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
August 1999
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INTRODUCTION
The United States (U.S.) compliments the International Joint Commission (the Commission or
"DC") 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 ensuring that the needs of the Great
Lakes are well met through the efficient use of all resources. The development of State of the
Lakes Ecosystem Conference (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
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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 continued progress in furthering
the adoption and full implementation of the ecosystem approach.
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.
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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 amounts 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, MI; completed in the summer of 1997, achieving a clean up of 3-5
ppm residual PCBs;
* 73,000 cy of PCB-contaminated sediment (2,700 Ibs. removed out of a total of 4,875 Ibs.
of PCBs) from the Manistique River and Harbor, MI from 1995 - 1998, thus far achieving
the clean up goal of less than 10 ppm; the remaining 45,000 cy to be removed during the
1999/2000 construction seasons;
*• 150,000 cy of PCB-contaminated sediment (10,000 Ibs. PCBs total) to be removed from
Bryant Mill Pond, Kalamazoo River, MI; to be completed in Summer 1999, achieving 0.1
- 0.6 ppm residual PCBs;
*• 440,000 cy of PCB-contaminated sediment and soil (300,000 Ibs. of PCBs) from the
Willow Run Creek, Huron River, MI completed in 1998; achieving the 1 ppm clean up
goal for sediment.
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> The removal of 345,000 cy of PCB-contaminated sediment from the Saginaw River, MI,
beginning in 1999/2000 and to be completed over a 2-year period.
> The removal of 700,000 cy of contaminated sediment (heavy metals, PCBs, PAHs,
cyanide, benzene, oil and grease) from the east branch of the Grand Calumet River, IN
(USX Site), targeted to begin in 2000/2001 season following design and construction of
the sediment disposal facility.
> The removal of 4.65 million cy of contaminated sediment from the Indiana Harbor Ship
Canal, IN, with construction of the sediment management facility targeted to begin in
2000 and dredging to follow in 2002.
> 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.
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 "Realizing Remediation, " 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
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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 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 it works 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.
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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 a critical component for restoring
and maintaining the health of the lakes. 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 is
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 monitored under the BNS
includes:
• 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 BNS-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.
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PBT Strategy
EPA has developed a draft national Multimedia Strategy for Persistent, Bioaccumulative, and
Toxic Pollutants (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. Starting
with the BNS Level 1 substances, National 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. In addition, work is ongoing to
develop a standard methodology 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 waste per day), and
hospital/medical/infectious waste incinerators (hereafter called medical waste incinerators). Both
include new requirements for emission limitation to control chlorinated dioxins, mercury,
particulate matter and carbon monoxide among other pollutants. 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 sector initiatives will result in a 75
percent or greater reduction in total dioxin releases to air between 1987 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 would include "Gasoline Distribution Stage I Aviation" in a listing under
Section 112(c)(6) of the Clean Air Act that would place the evaporative loss emissions of aviation
gas associated with airplane fueling, a source of alkyl lead, on a schedule for the development of
Maximum Achievable Control Technology (MACT) regulations.
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 (HCB) air emissions since 1990. A June 1999 air toxic
standard for pesticide active ingredients will further reduce HCB 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 on May 28, 1999 published an Advance Notice of Proposed
Rulemaking concerning potential revision of the land disposal restrictions for mercury containing
waste.
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The Administrator of EPA must make a finding as to whether regulation of mercury and other
toxics from electric utilities 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 in May 1999 and the EPA
will publish the results on its web-site shortly thereafter. This information collection will
continue through mid 2000.
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 pilot testing of technologies for mercury
control and includes engineering and economic studies. The second phase will consist of
three to five large scale pilot tests 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 pilot tests 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)
signed in June 1998 by members of the United Nations Economic Commission for Europe (ECE-
which includes the U.S. and Canada) under the Convention on Long-Range Transboundary Air
Pollution (LRTAP). The objective of the POPs protocol is to control, reduce or eliminate releases
of persistent organic pollutants, starting with a set of 16 substances which include many of those
targeted by the BNS. In June 1998, most of the ECE's 55 member countries signed the POPs
protocol. A second LRTAP Protocol concluded and signed by most of the ECE member
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countries in June 1998 will reduce emissions of lead, cadmium, and mercury below 1990 levels,
phase out leaded gasoline, and promote a number of voluntary measures to reduce mercury levels
in products. The Administration 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 by the end of the year
2000 on the first 12 POPs chemicals and on the criteria for selecting additional chemicals.
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 (CEC) 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. On June 28, 1999, the CEC Council announced the
development of a North American Regional Action Plan (NARAP) to reduce releases to the
environment of dioxins and furans, and hexachlorobenzene. The CEC Council reaffirmed its
commitment to reduce chemical pollutants affecting the health of their citizens, particularly
children, and also agreed to develop an environmental monitoring and assessment action plan in
support of 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.
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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.
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 was released by EPA in December
1998 and is available via the INTERNET at www.epa.gov/ardpublc/acidrain/egrid/egrid.htm
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. In September 1998, EPA called for a reduction in NOx
emissions, a major precursor of ozone, by 1.1 million tons annually in 22 eastern states. EPA
expects this action would mitigate ozone transport problems associated with power generation.
Implementation of this action has been stayed, at least temporarily, by U.S. Courts in relation to
ongoing litigation. However, EPA is in the process of moving forward on petitions filed by
several northeastern states under section 126 of the Clean Air Act. These petitions request EPA
to reduce NOx emissions from sources located in upwind states. In response to these petitions,
and on the basis of other information, EPA expects to promulgate a market-based capped trading
program to control NOx emissions from certain stationary sources, including utilities.
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.
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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.
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.
The U.S. would like to sound a cautionary note regarding the realities of achieving these laudable
goals. In many parts of the Great Lakes watershed, nonpoint source loadings are largely from
ground water, which may account for 60-80 percent of all stream flow. Nonpoint source loadings
from ground water may take years, decades, or longer to decrease and therefore may make it
difficult to achieve the 30 percent reduction goal by the year 2005. The U.S. is working to
improve its understanding of the impacts of ground water as a major source of herbicide loadings
to the Great Lakes. Recent improvements in herbicide application Best Management Practices
(BMPs) are designed to help reduce the infiltration of these substances into the ground water and
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therefore reduce loadings. A further confounding factor, identified by the USGS, is that pesticide
loads from urban watersheds can be as high or higher than those found in agricultural watersheds,
chiefly due to storm water runoff, and may further impact the ability to achieve the recommended
reductions. The U.S. Great Lakes Program in general, and the USGS in particular, will continue
to research and address the impacts of ground water in the Basin.
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 rural watersheds 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.
The U.S. fully recognizes the need to further reduce the loadings of pesticides and herbicides to
the Great Lakes. Although over 120 pesticide active 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
"AgriculturalProfile" 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
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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.
AOCS AND 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 appreciate 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 in-depth reviews of selected AOCs over the last biennium have also helped the
Parties to better target their efforts. This continuing complementary relationship between the
Parties and IJC will continue to enhance future RAP implementation and restoration activities.
The U.S. responses to specific recommendations contained in Beacons of Light are presented
below.
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.
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The LaMPs and AOCs programs 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 is 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 LaMP and RAP 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.
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
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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 LaMP Program 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.
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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/
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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
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 PCBs from the Waukegan Harbor AOC. PCBs are one of the compounds largely
responsible for fish consumption advisories in the Great Lakes. This removed mass represented
the largest single source of PCBs in 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 (CAG). In addition, the
work of the CAG and the associated governmental partners in achieving this unprecedented
cleanup was recognized at the SOLEC 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 (CAG). Also the CAG 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 LaMP Program Managers track progress on all AOCs within
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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.
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
• PCBs: 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 PCBs accumulating in fish,
but at much lower levels than found in most AOCs where PCBs are a major problem.
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• 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.
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
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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 County 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 County 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.
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 1990s 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-
+•» 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
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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 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.
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 result in 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)
developing a screening program 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
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of 1996, require the Agency to develop a screening program for endocrine disrupters by August
1998, implement the screening program 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 vitro and in vivo test 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 and the 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 supported 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 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, AT SDR'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, PCBs, 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.
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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 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 highly 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 of Great Lakes Research Managers. 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 last 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 workshop, a subsequent electronic network of Great Lakes communicators and educators
was established.
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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.
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3. The continued enhancement of Lake Ontario mass balance models.
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 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.
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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.
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.
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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
for 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.
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 to the IJC, 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 phosphorus
loadings, 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.
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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.
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: discontinuing the use of 2,4,5-T and Hexachlorophene; the manufacturing of PCBs; the
elimination of lead from virtually all gasoline sold in the U.S.; and major reductions in the dioxin
levels associated with the chlorine 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.
The U.S. is also improving the public's right to know about what chemicals are being used in their
communities. A proposed rule is intended to lower the reporting thresholds under section 313 of
the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA), also known as
the Toxics Release Inventory (TRI), for persistent bioaccumulative toxic (PBT) chemicals and to
add certain other PBT chemicals to the section 313 list of toxic chemicals. These PBT chemicals
are of particular concern not only because they are toxic but also because they remain in the
environment for long periods of time, are not readily destroyed and build up or accumulate in
body tissue. Relatively small releases of PBT chemicals can pose human and environmental health
threats and consequently these chemicals warrant recognition by communities as potential health
threats and as such need to be captured by the TRI Right-to-Know Program. The proposed rule
includes several actions necessary to insure that additional information on PBT chemicals is
reported under section 313 including a proposal for lowered reporting thresholds for PBT
chemicals and special reporting threshold for dioxin. The rule also includes proposed
modifications to certain reporting exemptions and requirements for those chemicals that would be
subject to the lower reporting thresholds.
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
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combustion processes. When the current cycle of dioxin-specific waste combustion regulations is
completed, EPA expects to 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. Over the next few months, drafting and review of the reassessment
will be conducted and a final document released in 2000. 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.
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).
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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 at this time 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 applicable
MACT regulations promulgated by EPA in 1997 or cease to operate. MACT is the level of
emission control required by the Clean Air Act for certain stationary sources of 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.
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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 transitoned
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 Biennial Progress Report to the IJC, 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.
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
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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 PCBs 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. PCBs 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 PCB challenge set out in the
Strategy. The Strategy challenge for PCBs 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 PCB 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.
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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 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 PCBs 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. 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 development 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
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nongovernmental entities need to be implemented to continue to make progress in removing
PCBs from the environment.
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 U.S. agrees that it is important to determine if monitoring in the Basin could better serve the
needs of the Agreement. As we do routine reviews of monitoring programs, we will explore ways
in which these programs could be adjusted or modified to accommodate the Agreement goals.
Our response to this recommendation identifies some of these opportunities
The December 1997 "Inventory of 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
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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 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 IJC. The U.S. will look for opportunities for making these changes during
routine reviews of existing monitoring programs.
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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.
The U.S. actively monitors a variety of substances used a nuclear power plants through regulatory
programs administered by EPA and NRC. Based on the findings of these programs, 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 (as explained more fully below) 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. These conclusions are based on the following
information.
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:
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"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 from the 110 commercial nuclear reactors; the predominant mixed
hazardous waste type was solvents (84 percent of total).
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. In addition, there does not appear to be large
volumes of radioactive forms of toxic chemicals from nuclear generating stations.
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The U.S. will continue to monitor nuclear generating stations to insure that toxic chemicals are
not being used in large quantities and that radioactive forms of toxic chemicals are not being
generated in sufficient amounts to cause significant impact on the Great Lakes ecosystem.
17. Governments investigate and report toxicological and ecological problems associated
with tritium, carbon-14, iodine-129, isotopes of plutonium and radium.
The U.S. agrees that these substances have the potential to impact the Great Lakes ecosystem and
are deserving of a heightened level of awareness regarding these impacts. In responding to the
IJC recommendation, the U.S. recognizes that there is considerable information available in the
existing scientific literature, most of which focuses on the toxicological impacts of these
substances. 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" (1991). A comprehensive literature review could inform any judgement
about supporting new research. The U.S. will explore the need for increased research into
ecological impacts.
The Commission's 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
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 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).
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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, the U.S.
recommends that attention should be paid to radium from groundwater as a significant, perhaps
insuperable, confounding factor. We will examine ways by which this determination could be
made.
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.
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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
(PCBs) 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 are the most powerful U.S.
methods of transit oning substances out of societal use. These bans and phaseouts may be
followed by actions by other regulatory programs which may include aggressive clean sweep
programs to collect and properly dispose of stockpiles of these substances or 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 BNS 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 BNS 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.
The U.S. agrees with the utility of using economic modeling to assess environmental impacts to
the Great Lakes ecosystem. However, the U.S. has reservations about endorsing an ecological
economics study without knowing more about the approach to be taken. While in accord with the
ecological economics motivation to acknowledge more broadly the contributions ecosystems
make to social welfare, ecological economics research has been advancing in many disparate
directions, some promising and others less so. 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.
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The U.S. believes that the 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 economic research that places
new emphasis on the complex interactions and interdependences between ecological and
economic systems. 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 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, appear to misapply economic concepts
to estimate substantial sums both misleading and ill suited to 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).
It would seem that total value estimates serve no practical purpose for decision making 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 this approach is not currently being used in the Basin, less contentious valuation methods
are being applied. One ongoing effort by EPA to assess benefits comprehensively is in the context
of water quality improvements to Lake Erie. To answer the question of what abating pollution to
Lake Erie has done to improve social well-being, the physical and ecological effects of regulation
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
modeling to estimate 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.
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Appendix I: References For Specific Recommendations
References for Recommendation #8
Lonky E, Reihman J, Darvill T, Mather, J, and 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, Zielezny 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 Economics 70:
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 35: 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," Ecological Economics 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," BioScience 47:
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," Ecological Economics 25: 57-60.
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Appendix II: Suggested Corrections to Text of Report
Pg. 16, 4thparagraph - 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 full 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. The IJC's description of the CERCLA
program contains additional inaccuracies. EPA would gladly welcome the opportunity to inform the
IJC regarding how the CERCLA program effectively employs a number of tools to protect the public
and the environment from uncontrolled releases of hazardous substances.
Pg. 19,1st bullet & follow ing 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 maj or 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
et al. data shows for Lake Ontario. Levels of dioxins/furans have been in the process of decreasing
for 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
Monitoring Program finds current levels of dioxin/furan entering Lake Ontario to be at nondetectable
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, WI and an
Ashta Chemical facility in Ashtabula, OH.
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Pg. 41 - The report somewhat overstates the significance of the issue of radioactivity as a current
environmental problem. 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 may be appropriate. 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 of virtual elimination. The inaccurate statements regarding the CERCLA
program could also be corrected in such an article.
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