
levels found in chlorine and in dioxins formation associated with the bleaching of wood pulp.
Additionally, EPA's New Chemicals Program works to insure that new chemicals coming to market
do not become new sources of dioxin contamination.
As with most industrialized countries, combustion is the dominant source of dioxins in the U.S. Of all
combustion processes, municipal and medical waste incinerators appear to be the largest single
dioxin source over the last decade. As a result of federal and state efforts, emissions from these
sources have been reduced during the 1987-1995 period by approximately 86 percent and 80
percent respectively. These decreases are based on a draft inventory conducted as part of EPA's
Dioxin Reassessment. And with the full implementation of MACT rules for these sources, we
anticipate dioxin reductions from municipal waste incinerators by about 99 percent and from
medical waste incinerators by about 94 percent. These reductions are from pre-regulatory baseline
levels. EPA is in the process of developing regulations for all commercial waste combustion
processes. When the current cycle of dioxin-specific waste combustion regulations is completed,
EPA will have promulgated new rules for municipal waste combustors, medical waste incinerators,
commercial hazardous waste incinerators, and cement kilns, and boilers and industrial furnaces
burning hazardous waste. Prior to these dioxin-specific regulations, it is thought that significant
reductions in dioxin releases from combustion sources were achieved through elimination of the
uncontrolled combustion of residential waste in urban areas, the replacement of burning dumps
with sanitary landfills, and the general imposition of pollution controls on combustion. EPA
continues to look for and characterize additional combustion sources as candidates for dioxin risk
management.
The cleanup of areas contaminated by dioxin-like compounds continues to be an important part of
EPA's Superfund program. PCB and dioxin-contaminated sites have been some of Superfund's
most ambitious projects. These have included Love Canal in New York, Times Beach in Missouri,
and Vertac in Arkansas. EPA will continue to address dioxin and PCB-contaminated sites in the
context of the overall risk-based priorities of the Superfund program.
One of the most important components of the U.S. response to dioxin is the EPA Dioxin
Reassessment effort. This project is a comprehensive review and assessment of dioxin science,
including dioxin sources, environmental levels and trends, environmental fate and transport, levels
of human exposure and exposure pathways, biological effects, and human risks. The reassessment
is addressing the full family of dioxin-like compounds and will assess both cancer and noncancer
effects. A draft document was published in 1994 and peer reviewed in 1995. EPA is currently
revising the document to incorporate new research and to respond to peer review and public
comments. Since 1995, a new dose response chapter has been submitted to peer review as has a
revised emissions inventory. In 1999, drafting and review of the reassessment will be completed
and a final document released. Concurrent with release of the final document, EPA will issue a
draft Dioxin Risk Management Strategy. This strategy will include a review of existing dioxin risk
management efforts in light of the reassessment findings, and will identify any modifications and/or
expansions of existing programs needed for EPA to effectively address dioxin risks. An opportunity
for public comment on the strategy will be provided before it is adopted as formal Agency policy.
Page 25 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
Specific measures identified by the IJC
A. The removal of sediments, contaminated with dioxin-like substances, from bays, rivers and
harbors;
Most sediments in the U.S. have detectable levels of dioxin-like substances. It is neither
economically nor technologically possible to remove sediments from most of the U.S. bays, rivers
and harbors. Consequently, priorities must be established, risks must be assessed, points of
diminishing returns determined, and tradeoffs evaluated. The U.S. believes the feasibility of
remediating highly contaminated sediments can best be determined on a case by case basis and
without a predisposition as to remediation approach (for a more detailed discussion, please see our
previous response to recommendation one and two regarding contaminated sediments).
B. The assessment and remediation of chemical landfill sites that contain and release
substances with dioxin-like activity;
The U.S. will continue to assess and remediate dioxin-contaminated chemical waste sites through
the EPA Superfund Program. Priorities for dioxin and PCB-contaminated sites will be established in
the context of the overall risk-based priorities of the Superfund program and other appropriate
regulatory programs.
C. The assessment and remediation of emissions containing dioxin-like substances from iron
sintering plants and secondary aluminum smelters;
EPA is committed to assessing these two sources, along with other dioxin sources, through its
Dioxin Reassessment. The EPA dioxin strategy, which will be released concurrent with the
reassessment, will identify Agency priorities for new and additional dioxin action. Iron sintering and
secondary aluminum will be considered both in the reassessment and in the strategy. Because no
test data existed for U.S. iron sintering facilities, EPA has recently conducted tests at two of these
plants. The reassessment is gathering and evaluating all of the available data on secondary
aluminum smelters. Until EPA has completed its assessment of these two specific sources and
considered the significance of these sources in relation to other dioxin sources, EPA is not prepared
to make specific commitments for remediation.
D. Increased recycling of solid waste to reduce precursors of dioxin-like substances to all types
of incinerators;
The U.S. supports reductions in the volume of waste through recycling and other waste minimization
strategies. Reducing the volume of waste incinerated should result in reduced emissions, including
dioxin, from commercial scale waste combustors. The U.S. does not believe there is sufficient
scientific justification to support singling out any particular component of the waste stream as being
more important in reducing dioxin emissions in commercial scale waste incinerators.
E. Phasing out and retrofitting of existing incinerators, particularly those for medical wastes,
with best available technology to prevent formation and release of dioxin-like substances;
This recommendation is fully consistent with the U.S. ongoing program to limit dioxin emissions
from waste incinerators. About 50 percent of medical waste incinerators that operated in the mid-
1980s have already been phased out. Those that remain will either have to meet the MACT
Page 26 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
regulations promulgated by EPA in 1997 or cease to operate. MACT is the criteria established by
the Clean Air Act for making best available technology decisions for hazardous air pollutants.
Similarly for municipal waste combustors, most of the highest emitting facilities have either already
ceased operation or undergone significant modification. All facilities will have to meet the 1995
MACT-based regulations. Emissions from municipal and medical waste incinerators are estimated
to have declined by 86 percent and 80 percent respectively, between 1987 and 1995. Regulations
under development by EPA for other waste combustion sources will also rely on a MACT approach in
establishing regulatory levels.
The implementation of uniform standards for the combustion of hazardous wastes, not only in
hazardous facilities, but also in cement kilns, may not be the best approach for addressing
emissions at these various facilities. We recognize this, and the Clean Air Act provides for a
"residual risk" determination and additional risk-based regulations if needed. As with municipal
and medical waste rules, EPA is required to use technology-based determinations to establish
regulatory levels. This means that uniform decision criteria are applied to all hazardous waste
combustion facilities, including commercial hazardous waste incinerators, cement kilns, and boilers
and industrial furnaces. However, because the technologies, economies of scale, and retrofit
capabilities may vary from one class of facilities to another, there may be differences in the
numerical emission limits established for different facility types.
13. Governments and business apply incentive-based approaches to identify and eliminate
specific uses of mercury.
The U.S. is fully supportive of the incentive-based approach and uses it as one of many tools to
identify and eliminate specific sources of mercury. Since the 1960s, mercury has transitioned from
a commodity for which there were escalating applications and demand within the U.S. economy, to
a substance with drastically curtailed consumption. Environmental regulatory costs, for parties
subject to these, provide incentive for avoidance of mercury. The promise of wooing green
consumers with mercury-free products offers a positive economic incentive to eliminate use of
mercury. For such reasons, fluorescent bulb manufacturers, for example, are evolving products
with less and less mercury, whereas automakers are using electrical switches which do not rely on
mercury. Similarly, many U.S. hospitals and chemical laboratories are looking to purchase products,
such as preservatives and instruments, which are mercury-free. The outlook for use of mercury by
U.S. manufacturers is that consumption will continue to decline. EPA has many voluntary, incentive-
based programs that provide this encouragement.
The Commission requests a tabulation of uses and the quantities of mercury involved,
along with a detailed schedule with measurable benchmarks to eliminate each use, be
incorporated into the Parties' 1999 report of programs and progress under the
Agreement.
In its 1999 Progress Report, the U.S. will provide the most recent tabulation of uses and the
quantities of mercury involved, as published by the U.S. Geological Survey. It should be noted that
these commodity market summaries are reliant upon provision of information by domestic users
and sellers of mercury. The U.S. is not committing to eliminate each use of mercury. Several uses,
such as low-mercury flourescent bulbs, have important environmental benefits, including reducing
emissions from power plants; and some applications of dental amalgam do not have satisfactory
alternatives. Similarly, some types of batteries which contain mercury have important uses which
may not have satisfactory substitutes.
Page 27 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
The principal U.S. use of mercury is the production of chlorine and caustic soda by 13 factories
which use mercury in their production process. Since mercury is used in the process rather than the
product, this consumption is tantamount to some form of loss, primarily via wastes and emissions to
air. This industrial sector has publicly declared a commitment to reduce its consumption by 50
percent from the level of consumption during 1990-1995, which was 160 tons per year. This goal
will be achieved by 2006 and adjusted upwards if any factories close during the interim. In
addition, one firm with two factories has committed to eliminate all of its mercury losses by 2001.
All remaining U.S. mercury cell chlor-alkali factories were built during the 1950s and 1960s; their
economic lives are likely to end by 2030, and for many, well before that time. During the remaining
years of these factories, the environmental challenge facing this industry is to tighten its process to
the fullest extent practical, so as to minimize its mercury losses.
Another major domestic user of mercury is the electrical industry. The U.S. government will open a
dialogue with this industry about the practical feasibility of gradually eliminating its reliance on
mercury. This is a necessary step in developing a realistic schedule for ending use, as
recommended by the IJC. As previously stated, there are some existing economic incentives for the
electrical industry to reduce its use of mercury.
The U.S. has set mercury use reduction challenges that apply to society as a whole. In some cases,
mercury users have stepped forward to make reduction commitments. However, in many cases,
reductions are occurring as the result of technology changes and pollution prevention actions that
were not specific commitments. To attempt to set up a detailed schedule of reductions leading
toward elimination of each use would be difficult at best and would use up resources perhaps
better spent on achieving further voluntary mercury reductions. A special mercury subcommittee
under the BNS is working to identify new reduction opportunities and tracking progress.
14. Governments develop a detailed program, including benchmarks and schedules, for the
systematic destruction of RGBs in storage, in use and in the Great Lakes environment.
The U.S. agrees with the overall recommendation and is able to report that the recommendation is
already undergoing active implementation. RGBs are a serious concern in all the Great Lakes
because they are long-lasting and build up in plants and wildlife. They pose a health threat to
untrained workers and people who eat contaminated fish from the Lakes. Once these pollutants
get into the Lakes, they are very difficult and costly to remove.
Under the BNS, EPA has formed a workgroup focusing on the RGB challenge set out in the Strategy.
The Strategy challenge for RGBs states, for the U.S.:
"Seek by 2006, a 90% reduction nationally of high-level PCBs (>500 ppm) used in electrical
equipment (1994 baseline); ensure that all PCBs retired from use are properly managed and
disposed of to prevent accidental releases within the Great Lakes Basin. "
The RGB Workgroup will develop benchmarks and schedules for the systematic destruction of PCBs.
The Workgroup consists of representatives of EPA, Environment Canada, Great Lakes States and
Provinces, and nongovernmental stakeholders.
EPA included the challenge of reducing the amount of high-level PCBs in electrical equipment since
the use of PCBs in this equipment is the last remaining significant use of high-level PCBs and, as
the equipment ages, the likelihood of a release increases. Consequently, as long as the high-level
Page 28 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
PCB electrical equipment remains in use, it is a potential source of PCB contamination to the
environment.
However, we disagree with the statement in the IJC's report that the "...(R)emoval of remaining uses
of RGBs is not considered cost effective, given the low PCB concentrations in electrical and other
equipment." We respectfully request the Commission to clarify further as to which PCB uses this
statement applies to. For example, this IJC statement on removal of remaining uses would be
accurate if it pertains to PCB uses less than 500 ppm.
We also note that the statement on addressing remaining uses of PCBs also contradicts another
statement included in the 4th paragraph of the PCBs section of the report which states that the
"challenge is to terminate remaining uses." It also contradicts a statement in the last paragraph of
the PCB section that "the program should quantify the amount of PCBs still in use." If removal of
remaining uses is not a priority, then the statements to "terminate remaining uses" and "quantify
the amount of PCBs still in use" would be an apparent contradiction. The U.S. requests further
clarification from the IJC regarding these parts of the recommendation.
The U.S. respectfully disagrees with the statements concerning the PCB recommendation in the last
paragraph of the PCBs section that the "program" should quantify PCBs in landfills. This would be
an extensive effort and it is not apparent what it would accomplish. Indeed, documenting the
amount of PCBs still in use, disposed of in landfills and other containments, in sediments, and in
the ambient environment would require extensive research and considerable resources. Instead,
voluntary reporting by entities that remove PCBs from the environment through proper disposal
methodologies could help governments to more efficiently track the amount of PCBs removed from
the environment. In the U.S., commercial storers and disposers of PCB waste must provide EPA an
annual summary of their activities.
The U.S. is encouraging voluntary actions, in addition to regulatory requirements, to reduce the
amount of PCBs which could be potentially released into the environment. EPA Region 5
announced a joint effort with the private sector to inform and encourage small businesses to
manage and dispose of PCBs and mercury in an environmentally safe way. The partnership will
provide training and information to small businesses, particularly electrical and demolition
contractors, and local government agencies to help them identify, handle, transport, and dispose of
PCBs and mercury. It also will help provide safe, low-cost disposal by a licensed hazardous waste
management firm. In recent years, more and more contracts and insurance policies have
specified recycling and environmentally safe job sites.
The U.S. strongly feels that stakeholder involvement from entities that use PCBs or have contributed
to PCB contamination (as compared to the develop of new government programs), will greatly
facilitate the removal of PCBs from the environment. The destruction of PCBs in storage for use, in
use, and in the Great Lakes environment is not mandated by U.S. law, whereas PCBs removed from
use for disposal purposes must be disposed of within one year of removal from service .Therefore,
considerable voluntary activities by both governmental and nongovernmental entities need to be
implemented to continue to make progress in removing PCBs from the environment.
Page 29 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
RADIOACTIVITY
15. Governments comprehensively review all monitoring at nuclear facilities in the Great
Lakes basin with a view to making the monitoring more accommodating to the needs of
the Agreement.
The December 1997 "Inventoryof* Radionuclides for the Great Lakes"'(the Inventory) prepared by the
Nuclear Task Force of the IJC does not precisely define "nuclear facility," but in context it seems to
mean all facilities making use of radioactive materials, whether the facility is part of the uranium
fuel cycle (e.g., uranium mine, mill, isotopic separation plant, nuclear generating station, waste fuel
handler) or a "secondary source" such as a medical, industrial, commercial, or educational entity.
The underlying justifications in the Inventory for the recommendation likely includes the statement,
"The [radiation] dose assessment models used to derive the allowable discharges [from a
nuclear facility] have a very limited relationship to the cycling of radionuclides for
development of an inventory."
This is a broad statement, difficult to critique fully, but filled with implications. Notably, it leads to
speculation about 'long-term toxicological and ecological problems' (p.92), not made evident by
existing monitoring programs. One relevant information source the IJC may wish to refer to is
"NCRP Report No. 109: Effects of Radiation on Aquatic Organisms" (National Council on Radiation
Protection and Measurements, 1991), which seeks to test hypotheses such as expressed in the
"Recommendations of the International Commission on Radiation Protection "(ICRP, 1979):
"Although the principal objective of radiation protection is the achievement and
maintenance of appropriately safe conditions for activities involving human exposure, the
level of safety required for the protection of human individuals is thought likely to be
adequate to protect other species, although not necessarily individual members of those
species. The Commission therefore believes that if man is adequately protected then other
living things are also likely to be sufficiently protected."
As the Inventory notes, nuclear generating stations, pursuant to their U.S. Nuclear Regulatory
Commission (NRC) licenses, conduct extensive monitoring of direct emissions and surrounding
ambient conditions, with the goal of determining the radiation dose imparted to people through all
pathways (e.g., inhaling airborne radioactivity, ingesting milk and fish from nearby sources,
absorbing external radiation).
Numerous examples doubtless are available of components of the biosphere near nuclear facilities
which because they are not obviously related to potential human radiation dose are not regularly
monitored for anthropogenic radioactivity. Possible examples are mollusks which accumulate
radioactive materials in shells, or other benthic invertebrates which are not directly consumed by
people. Presuming that such work is not part of existing monitoring and that adequate information
does not exist in the available literature on environmental partitioning and biological accumulation
of radionuclides, radiological comparison of sediment and organisms near nuclear facilities with
equivalent materials elsewhere may well provide indicators of possible ecological impacts.
The EPA and NRC are jointly updating draft guidance based on public comments on "Guidance on
Radioactive Materials in Sewage Sludge/Ash at POTWs". The original draft version was made publicly
Page 30 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
available in May 1997. The document will provide data on typical concentrations of radionuclides
in sewage sludge and ash at Publicly Owned Treatment Works (POTWs). Sewage sludge and ash at
POTWs may contain both naturally-occurring and man-made radioactive materials. Another
document publicly available is the "Joint NRC/EPA Sewage Survey: Survey Design and Test Site
Results". The document provides data on typical concentrations of radionuclides in soils, fertilizers,
and other commercial materials to allow comparison to concentrations of radionuclides detected in
a pilot study of sludges from nine POTWs. Radiation in the environment results from various
sources. For example, water moving in or through geologic deposits may contain naturally-occurring
radionuclides that travel to water treatment facilities in addition to radioactive materials
administered to patients for the treatment of illnesses or other industrial or residential discharges,
such as fertilizers. Specific questions can be directed to Robert Bastian and Behram Shroff, EPA
respectively at 202-260-7378 and 202-564-9707, or Tin Mo, NRC at 301-415-8151.
The Inventory called specific attention to the 1996 discontinuation of an annual report, prepared by
Brookhaven National Laboratory for the NRC which assembled in a standardized format the
emissions data from U.S. nuclear power plants. The Inventory went on to conclude that the
discontinuation "...represents a serious reporting setback for those groups interested in the
radionuclide emissions from U.S. nuclear power facilities." The desire for existing monitoring
findings to be put in a consistent form, as readily usable by environmental researchers as possible,
at a presumably small cost compared to expanding monitoring, is entirely reasonable; indeed, the
U.S. would recommend expanding such a report to encompass both this country and Canada.
Reviewing existing monitoring programs, with an eye toward evaluating whether they are well suited
to identifying recognized or heretofore unrecognized "long-term toxicological and ecological
problems" (rather than any unidentified, acute human risks) from anthropogenic radionuclides
seems reasonable. Making any consequent changes should be considered in the context of the
wide variety of other environmental monitoring and research potentially undertaken on behalf of the
DC.
EPA has the longstanding Environmental Radiation Ambient Monitoring System (ERAMS), intended
to monitor ambient levels of radioactive pollutants and background radiation. The ERAMS
coordinators have always been amenable to analyzing environmental media of concern to
researchers or communities near nuclear facilities. The U.S. will explore opportunities to amend the
ERAMS program in ways which address the IJC's concerns.
It should be noted that the State of Michigan's Radiation Environmental Monitoring Program,
established in 1958 to monitor the environment around Michigan's nuclear power plant sites, found
that no public health or environmental radiation impacts due to operation have ever been detected
off site. Additionally, for the first time in forty years, the results show only natural background
levels, indicating radiation levels from fallout due to past atmospheric testing continue to decline.
These levels will provide for a much improved environmental baseline for monitoring nuclear plant
impacts. Michigan will update this data annually and make the information available on the
Internet at:
www.deq.state.mi.us/dwr
16. Governments monitor toxic chemicals used in large quantities at nuclear power plants,
identify radioactive forms of the toxic chemicals and analyze their impact on the Great
Lakes ecosystem.
Page 31 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
In January 1998, EPA requested information from 36 Resource Conservation and Recovery Act
(RCRA) regulated facilities related to generation and storage of so-called "mixed waste," during the
twenty-month period between April 26, 1996, and December 31, 1997. Mixed waste is regulated
both by EPA as hazardous waste under RCRA, and by the NRC under the Atomic Energy Act (AEA) as
radioactive material. The queried facilities were intended to represent the range of "nuclear
facilities" which manage hazardous wastes. Of the twelve U.S. nuclear generating stations (fifteen
reactors) in the Great Lakes Basin, only the Davis-Besse Nuclear Power Station (DBNPS) in Ohio was
queried; the two queried "secondary sources" in the Basin were a university in the Detroit area and
a metal finisher in the Chicago area.
The First Energy Corporation responded that zero mixed waste was generated or stored at DBNPS
during the twenty-month period. Further:
"The DBNPS has a Pollution Prevention and Waste Minimization Plan, which includes mixed
wastes. A process change was implemented in 1991 which involved changing from a
solvent-based cleaning of anti-contamination clothing to water-based cleaning. This process
continues to be utilized which eliminated the generation of mixed waste solvents. Also,
hazardous materials use restrictions in radiological areas are emphasized. Administrative
controls have successfully eliminated the generation of mixed waste since 1992."
Because of the very limited number of facilities having the necessary RCRA permits and AEA
licenses for disposing of mixed wastes, most handlers of radioactive materials go out of their way
not to generate such wastes from such materials. Of the fourteen nuclear generating stations
queried, four had generated zero mixed waste during the twenty-month period; the remaining ten
cumulatively had generated approximately 170 cubic feet, an average of approximately twelve cubic
feet per station.
However, having no mixed waste as a remnant of past practice is unrepresentative of the fourteen
queried nuclear generating stations, which had a total of approximately 1,700 cubic feet of mixed
waste in storage, an average (including DBNPS) of approximately 120 cubic feet per station. While
some of this waste ostensibly is being stored for decay (radioactivity often is considered effectively
to have decayed to zero after ten half-lives) after which the wastes may be managed simply as RCRA
hazardous wastes, a large fraction (perhaps a majority) of the mixed wastes are being held because
of limited or non-existent disposal capacity. Inspection of the nuclear generating stations'
responses suggests that the largest fraction of the difficult to dispose wastes are radiologically
contaminated chlorofluorocarbon solvents and solvent filters generated in the laundering of work
clothes, and radiologically contaminated waste paint materials.
By comparison, the response from the Detroit area university indicated 46 drums of scintillation vial
waste and 53 drums of liquid waste (which, in context, appears to be scintillation liquid); assuming
that one drum typically contains 55 gallons, or 7.35 cubic feet, of material, the university generated
a total of approximately 730 cubic feet of mixed waste. The Chicago area manufacturer responded
that it had generated or stored no mixed waste.
The 1998 query responses seem generally consistent with findings in a 1992 report prepared by
Oak Ridge National Laboratory for EPA and the NRC: " National Profile of Commercially Generated Low
Level Radioactive Waste." This report identified a total of approximately 140,000 cubic feet of low-
level mixed waste being generated or stored during 1990, just less than 10 percent of which came
Page 32 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
from the 110 commercial nuclear reactors; the predominant mixed hazardous waste type was
solvents (84 percent of total).
The U.S. is not aware of any toxic chemicals used in "large quantities" at nuclear power plants.
Further, presuming that toxic chemicals at industrial facilities frequently become RCRA hazardous
wastes, responses from U.S. nuclear generating stations suggest that only small quantities of
"radioactive forms of the toxic chemicals" and radiologically contaminated toxic chemicals are
generated annually at nuclear generating plants. However, extrapolating from responses to the
1998 RCRA information request, and there being twelve U.S. nuclear generating stations in the
Basin, a total on the order of 1,500 cubic feet of mixed waste may be expected in extended storage
in U.S. stations in the Basin.
Both the 1992 EPA/NRC report and responses to the 1998 RCRA information request point to
considerably greater quantities of mixed waste cumulatively being associated with "secondary"
sources than with nuclear generating stations. Thus, the IJC's specific attention to radioactive forms
of toxic chemicals from nuclear generating stations does not seem warranted.
17. Governments investigate and report toxicological and ecological problems associated
with tritium, carbon-14, iodine-129, isotopes of plutonium and radium.
The Inventory divides radionuclides of special ecological interest into two groups, (I) long-lived
radionuclides, arising from natural sources and aspects of the nuclear fuel cycle, and (II) other
anthropogenic radionuclides present in the uranium fuel cycle. The Report ranks the first group as
deserving of priority investigation.
Extensive literature exists describing the environmental fate and toxicological impact of a range of
radionuclides. Much of this work derives from a desire to understand the harmful effects in
humans of exposure to the products of nuclear reactions, such as from commercial nuclear reactors
and nuclear explosions. Immediately identifiable sources of information on the environmental fate
of the radionuclides the IJC specifies include reports from the National Council on Radiation
Protection and Measurements; considerable expertise on the human toxicology of radionuclides
also resides in EPA's Radiation Protection Division. The voluminous literature on the subject is
authoritatively summarized in "Health Risks from Low-Level Environmental Exposure to Radionuclides:
Federal Guidance Report No. 13 -- Part 1, Interim Version "(EPA, 1998), available on the Internet at:
http://www.epa.gov/radiation/rpdpubs.htm
The literature surrounding ecological impacts of anthropogenic radionuclides seems to be smaller.
One source, as indicated earlier, is "NCRP Report No. 109: Effects of Radiation on Aquatic
Organisms" (
In responding to the IJC recommendation, the U.S. recognizes the considerable information
available in the existing scientific literature; a comprehensive literature review should inform any
judgement about supporting new research.
With the statement (sec. 2.3.2) that "[t]he nuclear fuel cycle is currently the main source of
anthropogenic radioactivity emitted to the Great Lakes," the Inventory devotes attention to radium
Page 33 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
from the mining and milling of uranium, and in particular, to the annual liquid releases from the
CAMECO Welcome and Port Granby low-level waste management facilities into the Serpent River,
Ontario (these facilities are identified as the only ones in the Great Lakes Basin associated with
uranium mining and milling). The average annual radium releases from 1983 through 1995 from
the Welcome and Port Granby ponds are 5.5 x 106 Becquerels (Bq) and 7.9 x 106 Bq, respectively
(in context, it would seem to be only radium-226).
In addition to being released during uranium milling and refinement, radium-226 is a common,
naturally occurring constituent of groundwater; the Maximum Contaminant Level (MCL) allowed by
EPA under the Safe Drinking Water Act is five picocuries per liter (pCi/L) (0.185 Bq/L). It may be
useful to compare the amounts released from Welcome and Port Granby to those introduced into
surface water from common groundwater use.
Assuming that drinking water is supplied at precisely the MCL to a hypothetical 100,000 people
using 75 gallons per day per person, the annual radium-226 throughput would be approximately
1,900 x 106 Bq - more than 100 times the combined annual release from Welcome and Port
Granby. Further, considerable radium-226 may be removed from groundwater before distribution,
either in a deliberate attempt to reduce radium or as an inadvertent consequence of reducing
suspended and dissolved solids. Settling flocculated and precipitated solids is a common
groundwater treatment method. At some drinking water treatment plants, the resultant sludge may
be scooped up and managed as solid waste; at others, the sludge may be slurried into a sewerage
system and thus add radium to that discharged from the treated throughput. Groundwater
treatment sludge, especially where radium removal is inadvertent, well may represent a significant
and largely unevaluated risk to waste handlers.
If the intent of the Nuclear Task Force in indicating radium as deserving of further study is to trace
the fate and possible harmful impacts of radium from the uranium fuel cycle, attention should be
paid to radium from groundwater as a significant, perhaps insuperable, confounding factor.
SOCIAL AND ECONOMIC ASPECTS
18. Governments structure a transition study and develop a transition model by December
31, 1999, for one of the chemicals presently under investigation through the Great
Lakes Binational Toxics Strategy.
The U.S. fully agrees with the Commission that an equitable and deliberative transition process is
necessary, putting into place the policies that can contravene negative impacts, and involving all
sectors. However, the U.S. does not believe that an additional transition study or transitional model
will help us progress towards virtual elimination, and therefore we do not fully support this
recommendation. Rather the U.S. believes that the processes currently in place serve the same
function as a new study or model. In order to best evoke change, we need to put our energies into
the existing efforts.
Specifically, the process being conducted under the Binational Toxics Strategy (BNS) contains
elements of what would be included in a "transition planning" model. Many of these elements are
currently contained in the four step process by which the BNS identifies candidate chemicals for
inclusion.
Page 34 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
In the U.S., of the twelve Level I substances listed, five are banned or canceled pesticides under the
Federal Insecticide Fungicide and Rodenticide Act (FIFRA) and one is a banned substance (RGBs)
under the Toxic Substances Control Act (TSCA). Through these regulatory processes the targeted
chemicals have, for the most part, been removed from U.S. commerce. The regulatory and legal
processes which led to these bans and phaseouts is the most powerful U.S. method of transitioning
substances out of societal use. These bans and phaseouts are followed by aggressive clean sweep
programs to collect and properly dispose of stockpiles of these substances, as well as remedial
activities to remove the contaminants already in the environment.
The challenge remains how to equitably and deliberatively transition the chemicals currently in use
towards virtual elimination. The Binational Strategy sets up a transitional framework. We are
writing reports to document achievements on the chemical challenges identified in the strategy,
and to communicate the state of knowledge for the targeted chemicals, including, as appropriate,
the regulatory framework, sources, and pollution prevention and reduction opportunities.
A true transition is best put in place in collaboration with stakeholders. Those who use the targeted
chemicals know their industrial and manufacturing processes best, and therefore are well suited to
figure out how to virtually eliminate these chemicals of concern.
An important element of the transition is working on a sector by sector approach. The U.S. is
working toward this goal by engaging industrial sectors directly, through Project XL and others, to
help define and promote innovative approaches to prevent pollution while remaining economically
strong. We are also actively pursuing strategic partnerships with industrial sectors. Examples of
these include our work with the American Hospital Association, the steel industry in Northwest
Indiana, and the chlor-alkali industry.
The U.S. will continue to work closely with a variety of stakeholders and sectors under the BNS
process as well as the National Persistent Bioaccumulative Toxics Strategy. We will continue to
ensure that we communicate our progress on the Binational Strategy through the reports, the
Internet and other methods. This communication is a crucial aspect to conveying our progress on
the transition taking place in the basin.
19. Governments commission a study to evaluate the practical value of utilizing the
ecological economics approach.
While in accord with the ecological economics motivation to acknowledge more broadly the
contributions ecosystems make to social welfare, the U.S. has reservations about endorsing an
ecological economics study without knowing more about the approach to be taken. Ecological
economics research has been advancing in many disparate directions, some promising and others
less so.
Ecological economics is more of a fresh perspective than a discipline in its own right, forcing
reconsideration of some of the simplifying assumptions in applied welfare economics. Most work
under the rubric of ecological economics is simply economic research that takes the complex
linkages between ecological and economic systems into careful consideration. Many economists
and interdisciplinary teams have focused their analytical efforts upon accounting for and valuing the
less familiar, though highly significant, ecosystem services (e.g., recreation, flood mitigation, and
biodiversity). Analytical methods under development include natural resource accounting (El Serafy,
1997), indicators of value (King and Crosson, 1995), bioeconomic modeling (Barbier, 1994), and
Page 35 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
quasi-option value pricing (Coggins and Ramezani, 1998). In accord with the conventions of
welfare theory, the approaches are conducive to policy analysis. They permit comparison of actual
and baseline states to gauge the increment of ecosystem service gained or lost through an action or
activity.
Some ecological economic attempts at valuation, however, misapply economic concepts to estimate
substantial sums both misleading and ill suited for policy analysis. In particular, the "total
valuation" approach seeks to estimate the value of an entire class of ecosystem using either the
cost to provide an engineered replacement for the services provided or the revenues generated
from the services (e.g., Costanza et al., 1997; Ehrlich and Ehrlich, 1997; Pimentel et al., 1997). On
the one hand, this application violates the necessary conditions to use the replacement cost
method (an otherwise bonafide valuation technique). For example, individuals must be shown
willing to incur these replacement costs. On the other hand, revenues from ecosystem services
bear little relation to the social benefits measure that is of interest. Moreover, the issue of double
counting surfaces when total valuation is used to value a region's ecosystems because the services
of one ecosystem may substitute for another's. These and other methodological critiques to total
valuation are well documented (e.g., Bockstael et al., 1998; Sagoff, 1997; Simpson, 1998; and
Toman, 1998).
In any case, total value estimates serve no practical purpose because total valuation assumes a
"zero" baseline. Few regulations result in the complete loss or recovery of an ecosystem or service.
As for more likely policy questions, the estimates are unable to say anything about incremental
changes in service flows.
While piloting an ecological economics study in the Great Lakes Basin may potentially be a sound
investment, the U.S. position is that any approach proposed must be well defined and acceptable to
the mainstream of environmental economists and ecologists. Thus, proposals akin to total
valuation would be viewed askance as they provide specious answers to the wrong questions.
One ongoing effort by EPA to assess ecological benefits comprehensively is in the context of
water quality improvements to Lake Erie. To answer the question of what pollution controls
affecting Lake Erie have done for social welfare, the physical and ecological effects of such controls
are first being estimated. Valuation methods will then use these data to monetize the change in
services flows attributable to environmental regulation.
This study is proceeding in several steps: First, pollutant loadings to the lake are being estimated
for two scenarios, current conditions and those absent pollution controls. An existing eutrophication
model is being updated to take advantage of recent advances in water quality the extent of hypoxia
and anoxia in the lake for both scenarios. These data will then be applied to a bio-energetics model
to quantify the difference in fish survival and growth resulting from regulatory actions to date. Last,
behavioral models, such as recreation demand models, will convert these effects into measures of
welfare useful for policy analysis.
Page 36 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
Appendix I: References For Specific Recommendations
References for Recommendation #8
Lonky E, Reihman J, Darvill T, Daly H. 1996. Neonatal behavioral assessment scale performance in
humans influenced by maternal consumption of environmentally contaminated Lake Ontario
fish. J Great Lakes Res 22:198-212.
Stewart P, Darvill T, Lonky E, Reihman J, Pagano J, Bush B. 1999. Assessment of prenatal exposure
to PCBs from maternal consumption of Great Lakes fish: An analysis of PCB pattern and
concentration. Environ Res Section A 80, S87-S96.
Mendola P, Buck GM, Sever LE, Zieiezny M, Vena JE. 1997. Consumption of PCB-contaminated
freshwater fish and shortened menstrual cycle length. Am J Epidemiol 146:955-60.
References for Recommendation 19
Barbier, E. 1994. "Valuing Environmental Functions: Tropical Wetlands," Land Economics70: 155-
173.
Bockstael, N.E., Freeman, A.M., Kopp, R.J., Portney, P.R., and V.K. Smith. 1998. "On Valuing
Nature," unpublished. Presented at the Resources for the Future Seminar Series, January
1998, Washington, DC.
Coggins, J., and C. Ramezani. 1998. "An Arbitrage-Free Approach to Quasi-Option Value," Journal of
Environmental Economics and Management^'. 103-125.
Costanza et al. 1997. "The Value of the World's Ecosystem Services and Natural Capital," Nature
387:253-260.
Ehrlich, P. and A. Ehrlich. 1996. Betrayal of Science and Reason. Washington, DC, Island Press.
El Serafy, S. 1997. "Green Accounting and Economic Policy," EcologicalEconomics-21: 217-229.
King, D., and P. Crosson. 1995. "Natural Capital Indicators." Paper prepared for the Resource Policy
Consortium, World Bank, Washington, DC.
Pimentel et al. 1997. "Economic and Environmental Benefits of Biodiversity," BioStiencebl:
747-757.
Sagoff, M. 1997. "Can We Put a Price on Nature's Services?" Report from the Institute for
Philosophy and Public Affairs, University of Maryland, College Park, MD.
Simpson, R. 1998. "Economic Analysis and Ecosystems: Some Concepts and Issues," Ecological
Applications, 8: 342-349.
Toman, Michael. 1998. "Why Not to Calculate the Value of the World's Ecosystem Services and
Natural Capital," EcologicalEconomies'^: 57-60.
Page 37 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
Appendix II: Suggested Corrections to Text of Report
Pg. 16, 4th paragraph - The suggestion is made that governments are moving away from regulation
toward voluntary efforts, and that this may be a cause for concern. However, it should be noted that
the U.S. Great Lakes Initiative will impose new, more stringent regulations to protect both human and
wildlife health.
Pg. 17, 2nd Ml paragraph, CERCLA- The text incorrectly states that a U.S. waste site cannot be listed
or remediated unless a potentially responsible party (PRP) can be identified. One of the most important
aspects of the Superfund Program is that cleanups are initiated regardless of whether or not a PRP
exists. The text goes on to state that some of the highest priority U.S. waste sites are not addressed
and that "no alternative mechanisms are in place to address the many contaminated sites that await
action throughout the U.S." No mention is made of state Superfund programs or other remedial tools
that exist to deal with waste site issues.
Pg. 19,1st bullet & following page - The U.S. 33/50 program, a voluntary waste reduction program
which ended in 1996, is discussed as if it is still an active program.
Pg. 34- The major Lake Michigan tributaries, including those in Michigan, were intensively monitored
during 1994 and 1995. Although routine monitoring of Michigan tributaries has been curtailed, some
special projects have included tributary monitoring.
Pg. 37, first bullet item - The suggestion that Lake Ontario currently receives 90 percent of its
dioxin/furan loads from sources within the Basin is based on an inappropriate interpretation of
sediment core data collected by Pearson et al. 1997. It is well understood that the levels of
contaminants in the environment in water, biota and sediment do not change to zero the moment that
all contaminant inputs are removed. Under a "zero load" scenario, contaminant levels in the system
undergo a first order rate of decrease in most environmental media. This is basically what the Pearson
etal. data shows for Lake Ontario. Levels of dioxins/furans have been in the process of decreasingfor
well over a decade. The sediment core data shows the system is responding to decreases to past
1970s reductions in dioxin loads to the system and do not only reflect current loads to the system. A
more complete review of a wide variety of environmental data would be required to compare or contrast
the relative importance of current sources. The Niagara River Upstream-Downstream Program finds
current levels of dioxin/furan entering Lake Ontario to be at nondeductible levels.
Pg. 38- Comment on the mercury narrative: second sentence-'Today, only one mercury cell facility
is still in operation in the Great Lakes Basin." There is a Vulcan facility in Port Edwards, Wl and an
Ashta Chemical facility in Ashtabula, OH.
Pg. 41-T\\Q report presents the issue of radioactivity a bit too strongly. On page 35 it is listed along
with PCBs, dioxins and mercury as a substance that is posing a problem. The IJC December 1997
report on radioactivity did not identify any specific environmental problems due to radioactivity.
The IJC may want to consider correcting the record regarding the status of monitoring of New York's
Great Lakes tributaries and the scope of the Superfund Program. Considering the magnitude of the
error, a formal correction would be best. Alternatively, the IJC could allow EPA Region 2 and/or New
York State to develop an article for their Focus magazine to describe the very advanced level of
environmental monitoring that is being undertaken in New York's Great Lakes Basin, toward the goal
Page 38 of 39
-------
DRAFT DELIBERATIVE COPY - DO NOT QUOTE, CITE, OR RELEASE-JUNE 1999
of virtual elimination. The inaccurate statements regarding the CERCLA program could also be
corrected in such an article.
Page 39 of 39
------- |