&EPA
United States
Environmental Protection
Agency
Great Lakes National
Program Office
230 South Dearborn Street
Chicago, Illinois 60604
EPA 905/9-89/006
GLNPO 05-89
U.S. Progress in
Implementing The
Great Lakes Water
Quality Agreement
Annex Reports to the
International Joint
Commission
Draft
March 22, 1989
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U.S. Progress in
Implementing the Great Lakes
Water Quality Agreement
Annex Reports to the
International Joint Commission
Draft
March 22,1989
U.S. Environmental Protection Agency
Great Lakes National Program Office
230 South Dearborn Street
Chicago, Illinois 60604
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DRAFT
TABLE OF CONTENTS
Page
INTRODUCTION
ANNEX 1: SPECIFIC OBJECTIVES 1
ANNEX 2: REMEDIAL ACTION PLANS AND LAKEWIDE MANAGEMENT PLANS 2
INTRODUCTION 2
REMEDIAL ACTION PLANS 2
LAKEWIDE MANAGEMENT PLANS 19
ANNEX 3: CONTROL OF PHOSPHORUS 28
ANNEX 12: PERSISTENT TOXIC SUBSTANCES 29
RESTRICTIONS ON THE DISTRIBUTION OF CRITICAL POLLUTANTS
IN COMMERCE 29
WASTE REDUCTION AND RECYCLING 32
TOXICITY REDUCTION ACTIVITIES 39
ANNEX 13: POLLUTION FROM NONPOINT SOURCES 41
INTRODUCTION 41
PHOSPHORUS REDUCTION PROGRAMS 41
WATERSHED MANAGEMENT PLANS TO CONTROL TOXIC LOADINGS
FROM NONPOINT SOURCES 43
1987 AMENDMENTS TO THE CLEAN WATER ACT ~ STATE NONPOINT
SOURCE ASSESSMENTS AND MANAGEMENT PROGRAMS 44
OTHER ACTIVITIES 44
ANNEX 14: CONTAMINATED SEDIMENT 47
INTRODUCTION 47
COORDINATION OF RESEARCH AND OTHER STUDIES 48
SURVEILLANCE PROGRAMS 48
TECHNOLOGY PROGRAMS 55
LONG TERM CONTROL MEASURES 61
ANNEX 15: AIRBORNE TOXIC SUBSTANCES 67
INTRODUCTION 67
GREAT LAKES ATMOSPHERIC DEPOSITION NETWORK 68
GREEN BAY MASS BALANCE STUDY 69
AIR TOXICS EMISSION INVENTORIES 70
ANNEX 16: CONTAMINATED GROUND WATER 71
INTRODUCTION 71
U.S. ENVIRONMENTAL PROTECTION AGENCY ACTIVITIES 71
U.S. GEOLOGICAL SURVEY ACTIVITIES IN THE GREAT LAKES BASIN 74
WELLHEAD PROTECTION ACTIVITIES 75
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TABLE OF CONTENTS (Continued)
SPECIAL REPORT TO THE INTERNATIONAL JOINT COMMISSION ON
POINT SOURCE CONTROLS 77
INTRODUCTION 77
THE NATIONAL COMBINED SEWER OVERFLOW STRATEGY 77
STORM WATER PERMITTING IN THE ROUGE RIVER 78
STORMWATER REPORT TO CONGRESS 79
SECTION 304(1) OF THE CLEAN WATER ACT 79
IMPLEMENTING WATER QUALITY-BASED POINT SOURCE EFFLUENT
LIMITATIONS FOR TOXIC SUBSTANCES 80
PRETREATMENT 80
NATIONAL MUNICIPAL POLICY 81
DEMONSTRATION PROJECTS 81
MONITORING DATA FOR TOXIC LOADINGS FROM POINT SOURCES 82
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INTRODUCTION
The 1987 revisions to the Great Lakes Water Quality Agreement (GLWQA) strengthened
many of the Agreement's provisions, including clarification of the responsibilities of the United
States and Canada as Parties to the Agreement. One significant revision requires that the Parties
report on progress in addressing Annexes 1, 2, 12, 13, 14, 15 and 16. In response, this document
was prepared as the first Report to the International Joint Commission (IJC) on U.S. progress
towards responding to these Annexes.
In addition to the specific reporting requirements to which this document responds, Article
IX of the GLWQA states that "the IJC shall be given, at its request, any data or information
relating to water quality in the Great Lakes system...." Such information is used extensively in
preparing the reports of the Water Quality Board to the Commission. One very important category
of this information relates to point sources of pollution and progress towards its control.
Therefore, a special section has been included at the end of this Report, to provide current
information on U.S. programs for the control of point sources.
U.S. programs and activities that address provisions of the GLWQA not covered in this
report are discussed in the 1988 Report to Congress on the Great Lakes Water Quality Agreement
and in the Five-Year Strategy for the Great Lakes National Program Office. Readers desiring
copies of those documents should contact the Great Lakes Program Office, 230 South Dearborn
Street, Chicago, Illinois 60604. Further information on U.S. and Canadian activities related to the.
GLWQA can be found in the Great Lakes Water Quality Board Report to the IJC, available from
the Windsor Regional Office of the IJC, Post Office Box 32869, Detroit, Michigan 48232.
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ANNEX 1: SPECIFIC OBJECTIVES
Annex I and its 1987 Supplement call for the development of Specific Objectives,
which are defined in the GLWQA as "the concentration or quantity of a substance or
level of effect that the Parties agree, after investigation, to recognize as a maximum
or minimum desired limit for a defined body of water or portion thereof, taking into
account the beneficial uses or level of environmental quality which the Parties desire
to secure and protect;..,"
In addition to the existing Objectives categories in the GLWQA -- Chemical,
Physical, Microbiological and Radiological the Supplement added Ecosystem
Objectives, to emphasize the aspect of "level of effect" in the above definition.
Achievement of Ecosystem Objectives is to be evaluated through ecosystem health
indicators, which will be developed as described in Annex 11.
The Supplement to Annex 1 modifies the Annex by clarifying responsibility and
establishing a framework for developing Specific Objectives. To assist in sorting out
the many chemicals that could be considered in this task, the Supplement requires the
development of three lists of substances believed to have toxic effects and found
within the Great Lakes System, or having potential for discharge into it. In proposing
substances for new Specific Objectives, the Parties are to be guided by these lists.
Although no new Objectives have been added, important work on identifying and
characterizing substances found within the Great Lakes was done by IJC committees.
Of the approximately 1,000 compounds reported to have been found, the committees
confirmed 264 (?), as reported in the 1987 Water Quality Board Report. The 1987
revisions to the GLWQA shifted the responsibility for such work from the IJC to the
Parties. In response, the United States and Canada formed an Objectives Development
Committee and began the process to developing lists of compounds and reviewing extant
and prospective Objectives.
Although implementing this new responsibility has progressed somewhat slowly,
progress is being made. The effort will be supported in part by the well-established
United States process for developing regulatory criteria and standards for ambient
conditions that are analogous to Specific Objectives. In the November 1988 semi-
annual meeting of the Parties, preliminary agreement was reached on definitions to be
used in creating the three substance lists, and a preliminary list (List #1) was
derived for substances that are toxic and present in the Lakes. Also, preliminary
agreement was reached on a new Specific Objective for dioxin and revisions in the
Objectives for selinium and toxiphene. These objectives will not become officially
adopted until public consultation occurs and offical communication is completed
between the U.S. Department of State and External Affairs Canada.
Efforts by the Parties to develop definitions, lists and objectives will
continue. This work will be reviewed regularly in the semi-annual meetings of the
Parties. Considerable progress is expected before the next formal report on the
development of objectives is due, in December 1990.
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ANNEX 2: REMEDIAL ACTION PLANS AND LAKEWIDE MANAGEMENT PLANS
INTRODUCTION
The basic management framework of the Great Lakes Water Quality Agreement
(GLWQA) defines environmental quality objectives and beneficial uses, calls for monitoring the
state of the Lakes and pollutant inputs, and outlines management plans to identify the remedial
actions needed to attain the desired objectives and beneficial uses. Nonattainment of Agreement
objectives is addressed on three geographic scales: Lakewide Management Plans (LMPs) will
address critical pollutants that are impairing beneficial uses in waters of the open Lakes, Remedial
Action Plans (RAPs) will address use impairments within designated Areas of Concern (AOCs),
and Point Source Impact Zones adjacent to discharge points will be identified and minimized.
Annex 2 of the amended GLWQA endorses and builds upon the existing efforts of the
Parties, States, Provincial governments, and the International Joint Commission (IJC) to develop
RAPs and LMPs. The major provisions of Annex 2 include specifications for the content of RAPs
and LMPs, and requirements for designating critical pollutants for the boundary waters of the
Great Lakes System with regards to LMPs. The Annex also introduces the concept of Point Source
Impact Zones, defining them as zones that "...exist in the vicinity of some point source discharges,"
the size of which "...shall be reduced to the maximum extent possible by the best available
technology." Methods for identifying and delineating point source impact zones will be developed
and progress must be reported beginning September 30, 1989, and reviewed biennially thereafter
(Annex 2, Section 7).
The Annex also requires that the Parties report to the IJC by December 31, 1988, and
biennially thereafter, on their progress in developing and implementing RAPs and LMPs, and in
restoring beneficial uses to the Great Lakes System.
REMEDIAL ACTION PLANS
RAPs are the result of a process that began in 1981 when the Great Lakes Water Quality
Board identified a number of geographic areas within the Great Lakes Basin that had severe water
quality problems, subsequently called AOCs. These areas were seriously out of compliance with
Agreement objectives or jurisdictional standards, criteria, or guidelines established to protect
beneficial uses. The present 42 AOCs include Lake areas adjacent to most of the major
metropolitan and industrial centers within the Basin (Figure 1). Of the total number of AOCs,
41 suffer from toxic substances contamination. Most of these have problems related to
contaminated bottom sediments.
Responsible Parties
Thirty AOCs are located wholly or in part within the United States. The States have
taken responsibility for developing RAPs with assistance from various Federal agencies, including
the U.S. Environmental Protection Agency's (USEPA's) Great Lakes National Program Office
(GLNPO), U.S. Army Corps of Engineers (USCOE), U.S. Fish and Wildlife Service (USFWS), U.S.
Department of Agriculture, and U.S. Geological Survey (USGS). Table 1 presents a summary of
the States responsible for RAP development and the completion status of U.S. RAPs.
Illinois and Indiana are both responsible for one AOC. The Illinois EPA is coordinating
efforts on the Waukegan Harbor AOC, and the Indiana Department of Environmental Management
is developing a RAP for the Grand Calumet River/Indiana Harbor AOC.
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Figure 1. Location of Areas of Concern in the Great Lakes
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Table 1. Status of U.S. Remedial Action Plans
Projected Date to
Areas of Concern Submit Completed RAPs
by State for IJC Review
Illinois
Waukegan Harbor Deferred
Indiana
Grand Calumet/ 1989
Indiana Harbor
Michigan
Torch Lake 1987
Deer Lake/Carp River 1987
Manistique River 1987
Kalamazoo River Pending Civil Litigation
Muskegon Lake 1987
White Lake 1987
Saginaw River/ 1988
Saginaw Bay
Clinton River 1988
Rouge River 1988
River Raisin 1987
Michigan/Ontario
St. Marys River 1989
St. Clair River 1989
Detroit River 1989
Minnesota/Wisconsin
St. Louis River 1990
New York
Buffalo River 1989
Eighteenmile Creek 1990
Rochester Embayment 1990
Oswego River 1989
New York/Ontario
St. Lawrence River 1990
Niagara River 1991
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Table 1. Status of U.S. Remedial Action Plans
(continued)
Projected Date to
Areas of Concern Submit Completed RAPs
by State for IJC Review
Ohio
Maumee River 1989
Black River 1990
Cuyahoga River 1991
Ashtabula River 1989
Wisconsin/Michigan
Menominee River 1989
Wisconsin
Fox River/ 1987
Southern Green Bay
Sheboygan Harbor 1989
Milwaukee Estuary 1990
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Wisconsin contains three AOCs in their entirety and shares two others: One with
Minnesota and one with Michigan. The Wisconsin Department of Natural Resources (DNR) is
responsible for coordinating RAP efforts. The State uses the Clean Water Act (CWA), Section 208
Water Quality Management Plans (WQMPs) as a management tool for statewide prioritizatkm. The
State is currently updating the WQMP for the Lake Superior Basin and will incorporate their
findings into the St. Louis River RAP that Wisconsin is developing in cooperation with Minnesota.
Michigan has 10 AOCs within its boundaries and shares 1 AOC with Wisconsin and 3
with Ontario. The Michigan Department of Natural Resources (DNR) is responsible for developing
and/or coordinating RAP initiatives. Michigan has several other statewide initiatives related to
the restoration of beneficial uses called for in Annex 2, For example, Michigan voters recently
supported a $425 billion bond issue to fund environmental protection programs. This fund will
finance the cleanup of toxic waste sites and other contaminated areas, contribute to a regional
Great Lakes protection fund, address solid waste problems, treat sewage and other water quality
problems, encourage reuse of industrial sites, and preserve open space.
Four AOCs are located in Ohio, The Ohio EPA is preparing the RAPs in cooperation
with various citizen advisory committees.
There are four AOCs located within New York's boundaries and two AOCs that New
York shares with Ontario. All of New York's RAP development and coordination and cooperation
initiatives are managed through the New York State Department of Environmental Conservation
(NYSDEC).
The following is a Lake-by-Lake discussion of the AOCs and the progress that has been
made on the RAPs since the IJC's 1987 Report on Water Quality.
LakeSuperior
Lake Superior, is the largest (82,100 km )and the deepest (maximum depth of 40? m and
mean depth of 149 m) of the Lakes, and has remained the most pristine and oligotrophic system.
Concentrations of polychlorinated biphenyls (PCBs) in lake trout in Lake Superior continue to
exceed the Agreement objective, while the DDT, dieldrin, and mercury objectives are being met.
Public health fish consumption advisories have been issued for lake trout taken from Lake Superior
waters.
The Water Quality Board has identified seven AOCs in Lake Superior, where GLWQA
objectives are not being met. The following three AOCs are located within the United States.
Si. Louis River/Bay
The St. Louis River/Bay AOC is located on the extreme southwest shore of Lake
Superior. The lower part of the river acts as the border between Minnesota and Wisconsin. Most
of the river's watershed is in Minnesota. The AOC includes the St. Louis Bay, Superior Bay,
Allouez Bay, the nearshore waters of Lake Superior and the St. Louis River below the Fond du
Lac dam.
Historically, water quality has been affected primarily by discharges from local industrial
and municipal sources. Although water clarity above the zone of dischargers is fairly good, the
water is stained slightly brown due to high content of humic acids and naturally occurring related
compounds. Current water quality data generally show no significant problems, although past data
have indicated elevated levels of mercury at some stations. High levels of PCBs, dioxin, and
mercury have also been found in northern pike, walleye, and carp tissue samples.
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The RAP for this AOC is being written by both Minnesota and Wisconsin. Minnesota's
Pollution Control Agency has accepted the lead role for this RAP, and Wisconsin is providing
technical assistance and review. A RAP Coordinator was hired in June 1988, and initiation of the
RAP development process has begun. Two public meetings were held in November, and a survey
of meeting participants' concerns and ideas has been completed. A Citizen's Advisory Committee
will be established in January 1989, and soon after, technical advisory committees will be
established for each issue area. The RAP will identify the beneficial uses impaired, data gaps, and
remedial actions to restore the beneficial uses. Completion of the RAP is scheduled for June 30,
1989.
Torch Lake
Torch Lake, located at the base of the Keweenaw Peninsula in the Upper Peninsula of
Michigan, is a tributary to Lake Superior. Degradation has been caused by mine tailings disposed
of in the Lake and sediments contaminated with creosotes and xanthates that were used in a
copper-concentrating process from 1926 to 1969. These substances are thought to have caused a
high incidence of liver tumors and other malignant deformities in older, larger walleye and sauger
fish. In recent years, the incidence of tumors seems to have decreased, however; fish of the
affected size class can no longer be found.
The Michigan DNR submitted a first draft of the Torch Lake RAP in October 1987
and received comments from IJC in June 1988. Those comments are currently being addressed.
Most of the possible remedial actions have already been taken. No effective method for sediment
removal has been developed and remedial action will entail allowing sediments from upstream to
cover the copper-contaminated sediment layer.
Deer Lake/Carp Creek/Carp River
The Deer Lake/Carp Creek/Carp River AOC includes Deer Lake, Carp Creek, and 20
miles of the Carp River downstream to Marquette, Michigan, on Lake Superior. Deer Lake is a
907-acre impoundment located near Ishpeming in Michigan's Upper Peninsula. In 1981, mercury
was found at high concentrations in fish, sediments, and fish-eating birds. A fish consumption
advisory has been in effect since 1981.
The RAP for Deer Lake was submitted in October 1987. In 1988, extensive fish
monitoring was conducted; fish were collected and their tissues analyzed for mercury content.
St. Marvs River
The St. Marys River is one of the four Great Lakes connecting channels. The river
flows approximately 110 km from Lake Superior to Lake Huron. The United States and Canada
share responsibility for developing remedial actions for the St. Marys River. Degradation of water
quality can be attributed to power generation, shipping traffic, and discharges of nutrients and
toxic substances from industrial and municipal point sources, as well as urban nonpoint source dis-
charges and combined sewer overflows. In particular, sediments are contaminated with iron, zinc,
cyanide, oils and greases, phenols, and wood particles, while the water column has elevated
concentrations of phenols, iron, zinc, cyanide, and ammonia.
Completion of the St. Marys River RAP has been delayed until September 1990 to allow
completion of the Upper Great Lakes Connecting Channels (UGLCC) Study. The study will
provide the region with new data that will be incorporated into the RAP. The Cannelton Tannery
has been designated as a Superfund site by USEPA. No new site specific studies or remedial
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actions have been undertaken since 1987, The site has a Binatkmal Public Advisory Council that
contributes to RAP development efforts.
Lake Michigan
Lake Michigan lies completely within the United States, and is the second largest Lake
in terms of volume and depth, but the third in terms of surface area (57,800 km ). PCS and DDT
concentrations are gradually declining in Lake Michigan lake trout, but still remain above the
Agreement objectives. Public health fish consumption advisories have been issued for lake trout,
salmon, and brown trout taken from Lake Michigan waters.
There are 10 AOCs on Lake Michigan. A brief discussion of each AOC and the status
of RAP development follows.
Manistique River
The Manistique River is located in Michigan's central upper peninsula and flows from
the northeast, discharging into Lake Michigan at Manistique City. Impacts to biota were first
noted in the mid-1950s and were attributed primarily to deposits of wood fiber and other organic
waste from sawmill and papermill operations and to sanitary wastes. Later studies also identified
several chemical wastes that contributed to degradation. Environmental degradation at this site
is primarily sediment contaminated with PCBs and heavy metals, which adversely impacts biota
and causes fish consumption advisories. "
The Michigan DNR submitted a draft RAP in October 1987, received comments from
the UC, and is revising the RAP accordingly. In addition, several studies have been conducted
in the past year to test for additional sources of contamination. Specifically, fish have been
collected from above the Manistique dam (outside the AOC). In summer 1988, fish tissue was
tested primarily for the presence of PCBs. The results were not available as of February 1989.
Sediment samples have also been collected from within the AOC and from above the dam to test
for and compare contaminant levels to State and Federal criteria.
Menominee River
The Menominee River AOC is shared by the States of Wisconsin and Michigan. It acts
as Wisconsin's northeastern corner border and flows between Menominee, Michigan, and Marinette,
Wisconsin, emptying into Sturgeon Bay, Lake Michigan. The river generally receives heavy
recreational use. In addition, lake sturgeon use the area for spawning and there is an extensive
walleye fishing industry located at this site. The primary concern here is the presence of arsenic
in the sediments of the Marinette Harbor, In addition, PCBs have been detected in area fish, and
local beaches have been closed occasionally due to high counts of fecal coliform bacteria.
Officials plan to submit a RAP for this area in 1989. A Citizens Advisory Committee
was established in early 1988. The Committee's role is to develop community support and review
recommendations. A technical work group is also being established and will hold its first meeting
in November 1989. The RAP will be developed in conjunction with a Consent Order between the
USEPA and the Ansul Fire Protection Company, which is being held responsible for discharges
of arsenic to the local publicly owned treatment works. More detailed information is confidential
to date and further RAP development is dependent upon disclosure. Wisconsin has the lead role
in this joint endeavor with Michigan and will hire a full-time RAP coordinator when funds
become available.
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Fox River/Southern Green Bay
The Fox River/Southern Green Bay AOC is located in northeastern Wisconsin near the
west shore of Lake Michigan. The AOC includes the City of Green Bay, the lower 7 miles of the
Fox River, and the southern end of Green Bay, extending north to an imaginary line from Long
Tail Point to Poing au Sable (approximately 20 square miles). Although there have been marked
improvements in the water quality and fisheries in this AOC, major problems still exist regarding
toxic contaminants, excess nutrients and turbidity, and habitat loss. Over 100 toxic substances,
including 37 priority pollutants and 11 different resin and fatty acids, were identified in the
discharges to the Lower Fox River from 14 pulp and paper mills and five major municipal
wastewater treatment plants.
The first draft of the Fox River/Southern Green Bay RAP was submitted in 1987. The
Wisconsin DNR has received comments from the IJC on the first draft and will address these
concerns in a letter to the IJC. The RAP has also been submitted to the Secretary of the DNR
as part of a statewide water quality management plan. The RAP is now being implemented, and
an implementation coordinating committee has been established. This committee is chaired by a
county executive, ensuring that local citizens will be involved with the RAP process. The
committee acts as an advisory council to the DNR and is divided into two subcommittees; a
nonpoint source subcommittee and a public education and participation subcommittee.
In support of the RAP, the Wisconsin DNR and the USEPA are coordinating the Green
Bay Mass Balance Study. Wisconsin is conducting numerous studies on the Fox River that will
contribute data to the mass balance modeling effort. The State is also developing a detailed
program for cleaning up the East River, which is a State-designated priority watershed. This
includes Best Management Practice development and a cost-sharing plan to aid local counties in
nonpoint source pollution cleanup. In addition, the Green Bay Municipal Sewerage District is
upgrading its system to meet current effluent limits.
Lower Sheboygan River and Harbor
The Lower Sheboygan River and Harbor AOC includes the entire Sheboygan Harbor
and approximately 12 miles of the river from its mouth to Sheboygan Falls, Problems include
PCB-coataminated fish and sediments resulting in a fish consumption advisory, high bacteria
levels, excess sediment and turbidity, and a poor quality community of aquatic organisms as
indicated by an overabundance of pollution tolerant insects and algae.
The Sheboygan River Task Force and the Citizens Advisory Committee are cooperating
with the Wisconsin DNR to develop the RAP for this site. Currently, a definition of the problem
has been distributed for public comment, and recommendations for corrective action are being
drafted. A draft of the RAP is now under public review. The final draft is expected to be
submitted to the IJC by April 1989. The State is cooperating with Superfund and priority
watershed designations to prevent a duplication of effort. In addition, the State recently completed
an update to the Sheboygan Water Quality Management Plan (as required by Section 208 of the
Clean Water Act), The State will submit this as a supplement to the RAP, which is projected for
completion in early 1989.
Milwaukee Harbor
The Milwaukee Harbor AOC encompasses the lake level portions of three rivers,
Milwaukee Harbor, and the nearshore areas of Lake Michigan. The rivers are the Lower
Milwaukee River, the Menominee River, and the Kinnickinnic River, Major water quality
problems include sediments contaminated with toxic inorganic and organic substances, low
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dissolved oxygen levels, a fish consumption advisory, excess nutrients and sediments, high bacteria
levels, lack of spawning habitat, and conditions that detract from recreational use of the area.
The Wisconsin DNR is currently completing a paper evaluating the need for developing
a traditional RAP. This paper discusses the problem, objectives, activities and responsibilities, a
timetable, and the public role in the process. It is currently being circulated among communities
for public comment. Other RAP components are being coordinated with at least 11 completed or
emerging management plans. The RAP is scheduled for completion in October 1990.
Currently, a minimum of five projects related to the restoration of beneficial uses in
Milwaukee Harbor are being conducted:
Currently, efforts are being conducted to identify nonpoint source pollution,
establish objectives for nonpoint source management, and ultimately provide
a cost-sharing plan to aid cleanup efforts.
The Southeast Wisconsin Regional Planning Committee completed the
Milwaukee Estuary Study in 1987, which involved intensive modeling of
the rivers and harbor to determine the level of pollution control needed to
meet water quality standards.
The University of Wisconsin is developing a strategic management plan for
navigation and environmental management for the Milwaukee Harbor.
The Port of Milwaukee Authority is conducting an economic plan for the
Harbor, which will address revitalization.
Wisconsin DNR is developing an integrated resource management plan for
nonpoint source pollution, fisheries, and wildlife.
In addition, a Citizens Advisory Committee is being established, consisting of a single advisory
committee for the RAP, the watershed, and the integrated management plan. The State has also
established a Milwaukee Revitalization Council to assess the economic, environmental, and
recreational revitalization of the Milwaukee River Basin.
Waukegan Harbor
Waukegan Harbor is located on the western shore of Lake Michigan, approximately 40
miles north of Chicago in Waukegan, Illinois. The Illinois EPA is responsible for coordinating the
development of the RAP for the 37 acres of contaminated harbor sediments and soils.
Specifically, the harbor's sediments and soils are ladened with PCBs. The principal
source is thought to be discharges from the Outboard Marine Corporation (OMC) in the early
1970s. As much as 1.1 million pounds of PCBs contaminate the site, 300,000 pounds of which are
in the harbor itself.
In 1984, USEPA set forth a Record of Decision authorizing expenditures of $21 million
to clean up the site. The project was suspended, however, pending the conclusion of litigation
regarding access to OMC's property. Negotiations have been under way since late 1986 between
USEPA, Illinois EPA, and OMC regarding a specific proposal for corrective action that was
submitter3 by OMC. In 1988, these negotiations led to a Consent Decree, which established the
areas to be remediated, the methods to be used, and the financial responsibility, both immediate
and long-term, for the cleanup. OMC will finance a trust to implement cleanup and will ensure
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performance of that trust. Once these remedial actions have been completed, the State will then
reassess the necessity of a RAP.
Grand Calumet River/Indiana Harbor
The Grand Calumet River/Indiana Harbor Canal is located in northwest Indiana. The
AOC includes the entire Grand Calumet River (13 miles long) and the Indiana Harbor, which is
approximately 15 miles south of downtown Chicago. Many years of heavy industrial and
municipal activity along the Grand Calumet River and the Indiana Harbor Shipping Canal have
created severe water quality problems that have only recently begun to diminish. Degradation is
primarily reflected in severely polluted sediments contaminated with oil and grease, polynuclear
aromatic hydrocarbons (PAHs), PCBs, heavy metals, and many other priority pollutants. Despite
improvements during the past 5 to 7 years, the capacity to assimilate pollutants in the River and
Canal is diminishing. The Indiana Department of Environmental Management (IDEM) is primarily
responsible for coordinating cleanup initiatives.
A preliminary draft RAP for the Grand Calumet River/Indiana Harbor, prepared in
1986, identified numerious data gaps including information on the harbor and nearshore areas, air
quality, solid and hazardous wastes, and sediment management issues. By January 1988, a revised
RAP had been drafted and distributed for public comment. The primary mechanism for the
development of this second draft was the Remedial Action Plan Work Group, composed of
individuals from the IDEM, USEPA, USCOE, USFWS, USGS, and several public interest groups.
The State is negotiating for expanded public participation, as reflected in the development of a
draft public participation/outreach workplan published in October 1988. The work plan, to be
implemented in FY 1989, includes recommendations for making videotapes, buying television time,
conducting workshops and seminars, and providing other general outreach to neighborhoods and
others the RAP will affect. The goal of the workplan is to rally community support for the RAP.
The State plans to submit a final RAP draft to IJC in early 1989.
The Indiana RAP will focus on corrective action for solid and hazardous waste
management issues and will recommend further assessment of sediment contamination and air
deposition. Some studies pertaining to the contaminated sediment issue are in progress. IDEM
has contracted with the USCOE to write an Environmental Impact Statement by early 1989 that
defines management options for contaminated sediments in the River and Canal. In addition,
work has begun on a State-funded study to define the amount and characteristic of sediment
buildup in the Grand Calumet River. The USCOE is conducting a similar study in the Indiana
Harbor.
Kalamazoo River
The Kalamazoo River is located in the southwest portion of Michigan's lower peninsula.
The river flows in a westerly direction and discharges into Lake Michigan. The major problem
in the Kalamazoo River is PCB contamination of biota, water, and sediments. Historically, the
primary source of PCBs has been wastewater discharges from paper industries. Presently, how-
ever, problems are directly attributable to inplace PCB-contaminated sediments, where an
estimated 230,000 pounds of PCBs reside.
The draft RAP for the Kalamazoo River, prepared in 1986, includes cost/benefit
analyses, tentative timetables, and feasibility studies. In addition, specific remedial actions have
been evaluated, although no particular methods have been officially selected. Georgia Pacific
Corporation completed a State-requested study of PCB-contaminated waste disposal ponds, as well
as a follow-up study to recommend options for remedial action. Michigan DNR is currently
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evaluating these options. Other studies reported in Appendix A of the 1987 Water Quality Board
Report to the IJC are ongoing. No new research initiatives were undertaken in late 1987 or 1988,
The Michigan DNR has reviewed and responded to public comments on the first draft
of the RAP, The final RAP was planned for submission to IJC in October 1988, however, the
deadline was postponed due to the State's involvement in civil litigation against Allied Paper
Incorporated and other parties that may be contributing PCBs to the river,
Muskegon Lake
Muskegon Lake is a 4,150-acre inland coastal lake located in Muskegon County along
the eastern shoreline of Lake Michigan, north of the City of Muskegon. Prior to 1973, Muskegon
Lake received direct discharges of industrial process wastewater, municipal wastewater treatment
plant effluent, combined sewer overflows, and urban runoff. The excess nutrient enrichment a-
nd solids and toxic substance loadings resulted in nuisance algal blooms, reduced oxygen
concentrations in the water column, tainted fish, and contaminated sediments. Petroleum,
chemical, and other heavy industries in the area have also contributed to contaminated ground
water.
The Muskegon Lake RAP has been submitted to IJC for secondary review. Most of
the remedial actions included in the RAP have already been taken. Proposed actions concern
studies regarding the environmental health of localized areas (i.e., tributaries and tributary mouths)
that do not affect the AOC as a whole.
Michigan is currently submitting fish tissue samples of bass and walleye for laboratory
analysis. Data is expected by April 1989 and should provide information on the sources of PCBs,
chlordane, and mercury. Preliminary analysis indicates that atmospheric deposition, rather than
point or localized sources, is responsible for increased contamination. Remedial action to contain
seepage of contaminated ground water into Little Bear Creek has begun.
White Lake
White Lake is also located in Muskegon County, along the eastern shoreline of Lake
Michigan in the vicinity of Montague and Whitehall, Michigan. This AOC includes White Lake
proper and a 0.4 km zone around the lake. The major environmental problem here is
contaminated ground water entering White Lake from the Occidental (Hooker) Chemical Company
property. The contaminants of concern include trichloroethylene, carbon tetrachloride, and
perchloroethylene in ground water, as well as hexachlorobutadiene, hexachlorobenzene, and
octachlororcyclopentene in the soil. Michigan DNR recently tested sediments as a potential source
for PCBs and chlordane found in carp. Preliminary results indicate that these two contaminants
are below the detection level for sediment.
The RAP has been submitted for secondary review by the IJC and most of the remedial
actions embodied in the plan have been taken. Attention is now being focused on more localized
problems that do not affect the AOC as a whole,
Lake Huron
o
Lake Huron is the second largest Great Lake in terms of surface area (59,700 km ).
Like Lake Superior, Lake Huron has a drainage basin that supports lower population densities and
more forested lands than the other Great Lakes. Consequently, the quality of the open waters of
Lake Huron is generally high, with levels of nutrients and major ions within GLWQA objectives.
12
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DRAFT
Concentrations of dieldrin and DDT in Lake Huron lake trout are below the Agreement
objective, although there appears to be no decreasing trend in concentrations since 1979, As with
most of the other Great Lakes, Lake Huron's PCB concentrations in lake trout continue to exceed
the objective. There also does not appear to be a trend of decreasing PCB concentrations since
1979. Public health fish advisories have been issued suggesting that the consumption of lake trout,
rainbow trout, and brown trout caught in Lake Huron waters be restricted.
Of the four AOCs on Lake Huron, only Saginaw Bay exists within U.S. boundaries.
Saginaw Bay
Saginaw Bay is a western extension of Lake Huron located in the east central portion
of Michigan's lower peninsula. Anthropogenic inputs to the Bay are dominated by agriculture in
the rural areas of the Basin and by industrial and municipal wastewater discharges from four
major urban areasFlint, Saginaw, Bay City, and Midland, Michigan. The major water quality
issues of concern are eutrophication and toxic contamination, including PCBs and heavy metals.
The final version of the Saginaw Bay RAP was produced in October 1988. The most
significant action taken since 1987 is the development of a mechanism for public education and
outreach under the auspices of the Saginaw Bay Natural Resources Steering Committee (SBNRSC).
This Committee was formed in July/August 1987. In September, the State submitted a rough
version of the RAP to SBNRSC, which the Committee reviewed for about 6 months, providing the
State with comments that were later incorporated into the RAP. A similar process was followed
for a second draft of the RAP.
The Committee is also in the process of establishing a nonprofit corporation to set up
a fund that would respond to natural resource problems throughout Saginaw Basin. SBNRSC
activities for 1989 include completing the nonprofit application process activities; gathering
personnel to administer the nonprofit corporation; maintaining interaction between the public and
the Michigan DNR regarding RAP activities; producing a lay version of the RAP consisting of a
55-page brochure to be distributed to the public; issuing a quarterly newsletter dealing with
Committee activities, as well as RAP issues and general resource issues; and establishing a
nonpoint source committee to coordinate and direct the nonpoint source management efforts on
a basin-wide scale,
St. Clalr River
The St. Clair River is a connecting channel that serves as an outlet of Lake Huron,
flowing south to Lake St. Clair. The St. Clair River is shared by the United States and Canada.
The river is an important international waterway with heavy demands placed upon it as a shipping
channel and as a source of water for commercial, industrial, and domestic uses. Sediments have
been contaminated by chlorinated organics and volatile hydrocarbons, while the water column has
been degraded by discharges of nutrients and toxic substances from industrial and municipal point
and nonpoint sources and from inplace pollutants.
The St. Clair River RAP's schedule has been extended to September 1990. Delays can
be attributed to extensive efforts in this region to complete the UGLCC Study, The study will
contribute new data that will be incorporated into the RAP. A Binational Public Advisory
Council is in place that contributes to RAP development efforts.
13
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DRAFT
Lake St. Glair
Lake St. Clair is a small shallow lake that connects the St. Clair River with the Detroit
River between Lakes Huron and Erie. It supports an active recreational fishery, as well as an
international navigation channel.
Clinton River
The Clinton River AOC is located on the eastern shore of Michigan, approximately 15
miles north of Detroit's Belle Isle and discharges into Lake St. Clair at Mount Clemens, Michigan.
In the past, nutrients, oxygen-consuming substances, and heavy metals have been discharged to
the Clinton River by industries and municipal wastewater treatment plants, resulting in low
dissolved oxygen and degradation of biological communities downstream of the discharges.
Impaired uses have been caused by exceedingly high fecal coliform bacteria counts, heavy metals,
and PCB-contaminated soil.
A RAP for this site was completed in October 1988 and was submitted to the IJC in
early November. Thus far, sources of contamination have been identified, but no remedial action
has taken place. The State is waiting for RAP recommendations to be approved.
Petrole River
The Detroit River connects Lake St. Clair and Lake Erie and serves as an international
boundary between Michigan and Ontario. The Detroit River AOC is the third international AOC.
The Detroit River is used extensively for shipping, recreation, and public and industrial water
supply. The river receives treated wastewater from numerous municipal and industrial facilities,
direct storm runoff, and combined sewer overflows. Sediments contain high levels of PCBs, heavy
metals (mercury, cadmium, chromium, copper, and zinc), and oil and grease.
This AOC has been a major focus of the UGLCC Study. The information gathered will
be particularly useful in developing the Detroit River RAP. The Detroit River RAP is scheduled
for submission to the IJC by December 1989.
Lake Erie
Lake Erie is the fourth largest Great Lake in terms of surface area (25,700 km^)and is
the most shallow lake, with a mean depth of only 19 meters. It consists of three distinct basins
that differ in water quality characteristics. Lake Erie's shores are highly urbanized and its major
tributaries drain intensively farmed soils. Lake Erie was the first of the Lakes to show
systemwide signs of cultural eutrophication, but was also quicker to respond than the other Lakes
to cleanup efforts because of its relatively short retention time.
Concentrations of DDT and dieldrin in Lake Erie remain below the Agreement objective
for fish tissue concentration. PCB concentrations are elevated above the objective level, with
concentrations in walleye being about five times the objective level. Both carp and catfish are the
subject of public health fish consumption advisories, with restricted consumption being
recommended in New York and no consumption being recommended in other States bordering the
Lake.
The Water Quality Board has designated seven AOCs within the U.S. boundaries of Lake
Erie, discussed below.
14
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DRAFT
Rouge River
The Rouge River flows through Metropolitan Detroit and empties into the Detroit River,
The lower Rouge River is the most severely polluted river in the Basin. Sediments are heavily
contaminated with toxic substances and organic sludges, precluding the presence of normal aquatic
life. Toxics include cadmium, chromium, copper, lead, mercury, nickel, and zinc. The river is
also moderately polluted with PCBs that are bioaccumulating in carp and catfish.
The first draft of the RAP was submitted to the IJC in 1988. The State is
simultaneously conducting discussions with local communities. The RAP recommends implementa-
tion and remedial action rather than further investigation and assessment. The State plans to make
a final submission to IJC in January 1989, but views the RAP as a fluid document that will be
revised continually to reflect yearly efforts until the Rouge River can be removed from the AOC
list.
River Raisin
The River Raisin is located in the southeastern portion of Michigan's lower peninsula
in Monroe County, Michigan, Problems that exist include heavy metals (copper, zinc, and
chromium) and PCB contamination of sediments and the water column, sedimentation, and
siltation from nonpoint sources.
The RAP was submitted in October 1987 and IJC's comments have already been
incorporated. The RAP will be updated as needed. Public meetings were held before the RAP
was developed to gain community input, and the public was asked to review the draft upon its
completion. The RAP already had strong public support, however, because the State capitalized
on an existing Rouge River Watershed Council (to the north of the River Raisin). The Council
acted as a Citizens Advisory Committee, developing and contributing to community support and
providing publicity.
The Michigan DNR has undertaken several studies to date in support of the River Raisin
RAP. The State completed a caged-fish study in July and August 1988 (fish were held for 28
days in cages suspended in the water column, then the fish tissue was sampled) to test for
bioaccumulation/bioconcentration. Samples have been submitted to a laboratory for analysis, but
there are no results to date. The State is also conducting preliminary sediment samples in six
different locations to identify hot spots and other sources of PCBs and heavy metals. Both of
these studies were funded with an $87,000 grant under Michigan's Act 307. Seyeral other cleanup
projects that were recommended in the RAP are being conducted independently of RAP
implementation. Both the Ford Motor Company and Port of Monroe have been designated Act
307 sites, and remedial action programs are being developed.
Maumee River
The Maumee River AOC has been tentatively identified as the area from river kilometer
33 to the mouth, Maumee Bay, the nearshore area southeast of the mouth, and the lower segments
of several streams tributary to the main stem and the Bay. Water quality violations include
dissolved oxygen, ammonia, arsenic, lead, copper, zinc, cadmium, iron, mercury, and fecal
coliform bacteria. Fish tissue samples indicate elevated PCB levels in whole-body composites and
sediments polluted with oxygen-consuming materials, cyanide, arsenic, copper, nickel, zinc, iron,
ammonia, total phosphorus, and oil and grease.
The Toledo Metropolitan Area Council of Governments (TMACOG) has initiated a
baseline investigative study describing the problems of this AOC. The report has been submitted
15
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DRAFT
to Ohio EPA, and the two groups are now in the process of negotiating the next step (i.e.,
determining who will take the lead for the draft RAP). The RAP completion date is set for
August 1989. TMACOG will draft and revise as necessary a recommendation paper on which
Ohio EPA will base its RAP development. TMACOG will continue to lead local involvement
since they were responsible for organizing the local communities into a Remedial Action Advisory
Committee, which is composed of both a technical and a public outreach component.
Black River
The proposed boundaries for the Black River AOC are the lower 15 miles of the river
from Elyria to the mouth, the harbor, and the adjacent nearshore. Violations of Ohio water
quality standards for protection of warm-water habitat are noted in the Black River for dissolved
oxygen, ammonia, fecal coliform bacteria, iron, lead, phenol, cyanide, cadmium, and copper.
Elevated concentrations of biological oxygen demand, total phosphorus, and zinc are also common.
In addition, sediments in the harbor are heavily polluted with metals, oils and grease, and oxygen-
consuming materials. A fish consumption and contact advisory is still in effect for the lower 5
miles of the river. The advisory was issued in 1983 due to a high incidence of tumors in fish.
The occurrence of tumors has been linked to comparatively high PAH levels in the sediment
adjacent to the old U.S. Steel Coke Plant.
GLNPO's contractor completed a background report for this AOC in 1986. A RAP
process integrating public participation has not yet been developed for the Black River, but a
number of major remedial activities are in progress and nearing completion. Activities include
major improvements to the Ilyria and Lorain municipal treatment plants and sewers. In addition,
U.S. Steel is planning to dredge PAH contaminated sediments from the river in the summer 1989.
Currently, it is anticipated that Phase I of the Black River RAP will be submitted to IJC in 1990.
Cuyahoga River
The Cuyahoga River winds its way from a reservoir just south of East Clarendon
southwest to Cuyahoga Falls and then flows north northwest through Cleveland, emptying into
Lake Erie. The most impacted area of the Cuyahoga River is the shipping channel. The natural
hydrology and morphometry of this segment have been altered through channel dredging and
shoreline development. The lower river is also affected by industrial dischargers, including steel
mills and chemical companies, urban runoff, combined sewer overflows, and municipal
dischargers. Violations of Ohio water quality standards occurred with dissolved oxygen, cyanide,
iron, and copper, as well as ammonia, fecal coliform bacteria, phenol, lead, cadmium, and zinc.
Sediments are heavily polluted with ammonia, total Kjeldahl nitrogen, phosphorus, cyanide, oil
and grease, cadmium, chromium, copper, lead, manganese, nickel, zinc, iron, and volatile solids.
The first public meeting was held regarding a RAP for the site in November 1987.
Ohio EPA identified approximately 30 individuals to create the Cuyahoga Coordinating Committee
(CCC). The CCC is further divided into three work groups: Communication, Technical, and
Resource. A Policy Advisory Committee will be established to review and comment on the
implementability of the RAP recommendations. The Ohio EPA is anticipating RAP completion
in 1991.
Ashtabula River
The Ashtabula River AOC includes the lower 2 miles of the river, the harbor, and the
adjacent nearshore. The major concern is sediments that have been contaminated with oxygen-
consuming materials, metals, industrial chlorinated prganics, and PCBs. The primary source of
these pollutants was past industrial discharge to Fields Brook, a tributary to the lower river.
16
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ORAFT
Fields Brook sediment was subsequently classified as hazardous and cleanup is being addressed
under Superfund.
A local advisory council was established in February 1987 and divided into
subcommittees to provide both technical and public outreach support. Recent RAP efforts have
focused on coordination with the Fields Brook Superfund site to dredge contaminated sediments
in the river. The river has not been dredged since 1962, and the water is becoming too shallow
to support the extensive marinas that now line the shores. The dredging program is being
coordinated with the USCOE. RAP activities will stress corrective action, rather than assessment
or management practices. The Ashtabula River RAP is scheduled for completion in late 1989.
Buffalo River
The Buffalo River is located in western New York and empties into Lake Erie. The
River is approximately 6 miles long and is fed by three major tributaries; Cayuga, Cazenovia, and
Buffalo Creeks. The AOC includes the lower portion of the river, the river's mouth, and the
nearshore lake area surrounding the harbor. The Buffalo River has been subject to pollution
problems such as bacteria, oil, excessive levels of phosphorus, chlorine, phenol, mercury, and
general discoloration since the 1940s. New and updated municipal wastewater treatment facilities
and controls on industrial point source discharges have reduced significantly most of the
conventional pollutants. The major problem in the Buffalo River aquatic system currently is toxic
substances, including heavy metals, pesticides, dioxin, and industrial organic compounds (PCBs,
chlorobenzenes, PAHs).
A draft RAP is scheduled for January 1989. The draft will be subjected to public
review and submitted to IJC by May 1989. The RAP will recommend corrective action, but will
not provide a detailed workplan. This site also has a Citizens Advisory Committee that has played
a significant role in the development of the RAP.
Niagara River
The Niagara River, the fourth connecting channel, connects Lake Erie and Lake Ontario
and forms the international boundary between Canada and the United States. The river is a
source of drinking water and industrial process and cooling water; is an energy source and a major
tourist attraction; and receives discharges and wastes from industries and municipalities along its
shores. The major issue in the Niagara River is toxic substances and their potential effects on
human health and the ecosystem. Water quality criteria are exceeded for heavy metals, including
aluminum, cadmium, chromium, copper, lead, and silver. Mercury, arsenic, cyanide, and
selenium, as well as several pesticides, have begun to pose water quality problems. Sediments are
also contaminated with conventional pollutants, heavy metals, industrial organic chemicals, PCBs,
and pesticides.
The preliminary steps for developing a RAP began in 1988. RAP development will begin
in January 1989, with an anticipated completion date of January 1991. The development of a
Citizens Advisory Committee is also forthcoming. The RAP will incorporate the 1984 findings
of the Niagara River Toxics Committee and the Niagara River Toxics Management Plan discussed
later in this report.
17
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DRAFT
Lake Ontario
Lake Ontario is the smallest of the Great Lakes (19,520 km ), but with a mean depth
of 86 meters, is deeper than Lake Erie. Located at the end of the Great Lakes chain, Lake
Ontario receives nutrients and toxic contaminants contained in the outflow of upstream systems,
Because of this source and those within the basin, Lake Ontario generally has high open water
pollutant concentrations.
Lake trout in Lake Ontario contain PCS concentrations that greatly exceed the
Agreement objective. Even though there appears to be a slight downward trend in concentration
over the last 9 years, PCB levels still are 10 times the Agreement objective. DDT concentrations
in lake trout approach the GLWQA objective and apparently have not declined significantly in
recent years, Dieldrin concentrations in lake trout appear to be declining in Lake Ontario and are
already lower than the Agreement objective of 0.3 mg/kg, however. Public health consumption
advisories have been issued for numerous fish species taken from Lake Ontario.
The Water Quality Advisory Board also identified four AOCs within the U.S. boundaries
of Lake Ontario, These areas, which exceed GLWQA water quality objectives for at least one
parameter, are as follows.
Eighteenmile Creek
The Eighteenmile Creek AOC includes Eighteenmile Creek, Olcott Harbor, and the
nearshore waters of Lake Ontario at Olcott, New York. Water quality, sediment, and fish have
been contaminated by heavy metals, PCBs, pesticides, and other volatile organic compounds.
GLNPO's contractor prepared an initial draft RAP in September 1988. NYSDEC has
no timetable for completion,
Rochester Embayment/Genessee River
The Rochester Embayment AOC is defined as nearshore Lake Ontario at Rochester and
Rochester Harbor, New York, and the Genessee River located in Monroe County, Major problems
include toxic contamination of the water column and sediments, PCBs and mirex in fish flesh, and
ammonia toxicity,
GLNPO's contractor prepared an initial draft RAP in 1987. The draft RAP for this
site is under way and should be completed by December 1990. The Monroe County government
will be the primary agency to develop issues presented in the RAP. Public participation will be
achieved through several existing citizen committees already involved with environmental issues.
i
Oswego River
The Oswego River AOC includes the Oswego River, Wine Creek, and the adjacent
nearshore waters of Lake Ontario at Oswego, New York. Major problems include nutrient and
toxic substance contamination of water and sediments, PCBs and mirex in fish flesh, and probable
ammonia toxicity,
GLNPO's contractor prepared an initial draft RAP in 1987. The draft RAP for this
site is scheduled to be completed by November 1989. A Citizens Advisory Council has been
designated and has been very active in providing both technical and political support.
18
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DRAFT
St. Lawrence River/Massena
The St. Lawrence River has been identified as an AOC due to degraded environmental
conditions in the Cornwall/Lake St. Francis and Maitland areas in Canada and the Massena, New
York, area in the United States, which are contaminated with heavy metals, PCBs, and other toxic
substances. RAPs for this site are being developed in parallel by both New York and the
governments of Canada and Ontario. Quebec and the Mohawk Nation at Akwesasne are
participating in the effort. NYSDEC is directing GLNPO's contractor in preparing an
environmental data base to assess the information available on impaired uses in the AOCs. In
addition, SAIC is analyzing 1984 sediment data from seven segments of the St. Lawrence River.
The anticipated date of RAP completion is June 1990.
LAKEWIDE MANAGEMENT PLANS
Lakewide Management Plans provide an approach for reducing contaminant loadings in
open lake waters and involve the same basic principles as those for RAPs. However, LMPs differ
from RAPs in the breadth of their focus, since they address entire lakes rather than the more
localized AOCs. Given this scope, monitoring becomes more complex and airborne deposition
becomes a far more important factor. In addition, the selection of the appropriate mix of
remedial actions and coordination among jurisdictions differ from those of the RAP process.
The concept of lakewide management planning involves a stepwise problem-solving-
process. In developing and implementing LMPs, the U.S. and Canadian governments, in
cooperation with the States and Provinces, are to:
Define the problem, in terms of threats posed by specific critical pollutants
Select remedial measures
Implement remedial programs
Monitor ecosystem recovery
Remove designation of a Critical Pollutant, once it can be demonstrated that it no
longer presents a problem.
GLNPO, in consultation with the States and other EPA offices, has initiated a detailed
study of technical and management options for the development of LMPs. In particular, GLNPO
is working with the States to relate this process to existing programs and requirements under the
CWA. This study will identify specific approaches for accomplishing each LMP step, analyze the
advantages and disadvantages of these approaches, and develop a prototype LMP outline.
This analysis of alternatives is expected to draw heavily upon the experience gained to
date in a number of recent studies and model lake management efforts, including the Niagara
River Toxics Project, the Green Bay Mass Balance Project, the Lake Michigan Toxic Pollutant
Control/Reduction Strategy, the Lake Ontario Toxics Management Plan, and the UGLCC Study.
As summarized in Table 2, these efforts have contributed substantially to the evolution of the
lakewide management planning concept. Additional information on each of these and other key
studies and planning activities is provided below.
19
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DRAFT
Niagara River Toxics Project
The Niagara River Toxics Committee is a binational group formed in 1981 to investigate
toxic chemicals in the Niagara River, its tributaries, and a small part of Lake Erie. The
objectives of the project were to identify specific contaminants of concern; determine the relative
contribution of sources of contaminants to the total load levels; monitor concentrations of key
contaminants in water, sediment, and biota; and assess the effectiveness of existing control
programs.
In 1984, the Committee reported on the results of its study. The Committee identified
261 manmade chemicals that occurred in the Niagara River, but focused on the distribution and
sources of eight contaminant groups (e.g., acid extractables, PAHs, PCBs). Numerous
improvements in regulatory programs were recommended to reduce point source loadings. Other
recommendations included expediting hazardous waste site cleanups, improving waste management
practices, and supporting additional studies on the local hydrogeology of contaminated ground
water.
A number of areas of contaminated sediment were identified as potential targets for
remedial action. Requirements for long-term monitoring were discussed and recommendations
were made on quality assurance requirements. The Canadian members of the Committee also
recommended that the Niagara River serve as a pilot site for implementing a toxic loading alloca-
tion plan based on a mass balance concept, and that regulatory programs be designed to
progressively reduce discharges of key contaminants toward a "zero discharge" goal. ~
Subsequently, the USEPA Region II, Environment Canada, the Ontario Ministry of the
Environment, and the NYSDEC signed a four-party agreement to restore Niagara River water
quality. The agreement, signed in February 1987, is embodied in the Niagara River Toxics
Management Plan that calls for a 50-percent reduction of the total loads of persistent toxicants
from point and nonpoint sources over the next decade.
The first phase of the agreement, completed in August 1987, created a list of persistent
toxic pollutants for which the load reduction will be pursued. Although this effort occurred
outside the IJC framework with little GLNPO involvement, it is an example of an institutional
arrangement among multiple jurisdictions to reduce the total loadings of persistent toxic chemicals
to a Great Lakes water body not presently achieving ail attainable uses,
Upper Great Lakes Connecting Channels Study
The Upper Great Lakes Connecting Channels Study is a binational effort initiated in
X 1983 to address four key contaminated waterways within the Great Lakes Basin. This Study has
served, in many ways, as a key model for the more recent lake management efforts described
above. The objectives of the Study were to:
Determine the existing environmental condition of the St. Marys River, St. Clair
River, Lake St. Clair, and the Detroit River and identify information gaps
20
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TABLE 2 CONTRIBUTIONS OF SELECTED RECENT ACTIVITIES TO THE EVOLUTION OF
LAKEWIDE MANAGEMENT PLANNING
Elements of Lakevide Managannt Plans
Niagara River Upper Great Lake Michigan
Project/Niagara Lakes Connect- Toxic Pollutant
River Manage- ing Channels ContmL/Reduc-
nent Plan Study tion Strategy
Green Bay Lake Ontario
Mass Balance Toxics Manage
Project ment Plan
Defining the Problon
Surveillance and Monitoring Methods/Strategy
*
o Sources *
o Ambient EcosystaB o
Pate/Distribution Assessments by Contaminant o
Effects/Risk Assessments by Contaminant
Source/Pathway Characterization
o Source Inventory *
o Load Measurements/Estimates o
Establishing Load-Concentration Relationships
Exposure Pathway Characterization
Establishing Exposure/Dose Relationships
Priority-Setting Process for Selecting Remedial Measures
Water Bodies Areas o
Pollutants
Sources
*
o
o
o
*
o
o
o
o
o
*
*
*
o
*
o
*
-------
TABLE 2. CONTRIBUTIONS OF SELECTED RECENT ACTIVITIES TO THE EVOLUTION OF
LAKEWIDE MANAGEMENT PLANNING (Continued)
Elements of Lakeuide Maiagenent Plans
Niagara River Upper Great Lake Michigan
Project/Niagara Lakes Connect- Toxic Pollutant
River Manage- ing Channels Control/Reduc-
ment Plan Study tion Strategy
Green Bay
Mass Balance Toxics Manage-
Project ment Plan
Priority Setting Process for Selecting Remedial Measures
Setting Load Reduction Objectives
Evaluating the Effectiveness of Existing ftangrtial o
Action Programs
Evaluating Remedial Action Alternatives
Reaching Agreement on Remedial Heasures Strategy o
Implementing Remedial Programs
Developing Operational Plans Cor
Tracking ftewfxlJal Measures Inplenentation
Evaluating Program Cost-Effectiveness
Monitoring Eoosystea Recovery
Surveillance and Monitoring to Determine
Effectiveness of R
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DRAFT
* Undertake additional, needed studies to:
- Identify and quantify the impacts of conventional and toxic substances from point
and nonpoint sources
- Determine the adequacy of existing or proposed control programs to ensure or
restore beneficial uses
- Recommend appropriate control and surveillance programs to protect and monitor
these waterways and the downstream lakes.
The results of this Study, which involved 12 government agencies and a multitude of
academic institutions and cost approximately $20 million, are presented in a draft final report
issued in July 1988. This final report represents a distillation of 19 media-specific reports, which
were based on 170 individual data reports.
An overview of the findings of the UGLCC Study are summarized below;
* The UGLCC Study confirms that many of the environmental quality problems of
the region cut across political jurisdictions and can only be resolved through
coordinated, long-term planning efforts by the jurisdictions affected.
There have been substantial reductions in conventional polllutants, however, ongoing
and historical discharges continue to affect the system. Elimination of combined
sewer overflows is strongly recommended.
* All four water bodies suffer from contaminated sediments, high concentrations of
oil and grease (except Lake St. Clair), and the bioaccumulation of certain toxic
pollutants in local aquatic organisms. Levels of contaminants in waterfowl need to
be examined.
* Point sources continue to contribute the largest loadings of contaminants. Nonpoint
loadings can be locally significant, but quantification of these inputs is needed.
Information is also needed on the relative contribution of waste sites,
Accidental spills are an insidious problem that requires immediate attention.
Specific recommendations for remedial action in each connecting channel are outlined in the
report.
Green Bay Mass Balance Protect
The USEPA, in conjunction with a number of other U.S. Government agencies and the
States of Michigan and Wisconsin, is developing and testing a modeling framework to increase the
information base on sources, transport, and fate of toxic compounds in the Fox River/southern
Green Bay area. The overall goal of the Green Bay Mass Balance Study is to test models for
toxics to improve our understanding of the sources, transport, and fate of toxic compounds, to
evaluate the technological capability to measure multimedia loadings to a system, and ultimately
to guide and support regulatory activity. The Study will serve as a pilot for future modeling
studies of Great Lakes ecosystems.
23
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DRAFT
The Mass Balance Study will apply models to PCBs, dieldrin, cadmium, and lead. The
physical/chemical models will be coupled with a food chain model to allow estimation of body
burdens in target fish species: carp, brown trout, and walleye. The integrated model will then
be used to predict concentrations in the water, sediment, and biota under alternative regulatory
and remedial actions.
The project was initiated in 1986, with the development of a monitoring plan and the
establishment of a quality assurance program for evaluating analytical and field methods to be
employed. During FY 1987, field reconnaissance was done in the Bay and tributaries, and the
first atmospheric deposition monitoring stations were established in preparation for the main field
season, August 1988 through September 1989. Samples to be collected include bottom sediments,
Bay-Lake exchange, atmospheric deposition, water and suspended sediments, tributary loads, point
and nonpoint sources, ground water, and biota.
As envisioned, the study will incorporate the following components:
* Comprehensive quantification of loads from all significant sources (e.g., atmosphere,
tributaries, ground water, point, and nonpoint)
« Determination of the net rate of exchange of contaminants between environmental
compartments (e.g., sediment, water, biota, and air)
* Net rate of exchange with Lake Michigan.
Analysis of field data, modeling, and interpretation is scheduled to begin in 1990. These
activities will be guided by several specific requirements, including:
* Usefulness in predicting concentrations of key contaminants in fish to help determine
human cancer risks
Utility for EPA and the State in making regulatory decisions
Applicability of the pilot study as a model for larger, lakewide studies.
Modeling results will be determined and the final report will be completed in 1991.
Lake Michigan Toxic Pollutant Control/Reduction Strategy
EPA's Region V and the States of Illinois, Indiana, and Michigan have prepared a Lake
Michigan Toxic Pollutant Control/Reduction Strategy. The objectives of the strategy are to fully
restore the multiple uses of Lake Michigan and to protect human health and the Lake Michigan
ecosystem by achieving a significant reduction in the loading rates of toxic pollutants. The
strategy includes specific commitments for each State, by fiscal year, which have been
incorporated into the annual State program plans negotiated with the Region V Water Division.
The strategy anticipates using a whole-lake mass balance approach to modeling toxic pollutants
and evaluating potential regulatory controls. The Green Bay Mass Balance Study is identified as
a key milestone in the development of a LMP for Lake Michigan.
In FY 1987 GLNPO encouraged USEPA Region V's Water Division to negotiate
performance objectives for implementation of the Lake Michigan Strategy into the State Water
Program Plans of the Lake Michigan States. Included are elements requiring a status summary of
tech no logy-based permit limits, including those for the Lake Michigan Pollutants of Concern; an
initiative to acquire the capability to calculate and sum loads from point sources to specific Lake
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Michigan tributaries and to Lake Michigan as a whole; and an inventory of municipal waste
combustion sources, cross-referenced in the Lake Michigan State Air Program Plans,
To assist the Lake Michigan States in developing a load quantification capability, GLNPO
is accessing the Permit Compliance System data base and roughly calculating loads by multiplying
average flow with average concentration. Such screening level estimates are intended to focus
additional monitoring attention on those sources contributing significant loads of pollutants of
concern and select toxic metals to Lake Michigan. As a complement to this effort, GLNPO has
also obtained loading inventories of pollutants of concern and select toxic metals to Lake Michigan
tributaries using Michigan's Critical Materials data base. While strictly applicable to Michigan
sources, the information may assist in identifying significant point source categories and in
defining screening level discharge factors applicable to other Lake Michigan sources.
Lake Ontario Toxics Management Plan
In February 1987, EPA, the State of New York, Environment Canada, and the Ontario
Ministry of the Environment signed a declaration of intent to prepare a Toxics Management Plan
for Lake Ontario, The draft plan, prepared in 1988, cites bioaccumulation of toxic chemicals in
fish to levels that make them unsafe for human consumption as the most serious known problem
in the Lake. To address the problem of toxic pollution in Lake Ontario, the draft plan calls for
three major actions:
* Full implementation of current programs, such as the State Pollutant Discharge
Elimination System program in New York State and the newly developed Municipal"
Industrial Strategy for Abatement program in Ontario.
* Development and implementation of RAPs to address the problems in eight
geographic AOCs, such as the Niagara River and Hamilton Harbor.
The development and implementation of chemical-specific management plans to
reduce the levels of problem toxics (e.g., PCB, mercury, mirex, chlordane, dioxin,
DDT, dieldrin, and hexachlorobenzene) below protective ambient standards. As a
check on the effectiveness of chemical-specific management plans, ecosystem
objectives will be developed and monitored independently.
Together, the above described administrative and technical initiatives represent a
concerted effort by the United States to develop the institutional arrangements, programmatic
structure and function, and technical tools necessary to carry out this crucial mandate, despite its
unprecedented scope and complexity.
Other Activities Related to Lakewide Management Plaas
The Great Lakes States have also worked jointly toward achieving the goals of the
GLWQA. In June 1986, the Governors of the eight Great Lakes States signed the Great Lakes
Toxic Substances Control Agreement. This Agreement pledges the States to treat the Lakes as a
single ecosystem despite political boundaries, acknowledges that toxic pollutants are the foremost
problem to be addressed, and lays out goals for the States. More recently, the Governors agreed
to establish a permanent fund for Great Lakes studies. Many of the activities under both of these
State agreements will lead directly and indirectly to the completion of and implementation of
management plans, and ultimately to the attainment of the Agreement objectives. Considerable
progress has already been made toward this goal by USEPA Headquarters and States' Regional
regulatory and remedial programs.
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GLNPO has begun to develop and test a number of technical tools that will be necessary
for LMP implementation. In terms of technical guidance, GLNPO and the Office of Water
Regulations and Standards have discussed the writing of a Great Lakes Waste Load Allocation
Guidance Document. GLNPO also continues to work with Region II and V Superfund programs
to institutionalize sediment cleanup priorities based within the Superfund Program on Great Lakes
area and lakewide exposure/load reduction needs. With respect to technical tools for problem
characterization, GLNPO is developing, via grants to Great Lakes academic institutions, the
following:
Statistical methods for determining the relationship between sampling frequency and
tributary waste quantification, accuracy, and precision
State-of-the-art atmospheric concentration/deposition monitoring station
Computerized concentration volume-weighting scheme to systematically calculate
area lakewide concentration averages
Mathematical models of the Great Lakes system capable of relating loading rates to
ambient concentrations in water, sediment, and biota (in cooperation with the Large
Lakes Research Station, Grosse lie, Michigan)
State-of-the-art effects monitoring tools, such as sediment toxicity and
bioaccumulation test methods, the fish embryo-larval carcinogen assay, and the fish
or sediment extract liver hepatoma P450 induction assay.
USEPA's Office of Research and Development will also be testing proposed sediment quality
criteria in the Fox River/Green Bay system.
In addition, GLNPO has developed a pesticide inventory for Erie County in Ohio via
Interagency Agreement (IAG) with Ohio State University's Cooperative Extension Service. The
inventory will complement the work on nutrient and pesticide concentrations during storm events
being conducted under a GLNPO grant by Heidelberg University in Tiffin, Ohio, and previous
demonstration projects funded through an IAG with USDA's Soil Conservation Service. Together,
this information can be used to develop aids for quantifying nonpoint source loading factors for
pesticides of concern based on application rate, crop type, tillage practice, land slope, soil types,
and distance to surface water.
The National Oceanic and Atmospheric Administration's Great Lakes Environmental
Research Laboratory (GLERL) has continued its research to evaluate the role of chemical kinetics
versus chemical equilibrium in contaminant-fate modeling. The results show that even in a
relatively stable environment, contaminants in organisms are not at a steady state with respect to
local sources. This research represents a significant contribution to our ability to model fate of
contaminants and will be useful in AOCs and for LMPs.
Additional research at GLERL has shown that situations exist in which toxicant fate
cannot be accurately predicted if toxicant effects are not modeled. This is contrary to the
traditional approaches to modeling toxicant fate that implicitly assume that toxicant effects on
organisms have no effect on subsequent toxicant fate.
With respect to problem remediation, GLNPO is providing contractor support to Great
Lakes municipalities to test innovative phosphorus removal technologies and has funded studies
of best available technology-equivalent metals removal. In addition, Region V is currently
conducting specific air emissions control studies to identify potential remedial measures for air
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toxicants. Furthermore, GLNPQ is working with the USCOE, USFWS, and Region V to develop
in-lake contaminated sediment disposal facilities that minimize loss rates to the lakes and human
or wildlife exposure to dredged toxicants via the aquatic or terrestrial food chains. Plans for such
disposal facilities, however, will be scrutinized closely given that, in some States, any in-lake
disposal of contaminated sediments is considered a violation of State water quality standards and
requires the responsible party to obtain a variance from the State rules. Other innovative sediment
cleanup technologies will also be tested on Waukegan Harbor sediments, the most heavily PCB-
polluted sediments in the entire Great Lakes system.
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ANNEX 3: CONTROL OF PHOSPHORUS
Annex 3 of the GLWQA sets targets for total phosphorus loads to the Lakes, which, when
achieved, would produce acceptable conditions in terms of aerobic conditions in the bottom waters
of Lake Erie, and algal biomass in all of the Lakes. The 1983 supplement to the Annex confirmed
target loads, quantified the further load reductions necessary to attain the targets, and called for
the preparation of Phosphorus Load Reduction Plans to guide their attainment. The U.S.
government and the States have prepared and transmitted Phosphorus Load Reduction Plans to the
IJC for Saginaw Bay of Lake Huron, and for Lakes Erie and Ontario.
The Supplement requires the Parties to review the effectiveness of the Plans by December
1988, and identify any remaining load reduction measures required to achieve the target loads.
The reviews have not yet been completed, although it is apparent that the target loads have not
yet been attained for any of the three water bodies. Phosphorus loadings to Lakes Superior,
Michigan and Huron all remain below the target loads, except for Saginaw Bay.
The United States expects to provide an update of its plans during 1989. Further
discussion of Phosphorus Load Reduction Plans and nonpoint source control programs are provided
in the section on Annex 13.
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ANNEX 12: PERSISTENT TOXIC SUBSTANCES
INTRODUCTION
The goal of the Great Lakes Water Quality Agreement is the virtual elimination of
persistent toxic substances from the Great Lakes ecosystem; the philosophy is zero discharge. To
that end, Section 2(a)(iii) of Annex 12 requires the Parties to pursue "the reduction of the
generation of [Great Lakes] contaminants, particularly persistent toxic substances, either through
the reduction of the total volume or quantity of waste or through the reduction of the toxicity of
waste, or both." Significant progress has been made in reducing the quantities of persistent toxic
substances entering the Great Lakes system from air emissions, wastewater discharges, leaks and
spills, and stormwater runoff. The reporting requirements of Annex 12 focuses on activities under
Section 2(a)(iii).
A variety of regulatory and nonregulatory approaches are under way in the United States
to reduce new sources of toxic pollutants. The approaches include:
Eliminating or restricting the use of toxic chemicals (e.g., bans)
Reducing the concentration of toxic substances in commercial products
t Limiting concentrations of toxics in non-hazardous waste streams
Regulating disposal of hazardous waste streams
Reducing the amount of toxic substances used in manufacturing processes
Reclaiming and recycling toxic substances from manufacturing processes or commercial
products.
RESTRICTIONS ON THE DISTRIBUTION OF CRITICAL POLLUTANTS IN COMMERCE
Several environmental statutes apply to restrictions on the distribution of critical pollutants,
including the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA); the Toxic Substances
Control Act (TSCA); and to a limited extent the Resource Conservation and Recovery Act
(RCRA).
Federal Insecticide. Fungicide, and Rodenticide Act
In the United States, the manufacture, use, and disposal of some 50,000 pesticide products
and devices are regulated under FIFRA as amended in 1978 (40 CFR Parts 152 to 173). The U.S.
Environmental Protection Agency (USEPA) carries out this responsibility by requiring all pesticides
to be registered with the USEPA, based on data adequate to demonstrate that the pesticide's use
will not pose an unreasonable risk to humans or the environment. When a product is registered,
certain labeling requirements must be met, including explicit directions for legal use; information
on the method, rate, and site of application; directions for storage and disposal; and restrictions
on use. Any application deviating from the labeled one is considered an unlawful use of the
product.
The regulations provide standards for the certification of commercial and private
applicators of restricted-use pesticides to ensure that these pesticides are handled and used in a
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safe manner. For commercial and professional applicators, methods of storage and disposal of
excess pesticide products and pesticide containers are also recommended under FIFRA. In
addition, RCRA regulates the treatment, storage, and disposal of some pesticide wastes. The above
measures are intended to reduce the quantities of pesticides entering the environment to the
minimum required for efficacious use.
If the environmental or health risks associated with a pesticide's registered use outweighs
its benefits, USEPA may further limit its use in terms of pests, crops, environmental conditions,
or geographic areas. In extreme cases, USEPA can move to cancel all uses of (i.e., ban) a
pesticide,
The following Critical Pollutants have been banned by the International Joint Commission:
DDT, dieldrin, hexachlorobenzene, and toxaphene. Mercury's use in pesticide formulations has
been severely curtailed, although some seed treatment uses continue. Voluntary restrictions on the
concentrations of 2,3,7,8-tetraehlorodibenzo-para-dioxin (2,3,7,8-TCDD) in chlorophenoxy
herbicides were adopted by manufacturers in 1971.
Recent Activities
In 1987, the ban on the use of herbicides containing 2,4,5-trichlorophenoxy carboxylic
acids (e.g., 2,4,5-T; Silvex) and derivative esters went into effect. Historically, such herbicides
were a significant source of 2,3,7,8-TCDD. Also in 1987, USEPA announced its intention to
severely restrict the use of pentachlorophenol, which is contaminated with various polychlorinated"
dibenzo-p-dioxins (PCDDs) and polychlorinated dibenzof urans (PCDFs) and to cancel all remaining
uses of chlordane.
In addition, USEPA's Office of Pesticide Programs has initiated an accelerated review
process for the registration of existing pesticides. One area of focus is lawn care herbicides,
including dacthal, one of the few herbicides identified in fish tissue collected under the Great
Lakes fish monitoring program.
Pesticide manufactures are more frequently initiating the removal of problematic pesticides
from the marketplace prior to USEPA action. For example, the sole U.S. manufacturer of
chlordane agreed not to contest the proposed registration cancellation notice, thus avoiding lengthy
administrating hearings. As a result of a similar voluntary action on the part of various U.S.
manufacturers, all remaining uses of Endrin are likely to be cancelled in the near future.
Serious concern over the extreme toxicity of alkylated tin compounds detected in Great
Lakes waters prompted the State of Michigan to propose a ban on the use of paint formulations
containing tributyl tin biocides on surfaces that could contact the aquatic environment. Of
particular concern was the use of antifoulant paints containing tributyl tin as the active ingredient
to prevent algae growth on recreational boat hulls. The ban went into effect in November 1988.
Subsequently, Wisconsin began to pursue a similar initiative.
Toxic Substances Control Act
TSCA provides USEPA with regulatory authority (40 CFR Parts 702-799) over the
manufacture, transport, storage, use, and disposal of chemicals on the TSCA Inventory intended
for commercial distribution in the United States. This is accomplished through reporting and
notification requirements and manufacture and use restrictions or bans.
TSCA also requires manufacturers of new chemical substances not on the TSCA Inventory
to submit a Premanufacture Notification prior to the manufacture of the chemical, supplying
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information on the properties of the new substance, its intended use, the method and extent of
manufacture, description of byproducts, and other data. TSCA also requires manufacturer
notification of "significant new uses" of chemical substances currently on the Inventory.
In addition, TSCA provides for Federal information requests of manufacturers and for
systematic testing of existing chemicals according to priorities set by USEPA in consultation with
the Interagency Testing Committee. Where new test results indicate substantial risk to human
health or the environment, USEPA can restrict manufacture, storage, use, or disposal. Where
unreasonable risks are found, USEPA can ban manufacture of the chemical and severely restrict
its disposal.
The use, manufacture, processing, and distribution of polychlorinated biphenyls (PCBs) and
PCB items are effectively banned by TSCA (40 CFR Part 761). In addition, TSCA regulations
require manufacturers and processors of certain chemical substances to analyze these chemicals for
the presence of halogenated dibenzodioxins (HDDs) and halogenated dibenzofurans (HDFs). If
testing confirms the presence of HDDs or HDFs above the prescribed level of quantitation,
additional information is required on production, process, exposure, and disposal.
Recent Activities
The private sector has become increasingly concerned about the number arid quantities of
toxic substances used in manufacturing and waste treatment processes. The sources of concern are
fourfold:
Existing occupational and environmental liabilities associated with toxic substances
manufacture or use
Growing paperwork burden associated with existing or new local, State, and Federal
reporting requirements
Increasing costs of solid and liquid waste disposal containing one or more listed toxic
substance
Existing public perception that the onsite storage of large quantities of highly toxic
substances presents an unreasonable threat to nearby communities.
In response, many communities are voluntarily pursuing the use of various raw materials
or product substitution strategies. For example, every Michigan facility discharging unsanitary
wastewater is required to report annually the quantities of Critical Materials used or produced,
discharged, and disposed of in solid residues. A substance is considered a Critical Material once
it is added to Michigan's Critical Materials Register (CMR) by the Director of Michigan's
Department of Natural Resources, who is advised by a committee of scientific experts. In response
to this program, several Michigan industries have systematically started to eliminate the use of
CMR-listed substances in product manufacture or wastewater treatment processes. The recent
expansion of the CMR under the Clean Water Act Section 205(j) grant from USEPA Region V
may further encourage this practice.
The use of PCBs in transformers and capacitors continues to be phased out, with disposal
of recovered PCB oils via high-temperature incineration only. Since 1987, regulations governing
the closure, cleanup, and disposal of structures contaminated with chlorinated dibenzo-p-dioxins
and dibenzofurans in PCB transformer fires have been implemented, and USEPA's National PCB
Spill Cleanup Policy is now in effect. Such regulations and policies will reduce the volume of
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contaminated matter capable of being released to the air, soil, and water of the Great Lakes
ecosystem,
WASTE REDUCTION AND RECYCLING
Management of solid and hazardous waste in the United States, including waste reduction
and recycling, is regulated in part by the Solid Waste Disposal Act (SWDA). The SWDA, amended
in 1976, is commonly referred to as RCRA, In 1984, the SWDA was again amended via the
Hazardous and Solid Waste Amendments. Subtitles C, D, and I of the SWDA regulations describe
the three distinct programs: the Hazardous Waste Program (Subtitle C), the Solid Waste Program
(Subtitle D), and the Underground Storage Tank Program (Subtitle I).
The Hazardous Waste Program is designed to ensure the safe and effective management of
hazardous waste (40 CFR Parts 260-272). As part of the Hazardous Waste Program requirements,
a paperwork manifest system is utilized that records the location of hazardous wastes. This
Uniform Hazardous Waste Manifest system provides specific information on the quantity and
nature of the waste and the parties involved in the waste's production, transportation, and disposal.
Specific requirements exist for generators, transporters, and owners or operators of
treatment, storage, and disposal facilities. All facilities must, at a minimum, possess a USEPA
identification number. Requirements for generators include proper labeling, packaging, and
limited accumulation of the waste; adequate training of personnel; and development of contingency
plans and emergency procedures. Transporters must be trained to adequately respond to
discharges, such as spills.
The primary goal of the Solid Waste Program is to encourage solid waste management
practices that promote environmentally sound disposal methods, maximize re-use of recoverable
resources, and foster resource conservation. There are two facets of the Solid Waste Program: the
technical standards for facilities, referred to as Subtitle D Criteria (40 CFR Part 257) and a
voluntary State solid waste management program (40 CFR Part 256).
The Underground Storage Tank (UST) program is concerned with tanks having 10 percent
or more of their underground volume containing petroleum products or hazardous substances (40
CFR Part 280). The UST program has five parts: a ban on unprotected new USTs (i.e., USTs
without cathodic protection to protect against corrosion), notification to authorities of existing
USTs, development of performance standards, State management of the program, and inspection
and enforcement authority at the State and Federal levels. For an UST to be permitted, the tank's
design must be shown to prevent release due to corrosion or structural failure, and that the
construction of the tank is compatible with the stored waste.
To limit the quantities of sediments, nutrients, and pesticides entering water bodies from
agricultural land use, USEPA has recently developed a multi-agency nonpoint source management
strategy, involving, among other Federal agencies, U.S. Department of Agriculture, particularly the
Soil Conservation Service. The approach to source reduction is through the encouragement of
alternative tillage practices, the use of buffer strips around agricultural fields, and the transfer of
technology on integrated pest management and alternative nutrient and pest management methods
from the academic center to the farmer.
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Recent Activities
Waste reduction and recycling activities occur at the Federal, State, and local levels.
Recent activities are discussed below,
Federal
Effective enforcement of existing RCRA regulations, the banning of the land disposal of
liquid hazardous waste, and increasingly stringent limitations on the land disposal of solid wastes
and sludges have raised the costs of waste disposal in the United States and placed an
ever-increasing waste disposal burden on a small handful of fully licensed hazardous waste
incinerators. At the same time, new RCRA restrictions on the emissions of PCDDs and PCDFs
from such incinerators are likely to further increase disposal costs. Onsite storage of liquid and
solid hazardous wastes awaiting proper disposal also creates environmental and occupational risks
and liabilities,
In response to these regulatory, economic, and litigatory pressures, manufacturers are
increasingly interested in reducing the volume of hazardous waste generated in their processes.
To this end, they are pursuing substitution of nonhazardous chemicals for those listed under
Subtitle C of RCRA (40 CFR Part 261), process modifications to reduce the volumes of liquid and
solid hazardous waste produced as manufacturing byproducts, and wastestream recycling within
the plant if possible, but between plants if necessary,
USEPA has recently announced the creation of a new Pollution Prevention Program (PPP)~
to be administered by a newly created Pollution Prevention Office within USEPA's Office of
Policy, Planning, and Evaluation in Washington, DC. An agency-wide advisory committee,
consisting of senior managers, will be established to coordinate waste reduction efforts in USEPA's
program offices.
The PPP will adopt an agency-wide, multimedia and multiprogrammatic approach to source
reduction and recycling. Although there are many cultural and institutional barriers to
implementing such an approach, the PPP will aggressively pursue the reduction of hazardous and
toxic wastes, as well as other wastes of environmental concern such as municipal and agricultural
wastes. This Program will become fully operational during FY 1989 fulfilling the Agency
commitment to four objectives:
* Promote a new culture both within and outside USEPA that emphasizes pollution
prevention, primarily through source reduction and secondarily through recycling
Encourage development of State and local pollution prevention programs
* Create incentives for and eliminate barriers to pollution prevention
* Develop reliable indicators of progress in source reduction and recycling.
To achieve these objectives across the Agency, PPP will concentrate on four primary
functions. First, the program will develop a cross-media pollution prevention policy and strategy
and will promote the pollution prevention ethic both within and outside USEPA. Central to this
activity will be the advice of the Pollution Prevention Advisory Committee. Second, the program
will develop technical assistance tools and coordinate outreach programs to deliver these tools to
State and local governments, the industry, the agricultural community, and the public. Third, the
PPP will foster the development of innovative approaches to pollution prevention. Finally, the
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program will develop a coordinated information management strategy to assess and report on
pollution prevention and will report on progress and problems.
Illinois
The Illinois Hazardous Waste Research and Information Center (HWRIC) and the Illinois
EPA promote waste reduction through technical assistance, research information services, waste
exchange operation, promotion of recycling, and related regulations.
The Illinois EPA does not require mandatory waste reduction or permit large generators
to landfill their hazardous waste unless they can prove that there is no technically feasible or
economically reasonable alternative. In their annual reports, generators must submit a description
of the waste minimization techniques considered and tried. The Illinois EPA, in cooperation with
the State Chamber of Commerce, operated the Industrial Materials Exchange Service. The Illinois
EPA is also implementing a waste minimization student intern program.
Recently, the Illinois EPA and the Department of Energy and Natural Resources were
awarded a RCRA Integration Training and Technical Assistance (RITTA) grant. The majority of
the money will be used in a pilot project to integrate and expand the activities of the Illinois EPA
and HWRIC through training and a student intern program. They will also work with two local
organizations, the Center for Neighborhood Technology in Chicago and Community Contracts, Ind.
of Kane and DuPage counties, to reach industry. Activities include using the computerized waste
reduction advisory system and industry audits to quantify the amount and toxicity of hazardous
waste reduced, developing a State action plan, providing training in waste management and
minimization, and providing public outreach through seminars and workshops.
HWRIC's activities include sponsoring research, onsite technical assistance, two Statewide
waste reduction conferences, and a Governor's award for innovative waste reduction. HWRIC is
active with the National Roundtable of State Waste Reduction Programs and has been working with
several member programs and the USEPA to develop an online national computerized waste
reduction advisory system called the Multi-Option Model.
HWRIC maintains five programs: research, industrial and technical assistance, information
services, data management, and laboratory services. HWRIC's $9 million Hazardous Materials
Laboratory will open in spring 1990 and will include state-of-the-art analytical services to support
bench- and pilot-scale laboratories for minimization and treatability studies. Research sponsored
by HWRIC focuses on problem assessment and solving. This includes $200,000 for waste reduction
studies, including matching-fund projects with industry. Technical assistance services include
information on chemical processes, waste treatment, siting, and permitting requirements. The
Center selves industries, State and local governments, and the public.
Indiana
Indiana is in the process of formalizing a hazardous waste minimization program that
includes developing waste minimization audit procedures.
Indiana has held annual training workshops on waste minimization practices, including audit
procedures. Pertinent waste minimization and audit procedure articles have been included on a
regular basis in the bimonthly Technical Bulletin, prepared by the Office of Technical Assistance,
and in the Indiana Waste Exchange Catalog, prepared by Environmental Quality Control, Inc.,
under contract to the Indiana Department of Environmental Management. In addition, the Office
of the Governor provides annual awards to private industries that have made outstanding progress
in voluntary waste minimization.
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The State has commenced efforts to build a library of waste reduction case histories.
Indiana is also planning to adopt a waste minimization policy. Although waste minimization is a
high priority in Indiana, continued efforts will depend on Federal and local funding.
Michigan
Michigan State statutes enacted in December 1987 created a Waste Reduction Assistance
Service, an Environmental Technology Board, and an Office of Waste Reduction, each charged
with furthering specific waste reduction needs. The Waste Reduction Assistance Service will
provide educational services and onsite technical assistance to help firms identify and implement
waste reduction practices. The Environmental Technology Board will report to the Governor and
Legislature by June 1989 on methods in which the State can better support research needs in the
field of waste reduction. The Office of Waste Reduction will focus its efforts on identifying
regulatory barriers to waste reduction, recommending how waste reduction might be encouraged
through existing regulatory programs, and analyzing waste reduction potentials and
accomplishments in various industrial sectors.
All three programs, which became operational in fall 1988, have a multimedia focus. While
the responsibilities are officially housed in two separate departments (the Department of Commerce
and the Department of Natural Resources), they are expected to be managed as a "joint venture"
between the departments, with a shared budget of approximately $450,000 and four or five
full-time personnel. Future program activities include public information and education, onsite
technical assistance, analysis of waste reduction potential, and identification of regulatory barriers
to waste reduction.
Current Michigan law does not mandate waste reduction, but it is encouraged through the
above programs and through a hazardous waste landfill disposal fee and credit system. Through
this system, firms may receive a refund of landfill fee payments upon documenting reductions in
the volume of waste generated due to implementation of source reduction practices.
Minnesota
The State of Minnesota enacted a Waste Management Act that encourages waste reduction,
processing, treatment, separation, and resource recovery. Waste minimization responsibilities are
divided between the State Planning Agency (SPA) and the Minnesota Pollution Control Agency
(MPCA). The SPA has planning authority in the area of solid and hazardous waste. The MPCA
develops hazardous waste regulations.
The SPA funds the Minnesota Technical Assistance Program (MnTAP) at the University
of Minnesota, MnTAP is a State program that performs confidential onsite consultations, manages
a resource information clearinghouse, administers a student intern program, and offers research
awards for minimization projects. The program also publishes a quarterly newsletter and has
published several industry case studies.
The SPA and MPCA plan to share funds received from the recently awarded RITTA
grant. The State will implement a State action plan, a RCRA training program, and a pilot
project. The pilot project will focus on reducing the volume of the State's solvent waste stream
in a variety of industries. Activities will include providing a public outreach program, conducting
seminars and workshops, performing onsite audits, implementing a telephone hotline, and
publishing a newsletter. The project is intended to encourage industries to voluntarily utilize waste
minimization techniques.
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New York
The New York State Department of Environmental Conservation (NYSDEC) encourages
waste minimization through the Bureau of Hazardous Waste Program Development. The Waste
Reduction Implementation Section within the Bureau is developing regulations, implementing
source reduction policies, developing public outreach programs, publishing manuals and fact sheets,
sponsoring conferences and workshops, and applying for Federal grants. The Waste Reduction
Evaluation Section will be reviewing and evaluating waste reduction impact statements, inspecting
facilities, developing a computer-based information system, assessing incentives and disincentives
for waste minimization, and preparing waste reduction forms. The NYSDEC has formed an
intra-agency task group to develop a. uniform, multimedia approach to waste minimization. The
NYSDEC also provides funds to the New York Center of Hazardous Waste Research for research
in new technology areas, Superfund cleanup efforts, and hazardous waste reduction.
The State established a preferred waste management hierarchy in August 1987. In addition,
the NYSDEC issued an organization and delegation memorandum directing each division director
to consider utilization of a Waste Reduction Impact Statement to analyze the potential for reducing
the generation and/or toxicity or hazardous waste across all media.
The Waste Reduction Sections are currently conducting two major projects. The first
project is a hazardous waste reduction guidance manual that will promote the State's waste
management hierarchy, provide a measure for waste reduction efforts, and help ensure that the
State has adequate hazardous waste disposal capacity over the next 10 years. An additional
component is two sets of workshops. The first set will solicit industry's comments on the guidance
manual, and the second set will educate industries on the techniques described in the manual. The
second project will provide an update of the hazardous waste treatment needs survey for the State.
The project will forecast hazardous waste generation and gather information on future hazardous
waste reduction opportunities.
The State imposes regulatory and Superfund fees on hazardous waste generators and
facilities designed to encourage "preferred" waste management practices. In addition, pending
legislation addresses waste minimization plans for hazardous waste generation.
The Environmental Facilities Corporation (EFC), a public benefit corporation established
by New York in 1970, is also involved in waste management efforts. Among other duties, EFC
conducts onsite industry audits for small quantity generators (SQGs), Under the Industrial
Recycling Act, some of the confidential audits are free.
Other EFC responsibilities include financing of environmental projects for industry;
providing technical assistance, an advisory service, and inactive hazardous waste site remediation;
and financing an information clearinghouse. The EFC also helps to fund the Northeast Industrial
Waste Exchange.
The Department of Environment and Planning in Erie County conducts an additional
waste reduction program of its own that focuses on SQGs. The County operates a technical
assistance and educational program that includes onsite consultations and an information
clearinghouse. In addition, the County has published several industiy specific small quantity
hazardous waste generator guidebooks, has sponsored several hazardous waste minimization
workshops, and publishes a quarterly newsletter.
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Ohio
Ohio's efforts related to hazardous waste reduction and/or minimization are conducted by
two agencies: the Ohio EPA, Division of Solid and Hazardous Waste Management, and the Ohio
Department of Development, Ohio Technology Transfer Organization (OTTO).
The Ohio EPA has sponsored Ohio's participation in the Northeast Industrial Waste
Exchange since 1983; requires waste minimization plans when reviewing applications for land
disposal in Ohio; sponsors and participates in waste minimization seminars; sponsors annual
Governor's Awards for Outstanding Achievement in Waste Management and Pollution Control,
which includes waste minimization candidates; participates in a Hazardous Waste Minimization Task
Force to advise the State of Ohio on appropriate government actions; and offers daily technical
assistance and regulatory interpretation related to waste minimization. These activities are funded
by Federal and State sources as part of the general hazardous waste management program.
The Ohio EPA requires waste minimization to be addressed as part of the conditions for
land disposal of hazardous waste. This requirement applies to all generators proposing to dispose
of more than 200 tons per year in an Ohio land disposal facility. Such generators must address
waste minimization or lose their disposal approval. Disposal may also be denied upon the initial
request for disposal approval.
OTTO provides technical assistance and oversees technology transfer related to waste
minimization. OTTO is composed of a network of 32 field agents working at 5 universities and
23 technical and community colleges in Ohio. These agents acquire the technical expertise from
academic institutions, State and Federal agencies, and other public and private resources associated
with Ohio's business and industrial sectors. Although OTTO's responsibilities address a broad
spectrum of business issues, this non-regulatory organization is the mechanism for technical
assistance in waste minimization.
Specifically, OTTO conducts waste minimization seminars and provides site-specific
technical assistance on effective waste minimization practices. In addition, OTTO agents will
either train employees themselves or locate the appropriate experts to provide training and
introduce new technologies. Ohio EPA was recently awarded a RITTA grant and will be
formalizing its coordination with OTTO in an expansion of the State's waste minimization program.
The Great Lakes Rural Network, located in Fremont, Ohio, is also working with OTTO to expand
the technical assistance program, including that under RITTA. The OTTO program would include:
Establishing a waste minimization training program for industry, agency staff, and local
officials
Providing site-specific technical assistance
Continuing to conduct outreach seminars through Ohio EPA and OTTO, including
technical assistance and referrals
Surveying the business community to assess waste minimization information needs
Publishing waste minimization manuals that target specific industries (yet to be
determined)
Publishing articles on waste minimization practices and potential savings
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Producing a quarterly newsletter that will be provided free of charge to Ohio businesses
for the first year
* Conducting technology transfer workshops
* Coordinating a waste minimization trade fair, during which Ohio businesses can exhibit
waste minimization and management products
Providing speakers for waste minimization lectures,
Pennsylvania
In Pennsylvania, waste minimization has currently been reorganized under the Department
of Environmental Resources as the Division of Waste Minimization and Planning. The Division
is divided into three sections: municipal waste planning, waste minimization (which encompasses
municipal to hazardous waste), and information management systems (which manages data for solid
waste facilities), Pennsylvania currently has no waste minimization legislation, but the State does
encourage waste minimization through research funding and fees for waste disposal facilities. In
addition, the Hazardous Waste Facilities Plan, published in 1986, emphasizes source reduction as
the primary waste management technique and reclamation of waste as a secondary alternative. A
Hazardous Waste Minimization Act is now pending.
The State helps to fund the Center for Hazardous Materials Research (CHMR), a nonprofit
subsidiary of the University of Pittsburgh Trust. The Center provides technical assistance through
a hazardous materials hotline, seminars, workshops, training courses, onsite consultations,
publications, and a quarterly newsletter, CHMR focuses on providing technical assistance to small
business, industry, and government, as well as providing hazardous materials worker training,
pesticide research, and education. The Center has published the "Hazardous Waste Minimization
Manual for Small Quantity Generators."
The State also cbntributes to the Pennsylvania Technical Assistance Program (PENNTAP)
at Pennsylvania State University. PENNTAP, founded in 1965, focuses on technology transfer by
responding to questions from industries and municipalities and by distributing new information
through workshops and consultations. PENNTAP also conducts confidential onsite audits of
industries on their request. The president of Pennsylvania State University appoints an advisory
council of industrial executives to discuss current and future policy decisions. PENNTAP has a
special task force for hazardous and solid waste.
Pennsylvania initiated a Governor's Waste Minimization Award in 1987. The award
program is open to individuals, companies, institutions, and government agencies in the State who
have established innovative waste minimization projects. The annual award is given in two
categories: industrial and municipal waste management. The criteria for selection include
environmental benefits through waste minimization achievements, technological/management
innovation, economic benefit, dissemination of innovative techniques, and commitment to
environmental compliance. Summaries of successful projects are published to help publicize waste
minimization as an alternative to disposal or treatment.
Wisconsin
Wisconsin's Department of Natural Resources (DNR) has a comprehensive solid waste
minimization program in place. The Waste Reduction and Recycling Program provides information
and education, technical assistance, financial assistance, and regulatory compliance assistance to
the RCR A-regulated community. Wisconsin has done little to minimize the production of waste,
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but has a comprehensive program for minimizing the landfilling of waste. As a result of these
solid waste minimization activities, Wisconsin's DNR has compiled an extensive publications list
regarding recycling and resource recovery technologies. The State is now turning its attention to
hazardous waste minimization and has recently been awarded a RITTA grant to facilitate the
effort. Hazardous waste minimization program efforts will include:
* Conducting site-specific waste audits
§ Sponsoring industry-specific seminars
Developing process-specific workshops
Establishing a waste reduction information clearinghouse pertinent to Wisconsin's
regulated community.
Local Programs
Many communities, some with the encouragement and assistance of local industries, are
providing for the collection and proper disposal of household hazardous wastes, ranging from old
containers of pesticides to paint, paint thinners, and waste oil. For example, in recent years Dow
Chemical Company's facility in Midland, Michigan, has sponsored an annual household hazardous
waste disposal week for area residents.
TOXICTTY REDUCTION ACTTVTniS
Toxicity reduction activities center largely on the National Pollutant Discharge Elimination
System (NPDES) Pretreatment Program and the inclusion of Toxicity Reduction Evaluations (TREs)
in select NPDES permit requirements.
Pretreatment Program
A Pretreatment Program is required for all municipal wastewater plants treating significant
quantities of industrial process wastewaters. The Pretreatment Program Plan for each State is
approved by the USE PA and implemented by the State via wastewater discharge permit
requirements of the NPDES created by Section 402 of the Clean Water Act. Each major industrial
contributor must install, operate, and maintain treatment equipment capable of removing select
Priority Pollutants to a degree specified for its industrial category(ies) by the Best Available
Technology (BAT) Economically Achievable guidelines. Full implementation of the Pretreatment
Program will have the effect of reducing not only the volume of municipal sludge containing
hazardous quantities of toxic substances, but also the toxic contaminant concentrations in
wastewater discharges.
The Pretreatment Program also requires the development of local limits to meet water
quality- or sludge quality-based controls, whichever are more restrictive. In some cases, additional
Pretreatment beyond BAT may be required, or chemical substitutions or process modifications may
be pursued as alternatives.
To facilitate Pretreatment Program implementation, USEPA continues to sponsor technology
transfer workshops for State and local regulators and publicly owned treatment works operators.
In November 1987, USEPA published its Guidance Manual for the Implementation of Local
Discharge Limitations Under the Pretreatment Program.
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Once the program is fully successful, one of the original intents of the Water Pollution
Control Act Amendments of 1972 will have been fulfilled: to restore municipal sludge quality to
the point where it can be used as a soil amendment on agriculture, silviculture, and horticulture
without unacceptable risks to the public health or the environment. When this occurs, significant
sources of pollution associated with dewatering and disposal or incineration of contaminated
municipal sludge will have been virtually eliminated while maximizing the benefits associated
with nutrients recycling.
ToxicitY Reduction Evaluations
With the publication of USEPA's Technical Support Document for Water Quality-Based
Toxics Control in September 1985, the era of whole effluent toxicity testing as a component of
the NPDES permit program began.
The number of Great Lakes Basin permits with whole effluent toxicity monitoring and
limitations continues to grow as NPDES permits are re-issued. These limits vary from restrictions
on end-of-the-pipe acute toxicity to chronic toxicity limits of the low flow in-stream waste
concentration to back-to-back flow-through chronic toxicity tests. For example, the State of
Illinois is doing extensive biomonitoring of dischargers with toxicity potential. When problems are
identified, whole effluent toxicity testing is required as part of permit conditions as well as
provisions for TREs if needed.
When whole effluent toxicity limits are in permits and the discharger has problems meeting
those limits, it is often necessary for the discharger to reduce whole effluent toxicity in a
systematic fashion, USEPA developed two approaches to conducting TREs to identify and reduce
the source(s) of toxicity in the discharged effluent
A TRE is conducted if an unacceptable level of toxicity is detected in short-term (acute)
or long-term (chronic) tests using sensitive indicator organisms with a reproducible response. If
the toxic component or components and their sources can be readily identified, improved
housekeeping, chemical substitution, process modification, or wastestream pretreatment can be
instituted to reduce the toxicity below unacceptable levels. If the cause(s) and source(s) of the
toxicity are not obvious, a more sophisticated TRE procedure can be used that involves
fractionation of the wastewater to isolate the toxic fractions. Once toxic components are isolated,
source reduction efforts can be targeted at the most significant sources of the problem pollutants
amenable to improved housekeeping, chemical substitution, process modification, or wastestream
pretreatment.
In 1987, USEPA published a TRE Implementation Guidance Manual to facilitate
implementation of toxicity-based effluent limitations and toxicity reduction permit requirements.
A companion volume is being developed to provide further standardization and quality
assurance/quality control of toxicity testing methods used in the TRE program,
USEPA's Great Lakes National Program Office has contributed to the body of
methodologies available for implementing toxicity reduction in wastewaters with the development
of a Process Characterization Users Manual. Although targeted to a chemical-by-chemical
approach to effluent monitoring and limitations requirements development, the same methodology
can be applied to chemical substitution, process modification, or wastestream pretreatment goals.
The Manual is in the final stages of completion.
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ANNEX 13: POLLUTION FROM NONPOINT SOURCES
INTRODUCTION
Annex 13 mandates a number of measures to address nonpoint sources of pollution from
land-use activities in the Great Lakes Basin. These measures specifically encompass efforts to
further reduce nonpoint sources of phosphorus, sediments, toxic substances, and microbiological
contaminants that drain into Lake waters from surrounding urban and rural lands, including waste
disposal sites. Under this Annex, the Parties are required to identify land-based activities that
contribute to the water quality problems described in Remedial Action Plans (RAPs) for Areas of
Concern (AOCs) or in Lakewide Management Plans (LMPs)(under Annex 2), and to develop and
implement watershed management plans that will reduce nonpoint source inputs to priority
hydrologic units.
The Parties must also identify, preserve, and rehabilitate (where necessary) significant
wetland areas that are threatened by urban and agricultural development and waste disposal
activities, determine nonpoint source pollutant inputs in order to estimate loadings to Great Lakes
boundary waters, and identify the extent of change in land use and land management practices that
significantly affect water quality in order to track the effects of remedial measures.
This Annex encourages demonstration projects of remedial programs on urban and rural
watersheds in order to advance knowledge and enhance information and education services,
including extension services.
Finally, Annex 13 requires the Parties to report biennially on progress in developing
specific watershed management plans and implementing programs and measures to control nonpoint
sources of pollution.
Historically, the primary U.S. activities to identify and control nonpoint sources of
pollution in the Great Lakes have focused on reducing the phosphorus load to the Lower Lakes
(Lakes Ontario and Erie) and to the eutrophic embayments (Green Bay in Lake Michigan and
Saginaw Bay in Lake Huron). However, in addition to recent efforts led by the U.S.
Environmental Protection Agency (USEPA) to meet the requirements of Annex 13, a variety of
programs at both State and Federal levels (including Department of Agriculture's Soil Conservation
Service, Department of the Interior's Fish and Wildlife Service, and State Coastal Zone
Management programs) also address nonpoint issues such as soil erosion, construction site runoff,
and wetland protection on an ongoing basis. Often these efforts are conducted in cooperation with
USEPA. These and more recent strategies for meeting the requirements of Annex 13, such as
nonpoint source assessments and management programs under the Amendments to the Clean Water
Act (CWA), are briefly discussed in this section.
PHOSPHORUS REDUCTION PROGRAMS
Annex 3 of the Great Lakes Water Quality Agreement (GLWQA) of 1978 sets forth a
general framework for Canada and the United States to reduce phosphorus loadings to the Great
Lakes. In 1983, a Supplement to Annex 3 was approved, delineating phosphorus loading levels to
be achieved by 1990, and restating the belief that phosphorus loading objectives could be attained
through existing programs in the Upper Lakes.
Additional action was required to obtain target loads for Lake Erie, Saginaw Bay, and
Lake Ontario, however. Consequently, the 1987 GLWQA modified the reductions needed for Lake
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Ontario, based on new analyses. In setting these load reduction requirements, the GLWQA
recognized that nonpoint source controls on phosphorus, particularly from agricultural activities,
would be required to meet Agreement goals. To achieve these target goals, each State and
Province was required to develop and implement a detailed phosphorus load reduction plan for
these Lakes. The last State Plan was completed in September 1986.
In 1986, the Great Lakes Phosphorus Task Force (representing the States of Indiana,
Michigan, New York, Ohio, Pennsylvania; the Soil Conservation Service, Agricultural Stabilization
and Conservation Service, and Cooperative Extension Services of the U.S. Department of
Agriculture (USDA); and the USiPA Regions II, III, and V, as well as the Great Lakes National
Program Office (GLNPO)), allocated Lake Erie target load reductions among each responsible
State. In addition, Michigan and New York were assigned a target load reduction for Saginaw Bay
and Lake Ontario, respectively. The nonpoint source pollution abatement components were based
upon obtaining new funds to support an accelerated effort that would meet the 1990 goal.
This phosphorus load reduction strategy evolved from the cooperative efforts of USEPA,
USDA, and the States to conduct demonstration programs, public outreach efforts, and other
projects to promote the use of conservation tillage, animal waste, and fertilizer management
techniques by farmers throughout the Great Lakes Basin. As part of these activities, under an
Interagency Agreement with the USDA Soil Conservation Service, USEPA conducted a project to
track conservation tillage practices using highway transects and remote sensing techniques in 58
counties in Indiana, Michigan, and Ohio. The study has provided an estimate of phosphorus load
reductions that would be achieved as a result of expanding the use of conservation tillage. A
special study was also carried out in Ohio, an area where nonpoint phosphorus discharges are
particularly high because of regional conditions.
These studies indicated that USDA programs would have to be expanded in Ohio,
Pennsylvania, and New York in order to decrease nonpoint source phosphorus loads sufficiently
by 1990 to meet the Agreement goal. Based on the allocated load reductions and State plans to
comply with the allocations, the nonpoint source components of required load reductions have been
isolated and tracked. For each State, the majority of the nonpoint source load reduction was
expected to come from agricultural sources. Although increased attention has been paid to
encouraging the agricultural communities in these States to adopt conservation tillage and animal
waste management activities, program expansion has not occurred to an appreciable degree. Thus,
the States are generally behind schedule in reducing nonpoint source phosphorus loads. ;
The 1990 target load reductions for Lake Erie, Lake Ontario, and Saginaw Bay are
compared with load reductions achieved by 1988 in Table 1. New York has already made
substantial progress reducing nonpoint source phosphorus loads to Lake Ontario, achieving more
than 50 percent of the targeted load reduction goal. Similarly, Michigan has attained 36 percent
of its load reduction goal for Saginaw Bay and an acceptable 25-percent reduction for Lake Erie.
Phosphorus load reductions to Saginaw Bay and Lakes Erie and Ontario as of 1988 were 207.8,
330.2, and 105.5 metric tons, respectively. These reductions were significant given that they were
achieved with existing programs and competing priorities. The reductions fall short of meeting
the 1990 goals, however, and additional funding and perhaps some modification of existing USDA,
USEPA, and State programs for the accelerated program may be necessary.
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Table 1. Summary of the 1990 Phosphorus Load Reduction Goals for Lake Erie, Lake Ontario,
and Saginaw Bay as compared to 1988 Reduction in Phosphorus Loads
Lake Erie
1990 Goal 1700
1988 Reductions _3JQ
Reduction Needed to Meet 1990 Goal ' 1370
Lake Ontario
1990 Goal 235
1988 Reductions 106
Reduction Needed to Meet 1990 Goal 129
Saginaw Bav
1990 Goal 225
1988 Reductions 20$
Reduction Needed to Meet 1990 Goal 17
WATERSHED MANAGEMENT PLANS TO CONTROL TOXIC LOADINGS FROM NONPOINT
SOURCES
In FY 1988, GLNPO sponsored a workshop on developing watershed management plans
for State agencies in the Great Lakes Basin. This workshop was the first step toward fulfilling
the requirements of the GLWQA for controlling toxic pollution from nonpoint sources.
RAPs for AOCs and LMPs (both required by Annex 2) also provide opportunities to focus
on nonpoint sources of toxic loadings. In particular, the USEPA, Environment Canada, New York
Department of Environmental Conservation, and the Ontario Ministry of the Environment have
committed to developing a LMP for Lake Ontario to control toxic loadings. Because of the
importance of leachates from land disposal sites in the drainage basin, significant aspects of this
plan will be directed toward nonpoint sources. The Lake Ontario Toxics Management Plan will
be completed in February 1989.
In 1986, USEPA and the States of Illinois, Indiana, and Michigan prepared a Lake
Michigan Toxic Pollutant Control/Reduction Strategy. The objective of the strategy is to restore
multiple human uses to Lake Michigan and to protect human health and the Lake Michigan
ecosystem by achieving a significant reduction in the loading rates of toxic pollutants. The
strategy will use a whole-lake mass balance approach to modeling toxic pollutants and evaluating
potential regulatory controls.
The Great Lakes States also have worked jointly toward achieving the goals of the
GLWQA. In June 1986, the Governors of the eight Great Lakes States signed the Great Lakes
Toxic Substances Control Agreement. This Agreement pledges the States to treat the Lakes as a
single ecosystem despite political boundaries, acknowledges that toxic pollutants are the foremost
problem to be addressed, and lays out goals for the States. More recently, the Governors agreed
to establish a permanent fund for Great Lakes studies. Many of the activities under both of these
State agreements will lead directly and indirectly to the completion of and implementation of
management plans and ultimately to the attainment of the Agreement objectives. Considerable
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progress has already been made toward this goal by USEPA Headquarters and regional regulatory
and remedial programs by the States.
In FY 1989, USEPA will continue to characterize the extent of nonpoint sources of toxic
pollution and identify opportunities for conducting demonstration projects to assist with programs
for conventional pollutants.
1987 AMENDMENTS TO THE CLEAN WATER ACT STATE NONPOINT SOURCE
ASSESSMENTS AND MANAGEMENT PROGRAMS
Other recent U.S. efforts to identify and control nonpoint sources of pollution are derived
from Section 319 of the CWA, as amended in 1987. Under this Section, each State was required
to develop a Nonpoint Source Assessment and a Nonpoint Source Management Program by August
4, 1988. The assessments are intended to determine the waters of each State that are adversely
affected by nonpoint source inputs, identify the categories of nonpoint sources that contribute to
water quality degradation, and describe existing programs designed to control each significant
category. Management programs are required to address the major categories of nonpoint source
pollution that cause water quality degradation, including presentation of milestones and schedules
for remediation activities.
Consistent with Annex 13 requirements, USEPA issued guidance to the States encouraging-
the use of a watershed approach in developing these management programs, with areas designated
as AOCs receiving priority attention.
The federal government provided limited funding for assessment and management program
development under Section 205(j)(5) of the Act. Although use of these funds was optional, all of
the Great Lakes States availed themselves of these additional resources, and have prepared draft
assessments and programs that are currently under by USEPA review.
The draft nonpoint source management programs cover a wide range of control activities,
including those for nutrients (particularly phosphorus), toxics, and microbiological and sediment
pollutants. Significant gaps in this effort remain, however, as most States have not had the time
or the resources to fully develop all aspects of their programs. Over the next 6 months, additional
effort will be made to more fully develop the State management programs. Once the programs
are completed, Congress may allocate funds under Section 319 of the Act to assist in program
implementation, or States may use State Revolving Funds once in effect in 1990. As described
below, additional funds will be needed for States to meet the agreed phosphorus load reductions,
regardless of the amounts needed for toxics controls that may be part of their nonpoint source
management programs under the CWA.
OTHER ACTIVITIES
Because an important function of wetland areas is to act as a filter for nonpoint sources
of pollution from upland, wetland protection is an important component of watershed management.
The U.S. Army Corps of Engineers, in cooperation with the USEPA, administers a permit program
under Section 404 of the Clean Water Act to regulate the dredcing and filling activities in U.S.
waters, including wetlands. In 1988, the number of dredge and fill permits issued in the Great
Lake States declined 19.5 percent from 1987, with a total of over 680 standard permits.
Other efforts to protect wetlands include the advanced identification (ADID) of significant
wetlands, which assists in determining wetland areas that are unsuitable for filling. In Region V,
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four ADID studies have been completed, involving over 2,500 acres of wetlands. The study areas
include the Grand Calumet River/Indiana Harbor Canal, Indiana; Lake County, Illinois; Green
Bay, Wisconsin; and Lake Calumet, Illinois.
The National Oceanic and Atmospheric Administration (NOAA) currently administers and
supports approved coastal zone management (CZM) programs in four of the Great Lakes States.
These State programs address not only wetlands protection, but also land use, energy facility siting,
and other activities affecting the wetlands and coastal areas. CZM programs are particularly
important as regulatory mechanisms for controlling upland activities that contribute to nonpoint
source discharges. Federal activities that affect the coastal zones of these States must be certified
by the State as consistent with its CZM program.
Another example of recent State activities in nonpoint source programs is Minnesota's Clean
Water Partnership Program, established in 1987. This program's goal is to protect and improve
surface and ground water in the State through financial and technical assistance to local
governments. The Program focuses primarily on water pollution associated with land management
activities.
NOAA also has a diverse research and monitoring program addressing nonpoint source
pollutants ranging from collecting data on inputs, transport, fate, and effects of pollutants to
studies on the interactions of these pollutants with the marine environment. NOAA research is
conducted and/or supported through its National Sea Grant College Program and its Great Lakes
Environmental Research Laboratory (GLERL).
GLERL supports a small project in cooperation with the Soil Conservation Service of the
USDA and several State agencies on the effectiveness of Best Management Practices (BMPs)
implemented as part of the Saline River Rural Clean Water Project for the reduction of major
nutrients and sediments to the small streams in the basin. This project is intended to assist in
providing estimates of loadings of nutrients to the boundary waters, and also serves as a
demonstration project on the importance of land-use and land management practices that affect
water quality.
Demonstration projects for nonpoint source pollution control techniques have had many
successes in the Great Lakes, over the years. In 1972, Section 108(a) of the CWA authorized $20
million for USEPA to demonstrate the engineering and economic feasibility of pollution control
in the Great Lakes Basin. GLNPO worked closely with USEPA's Office of Research and
Development, Headquarters and regional water program, as well as with State and local government
organizations, to conduct demonstration programs that covered a range of objectives, including
demonstrating specific control technologies, controlling agricultural pollution through BMPs,
increasing public awareness of water pollution issues, documenting water quality results through
monitoring, evaluating combined sewer systems, and evaluating various sewage land application
techniques.
Management projects conducted under the Section 108(a) program included development
of a watershed management computer model for identifying important pollution sources, model
ordinances for pollution control, and other management tools. Other projects involved
demonstrating sewage sludge land application techniques and conservation tillage practices. A key
aspect of the tillage demonstration projects was that by providing funding and technical assistance
to local soil and water conservation districts, tremendous amounts of local support was developed.
Thus, these projects have provided important institutional and technical insights beneficial to State
and local programs.
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The USDA also supports demonstration programs that address nonpoint sources of
pollutants, including the USDA/Agricultural Stabilization and Conservation Service-sponsored
Rural Clean Water Program. The goal of this program is to develop agricultural BMPs by
providing technical and financial assistance to farmers for nonpoint source pollution control.
Similarly, the USEPA Nationwide Urban Runoff Program has funded demonstration
projects focused on an evaluation of the effectiveness of alternative nonpoint source pollution
control techniques. USEPA will continue to sponsor nonpoint source demonstration projects to
ensure that the reductions in phosphorus discharges already achieved in the basin are maintained.
If ongoing evaluations show that more controls are necessary, USEPA will work towards further
reductions through new demonstration and public education projects.
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ANNEX 14: CONTAMINATED SEDIMENT
INTRODUCTION
Annex 14 of the Great Lakes Water Quality Agreement (GLWQA) requires the Parties, in
cooperation with State and Provincial governments to identify the nature and extent of sediment
pollution of the Great Lakes system. Based on these findings, methods will be developed to
evaluate both the impact of polluted sediments on the Great Lakes and the technological
capabilities of programs to remedy such pollution.
This report describes progress made by the United States to fulfill its responsibilities under
Annex 14. After a brief overview of U.S. sediment activities, progress is described in three
general areas: surveillance programs, technology programs, and long-term control measures.
Overview of U.S. Contaminated Sediment Activities
U.S. activities related to contaminated sediment are implemented under Sections 118(c),
Section 404, and Section 401 of the Clean Water Act (CWA) and the GLWQA.
Section 118(c)(3) of the CWA requires USEPA to carry out a 5-year study and
demonstration program for the control and removal of toxic pollutants from the Great Lakes. The
CWA specifically designates five AOCs for "priority consideration" in locating demonstration sites:
Saginaw Bay, Michigan; Sheboygan Harbor, Wisconsin; Grand Calumet River, Indiana; Ashtabula
River, Ohio; and Buffalo River, New York.
It should be noted that both Annex 14 of the GLWQA and Section 118(c)(3) of the 1987
Amendments to the CWA represent a new direction in contaminated sediment management. Both
the Agreement and the Act directly address the problem of contaminated sediments outside the
context of navigational dredging and dredged material disposal. Concern is now focused on
situations where contaminated sediments, if left in place, present risks to humans and the eco-
system through contaminant mobility or bioaccumulation. (Annex 7 of the GLWQA deals further
with issues related to navigational dredging.)
Section 404 of the CWA provides for the regulation of discharges of dredged or fill
material into all U.S. waters. The U.S. Army Corps of Engineers (USCOE), in cooperation with
the USEPA, administers the Section 404 permit program. Michigan is the only Great Lake State
that has assumed the administration of the Section 404 permit program for selected waters in the
State. The USCOE retains jurisdiction of navigable waters and adjacent wetlands and regulates
all U.S. waters in the absence of an approved State program. The U.S. Fish and Wildlife Service
(USFWS) and the National Marine Fisheries Service review and comment on 404 permit
applications and provide technical assistance to protect fish and wildlife resources and to mitigate
project impacts.
Under Section 401 of the CWA, anyone conducting any activity that may result in a
discharge requires a Federal permit and must obtain State certification stating that the activity
described in the permit will comply with all applicable effluent and water quality requirements
and other appropriate requirements of State law. Certification provided under Section 401 shall
set forth effluent limitations and other limitations and monitoring requirements necessary to assure
that applicants for a Federal license or permit will comply with the applicable limitations. As
such, Section 401 of the CWA requires the USCOE or any other agency conducting dredging
activities to notify the State in which dredging is to take place to obtain a certification of
compliance with State requirements.
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Worst cases of contaminated sediments are located in the designated Areas of Concern
(AOCs). Of the total 42 in the United States and Canada, 41 AOCs have contaminated sediments
that are impairing beneficial uses. Preparation of Remedial Action Plans (RAPs) are under way
in all 30 U.S. AOCs and will address contaminated sediments.
COORDINATION OF RESEARCH AND OTHER STUDIES
In FY 1988, GLNPO started work to improve its coordination procedures within EPA and
with other Federal Agencies and the Great Lakes States. GLNPO established interagency
agreements related to contaminated sediments with several other government offices and
institutions.
Within USEPA, GLNPO has also established agreements for participation by other EPA
programs and offices in Great Lakes initiatives. In FY 1988, GLNPO entered into agreements
with the Office of Research and Development to fund Great Lakes work at the Large Lakes
Research Station (LLRS) and the National Water Quality Laboratory. These two laboratories are
contributing substantially to the Green Bay/Fox River Mass Balance Study, demonstration projects
undertaking research on contaminated sediment, and other GLNPO initiatives.
During FY 1989, GLNPO established procedures for participating with EPA Headquarters
in development of the Agency Operating Guidance for water programs and participated with
regional water divisions in development of State water program guidance. These two guidance
development activities are the principal methods by which EPA program priorities are
communicated throughout the Agency and to the States. In FY 1989, GLNPO plans to expand its
efforts in this area to include participation in program guidance development for other EPA
programs as well.
Also in FY 1988, GLNPO entered into an agreement with the Council of Great Lakes
Governors to assist with implementation of the Great Lakes Toxic Substances Control Agreement,
signed by the Governors in 1986. This Agreement pledges the States to treat the Lakes as a single
ecosystem despite political boundaries, acknowledges that toxic pollutants are the foremost problem
to be addressed, and lays out goals for the States. More recently, the Governors agreed to establish
a permanent fund for Great Lakes studies. GLNPO plans to continue work on all of these efforts,
as well as initiate new projects with State organizations in FY 1989.
During FY 1988, GLNPO made important progress toward fulfilling obligations under both
the CWA and the GLWQA. All of these achievements have involved other organizations working
in the Great Lakes. By working cooperatively with the States and other Federal Agencies, GLNPO
was able to ensure that significant progress toward achieving GLWQA goals was made during FY
1988. Much work remains to be done, however, and can be accomplished only through continued
cooperative efforts throughout the Great Lakes Basin within the United States and with Canada.
Future prospects focus primarily on control and abatement of toxic pollution in the Great Lakes.
SURVEILLANCE PROGRAMS
The progress of surveillance programs is discussed in three categories: classification of
sediment quality, monitoring activities, and management of contaminated sediments.
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Classification of Sediment Quality
Over the last several years, USEPA's Office of Water has initiated the development of
sediment quality criteria. The following approaches have been considered by USEPA in the course
of this criteria development effort
Sediment toxicity tests -- safe sediment concentration of specific chemicals are
established by a dose-response relation in sediment spike toxicity tests,
Apparent effects threshold (AET) -- field data on biological effects are compared with
sediment concentrations of individual chemicals. The AET is defined as the
concentration above which biological effects are always observed.
Equilibrium partitioning (EP) interstitial water concentrations of individual sediment
chemicals are predicted from equilibrium partitioning theory and compared with water
quality criteria.
Sediment quality triad correspondence between sediment chemistry, toxicity, and
biological effects is used to determine sediment concentrations that discriminate
conditions of minimal, uncertain, and major biological effects.
Tissue residue approach safe sediment concentrations of specific chemicals are
established by back-calculating from an acceptable tissue residue to the sediment
concentration resulting in that residue.
* Reference approach frequency distributions of sediment chemical concentrations are
established separately for reference (i.e., background) and contaminated sites, and
compared with sediments of concern on a statistical basis.
* Extraction (elutriate) test contaminant concentrations in an elutriate from a 4:1
water/sediment mixture are compared with drinking or water quality criteria or various
multiples thereof to protect the water column biota during dredged material disposal
operations.
* Bulk sediment toxicity the toxicity of field-collected samples is determined by
sediment bioassays.
All of these approaches have some history of application in other government programs. For
example, the extraction test and reference approaches are being used in dredged material permit
evaluations in many USEPA regions and the AET approach has been extensively applied in USEPA
Region X. Additional work has been done by the Puget Sound Program to develop and test the
sediment quality triad approach and AET method.
After evaluating the full range of alternatives, the USEPA has selected the EP approach
as the most effective regulatory tool based on technical, programmatic, and regulatory criteria.
Using the EP approach, national sediment criteria can be derived from available national water
quality criteria and standards with the least additional data gathering and basic research.
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DRAFT
USEPA has undertaken a major research effort aimed at verifying and refining the EP
approach for both metals and nonpolar organic chemicals. The Office of Water has presented the
results of the studies undertaken on the EP approach to the USEPA Science Advisory Board (SAB)
in December 1988. The SAB's approval is being sought for the methods being used in deriving
the national sediment criteria. A final report from SAB commenting on the approach will be
issued in May 1989, A favorable review by the SAB would result in the issuance of guidance on
the regulatory uses of the national sediment criteria. In addition, USEPA would pursue further
refinement of the criteria development approach and the development of additional national
sediment criteria for contaminants of concern.
The Office of Water is working with several Regions and States on the national sediment
criteria effort, as well as on other facets of evaluating the effects of contaminated sediments, such
as biological community structure, AETs, and acute and chronic effects laboratory bioassays. The
Office of Water is also developing a guidance document on the regulatory application of the
sediment criteria. In addition, a methods manual is under development by USEPA that describes
each method and its history of application.
USEPA Region V is working with the States on methods to assess sediments through a draft
In-Place Pollutants Control Initiative. In lieu of numerical sediment quality criteria derived in a
manner consistent with that used for numerical water quality criteria, the present approach to
classify contaminated sediment sites in the Great Lakes involves the application of the "Guidelines
for the Pollutional Classification of Great Lakes Harbor Sediments" developed by USEPA
Region V. First published in 1968, these interim guidelines evolved from studies of Great Lakes
harbor sediments started in 1967 by the Federal Water Pollution Control Administration. Those
studies established three broad categories of sediment contamination based on field observations
and professional judgment: nonpolluted, moderately polluted, and heavily polluted. Factors
considered included color, odor, particle size distribution, presence of oil, and the condition of the
benthic faunal community. Natural breakpoints in the sediment contaminant level data for samples
from over 100 different Great Lakes harbors were then used to establish pollutant parameter
concentration ranges corresponding to the observed conditions. Supplementary interim guidelines
for 11 additional parameters were added in 1977, based on data from 260 samples collected at 34
harbors. These guidelines are used to determine if open lake disposal of dredged sediments is
appropriate.
The Great Lakes Water Quality Board of the International Joint Commission, through its
Dredging Subcommittee, also published Dredged Material Disposal Guidelines in 1982. The
guidelines are based on the concentrations of pollutants in the sediments of depositional zones of
the Great Lakes, rather than on the concentrations of pollutants in the harbor sediments.
In addition, USEPA's Office of Research and Development is developing sediment bioassays
and measures of benthic community structure to evaluate benthic ecosystem effects of specific
chemicals in complex wastes.
Some States have developed their own classification system. The following describes each
State's approach to sediment classification:
Illinois has developed a five-tier classification system of stream sediment quality based
upon standard deviations for background levels. This system is currently used by Illinois
monitoring programs to assess sediment quality.
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DRAFT
Indiana uses bulk analysis to evaluate sediment samples. In order to assess the test results,
Indiana has established background levels for each substance of interest. The background levels
were established using data collected over several years from uncontaminated sites. The test results
are compared with established background levels, with USEPA Guidelines for the Pollutional
Classification of Great Lakes Harbor Sediments and with Indiana water quality standards. PCBs
are considered the contaminants of primary concern; 0.5-1.0 ppm total PCB, depending on the
sediment type, is considered the maximum acceptable concentration. Sites with levels exceeding
this limit may require sediment removal. Fish tissue samples remain the primary indicator of toxic
contamination, however. If fish tissue samples collected from the sediment site do not show
accumulation, it is unlikely that sediment will require removal.
In Michigan, Minnesota, and New York the choice of classification criteria is
site-dependent, although the 1977 USEPA Guidelines for the Pollutional Classification of Great
Lakes Harbor Sediments are commonly used. Recently, Minnesota has also been using guidelines
set by Wisconsin. Pennsylvania conducts assessments on a site-by-site basis since it has no
standardized assessment criteria for contaminated sediments.
New York attempts to link the sediment classification to actual use impairment within
specific water bodies. New York State Department of Environmental Conservation is currently
developing a technical guidance document for evaluation of water quality impacts during dredging
operations.
Ohio uses criteria developed by Illinois to classify Ohio stream sediments. Since the Illinois
criteria were developed for streams similar to those in Ohio, Illinois criteria are more applicable
than the USEPA Great Lakes Harbor sediment guidelines. Ohio does continue to use the USEPA
Great Lakes Harbor sediment guidelines for harbor areas (river mouths), however.
Wisconsin has developed a three-tiered sediment assessment scheme and has established
sediment quality criteria. These criteria are based on background data from several sources. The
background data for metals were collected from recent and 200-year-old Lake Michigan sediments,
bluff material from Lake Michigan shorelines, and average concentrations of metals in surficial
sediments from all the Great Lakes. Background levels for organics were also determined using
data from surficial sediments from all the Great Lakes. Wisconsin has developed background
criteria for metals, total PCBs, total tetrachlorodibenzodioxin (TCDD), total tetrachlorodibenzofuran
(TCDF), selected pesticides, and oil and grease.
Monitoring Activities
The GLWQA, as amended by a Protocol signed November 18, 1987, sets forth several
monitoring and research programs. Specifically, the Agreement requires the establishment of
monitoring and research programs in support of the Great Lakes International Surveillance Plan
at a level sufficient to identify:
* Temporal and spatial trends in concentration of persistent toxic substances
Impact of persistent toxic substances on the health of humans and the quality and health
of living aquatic systems
Sources of input of persistent toxic substances
* Presence of previously unidentified persistent toxic substances.
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The Agreement also stipulates that research should be intensified to determine the
pathways, fate, and effects of toxic substances aimed at the protection of human health, fishery
resources, and wildlife of the Great Lakes Basin ecosystem. Research should be conducted to
determine:
* Significance of effects of persistent toxic substances on human health and aquatic life
Interactive effects of residues of toxic substances on aquatic life, wildlife, and human
health
* Approaches to calculate acceptable loading rates for persistent toxic substances,
especially those which, in part, are naturally occurring.
The following discussion of U.S. progress toward a comprehensive monitoring program
focuses on monitoring to determine the impact of contaminated sediments on the Great Lakes
system and on monitoring to increase our understanding of the transfer of contaminants to and
from bottom sediments.
Ambient Monitoring and Assessment Activities
Some States in the Great Lakes Basin undertake sediment monitoring as part of specific-
remedial activities. In particular, Indiana and Michigan have identified contaminated sediment
sites near industrial discharge points requiring remedial action. Michigan also has performed some
investigative monitoring at three contaminated sediment study sites.
GLNPO has conducted harbor and estuary sediment sampling to identify toxic hot spots
and to aid in the identification of areas that are contributing large amounts of toxics to the Lakes.
Twenty-five harbors on Lakes Superior, Michigan, Erie, and Ontario were sampled for
conventional or priority pollutants in 1981 and 1982, including intensive sampling of the Buffalo
and Niagara Rivers in 1981 and the Detroit River in 1982. The St. Lawrence River and its
tributaries were sampled in 1984.
GLNPO sampled 52 tributaries to the four upper Great Lakes connecting channels during
1985. The levels of contaminants in the sediments were compared against guidelines developed by
USEPA, Ontario Ministry of the Environment (OMOE), and the IJC. Overall contamination at
each tributary to the connecting channels was evaluated relative to the levels of metals, nutrients,
total PCBs, pesticides, and other organic compounds. The evaluations allowed for the
identification of tributaries that were substantial contributors of pollutants. In addition, over all
comparisons were made among all of the connecting channels studied to assist GLNPO in
prioritizing remedial action needs.
Future plans extend sampling to sediments in the open waters of the Lakes to measure the
distribution, storage, and fate of toxics in the ecosystem, beginning in Lake Michigan in 1991.
This sampling will provide a chronology of toxic inputs to the Lakes and will support mass balance
models for Critical Pollutants. Sampling will also support development of Lakewide Management
Plans (LMPs) as required by the GLWQA, GLNPO coordinates this work with the development
of national sediment criteria and sediment contaminant cycling studies conducted by USEPA's
Office of Research and Development laboratories at Duluth, Minnesota, and at Grosse He,
Michigan.
USEPA also is working with the States and local agencies on sediment monitoring during
the development of Remedial Action Plans for the Areas of Concern by the IJC.
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DRAFT
The Great Lakes States are also performing general area sediment monitoring. These
monitoring efforts are performed either in response to a specific problem or as part of the State's
routine basin monitoring programs. Specific efforts are described in Table 1.
Activities to Quantify the Transfer of Contaminants from Sediments
In addressing the issue of contaminated sediment management in the Great Lakes, the
Water Quality Board convened the Sediment Technical Oversight Committee, which is composed
of technical experts within the region. The overall objective of this Committee is to identify,
coordinate, and provide guidance on contaminated sediment activities. The Committee's research
plan includes the implementation of the following activities over the next 5 years:
Identification and detail of chemical specific and bulk sediment toxicity methods
* Development of benthic organism chronic toxicity, bioaccumulation, and carcinogenicity
test methods
* Performance of an ecological assessment of known sediment activity of metal ions in
pore water and its toxicity.
The USEPA Environmental Research Laboratory at Duluth, Minnesota, is involved in
monitoring efforts at sediment contamination remediation sites. Recent studies at various sites
have involved sediment transport and deposition studies, acute and chronic toxicity testing,
physical characterization, chemical analyses, Ames testing, and carcinogenicity testing of the
sediment.
Contaminated sediment monitoring is also an important element in the Green Bay Mass
Balance Study. This Study, coordinated by USEPA and Wisconsin Department of Natural
Resources, is intended to develop and test a modeling framework on sources, transport, and fate
of toxic compounds in the Green Bay area. The study is intended to support regulatory activities
within the study area and to serve as a pilot project for larger modeling studies.
The project began in 1987 with the development of a monitoring plan and the
establishment of a quality assurance program for evaluating analytical and field methods to be
employed. Field reconnaissance and sampling commenced the following year and will continue
through 1989 to determine levels of selected contaminants (i.e., those known to present problems
in the Great Lakes and which also serve as surrogates for larger classes of contaminants) in various
compartments (i.e., atmosphere, water, sediment, biota) of the Green Bay ecosystem. The model
will incorporate the following components:
* Comprehensive quantification of loads from all significant sources (e.g., atmosphere,
tributaries, ground water, point, and nonpoint)
Determination of the net rate of exchange of contaminants between environmental
compartments (e.g., sediment, surface water, ground water, biota, and air)
* Net rate of exchange with Lake Michigan.
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TABLE 1. SUMMARY OF STATE AMBIENT UATER AND SEDIMENT MONITORING PROGRAMS
Illinois
Stream sediment data are collected through two programs: the Ambient Water Duality Monitoring Network (AUQMN) and the Intensive River Basin Survey Program.
The AUQMN provides background and trend information, as well as information on current conditions in specific streams. Intensive surveys are basin-specific,
and provide surveillance information for response to known or suspected water quality problems. Lake sediment data are collected through the State's anbient
lake Monitoring program and intensive lake surveys.
Indiana
Indiana collects sediment quality data through its Toxics Monitoring Program. This program concentrates on analyzing fish tissue sanples collected at the State's
21 CORE stations. Sediment samples are routinely collected at the CORE stations as well. Intensive surveys have also been conducted on several lakes, reservoirs
and streams in Indiana. Through intensive surveys and special studies 33 streams and 62 lakes and reservoirs have been studied in the past 3 years.
Michigan
Field investigations, including sampling and analyzing sediment for historic and ongoing discharges, gay be conducted when sediment contamination is suspected
based on results of water quality Monitoring programs.
Minnesota
Prior to 1980, sediment quality sampling was a component of routine water quality Monitoring in Minnesota. In 1973, 1976, and 1979, sediment samples were
collected at 19 fixed monitoring stations in the State. This was discontinued after 1979 because of the lack of an established framework for data assessment.
Currently, stream sediment quality data are collected through intensive stream surveys only. The lake monitoring programs do not regularly include sediment
quality analysis.
|fH Tork
Benthic macroinvertebrate and fish community assessments, along with sediment samples analyzed for PCBs, chlorinated pesticides, and priority pollutant metals,
are used in conjunction with water coluan data to describe overall water quality conditions. Additionally, site specific investigations to assess sediment condi-
tions have included sediment napping, contaminant distribution and toxicity, bioavailability, and credibility testing.
Ohio
Ohio selects several streams each year for intensive surveys. Surface water quality is tested and fish and benthic populations are sampled at each site. Fish
tissue and sediment testing are done less regularly. Sediment tests are done when there is reason to believe that sediments may be contaminated. Roughly one
third of the intensive survey sites throughout the State, or 60 sites, conduct sediment sampling each year.
Pennsylvania
When sediment contamination is suspected based on results of other investigations, detailed analysis nay be undertaken, including sediment sampling to determine
the extent and magnitude of the contamination.
Wisconsin
Contaminated sediments have been identified as one of six primary elements to be evaluated by monitoring programs. Monitoring of contaminated sediments is
conducted under several programs, including basin assessments, special projects, Mississippi River monitoring, and specific response actions.
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DRAFT
Analysis of field data, modeling, and interpretation are scheduled to begin in 1990. These
activities will be guided by several specific objectives:
Usefulness in predicting concentrations of key contaminants in fish to help determine
cancer risks to human fish consumers
Utility for USEPA and State in making regulatory decisions
* Applicability of the pilot study as a model for larger, lakewide studies.
The U.S. Fish and Wildlife Service also has been involved in general area sediment
monitoring. The National Fisheries Center-Great Lakes has performed caged organism studies in
and around sites with contaminated sediments in order to examine biomagnification and
bioconcentration of the pollutants found in the sediments. Clipped wing duck studies at a
confined disposal facility (CDF) confirmed that birds, including ducks hunted by sportsmen,
foraging in such areas can accumulate considerable body burdens of contaminants such as PCBs.
Other studies have focused on eagles because of their reduced reproduction in the Great Lakes
area. These studies showed that eagles may be indirectly accumulating sediment contaminants
through injestion of prey organisms.
The National Oceanic and Atmospheric Administration's (NOAA's) Great Lakes
Environmental Research Laboratory (GLERL) is continuing research important to the
implementation of Annex 14. The research deals with measurement of the bioavailability and
uptake of contaminants from sediments by Pontoporeia frovi and the incorporation of the results"
into contaminant behavior models. A major publication provides a synthesis of 5 years of studies
on the bioaccumulation of PAH from sediments of £. hoyi.
The GLERL HI-SED project made comparative studies of radionuclide inventories between
1972 and 1982 in Lake Michigan and between 1976 and 1982 in Lake Erie. These studies show
the long-term process of particle associated tracers and contaminants focusing on sediment
depositional basins. A model has been developed to interpret distributions of chlorinated organic
compounds (e.g., PCBs and pesticides).
Management of Contaminated Sediments
The United States and Canada are working jointly to develop a standard approach for the
management of contaminated sediments. The first draft of the report is currently being reviewed
by Federal, State, and Provincial officials in both countries. A final report will be issued
sometime during 1989.
\
TECHNOLOGY PROGRAMS
Remediation Demonstration Program
Under Section 118(c)(3) of the CWA as amended by the Water Quality Act of 1987, the
USEPA's Great Lakes National Program Office (GLNPO) will conduct a 5-year study and
demonstration project relating to the control and removal of toxic pollutants from bottom
sediments. The geographic focus of this study, termed the Assessment and Remediation of
Contaminated Sediments Study (ARCS), will be in several Great Lakes Areas of Concern. This
program gives priority consideration to conducting demonstration projects at five Great Lakes
locations: Saginaw Bay, Michigan; Sheboygan Harbor, Wisconsin; Grand Calumet River, Indiana;
Ashtabula River, Ohio; and Buffalo River, New York. The program will be carried out jointly
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DRAFT
with GLNPO and other Federal, State, and local agencies. The final locations of the demonstration
sites will be determined by matching technologies and site specific characteristics, including
complementary activities by USEPA, States, and particularly by the USCOE. GLNPO has also
entered into an agreement with the Illinois Natural History Survey for assistance in planning and
designing ARCS.
An Activity Integration Committee (AIC) has been created for the ARCS program. The
AIC will coordinate the ARCS program activities at the operational level. This Committee will
be chaired by the chief of the Contaminated Sediments staff at GLNPO. The AIC chair will also
be an ex officio member of, and report directly to, the management committee. The AIC will be
responsible for the accomplishment of program tasks through its oversight of the scientific and
technical Work Groups.
Accomplishments during FY 1988 include work on site selection criteria for the
demonstration projects and work with USEPA's Office of Water on cleanup criteria for pollutants
in sediment. Also in FY 1988, GLNPO entered into an interagency agreement with the USCOE
to assist with planning the demonstration program. Under the agreement, the USCOE will assist
GLNPO with research and evaluation of remedial technologies for sediments and will conduct
other information collection and literature review activities. The Chicago District,of USCOE has
already performed a study to characterize Indiana Harbor sediments and to evaluate various
treatment technologies including solidification and densification processes.
Remediation Activities
Remediation programs are carried out by Federal, State, and local government organizations
throughout the Great Lakes Basin, working under authorities granted by Federal and State
environmental statutes.
The States conduct monitoring as part of the Section 401 certification process for a 404
dredging permit. Each State's process, summarized in Table 2, is considered to be a remediation
approach for dealing with contaminated sediments.
To date, USEPA has had limited success in mitigating sediment contamination problems
due to a number of factors. These include the lack of national guidelines for determining what
levels of contaminated sediments cause problems, the problems and expense involved in dredging
and disposal operations, and USEPA and USCOE limitations for management of contaminated
sediments. Virtually the only ongoing effort to remove contaminated sediments in Region V is
the USCOE dredging program. This program, however, is limited to dredging only where
necessary for navigation purposes. Additionally, USCOE is congressionally limited to dredging no
more than 2 feet below the channel depth in navigable waterways. In some instances, this practice
may expose more contaminated sediments than were present prior to dredging.
Another potential mechanism to remediate contaminated sediment problems is the
Superfund program. However, sites with only contaminated sediment problems are typically not
ranked very high on the Hazard Ranking System (HRS) and are not often placed on the National
Priorities List (NPL). This is due to a lack of specific consideration of sediments in the HRS and
lack of Sediment Quality Criteria (SQC) with which to compare sediment contaminant
concentrations. For sites which are placed on the NPL, sediments are often not remediated along
with on-site media (soil, ground water) due to the lack of SQC, the difficulty in linking sediment
contamination to a single site, and remediation/disposal difficulties and costs. Nevertheless, three
contaminated sediment sites in the Great Lakes Basin are slated for Superfund cleanup: Waukegan
Harbor, Illinois; Fields Brook, Ohio; and Sheboygan River, Wisconsin.
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TABLE 2. STATE PROGRAMS FOR CLASSIFICAT10* AID DISPOSAL OF DREDGED SEDIMENT
APPLICABLE PROGRAMS
CtlTFJUA
DISPOSAL OPTIONS
Illinois
Issuance of an Illinois Section 401 permit for
a dredge project certifies that the dredging
activity and associated disposal actions
comply with Illinois water quality standards
and laws. Federal 404 permits are also
required for all dredge projects.
Indiana
Indiana Monitors dredged sediment disposal
through Section 401 of the Clean Uater Act.
Federal 404 dredge and till peraits are also
required.
Sedi*ent quality is determined through
particle size analysis, then if necessary,
supernatant or Modified elutriate testing.
The preferred Method of sediment
classification is comparison of the elutriate
test results (based on dredging technique,
disposal plans, and contaminants) to the water
quality standards and effluent standards set
by State Code.
Sedinent quality analysis is required if
tissues from fish in the area exceed U.S. Food
and Drug Acton nistrati on (FDA) action levels.
The USEPA "Interim Guidelines for Evaluation
of Dredged Sediments" are used as a general
guideline for evaluating bulk sediment test
results, supplemented by Indiana water quality
Standards. Test results ar* also compared to
background data compiled by Indiana through
its monitoring programs.
The accepted means for disposal of dredge
spoil in Illinois are Confied Disposal
Facilities
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TABLE 2. STATE PROGRAMS FOR CLASSIFICATION AND DISPOSAL OF DREDGED SEDIMENT CONTINUED)
APPLICABLE PROGRAMS
OUTER IA
DISPOSAL OPTIONS
in
oo
Michigan
Dredge and fill permits are required under
Section 404 of the Clean Hater Act. and under
the Michigan Submerged Lands Act of 19SS.
Michigan maintains a Section 404 data base to
catalog information affecting permit review.
Characterization data are stored by township
and section, and include factors such as
contamination of bottom sediments, areas of
severe coastal erosion, fish consumption
advisories, and/or historic discharge
information. For each dredge and fill permit
application, a computer check deternines which
characteristics of the project site nay
warrant special attention. Thus, sediment
data are generated as a result of the permit
application process.
Minnesota
In Minnesota, dredging projects are regulated
by the issuance of a State Disposal System
permit, in addition to Federal 404 permits.
In cases where sediment analysis is required,
bulk sediment testing is performed for those
parameters deemed likely to be present based
on historic data.
Secondary treatment, toxic effluent standards
and water quality standards are applicable to
each individual project. Variances from the
standards or procedural requirements are
granted on an individual basis.
In most cases, historic data are used to
determine whether the sediment is suitable for
open water disposal. Permits for sites that
require frequent and regular dredging are
handled by the district USCOE field staff and
do not require State referral.
All hydraulic dredging projects are usually
required to obtain a state disposal system
permit as there is potential for carriage
water flow to contaminate ground or surface
water. Flow from confined disposal facilities
is monitored. If the history of the site
gives reason to suspect contamination, and
there is no existing sediment data, testing
may be required.
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TABLE 2. STATE PROGRAMS FOR CLASSIFICATION MB DISPOSAL Of DREDGED SEDIMENT (CONTINUED)
APPLICABLE PROGRAMS
CRITERIA
DISPOSAL OPTIONS
New York
Section 401 permits are required for dredging
projects to ensure consistency with New York
programs, laws, and regulations.
Ohio
Issuance of a 401 permit is required for alt
dredging operations to ensure compliance with
all Ohio programs, laws, and regulations.
There are no set criteria to classify
sediment. Sediment are classified as either
incidental to channel Maintenance or those
which pertain to water use impairments and
hazards posed by contaminated sediments.
If contamination is suspected, physical
characterization, bulk and/or elutriate
analyses are required. Sand and coarser
sediments are considered uncontaMi rated, fine
sediments require ctienical analysis.
Parameters are determined by the site history,
using EPA guidelines for pollution
classification. Bioassays are recoMiended to
be coordinated with EPA.
CNo Information Available)
Pennsylvania
Issuance of a 401 Water Quality Certification
for a dredging project in Pennsylvania
certifies that the activity complies with
relevant water quality standards. Federal 404
penalts are also required.
The USCOE criteria are used to review the
degree of contamination in determining
appropriate disposal action*.
Most dredged sediments are disposed of on
upland sites and are sU>ject to Pennsylvania's
solid and hazardous waste regulations.
Existing Pennsylvania law allows open lake
disposal depending upon the degree of
contamination. Heavily contaminated dredged
spoils are disposed of in confined disposal
facilities (COfs).
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TABLE 2. STATE PROGRAMS FOR CLASSIFICATION AND DISPOSAL OF DREDGED SEDIMENT {CONTINUED)
PROGRAMS
CRITERIA
DISPOSAL OPTIONS
Uisconsin
Uisconsin has codified procedures for
assessment and criteria for in-water or beach
disposal of dredged sediments. This IM is
currently being redrafted to expand and
clarify the revieu procedures. Federal 404
permits are also required.
Wisconsin currently applies a tiered
assessment scheme in evaluating dredge project
sites for regulatory, remedial, and monitoring
activities. The initial assessment step is
conducted using existing and readily
accessible Wisconsin data or information
submitted by the applicant.
The second tier is establishing sampling and
analysis requirements. Bulk chemistry
analysis is performed on the samples to
determine potential disposal methods.
Background criteria are used to determine
suitability for open-water disposal or beach
nourishment. Open water disposal is only
allowed by law if a beneficial use is derived.
If the bulk chemistry criteria are exceeded,
the applicant may enter the third tier of the
assessment scheme--toxicity testing.
For any project where upland disposal is
required or planned, assessment requirements
are determined under the State solid waste
program review. A new law has been proposed
to define the requirements for in-water
confined disposal facilities.
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DRAFT
In Region V, the thrust of the sediment work has been on the Great Lakes. Two USEPA
activities intended to remediate contaminated sediments in Great Lakes harbors and tributaries are
the development of Remedial Action Plans (RAPs) for 30 Areas of Concern (AOCs) and the 5-year
demonstration program. GLNPO has provided technical support to all of the Great Lakes States
in preparing the RAPs. Since virtually all of the AOCs have contaminated sediment problems,
implementation of these RAPs will be a major step toward remediating Great Lakes sediments.
While the above two activities relate solely to Great Lakes harbors and tributaries, the current
In-Place Pollutant Strategy will emphasize inland waterways.
Table 3 lists State programs and projects, both underway and proposed, related to the
remediation of sites with contaminated sediments.
LONG TERM CONTROL MEASURES
At present, almost all contaminated dredged material is disposed of either at suitable upland
sites or in engineered confined disposal facilities. Isolation of the material is achieved through
placement in an area that has been specifically prepared and dedicated as a long-term storage or
disposal site. The dedicated storage location is normally prepared by construction of perimeter
dikes to withhold the contaminated materials.
Contaminated sediments are first collected and removed from their original site of
deposition by dredging. These contaminated sediments are then transported and deposited into the
confined disposal facilities (CDFs) located in nearshore waters. The specific design of the CDF,
the specific type of dredging equipment to be used, the method of transportation, as well as the
operation of the CDF must be tailored to site specific circumstances in order to insure that
contaminants of concern are captured, deposited into, and retained by the CDF at the minimum
necessary cost.
The first CDF to come into use in the Great Lakes was the Grassy Island site for
contaminated sediments from the Rouge River Michigan navigation project in 1960. Use of CDF
sites has increased significantly in the Great Lakes since 1970, with most sites having been
constructed between 1972 and 1979. Considerable experience has been gained and improvements
made in the design, construction, and operation and maintenance of such facilities over this period.
Significant improvements have been made to ensure structural integrity of containment dikes so
that there is minimal loss of contaminants from the CDFs.
Removal and confinement of over 2 million cubic yards of contaminated bottom sediments
took place in 1988 at the following ten Great Lakes harbors:
Green Bay, WI
Duluth-Superior Harbor, MN and WI
Saginaw Bay, MI
Monroe Bay, MI
Cleveland Harbor, OH
Toledo Harbor, OH
Huron Harbor, OH
Lorain Harbor, OH
Buffalo Harbor, NY
Construction of two new CDFs were completed by the Detroit District of the USCOE in
1988 at the Keweenaw Waterway, Michigan, and at the Clinton River, Michigan. Construction
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DRAFT
of additional structures to contain contaminated dredged material are contemplated at Green Bay,
Wisconsin; Indiana Harbor, Indiana; and Waukegan Harbor, Illinois.
A number of special studies have been conducted by the USCOE to evaluate how well
existing CDFs are working to contain contaminants or to obtain needed information to properly
design and operate CDFs. The following studies were conducted in 1988:
Monitoring study in the Buffalo Harbor area to determine whether contaminants from
disposal areas may be leaking into the surrounding environment.
Field and laboratory testing was conducted to verify some assumptions of and the
relative magnitude of the predictions of a model which had been previously developed
to estimate the potential loss of small quantities of dissolved PCBs from CDFs.
Study to evaluate the chemistry of pore water from Waukegan Harbor, Illinois,
sediments to determine the potential water quality impacts of the release of this water
from a CDF.
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TABLE 3. SUMttRY OF STATE PROGRAMS AND ACTIVITIES RELATED TO CONTAMINATED SEDIMENTS
PROGRAM
CURRENT PROJECTS
PROPOSED PROJECTS
O\
Illinois
The Clean Illinois program is in place
to fund the cleanup of contaminated bottom
sediments.
Indiana
A State bill has been drafted for a
hazardous waste cleanup or "State Superfund"
program. The proposed law outlines a
program that is meant to complement the
USEPA Superfund program.
Michigan
The Michigan Environmental Response Act
(MERA) provides a method for identifying and
assigning priority to sites of environmental
concern within Michigan and conducting risk
assessments.
The Upper Uaukegan Harbor is currently
being investigated under USEPA Superfund
authority and is the subject of litigation
and negotiation between USEPA and Outboard
Marine Corporation (QHC). Negotiations
between EPA and CMC have resulted in a
Consent Decree and recownended remedial
alternatives to clean the OMC/Uaukegan
Harbor site. An estimated 1,100.000 pounds
of PCS are contained in 220,000 cubic yards
of sediment and soil. The USCOE is
developing an Environmental Impact Statement
(EIS) for dredging and disposal for the
Lower Harbor adjacent to the area subject to
Superfund action.
Sediment data for the Grand Calumet
River/Indiana Harbor Canal area have been
collected by the USCOE, Indiana Department
of Environmental Management (IDEM), and
USEPA. Dredging of the Indiana Harbor
Canal, has been delayed due to concerns over
disposal methods for the PCB-contaminated
dredged sediments.
Michigan DNR has submitted nine RAPs to
the IJC which include remedial actions for
contaminated sediments.
Once Superfund-related remedial
actions have been planned, the Illinois
USEPA will assess other actions required to
satisfy the IJC requirements for BAP
development.
Michigan DNR is responsible for
overseeing the development of one additional
RAP.
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TABLE 1. SUMMIT OF STATE PROGRAMS MB ACTIVITIES RELATED TO CONTAMINATED SEDIMENTS (CONTINUED)
PROGRAM
CURRENT PROJECTS
PROPOSED PROJECTS
ON
Minnesota
Under the Minnesota Environmental
Response and Liability Act (MERLA) the
Minnesota Pollution Control Agency (NPCA)
has the authority to respond to the release
of hazardous substances to th« environment.
MERLA ranks potential sites using the
Federal Hazard Ranking System.
Investigation at a potential site near any
surface water body must include sediment
quality analysis for contaminants of
concern.
Sediment data collected by MPCA show
the St. Louis lay sediments to be polluted
with arsenic and chromium. Some PAH
contamination also exists within the bay.
SediBents near the Western Lake Sanitary
District outfall are contaminated uith PCBs.
arsenic, cadmium, chromium, copper, mercury,
and lead.
The St. Louis River site ranks on the
National Priority List and is currently
being investigated for Federal Superfund
action. The St. Louis River/Bay is also an
AOC. Development of a RAP for this area is
in progress.
New York
(NOTHING HERE YET)
The State of Neu York has taken
remedial actions involving sediments to
alleviate water quality problems. Sediment
removal has been used as part of lake
restoration programs, and demonstration
projects of alum additions to reduce
phosphorus release from sediments have been
completed.
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TABLE 3. SUMMARf OF STATE PROGRAMS AND ACTIVITIES RELATED TO CONTAMINATED SEDIMENTS (CONTINUED)
PROGRAM
CURRENT PROJECTS
PROPOSED PROJECTS
in
Ohio
A State cleanup priority list uas
conceived to focus State attention on
contaminated sites that were not addressed
under Superfund. The proposed list was to
be designed especially to focus on sites
with long-term environmental threats, and
therefore, do not rank high on the Federal
Hazard Ranking System. Contaminated
sediment sites fit this description.
Four AOCs exist in Ohio. All four are
characterized by contaminated sediments. The
development of the RAPs for all four areas
is in the early stages. One of four Ohio
AOCs is Ashtabula Harbor, which contains
Fields Brook, a Superfund site. A remedial
investigation/feasibility study has been
prepared. The Fields Brook Record of
Decision proposes to incinerate the most
contaminated sediments and landfill those
remaining. Rising costs and a number of
other complications may preclude efforts to
dredge the highly contaminated and toxic
sediments in the river navigation channel.
The river may be classified as. a Superfund
site or as an extension of the Field Brook
Superfund site.
A recent lawsuit settlement requires
Bethlehem Steel to cleanup a stretch of the
Black River, impacted by historical coke
oven discharges, including phenolics and
PAHs.
Pennsylvania
Under the Hazardous Sites Clean Up Act (Act
108) Pennsylvania Department of
Environmental Resources has the authority to
respond to the release of hazardous
substances to the environment.
No current projects in the Great Lakes
System.
No proposed projects in the Great Lakes
System.
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TABLE 1. SUMMARY OF STATE PROGRAMS MB ACTIVITIES RELATED TO CONTAMINATED SEDIMENTS {CONTINUED)
PROGRAM
GUMEMT PROJECTS
PROPOSED PROJECTS
Wisconsin
Under its Environmental Repair Program,
Wisconsin has developed a State list and
ranking process similar to the HPL. The
criteria for this ranking system makes it
unlikely that any contaminated sediment
sites will be targeted for action.
The IJC has identified four AOCs in
Wisconsin: 1) the Lower fax River and Lower
Green Bay, 2) the Menoainee River, 3) the
Milwaukee Harbor Estuary, and 4) the Loner
Sheboygan River and Harbor. Contaminated
sediments are a problem at all four sites.
RAPs for all four are being developed by
Wisconsin.
An initial draft has been prepared for
the Lower Fox River and Lower Green Bay.
The RAP for the Lower Green Bay/Lower Fox
River was signed by the Governor of
Wisconsin as an amendment to Wisconsin's
Water Quality Management Plan.
In 1985, the Lower Sheboygan River and
Harbor AOC was designated as a USEPA
Superfund site. A major source of PCi
contamination of fish and sediments has been
identified as a landfilled dike. The
contaminated soil from this dike was removed
under State orders.
The potentially responsible party for
the PCS contamination of the Lower Sheboygan
River and Harbor will conduct the Remedial
Investigation and Feasibility Study under
the guidance of USEPA and the UDNK.
Implementation is scheduled to begin in 1989
after completion of the feasibility study.
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DRAFT
ANNEX 15; AIRBORNE TOXIC SUBSTANCES
INTRODUCTION
Although early studies indicated that measurable levels of phosphorous were contributed
to the Great Lakes by air transport, giving rise in 1976 to the U.S. Environmental Protection
Agency's (USEPA's) Atmospheric Deposition Network, it has only been in the past decade that
atmospheric deposition has been recognized as a significant source of contaminants to the Lakes
and perhaps the only source of some toxic chemicals found in the Upper Great Lakes where their
presence is not attributable to either direct discharges or land runoff.
In 1981, the original Network mission was expanded from collecting data on airborne
phosphorus loadings to Lake Erie to monitoring the deposition of a variety of pollutants into all
the Great Lakes, Renamed the Great Lakes Atmospheric Deposition (GLAD) Network at this
time, the project envisioned 36 U.S. monitoring sites representing industrial, agricultural, and
urban sources of airborne contaminants around the Great Lakes.
The results of the GLAD Network and individual research projects in both the United
States and Canada confirmed the atmosphere as a chief pathway of certain toxic chemicals to the
Great Lakes. Recognizing the need for a fully coordinated, joint U.S. and Canadian program with
compatible sampling and analytical protocols, two major workshops of experts were convened to
assess the problem of atmospheric deposition and to assist in the design of an atmospheric research
and monitoring program.
The first workshop, held in 1985, was sponsored by the Great Lakes National Program
Office (GLNPO) and the University of Minnesota; the second, in 1986, by the International Joint
Commission (IJC). Shortly thereafter, the IJC Surveillance Work Group established the
Atmospheric Deposition Task Force to design a joint atmospheric research and monitoring network
and to develop necessary protocols.
In 1986, the Governors of the Great Lakes States signed a Toxics Substances Control
Agreement calling for cooperative action involving water discharge permits, accidental discharges,
monitoring and surveillance, information exchange, fish consumption advisories, and atmospheric
deposition.
Based upon an increased knowledge and concern about atmospheric deposition, provisions
for addressing airborne toxic pollution were added to the Great Lakes Water Quality Agreement
in 1987 (Annex 15). Annex 15 requires research, surveillance and monitoring, and implementation
of pollution control measures to reduce atmospheric deposition of toxic pollutants to the Great
Lakes Basin ecosystem. The Annex also requires the United States and Canada to report biennially
on progress in implementing the Annex. In response to this and to the amendments to the Clean
Water Act (CWA), the GLAD Network effort was expanded in FY 1988 to include sampling for
airborne toxic organics.
With regard to regulatory programs under the Clean Air Act (CAA), USEPA began
encouraging States to assess the scope and severity of air toxic exposures in 1986, USEPA's Air
Program has provided States with grants for compiling emission inventories for certain source
categories, investigating capabilities to model deposition patterns for toxic pollutants, and
developing permit review procedures that explicitly consider air toxic impacts on the Great Lakes.
State air programs have made considerable progress in reducing conventional pollutant
concentrations, especially of sulfur and nitrogen compounds. Attention has now turned to the
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control of air toxics. In FY 1988, USEPA Regions V and VII were allocated $980,000 to support
State air programs under CAA Section 105, focusing on the issue of toxic deposition. All eight
Great Lakes States are coordinating emissions inventory procedures for air toxics and jointly
developing permit guidelines to ensure that appropriate controls are placed on sources of air toxics.
There are currently 609 regulated facilities in the counties of the Great Lakes area that are in
compliance with all CAA requirements. Of the 26 facilities that are in violation, 7 are on
compliance schedules.
Also in 1988, USEPA published a decision to regulate municipal waste combusters (MWCs)
for dioxins, dibenzofurans, heavy metals, and other organics, such as polychlorinated biphenyls
(PCBs) under the authority of Section 111 of the CAA. The regulations will be based on the use
of best demonstrated technology considering cost and other impacts. USEPA has issued interim
operation guidance under the new source review requirements of the CAA that would effectively
require emission limits for new MWC permits, thus substantially reducing the toxic components
of MWC emissions. To control mercury emissions from other sources, USEPA has listed mercury
as a hazardous air pollutant under Section 112 and has regulated mercury ore processing plants,
chlor-alkali plants, and sewage sludge incinerators.
In addition to the GLAD Network and CAA regulatory programs, GLNPO coordinates
data-gathering projects to address atmospheric deposition through the developing Green Bay Mass
Balance Study and grant-funded urban toxic emissions inventories.
GREAT LAKES ATMOSPHERIC DEPOSITION NETWORK
The GLAD Network was originally established to determine atmospheric loadings of
conventional contaminants, evaluate annual trends, and assess the results of various program
strategies. In 1985, GLNPO enlisted the assistance of technical experts to evaluate the GLAD
Network. The group concluded that 1) the system was not adequate to provide data on airborne
loadings of trace organics, 2) sites were not located on the basis of USEPA siting criteria, 3) there
were potential problems in GLNPO's quality assurance/quality control program, and 4) there was
a lack of coordination between Canada and the United States.
To remedy these deficiencies, new objectives for the GLAD Network were adopted,
focusing on bioaccumulative pollutants found in Great Lakes fish. These pollutants include
metals, pesticides, polynuclear aromatic hydrocarbons, and PCBs. In addition, recommendations
were made to design a monitoring network that would combine deposition measurement and
modeling to assess atmospheric deposition.
In October of 1986, three of the International Joint Commission boards the Science
Advisory Board, the Great Lakes Water Quality Board, and the International Air Quality
Board hosted a major international workshop on the GLAD Network. The purpose of the
workshop was to reach a consensus among the participants on the nature of atmospheric loadings
of 14 specific toxic chemicals to the Great Lakes Basin. The workshop findings demonstrated,
first, the lack of knowledge on the atmospheric loadings of these chemicals, and second, the
relative significance of these loadings compared to other sources. The resulting report estimated
that 90 percent of the PCB loadings to Lake Superior are from the atmosphere. It also estimated
that Lakes Superior, Michigan, and Huron receive over 90 percent of their lead input from the
atmosphere. The report concluded with recommendations related to improving our ability to
measure and predict atmospheric loadings.
As a result of these activities, two research and monitoring plans have been developed to
address the deposition of air toxics to the Great Lakes. In 1987, GLNPO completed its proposed
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modification of the GLAD Network to include toxic organics. This plan calls for the
establishment of five master stations across the Great Lakes to support necessary research on
deposition and exchange processes, along with development of improved samplers. In addition,
12 routine GLAD Network stations are proposed, which will include sampling for toxic organics
using currently available sampling equipment. Each station is to be equipped with wet
precipitation collectors, high-volume samplers for collecting trace organics in the ambient air,
snow gauges, wet/dry automatic precipitation collectors, high-volume samplers for collecting total
suspended particulate and total organic carbon measurement, meteorological towers for collecting
routine data, and other equipment.
Under a joint grant to the Illinois State Water Survey and DePaul University, GLNPO
established the first master station and two routine stations on Green Bay in 1988 to begin
deployment of the planned Network and to support the ongoing Green Bay Mass Balance Study,
Each site is equipped with a 10-meter tower from which continuous measurements are taken on
wind speed and direction, temperature, relative humidity, rainfall, and solar radiation.
GLNPO plans to set up routine stations and initiate monitoring programs for Lakes Huron
and Erie in FY 1989. Master and routine stations for Lake Superior are scheduled for FY 1990,
and for Lake Ontario in 1991,
The Great Lake States will continue to participate with GLNPO in operating the monitoring
stations, and grants will be provided to universities for assistance with the stations and laboratory
support for chemical analysis. As required by the Water Quality Agreement, GLNPO will also
produce biennial reports on the implementation of this joint U.S. and Canadian air deposition'
network. Meanwhile, GLNPO continues to participate in planning discussions with Canadian and
U.S. experts to further refine plans for enhancing the GLAD Network to achieve compatibility
and concurrence with Canadian programs.
The second major research plan, completed by the IJC Atmospheric Deposition Task Force
in 1988, is a Plan for Assessing Atmospheric Deposition to the Great Lakes. The IJC Plan
submitted to the Water Quality Board with recommendation for inclusion in the Great Lakes
International Surveillance Plan, calls for two master stations to be established over a 2-year period,
followed by the phased establishment of routine stations as research results become available.
In December 1988, a committee was established to review the two plans, resolve remaining
differences, and recommend a joint U.S. and Canadian research and monitoring plan on
atmospheric deposition. The joint plan should be completed by June 1989, Currently, three ad
hoc committees of experts are detailing plans for quality assurance/quality control procedures,
analytical methods, sampler design, and siting criteria to be used in the deployment of the joint
network. \
GREEN BAY MASS BALANCE STUDY
Traditionally, water quality management focused on control of direct discharges of
pollutants to surface waters. Such point sources were the easiest to identify, characterize, and
control. In many cases, however, their control did not solve water quality problems. Recognizing
that pollutants are also introduced by contaminated air, soil, sediments, and ground water, the
management approach to Great Lakes water quality had to be reassessed. This reassessment led
to the initiation of a "mass balance" approach, in which the total contributions of pollutants from
all sources are estimated and analyzed.
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GLNPO, in conjunction with the Wisconsin Department of Natural Resources, the National
Oceanic and Atmospheric Administration, and EPA's Office of Research and Development is
conducting a mass balance pilot study for toxics in a mid-sized ecosystem, prior to expanding this
effort to whole-lake situations. In Green Bay (the chosen site for study), a modeling framework
is being developed and tested to provide greater understanding of the sources (including
atmospheric sources), transport, and fate of toxic substances and to ultimately guide and support
regulatory activity. The models will be capable of alerting managers to the presence of currently
unidentified pollutant sources, of describing the relative significance of the sources, and of
predicting the response of the ecosystem to proposed regulatory actions involving a single source
or a combination of sources.
AIR TOXICS EMISSION INVENTORIES
In FY 1988, GLNPO also began work to fulfill Annex 15 requirements to inventory toxic
emissions in the Great Lakes Basin. There are three major projects recently completed or ongoing
in the Great Lakes Basin that contribute to this effort. The first is the Air Toxic Emission
Inventory for Southeast Chicago, the first phase of which attempted to estimate the emissions rates
of a wide variety of inorganic and organic pollutants in a well-defined, highly industrialized
geographic area of the shores of Lake Michigan. In the second phase, mathematical modeling will
relate emissions rates to concentrations at ground level and the corresponding health risks to_
exposed humans.
The second project is the Emissions Inventory and Deposition Modeling of Air Toxics in
the Lake Michigan Region, now underway. Once air source data from the major metropolitan
areas are collected, USEPA will attempt to model deposition of toxic pollutants to the Lake
Michigan watershed and directly to the Lake to estimate total atmospheric deposition loadings from
near-field sources in the Lake Michigan airshed.
The third project, the Great Lakes Air Toxics Transboundary Project, focuses on sources
located in a 50-kilometer-wide corridor on either side of the shores of the Detroit River and
St. Clair River systems, including the Detroit/Windsor and Port Huron/Sarnia urban/industrial
centers. The project includes an emissions inventory, dispersion modeling, human risk assessment,
and deposition analysis of pollutants of concern in the watershed basin.
These projects involve the cooperation of GLNPO, the EPA Region V Air Program, and
local governments. Together, they should increase considerably USEPA's understanding of the
significance of air deposition to the water quality of the Great Lakes and their connecting
channels.
\
Future efforts in the area of atmospheric deposition of toxic materials include GLNPO's
plan to work with USEPA's Air Program to complete an emission inventory for air toxics to the
Great Lakes, and to support initiatives for State toxic programs and for monitoring results.
Ultimately, if regulatory or other controls are necessary to meet the goals of the Great Lakes
Water Quality Agreement, recommendations will be developed.
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ANNEX 16: POLLUTION FROM CONTAMINATED GROUND WATER
INTRODUCTION
Determining the magnitude, distribution, and impact of contaminated ground water of the
Great Lakes Basin is the subject of Annex 16 of the 1987 Great Lakes Water Quality Agreement
(GLWQA). In support of this overall goal, responsible State and Provincial environmental agencies
must first identify existing and potential sources of contaminated ground water to the Great Lakes.
To identify sources, each nation must map the regional hydrogeologic conditions in the vicinity
of significant contamination sources to determine the probable and potential extent of pollution,
Next, a standard approach and procedures for sampling and analysis of the contaminants in the
ground water must be developed. Implementation of standard sampling and analysis programs will
enable the Parties to quantify the extent of contamination and accurately estimate contaminant
loadings to the Great Lakes to support development of Remedial Action Plans and Lakewide
Management Plans. The Parties must report by December 31, 1988, and biennially thereafter, on
progress in controlling sources of groundwater contamination and preventing movement of polluted
ground water to the boundary waters of the Great Lakes.
In this first progress report, numerous U.S. agencies commented on activities conducted in
FY 1988 and, in some cases beyond this year, in support of the goals of Annex 16. Under Federal
statutory authorities such as the Comprehensive Environmental Response, Compensation, and
Liabilities Act (CERCLA), the Superfund Amendments and Reauthorization Act, the Resource
Conservation and Recovery Act (RCRA), the Hazardous and Solid Waste Amendments (HSWA),
and the Safe Drinking Water Act, or in conjunction with existing programs for monitoring and
protecting groundwater resources, these agencies have made advances in protecting the Great Lakes
from contaminated ground water.
Significant progress has been made toward controlling and remedying uncontrolled
hazardous waste sites and toward ensuring that active hazardous waste management facilities are
operated in accordance with Federal and State regulations. States are developing proposals for
wellhead protection grants and have begun conducting pilot projects to demonstrate protection
strategies. Much has also been accomplished in researching the significance and effects of
groundwater contributions to Great Lakes contamination. The major activities and
accomplishments in these areas are discussed in this section.
U.S. ENVIRONMENTAL PROTECTION AGENCY ACTIVITIES
Groundwater Protection Strategies
In 1984, the U.S. Environmental Protection Agency (USEPA) initiated a National
Groundwater Protection Strategy. This strategy consisted of four principal elements:
* Strengthening the capacity of State governments to protect groundwater quality
* Addressing groundwater contamination sources of particular national concern
Establishing a groundwater classification system to guide USEPA policies
Coordinating the development and implementation of groundwater protection policies
at the Federal, Regional, and State levels.
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Since 1984, various States, including those in the Great Lakes Basin, have developed their own
State groundwater protection strategies that are tailored to their existing regulatory programs and
that focus on their specific groundwater quality issues. USEPA Regional strategies have been
developed to promote and assist the States in implementing their strategies and to bridge the gap
between the broadly focused national strategy and the very specific State strategies.
The Region V Grouhdwater Strategy, adopted in May of 1988, was developed as a vehicle
for unifying groundwater initiatives underway in the Region. The Strategy highlights those
groundwater objectives that require more than a single contaminant source perspective, and
provides a proactive method for achieving objectives given the legislative and fiscal constraints
of individual programs. The Strategy has three principal parts: a set of groundwater goals, a set
of Regional groundwater objectives and general implementation steps necessary to attain those
objectives, and a process for conducting an annual review of Strategy-related activities.
Geographic Information Systems (GIS) will be an important tool for implementation of the
Strategy. During FY 1989, Region V will form a work group to begin developing a GIS for the
Region with capabilities applicable to implementing Remedial Action Plans (RAPs) in Areas of
Concern (AOCs), managing wellhead protection areas, monitoring and evaluating, area-wide use
of agricultural chemicals, and assessing wetlands and other surface waters affected by groundwater
contamination.
The Great Lakes National Program Office
The Great Lakes National Program Office (GLNPO) dedicated resources this year to the
development of strategies to accomplish each of the goals of Annex 16 and charted a 5-year
strategy to ensure completion of these goals. Recognizing that groundwater research strategies are
always evolving in this relatively early stage of study, GLNPO committed substantial resources
to train staff in using GIS to fulfill the Annex 16 requirement to inventory and map
hydrogeological conditions of the Great Lakes. In conjunction with this technical training, the
Office is planning strategies to identify existing and potential groundwater contamination sources.
GLNPO staff will assume an important role in establishing a Regional GIS for Region V under
the Region's Groundwater Strategy.
In addition, GLNPO submitted a series of proposals for site-specific exploration. GLNPO
will participate in a study in the Ashtabula, Ohio, area to characterize pollutant sources and
exposure pathways by implementing the Multimedia Environmental Assessment Tracking System
(MEATS) in conjunction with a standard GIS. The MEATS monitors environmental data in a
regulatory context and will enable GLNPO to generate reports on compliance schedules and other
regulatory requirements for industries discharging pollutants in the Great Lakes Basin.
GLNPO has outlined several goals for the Ashtabula project. The project will offer
program staff the opportunity to gain expertise in GIS map production techniques and encourage
the development of standard GIS applications, programs, and models for environmental assessments
in a geographic setting. The project will also identify cross-media issues and areas where
regulatory actions are necessary. Finally, the Ashtabula project will increase coordination among
regulatory programs and subsequently integrate planning efforts within existing regulatory and
organizational frameworks.
A second site-specific project with a significant groundwater component, the Green Bay
Mass Balance, will include compiling a comprehensive inventory of known and potential sources
of groundwater contamination in the Green Bay Basin. By using geophysical/hydrological
techniques to determine the groundwater flux on a continuous basis, GLNPO will identify the
sources, pathways, and fate of key indicator toxic chemicals into and through the Green Bay. In
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addition, staff will analyze data derived from groundwater discharge maps to define priority
groundwater areas. These activities will further the goal of improving permitting and enforcement
decisions for waste sites by compiling maps to reflect hydrogeological information and
contamination sources.
To support the Green Bay Mass Balance and other important initiatives related to the
GLWQA, GLNPO has and continues to support important research initiatives related to the
significance of groundwater contamination for Great Lakes water quality. For example, the Office
is presently funding a grant to the University of Wisconsin for research on groundwater intrusion
monitoring techniques. The results of this research will have important implications for the Green
Bay project. The Green Bay Mass Balance study plan includes a number of initiatives related to
estimating and measuring rates of groundwater intrusion; work in this area is expected to continue.
GLNPO is also funding groundwater research to assist with RAPs. Presently, GLNPO is
providing funds to the State of Indiana for development of a RAP in the Grand Calumet River
AOC, where contaminated ground water may be an important source of toxic pollutants. At the
Grand Calumet site, the State and the U.S. Geological Survey (USGS) are collaborating on a
project to describe the hydrogeologic characteristics underlying the region. This effort will allow
scientists to predict how contaminants from the heavily industrialized region migrate from the site
and whether they are an important source of toxic pollution to the Indiana Harbor.
In FY 1989, GLNPO continues to work with the Region V program divisions to assemble
and map the inventory of known and potential sources of groundwater contamination in the Great
Lakes Basin. During FY 1989, GLNPO will also develop pilot GIS projects for wetlands in the:
Great Lakes Basin, the Green Bay Mass Balance Study, and the Ashtabula RAP.
USEPA has made considerable progress during FY 1988 toward addressing groundwater
contamination in the Great Lakes Basin. In support of Annex 16, paragraph (iv), the Agency's
hazardous waste programs implemented under RCRA and under CERCLA have continued to
address both active and inactive hazardous waste sites, one of the principal sources of contaminated
groundwater in the Great Lakes Basin and throughout the United States. Additionally, USEPA
is now implementing a Wellhead Protection Program, as mandated by the 1986 amendments to the
Safe Drinking Water Act, and Groundwater Protection Strategies are being developed and
implemented at the USEPA Regional level and within the Great Lakes States:
Under RCRA, USEPA and the States have continued to issue permits for active hazardous
waste treatment, storage, and disposal facilities in the Basin, and have begun to implement the
corrective action program mandated by the 1984 amendments to RCRA. This program will ensure
that all existing environmental contamination at active facilities is remedied as a condition of State
or Federal permits. In addition, during FY 1988, USEPA began promulgating regulations that
restrict certain hazardous waste from land disposal. This program, together with minimum
technology standards for land fills and surface impoundments, which became effective this year,
provide considerable protection against future groundwater contamination caused by placement of
hazardous waste on the land. Also in FY 1988, EPA began reviewing its present guidelines for
municipal and industrial solid waste disposal facilities. The Agency is now embarking on an effort
to develop and promulgate more stringent guidelines for these facilities.
Under CERCLA, USEPA regional programs and State environmental agencies have
continued to identify, characterize, and address abandoned hazardous materials durnpsites in the
Great Lakes Basin. In addition, States have taken initiatives to address their own priorities for
cleanup.
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Specific accomplishments by USEPA regional programs and GLNPO in these and other
areas are presented in the following discussion.
Regional RCRA Programs
In USEPA's Region V (comprising six of the eight Great Lakes States), there are nearly
1,000 companies that treat, store, or dispose of hazardous waste. In FY 1987, Region V and the
States inspected more than 1,700 facilities and initiated more than 1,000 enforcement actions in
response to violations. During FY 1988, Region V and the States continued to issue operating
permits to active hazardous waste management facilities and to conduct an aggressive enforcement
and compliance monitoring program. Future activities in the Region and at the State level will
focus increasingly on the problems of solid waste disposal and leaking underground storage tanks.
USEPA's Region II and Region III offices, together with the States of New York and
Pennsylvania, have made similar progress toward implementing Great Lakes groundwater protection
programs under RCRA and RCRAs Hazardous and Solid Waste Amendments (HSWA). USEPA
estimates that nearly 26,000 RCRA permittees and permit applicants are located within the
counties of the Great Lakes Basin. New program provisions implemented under HSWA will ensure
that these facilities are fully evaluated and that all existing contamination is remedied as part of
the permit issuance process.
Regional CERCLA Programs
Similar progress has been made to address uncontrolled hazardous waste sites in the Great
Lakes Basin. By 1988, USEPA's Region V had identified over 5,300 sites within its jurisdiction.
Presently, there are 228 Region V sites on the National Priorities List (NPL), more than any other
area of the country. As of the end of September, 1988, Region V had completed preliminary
assessments at 4,730 sites and site inspections at 1,310 sites.
The Region conducts both long-term cleanup actions and emergency removal actions under
CERCLA. In FY 1987, Region V completed 8 removal actions at sites not listed on the NPL and
24 at sites listed on the NPL. Long-term cleanups have begun at nearly 150 sites within Region
V. These actions may be conducted by the Region or under Consent Decree with the responsible
parties.
USEPA Regions II and III operate similar programs for cleanup of uncontrolled hazardous
waste sites that affect potential sources of groundwater contamination in the Great Lakes Basin.
In addition to the Federal programs, the States of Michigan, New York, Ohio, and Minnesota have
created their own State Superfunds to address sites that are not eligible for the Federal NPL, but
are important State cleanup priorities.
U.S. GEOLOGICAL SURVEY ACTIVITIES IN THE GREAT LAKES BASIN
The USGS recently completed a 2-year study in cooperation with Canada on environmental
conditions in the Upper Great Lakes Connecting Channels (UGLCC). This study includes a
groundwater component and is part of an effort to study water quality problems on a regional
basis within the Great Lakes Basin. A similar study was completed several years ago on the
Niagara River in conjunction with the State of New York. Both of these studies involved
characterizing the significance of nonpoint sources of pollution, including pollution from
contaminated ground water.
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The objective of the groundwater component of the USGS study was to determine
groundwater loadings into the UGLCC, In its preliminary administrative report, USGS
recommends greatly increasing extensive investigation into groundwater conditions in the Detroit
area. The development of a flow model would facilitate collection of water quality information.
The USGS made a preliminary finding that the deep injection of billions of gallons of hazardous
waste on the Canadian side of the connecting channels is causing brines to flow into U.S. wells.
The USGS has recommended that the Port Huron and St. Clair River areas in Michigan be
investigated further. The USGS has submitted a request to USEPA Region V for additional
funding to continue research efforts on groundwater contamination in the UGLCC.
WELLHEAD PROTECTION ACTIVITIES
State Wellhead Protection Programs are required by the Safe Drinking Water Act
Amendments (SDWA) of 1986. Wellhead protection programs contribute to efforts to identify
existing or potential sources of contaminated ground water. All Region V States are preparing
grant proposals to USEPA to obtain funding for wellhead protection program development
activities. The submittal date for grant proposals is June 19, 1992.
The State of Illinois has developed the most sophisticated wellhead protection strategy of
all the Great Lakes States thus far. The State Legislature recently passed the Illinois Ground Water
Protection Act that requires the establishment of setback zones around public water supply wells.
These zones are to be established according to a specified schedule and consistent with the
particular hydrogeological conditions of each area. The Act also places restrictions on land use
in relation to wellhead areas,
The States of Minnesota, Wisconsin, Indiana, and Ohio have also initiated some preliminary
wellhead protection projects. Pilot protection programs are underway in Minnesota and Wisconsin.
The State of Indiana has funded a program for development activities on site-specific wellhead
protection projects, and the State of Ohio has commenced a project to identify methods for
delineating critical groundwater regions in the State.
The State of Michigan has delegated authority for wellhead protection programs to both
the Michigan Department of Natural Resources and the State Department of Public Health. These
agencies will collaborate to develop a wellhead protection program in the future. A task force
will work during FY 1989 to generate consensus regarding the State's wellhead protection program.
Michigan also has an extensive groundwater contamination site inventory and has initiated a
number of groundwater cleanup activities under the State's Water Resources Commission Act of
1929 and the State Superfund Program.
In Region II, New York State has committed to submitting a wellhead protection strategy
for the June 19, 1989, deadline as required by SDWA. This proposal must only explain the State's
approach to devising its strategy, including the option to phase-in various programs currently
under review as potential components of the overall program.
Regardless of the program strategy, New York has decided to use existing regulations and
to increase enforcement capabilities. Details on the specific strategy to delineate wellhead areas
are yet to be finalized, however, current thinking favors the "fixed radius approach." The State
will also address the importance of land use issues with respect to groundwater protection
programs. As land use remains a local issue, New York recognizes that a major part of the
strategy will focus on involving local authorities in program development.
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In some areas of New York, wellhead protection activities are already underway, funded
by the Clean Water Act, Section 205(j). For example, Suffolk County's water supplier is initiating
a wellhead protection program on its own, and EPA Region II is encouraging county officials to
participate. If this program is successful, it may be extended to Nassau County. The program
uses existing regulations and strengthens enforcement provisions. Officials are also distributing
educational materials to the public, conducting audits, and establishing inventories of industrial
facilities. In addition, Section 205(j) money has been allocated to three local planning agencies
in upstate New York for mapping sources of contamination.
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SPECIAL REPORT TO THE INTERNATIONAL JOINT COMMISSION
ON POINT SOURCE CONTROLS
INTRODUCTION
Much progress has been made in controlling point sources to the Great Lakes system.
Direct discharges to the Great Lakes system in the United States are regulated by nearly 3,675
discharge permits for industry and municipal sewage treatment facilities, issued as part of the
National Pollutant Discharge Elimination System (NPDES) under Section 402 of the Clean Water
Act (CWA). Through 1986, $7.9 billion in Federal and State grants had been invested in the Great
Lakes Basin for municipal sewage treatment works. In 1985, more than 95 percent of the
population in the Great Lakes States of the U.S. Environmental Protection Agency's (EPA's)
Region V (Illinois, Indiana, Michigan, Minnesota, Ohio, and Wisconsin) was served by municipal
sewage treatment facilities and 99 percent of the sanitary wastes in sewered areas received at least
secondary treatment.
Among the most significant achievements to date in the Great Lakes regarding point source
controls is the reduction of phosphorus discharges from point sources. Special treatment for
phosphorus removal was provided for 79 percent of all sewage handled in sewered areas during
1985, and 163 of 187 major municipal sewage treatment facilities complied with the 1 milligram
per liter (1 mg/1) effluent limit for phosphorus set by the Great Lakes Water Quality Agreement
(GLWQA). Advanced waste water treatment was provided in 1985 by 15 percent of all treatment:
facilities, and 8 percent provided high-level nitrogen control. The most recent data on phosphorus
discharges from point sources show that since 1972, the United States has achieved a reduction of
phosphorus of approximately 80 percent.
In other areas, the commitment to identify Point Source Impact Zones and reduce their size
and effect is also an important aspect of attaining the GLWQA objectives. The first report on
Point Source Impact Zones is due September 30, 1989. USEPA is currently working with the
Great Lakes States to establish consistent definitions and methods of reporting.
Although the GLWQA does not expressly call for a report on point sources, the United
States considers it important to report on activities and progress regarding two point source areas:
activities related to controlling stormwater impacts from both separate and combined sewers and
efforts directed at controlling toxic chemicals from point sources. These efforts include
implementation of Section 304(1) of the CWA and State water quality-based control programs such
as Michigan's Rule 1057.
THE NATIONAL COMBINED SEWIR OVERFLOW STRATEGY
USEPA is leading efforts to develop a national permitting strategy to control the impact
of some 15,000 to 20,000 combined sewer overflows (CSOs) nationwide on human health and water
quality. The strategy now proposed in Region V is intended to complement control programs for
sanitary sewers and separate storm sewers by fashioning CSO permits on technology- and water
quality-based standards.
Because CSOs are considered point sources, they must meet the permit requirements of the
NPDES. Thus, technology-based permit limits must be established for Best Practicable Control
Technology (BPT) currently available, Best Conventional Pollutant Control Technology (BCT), and
Best Available Technology (BAT) economically achievable based on best professional judgment.
The 1987 amendments to the CWA mandate compliance with BCT/BAT on or before March 31,
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1989. Similarly, CSO permit requirements must be consistent with State water quality standards
and, in some cases, with the control requirements of Section 304(1) of the CWA.
In the process of writing new permits for CSOs, Regions and States must conduct
system-wide evaluations and set priorities by estimating such factors as flow, frequency, duration,
and pollutant loadings to rank publicly-owned treatment works (POTWs) collection systems and
CSO discharge points. The permits must contain compliance dates as listed in Section 301 and
Section 304 of the CWA for those CSOs discharging toxic substances. Permits must allow for
monitoring of CSOs to determine whether facility modifications or system improvements are
necessary and to ensure that best management practices are used at a particular facility.
Other control measures that should be explored by municipalities for controlling discharges
from CSOs are improved operation and maintenance, a system-wide stormwater management
program, pretreatment program modifications, pollutant-specific limitations, compliance schedules,
flow minimization and hydraulic improvements, sewer ordinances, identification and elimination
of illegal discharges, local limits program modifications, and construction of CSO controls within
the sewer system and/or new and modified wastewater treatment facilities.
STORM WATER PERMITTING IN THE ROUGE RIVER
USEPA regards storm water as a point source to the extent that it is discharged through
industrial and municipal storm drains. Under the 1987 amendments to the CWA, industries
discharging storm water must apply for a permit and must equip storm drains with BAT or BCT.
Municipalities serving more than 250,000 people must decrease discharges from storm drains to
the maximum extent possible. While the other sized communities are also affected, permitting
requirements are phased with largest communities first to comply. Regulations on issuing storm-
water permits as required by these provisions are expected in 1989.
Michigan's Rouge River Basin is an example of a recognized Area of Concern that could
benefit from more restrictive stormwater permitting requirements. The amendments to the CWA
gave the USEPA firm statutory authority to require permits for storm drains discharging to the
Rouge River, whereas regulations concerning such discharges prior to these amendments were
not specific as to the authority governing stormwater runoff. The Michigan Department of
Natural Resources (DNR) estimates that pollutant loadings to the Rouge River from point and
nonpoint source discharges were 473 million pounds in 1987, Although CSO and stormwater
runoff represent less than half of this amount, such discharges are most likely to impair water
quality. Stormwater runoff alone accounts for two-thirds of the lead discharged to the Rouge
River, as well as conventional and nonconventional pollutants.
State officials are currently identifying all industrial and municipal storm drains that
discharge pollutants to the Rouge River. So far, 273 have been identified that need permits, but
officials suspect that there are many more that must be regulated and monitored. Industrial permit
applicants are required to submit maps of onsite drainage, management practices and control
measures, and test data on various pollutants and other discharges. Municipal permit applicants
must provide information on dischargers including source, amount, and type of discharge,
USEPA and Michigan DNR issued a draft remedial action plan in June 1988 for the Rouge
River Basin and recommended a series of actions to address the pollution problems associated with
discharges from storm drains including eliminating illegal connections to storm drains, issuing
permit for stormwater discharge in 1990, reviewing and updating local stormwater management
programs, and when necessary, building retention basins to reduce discharges to the river. This
prototype plan will serve as a model for similar efforts in the Great Lakes Basin.
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STORMWATER REPORT TO CONGRESS
USEPA is required by the amendments to the CWA to submit two reports to Congress to
identify stormwater discharge sources, determine the nature and extent of pollution from those
identified, and establish procedures and methods to control such discharges, USEPA must
promulgate regulations by February 1989, establishing application requirements for industrial and
stormwater systems serving cities with populations over 250,000. USEPA must also promulgate
regulations by February 1991, establishing application requirements for systems that serve cities
with populations ranging from 100,000 to 250,000. In addition, smaller cities, other jurisdictions,
and commercial point sources will be studied to assess stormwater discharge status.
The reports to Congress will discuss the regulatory and environmental background of the
stormwater program with regard to the NPDES, CSO, nonpoint source strategies, and State and
local programs. In addition, USEPA will identify moratorium sources for stormwater discharges.
SECTION 304(1) OF THE CLEAN WATER ACT
The CWA, as amended, provides an accelerated timetable within which USEPA and the
States are required to assess and target impaired surface waters for remediation and abatement
programs. Section 304(1) imposes important new statutory requirements on the ongoing national
program for pollutant control by requiring States to identify waters that are not expected to meet
water quality standards after dischargers have met current cleanup requirements. Section 304(1)
requires increased activity in addressing known water quality problems by requiring States to
develop lists of impaired waters, identify point sources and the quantity of pollutants they
discharge that cause adverse impacts, and develop individual control strategies for each such point
source,
Regions and States were to have submitted preliminary lists of impaired waters to USEPA
by April 1, 1988, so that the lists could be revised and expanded by the statutory deadline of
February 1989. USEPA's Water (Management) Divisions in Regions II, III* and V (along with the
Environmental Sciences Division in Region V) are now reviewing lists submitted by the Great
Lakes States. Individual control strategies must be designed to reduce discharges to listed waters
and bring water quality into compliance through final, enforceable NPDES permits and water
quality standards by the statutory deadline of June 1992.
Other statutory provisions of the CWA require States to further data collection under
existing programs to curb pollution from non-conventional pollutants (including ammonia and
chlorine). In response to this mandate, the States (with the exception of Minnesota) have
developed their own Clean Water Strategies to help provide new frameworks for monitoring
programs, problem assessments, and controls. Such programs ensure that waters not listed under
Section 304(1), but polluted from any type of contaminant, have water quality-based permits so
that permitting priorities are based on degree, not cause, of pollution.
USEPA will assist States in routinely updating and refining procedures for implementing
point and nonpoint source controls by publishing criteria and advisories on additional pollutants
of concern (in addition to the CWA Section 307(a) toxic pollutants); providing supplemental
guidance on improved biological monitoring, assessment, and evaluation techniques for complex
point and nonpoint source discharges; publishing national technical guidance on sampling,
modeling, and procedures for calculating total maximum daily loads and waste load allocations;
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and developing risk assessment/risk management procedures to define program priorities for the
national program for toxics control.
IMPLEMENTING WATER QUALITY-BASED POINT SOURCE EFFLUENT LIMITATIONS FOR
TOXIC SUBSTANCES
To fully implement Section 304(1), each State must promulgate enforceable numerical water
quality standards to complement existing narrative water quality standards. Numerical WQS are
enforceable without negotiation. Narrative water quality standards are flexible, providing the State
with an opportunity to update criteria to reflect the current data base and allow permittees to
assess the applicability of numerical criteria to facility- and site-specific circumstances. Once
standards have been promulgated, point source effluent quality is regulated by numerical effluent
limitations of individual chemical constituents and whole effluent toxicity limitations.
New York has adopted numerical WQS while Michigan has adopted narrative WQS. New
York was immediately sued by the private sector upon promulgation of its WQS, but prevailed in
court. Michigan has not been sued nor has Michigan had to sue to enforce its authority to impose
water quality-based effluent limitation calculated according to Rule 1057 in its NPDES permits.
Ohio, Wisconsin, and Minnesota have adopted or are in the process of adopting an approach similar
to Rule 1057. During its triennial review of its WQS, Michigan is now contemplating revisions
to Rule 1057 to allow it to derive enforceable numerical ambient WQC as required by the 1987
amendments to the CWA.
The most controversial portion of Rule 1057 has been its regulation of carcinogens. For
those substances causing cancer in laboratory animals, humans, or both, Rule 1057 provides that
exposure to humans resulting from body contact, recreation, and fisJi consumption shall not result
in a cancer risk exceeding one-in-one hundred thousand (10~5)for a 70 kg adult exposed
continuously for a 70-year lifetime. Michigan is the first state to propose an acceptable cancer
risk threshold for its surface waters. New York has adopted a 10~Tlesign acceptable cancer risk
in deriving its numerical WQS for carcinogens (other than those for which Federal Drug
Administration action levels have been promulgated). Both Michigan and New York calculate risk
on a chemical-by-chemical basis, while USEPA recommends adding the cancer risks of individual
carcinogens to estimate the aggregate risk. Minnesota has adopted USEPA's approach.
PRETREATMENT
Authorized by Section 307 of the CWA, the National Pretreatment Program is designed to
regulate non-domestic wastewater contributions to POTWs. The General Pretreatment Regulations
(40 CFR 403) promulgated on June 26, 1978, established the administrative framework for the
program and identified the roles and responsibilities necessary to achieve the CWA goals.
Since 1978, the General Pretreatment Regulations have been the focus of numerous legal
challenges and amendments. The amendments have expanded and clarified the requirements
included in the regulation. Most recently the regulations were amended on October 17, 1988, to
incorporate changes recommended by the Pretreatment Implementation Review Task Force.
Concurrent with USEPA efforts to develop the General Pretreatment Regulations, the
Agency has worked toward the full promulgation of National Categorical Pretreatment Standards.
These standards establish technology-based control for specific industrial categories known to
discharge significant pollutant quantities to POTWs. In addition to these Federal standards and
requirements, POTWs are expected to develop more stringent or supplemental "local limits" as
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necessary to ensure the integrity of the POTW treatment works and its sludge disposal practices,
with NPDES-approved States exercising program oversight as "Approval Authorities," The local
POTW programs act as "Control Authorities" in imposing Federal, State, and local standards and
requirements on their contributing industries.
In the Great Lakes States, a total of 476 POTWs are subject to these pretreatment
requirements. (Of this total, 222 POTWs have effluent flows greater than 5 million gallons per
day.) The program approval rate within the Great Lakes States has been better than the national
average. There are 33 approved pretreatment control authorities in New York State counties
containing areas that drain into the Great Lakes area. A total of 466 facilities, or 97.9 percent
of those POTWs subject to the new requirements received program approval by September 30,
1988.
Efforts are currently underway to delegate administration of the CWA Pretreatment
Program to the States. As of September 30, 1988, four Great Lakes States have received approval
for State Administration, and three other States have been active in Pretreatment Program
Implementation, although program administration has not yet been officially delegated.
(Nationwide, 25 of the 39 NPDES States and territories had received delegation of the Pretreatment
Program.)
NATIONAL MUNICIPAL POLICY
The CWA required that by July 1, 1988, POTWs meet NPDES permit effluent limits based
on secondary treatment or any more stringent limit necessary to meet water quality standards.
Because of historic problems with municipal compliance, the Agency developed the National
Municipal Policy (NMP) in January 1984, which places renewed emphasis on improving municipal
compliance rates in order to protect the Nation's water quality. NMP establishes enforcement
priorities for facilities that are unlikely to meet the July 1, 1988 deadline.
As of July 27, 1988, 87 percent of Region V's major POTWs have met the requirements
of the NMP. Ninety percent of the Region's minor facilities are also in compliance, compared to
77 percent prior to NMP enactment. As a result, 95 percent of the total sewage processed in the
United States receives at least secondary treatment. Voluntary compliance and Federal and State
enforcement are responsible for achieving the compliance record. Of the 13 percent of POTWs that
did not achieve compliance, most are on enforceable timetables leading to compliance or litigation.
USEPA Region V or the States have court actions pending against 62 large cities that have failed
to meet the NMP and have placed 29 city plants on court-ordered compliance schedules. Figure
5-3 provides a summary of progress in meeting the NMP goals.
DEMONSTRATION PROJECTS
Demonstration projects for addressing point sources of pollution on the Great Lakes have
concentrated on controlling conventional pollutants and reducing eutrophication. The Great Lakes
National Program Office (GLNPO) has participated in evaluating and demonstrating techniques for
phosphorus uptake from sewage, anaerobic oxidation phosphorus removal techniques, and in-line
storm flow control devices. Each of these has shown potential for reducing discharges of
phosphorus and other pollutants to the Lakes at a lower cost.
In future years, Great Lakes programs for point sources will focus on controlling discharges
of toxic pollutants. During the next 2 years, several important new programs for controlling point
source discharges of toxic pollutants will be developed and implemented under the CWA, including
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programs under Section 304(1), discussed earlier. In FY 1989, GLNPO will begin developing a
process for addressing Point Source Impact Zones in the Great Lakes, as required by the GLWQA,
and will continue to work toward development of Lakewide Management Plans. These programs
will require new or improved biological and chemical monitoring techniques and new regulatory
approaches that will be the subjects of future Great Lakes demonstration projects.
MONITORING DATA FOR TOXIC LOADINGS FROM POINT SOURCES
Existing information on toxic pollutants of concern in wastewater discharges within the
Great Lakes system is still too scant for accurate estimates of point source load contributions to
each of the Great Lakes. Some permits require routine toxicity testing of effluents, involving tests
such as bioassays. While these tests are carried out by the permittee, results are shared with State
and Federal agencies. Surveys to assess compliance with permit limitations are also conducted by
regulatory agencies.
Permittee self-monitoring data are stored in a computer information system known as the
Permit Compliance System. The results of Federal or State agency compliance inspection
monitoring and select self-monitoring data are also contained in STORET, USEPA's general water,
sediment, and biota quality data base. Permittee and agency whole effluent toxicity test results-
are summarized in the CETIS data base.
To analyze the contributions of persistent toxic pollutants by point sources, GLNPO has
supported the development of a national data base of monitoring data from Form 2c NPDES
permit applications. In addition, USEPA Region V and GLNPO have supported the Michigan
DNR with a 205(j) grant to update and expand its Critical Materials Register, a list of toxic
substances meriting State surveillance. Each year, Michigan facilities are required to report the
production or use, discharge, and disposal* in solid residuals of Critical Materials. These data are
compiled in a computer data base developed under a Toxic Substances Control Act grant to
Michigan from USEPA. Total loadings of Great Lakes pollutants of concern can be compiled on
an individual facility, river, or lakewide basis. GLNPO is using these loading estimates as part
of a larger effort to calculate total loadings of persistent toxicants to the Great Lakes from all
sources.
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RAP COORDINATOR PHONE NUMBERS
AOC
Ashtabula River, OH
Black River, OH
Clinton River, MI
Cuyahoga River, OH
Deer Lake/Carp River, OH
Detroit River, MI/ONT
Fox River/Green Bay, WI
Grand Calumet/IN Harbor
Kalamazoo River, MI
Manistique River, MI
Maumee River, OH
Menominee River, WI/MI
Milwaukee Estuary, WI
Muskegon Lake, MI
River Raisin, MI
Rouge River, MI
Saginaw River/Bay, MI
Sheboygan Harbor, WI
St. Clair River, MI/ONT
St. Louis, River, MI/ONT
St. Mary's River, MI/ONT
Torch Lake, MI
Waukegan Harbor, IL
White Lake, MI
USEPA-COORD.
Jennifer Wolf
Tom Murphy
Mark Moloney 8-
Marcia Damato
Kelly Moore
Robert Tolpa
Terry Bonace
Dan Lawson
Cathy Allen
Wayne Davis
Peter Swenson
Mardi Klevs
Bonnie Eleder
Bill Melville
Al Fenedick
Dave Pfeifer
Phone #
6-6873
6-6874
-942-7260
6-6297
3-1869
3-2110
6-6219
6-3017
6-0136
6-6233
6-0236
6-6195
6-4885
6-1504
6-6872
3-9024
Janet Causey 3-8999
State Coord. Phone #
Julie Letterhos 614/644-2866
Julie Letterhos 614/644-2866
Brenda Sayles 517/335-4198*
Robert Wysenski 216/425-9171
Elwin Evans 517/335-4182*
Susan Benzie 517/335-4193*
Victoria Harris 414/492-5904
317/232-8602
William Creal 517/335-4193*
Bill Taft 517/335-4205*
Pat Bulzan 614/644-2865
Terry Lohr 608/267-2375
Dan Kaemmerer 414/263-8712
John Wuycheck 517/335-4195*
Scott Cornelius 517/335-4200*
Jim Bredin 517/335-4140*
Greg Goudy 517/335-3310*
Al Stenstrup 414/263-8586
Diana Klemens 517/373-2758*
Brian Fredrickson 218/723-4663
Diana Klemens 517/373-2758*
Elwin Evans 517/335-4182*
Jim Park 217/782-1654
John Wuycheck 517/335-4195*
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