&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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WUJKEGAM HAMOK
            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.
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         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  areas—Flint, 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.
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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.
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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


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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.


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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.
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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.
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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
*

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          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


                                            24

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                                                                            DRAFT


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.
                                            25

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                                                                            DRAFT


         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


                                            26

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                                                                             DRAFT


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.
                                             27

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                                                                            DRAFT


                       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.
                                            28

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                                                                            DRAFT


                  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


                                            29

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                                                                              DRAFT


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


                                             30

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                                                                              DRAFT


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
                                             31

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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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       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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       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.
                                            52

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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.
                                            53

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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


                                           55

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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.
                                            56

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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
                                            61

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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.
                                           62

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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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                                                                             DRAFT


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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