Great Lakes Report to Congress 1994

REPORT TO CONGRESS ON THE GREAT LAKES ECOSYSTEM

Chapter 3
The Great Lakes Program: A Holistic Ecosystem Approach

This chapter presents the holistic approach to ecosystem protection that EPA has launched to address Great Lakes environmental problems. Under this approach, the Agency began to develop a joint five year strategy among the different agencies involved in protection of the Lakes, rank ecological and human health risks facing the region, promote pollution prevention as the preferred means to reduce risks from contaminants, target priority geographic areas, meet local needs with a blend of solutions from across the range of environmental programs, enforce environmental laws in a comprehensive, integrated manner, encourage public participation, and evaluate progress using ecological indicators. In all these elements, the Agency is taking advantage of every opportunity for cooperative actions with States, partner Federal agencies and Canada.

EPA has successfully used many individual elements of this approach in the past. The fundamental changes now being pioneered for the Great Lakes ale to promote innovative pollution prevention measures, enforce environmental laws in a comprehensive way while focusing on targeted geographic areas, harness local community participation in the remedial planning process, and integrate the Agency's programs around the ecosystem, setting goals on the basis of environmental needs and measuring progress with ecological yardsticks.

This innovative approach is consistent with, and enhances implementation of, the Great Lakes Water Quality Agreement between the United States and Canada. Under this Agreement, the two nations have dedicated themselves to restoring and maintaining the chemical, physical, and biological integrity of the Great Lakes ecosystem by virtually eliminating releases of bioaccumulative toxic substances to the Lakes. EPA's new ways of doing business are aimed at fuller achievement of the Agreement.

A Shared Strategy

In 1991, EPA joined States and Federal agencies that have stewardship responsibilities for the Lakes in developing a shared five year strategy that started in 1992. In addition to the eight Great Lakes States, partners to the plan include the Army Corps of Engineers, the Coast Guard, the Fish and Wildlife Service, the National Oceanic and Atmospheric Administration, and the Soil Conservation Service. The strategy joins environmental protection agencies with natural resource agencies in pursuit of common goals. These partners envision updates that will keep the strategy a current, action-forcing document that targets different problems in succession.

The ultimate purpose of the strategy is that of the Great Lakes Water Quality Agreement--to restore and maintain the chemical, physical, and biological integrity of the Great Lakes ecosystem. To realize this purpose, the strategy has three long-term goals:

1. Reduce Toxic Loadings: Prevent and reduce releases of toxic pollutants and remedy past contamination with an emphasis on bioaccumulative pollutants

2. Protect and Restore Habitat: Protect and restore wetland, land, and aquatic habitats vital for healthy communities of plants and animals, emphasizing the habitat needs of threaten species

3. Protect the Health of Human Residents and the Ecosystem's Living Resources: Protect the health of human residents of the region from pathogens and protect the abundance and biological diversity of its plant and animal communities.

The strategy relies on pollution prevention as the preferred means to reduce releases of toxic substances. While the partners to the strategy recognize that full attainment of its goals is a long- term proposition, the strategy spells-out numerous practical steps to make progress toward these goals. The partners envision that their ultimate attainment will provide an ecosystem in which fish are safe for human consumption in unlimited quantities and there are thriving populations of vulnerable species, such as bald eagle and lake trout.

Identification of Priority Problems

During 1991, EPA conducted a comparative, risk-based characterization of human health and ecological hazards facing the Great Lakes region. The study looked at evidence on 23 different problems. It helped EPA and its partners identify priority problems and the best opportunities for making environmental progress. Among its findings, the comparative risk study concluded that the the Greatest ecological risks are the following:

• Bioaccumulative toxic substances that cause health problems for fish and wildlife
  
• Bottom sediments that harbor such contaminants and that contribute to poisoning the food web
  
• Water runoff from agricultural and urban lands that carries pesticides and other pollutants
  
• Industrial and municipal discharges to surface water
  
• The possibility of large accidental spills of toxic substances
  
• Introduction of exotic species, such as the zebra mussel, that can greatly affect the balance between existing species
  
• Destruction of valuable wildlife habitats, such as fish spawning areas, wetlands, prairies, and old growth forests, by agricultural, residential, and other development activities
  
• Atmospheric deposition of sulfur oxide, nitrogen oxide, and mercury which affect inland lakes
  
• Global climate change.

The study concluded that the following posed the most significant human health risks:

• Consumption of Great Lakes sport fish because of their widespread contamination with PCBs and contamination in certain areas with chlordane, mercury, dioxins, and mirex
  
• Consumption of sport fish from inland lakes because of their contamination with mercury
  
• Accidental spills
  
• Respiratory exposure to toxic air pollutants.

In addition, the study concluded that the most significant sources of environmental contaminants were concentrated around Chicago, Illinois, and Gary, Indiana; Detroit, Michigan; Buffalo and Niagara Falls, New York; and Cleveland, Ohio. This information helped the Agency begin to target several of these areas for reduction of toxic releases and for habitat restoration.

Promotion of Pollution Prevention

EPA sees the Great Lakes as a proving ground for its pollution prevention efforts. Buttressed by other Agency activities, pollution prevention is to be the preferred means to reduce toxic pollutants. EPA is weaving pollution prevention into the fabric of all its Great Lakes activities and encouraging all sectors of society to contribute their ideas for reducing the quantity and harmfulness of resources used to satisfy human needs.

In April 1991, in concert with the eight Governors of Great Lakes States, EPA launched a Pollution Prevention Action Plan for the Lakes. The Action Plan augments State pollution prevention programs. During recent years, States have started various prevention initiatives, involving education, research, technical assistance, and recognition of prevention successes. Some States are also exploring ideas such as issuing one permit to cover all the pollutant releases from a facility as a means to increase pollution prevention, incorporating pollution prevention into enforcement settlements, and linking permit fees to the generation of pollution. EPA will continue to work closely with States in support of their prevention programs.

The Action Plan also complements EPA's national pollution prevention strategy, which includes the 33/50 Program. EPA has identified 17 high risk chemicals that offer strong opportunities for prevention. In February 1991, EPA announced a goal of encouraging firms across the Nation to cut their releases of these substances 33 percent by the end of 1992 and 50 percent by the end of 1995. Among the 17 high risk chemicals are three metals--cadmium, lead, and mercury--that can concentrate at upper levels of an aquatic food web. Mercury contamination is the basis for the issuance of several Great Lakes fish advisories.

Large manufacturing firms report their annual releases or transfers of more than 300 toxic substances. Under the 33/50 Program, EPA has asked firms that have reported releases of the target chemicals to voluntarily reduce these through pollution prevention. EPA anticipated widespread cooperation because pollution prevention offers economic benefits to firms. By the end of 1991, the Agency had received voluntary commitments from companies to cease 280 million pounds of releases of the 17 chemicals by 1995.

Pollution Prevention Action Plan

The Great Lakes Pollution Prevention Action Plan is predicated on challenging all sectors of society; focusing on high risk pollutants, sources, and areas; and measuring progress. The Plan contains five elements:

1. The Challenge: The Governors challenged all sectors of society to reduce, on a voluntary basis, releases of pollutants harmful to the Great Lakes.

2. Lake Superior: EPA and the Lake Superior States agreed to define procedures to prevent degradation of this relatively pristine lake, end loadings of bioaccumulative pollutants, and establish air deposition sites to monitor loadings of air pollution to the Lake.

3. Car Manufacturing: EPA and States announced that they would work with the Chrysler, Ford, and General Motors Corporations to promote prevention of substances that injure the Great Lakes ecosystem. These companies are joining EPA and States to determine substances of concern, to evaluate which substances are being used in their operations, and to reduce this use.

4. Urban Non-point Pollution: EPA and New York announced that they would co-sponsor education campaigns in four New York State counties to prevent urban non-point source pollution from households.

5. Binational Symposium: In September 1991, EPA co-sponsored with Environment Canada a symposium to bring together representatives from government, industry, and the public to share information on pollution prevention.

Geographic Targeting

A hallmark of the ecosystem approach is to focus on priority ecological problems and geographic areas, though Special Geographic Initiatives and Remedial Action and Lakewide Management Planning.

Special Geographic Initiatives
Under Special Geographic Initiatives, EPA and States focus prevention, inspection, enforcement, and cleanup efforts on a targeted area. During FY 1992, EPA and States targeted southeast Chicago-northwest Indiana and the Niagara River watershed because of their high ecological risk and noncompliance with permits and regulations.

Remedial Action Planning
The United States and Canada have committed to develop and implement plans--termed Remedial Action Plans (RAPs)--to restore the most impaired areas around the Great Lakes. In general, these Areas of Concern are bays, harbors, and river mouths with damaged fish and wildlife populations, contaminated bottom sediments, and past or continuing loadings of toxic and bacterial pollution. The United States has 31 Areas of Concern, including five shared with Canada. The Remedial Action Planning process defines ecological problems, identifies appropriate solutions, and measures progress toward ecological goals. States develop and implement RAPs, drawing on grass-roots collaboration from local communities.

Through 1992, States had completed initial versions of 23 Stage I (problem definition) and 12 Stage II (remedial action definition) RAPs. RAPs will be updated periodically as the results of preventive and remedial measures warrant.

Even while RAPs are being developed, EPA and States concurrently take many warranted actions to protect and restore Areas of Concern. Examples of such actions are summarized in the next chapter.

In further support of RAPs, EPA is continuing its Assessment and Remediation of Contaminated Sediments (ARCS) program that has assessed contaminated sediment problems and is demonstrating innovative treatment technologies in five Areas of Concern. ARCS will develop guidance on assessment methods and on remedial alternatives to assist local decision-makers in addressing contaminated sediment situations within Areas of Concern. ARCS is also discussed at greater length in the next chapter.

Lakewide Management Planning
The United States and Canada have also committed to develop and implement Lakewide Management Plans (LAMPs) to address whole-lake problems that extend beyond Areas of Concern. While EPA has the lead responsibility within the United States for developing these plans, participation by other Federal agencies, States, Tribes and local communities is fundamental to their success. A joint Federal-State policy committee has been established to guide the LAMP process and to incorporate participation by the public.

During FY 1991, EPA completed LAMPs for the Lakes that have experienced the greatest contamination-- Michigan and Ontario. The early objectives of LAMPs are to identify key pollutants and their sources and to schedule reduction measures. In FY 1992, the Agency began working with partners on a LAMP for Lake Superior; plans for Lakes Erie and Huron will follow.

Application of Multimedia Tools

To implement geographic targeting, EPA and States apply appropriate measures from their full range of programs--air, land, and water. This section discusses some of these programs and their application to the Great Lakes.

Air Programs
Since the discovery of polychlorinated biphenyls (PCBs) and other bioaccumulative toxicants on remote Isle Royale in Lake Superior in the late 1970s, the Great Lakes scientific community has been aware of the potential importance of the atmosphere as a pollution pathway. Researchers theorized that this contamination could only have resulted from atmospheric deposition. More recent research has concluded that the atmosphere is a significant pathway for mercury, which accumulates in fish in some inland lakes, posing risks to consumers of sport fish.

Under amendments to the Clean Air Act passed in l990, all U.S industrial sources of air pollution must significantly decrease their emissons of 189 different toxic pollutants over a ten year period. In addition, EPA and Canada have recently established stations on each of the Great Lakes to begin routine monitoring of toxicants. And during 1994, EPA will complete its first report on the extent, sources and effects of atmospheric deposition to selected water bodies, including the Great Lakes.

Land Programs
Under the Superfund Program, EPA and States address abandoned and uncontrolled hazardous waste sites that endanger public health, welfare, or the environment. Currently, about 140 NPL sites in the Great Lakes watershed are targeted by Superfund for permanent cleanup; 25 of these are vital to restoration of 14 Areas of Concern. For instance, the Superfund Program is addressing the site of greatest PCB contamination in the Great Lakes--Waukegan Harbor, Illinois. Through 1993, one million pounds of PCBs in and around this harbor are being removed, treated, burned, or isolated.

Whereas Superfund generally addresses past contamination, the Resource Conservation and Recovery Act (RCRA) regulates today's management of hazardous wastes, from generation through disposal. Facilities that treat, store, or dispose of hazardous waste must obtain permits that set forth management standards and closure requirements. If contamination is suspected at a RCRA-regulated facility, EPA or States may require the facility to conduct an investigation and correct any problems. Inspections of RCRA-regulated facilities are an important element of Special Geographic Initiatives. In the past several years, EPA and States have required RCRA-regulated facilities to conduct investigations and take corrective measures in five Great Lakes Areas of Concern. EPA has also issued regulations for onshore and offshore oil facilities to prevent accidental spill of oil. These regulations require such facilities to follow Spill Prevention Control an Countermeasures (SPCC) Plans, which are subject to EPA inspection. During 1991, EPA planned 182 SPCC inspections within the Great Lakes watershed and completed 196, almost triple the number conducted in 1990.

Water Programs
A discharge of pollutants into the surface waters of the United States is regulated by a National Pollutant Discharge Elimination System (NPDES) permit issued by EPA or a State. Permits limit the discharge of contaminants and establish treatment performance requirements for industrial and municipal wastewater. There are about 600 major and 3,000 minor NPDES dischargers in the Great Lakes watershed.

Two principles govern NPDES permits. The first principle is that dischargers meet technology-based treatment standards by industrial category. The second is that more stringent limits are imposed to protect water quality where technology-based limits prove insufficient to maintain designated water quality. Through water quality standards, States define the chemical and biological conditions necessary to maintain water quality. To assist States in establishing these standards, EPA prepares criteria to define the maximum allowable concentrations of pollutants that are acceptable for human health and aquatic life, based on scientific evidence.

In 1989, EPA and States began a "Great Lakes Water Quality Initiative" to develop binding guidance for States on water quality criteria for the Great Lakes, implementation procedures, and anti-degradation policy. EPA published this proposed guidance in April 1993. Implementation of the guidance will fulfill several purposes. It will ensure that Great Lakes environmental needs are fully incorporated into State water quality programs, which will provide a sound scientific basis for water quality-based protection of the Lakes. It will also promote consistency among States in their standards and implementation procedures for the Lakes, and serve as the basis for agreeing with Canada on chemical specific objectives for the Great Lakes.

Other water programs also benefit the Great Lakes ecosystem. For example, one program addresses contaminated storm water (rainwater runoff). Before entering a sewer, rain runoff can collect soil- surface contaminants that are then funneled into receiving surface waters by storm sewers. Following a rule that EPA issued in 1990, large cities and certain industries are curtailing discharges of contaminated storm water, subject to the terms of NPDES permits, which emphasize management practices and pollutant monitoring.

Particularly in older urban areas, storm water and household wastewater are delivered to municipal wastewater treatment facilities via combined sewers. During rainstorms, increased flow can exceed either a facility's treatment capacity or the carrying capacity of a sewer, leading to the release of untreated wastewater. The significance of combined sewer overflows (CSOs) varies around the Great Lakes. Michigan reports that CSOs are a major cause of impairments to its rivers, including the Rouge River, which receives an estimated 7.8 billion gallons of untreated water each year as it flows through metropolitan Detroit. States with such problems are pursuing strategies to control CSO releases to meet their water quality standards. In some areas, these strategies entail major capital investments, such as sewer separation and tunnels or basins to store untreated water. It is expected that, together, the storm water and CSO control programs will significantly reduce wet weather loadings of pollutants to the Great Lakes, especially around urban areas.

During the last two decades, EPA, States, and municipalities have made a concerted investment to improve municipal wastewater treatment. As a result, 95 percent of U.S. treatment facilities in the region now provide at least "secondary" treatment. Remaining jurisdictions are following schedules to achieve this treatment level and continue to improve their facilities.

The Clean Water Act also requires certain industries to "pretreat" toxic discharges to municipal treatment systems. Approximately 170 major municipal dischargers on the U.S. side of the Great Lakes have industrial pretreatment programs that are subject to regular inspections by EPA and States. Implementation of pretreatment requirements has effected sharp reductions in contaminant inflows to many facilities.

EPA jointly administers the principal Federal regulatory program to protect wetlands with the Army Corps of Engineers. This program issues permits to regulate the discharge of dredge or fill materials into water, including wetlands. The Agency seeks to prevent a net loss of wetlands on national basis in the short term and to increase the quantity and quality of wetlands in the long term. EPA also joins States in identifying high value wetlands in order to give advance notification to landowners prior to permit applications.

In addition, the Agency has made the Great Lakes watershed a priority in its support to State nonpoint source control programs, including education and incentive programs to abate runoff of pesticides, fertilizers, and animal wastes from farmland and others to prevent urban runoff of wastes from homes and industries.

Promotion of Public Stewardship  

EPA and States are encouraging public involvement in their activities and promoting public stewardship of the Lakes:

• Local community "stakeholders" are strongly involved in Remedial Action Planning, helping governments be more responsive to local concerns.

• Representatives from environmental groups, business associations, and municipalities were invited to comment during development of guidance under the Water Quality Initiative.

• In 1991, EPA put into service a state-of-the-art research vessel that will also serve as an educational platform. Tours for the public, including school children, will promote broader awareness of Great Lakes environmental issues.

• EPA's Assessment and Remediation of Contaminated Sediments (ARCS) program to test innovative remedial technologies for sediment contamination has held public meetings to inform residents living near the arreas of study.

Strengthening of the Knowledge Base

To ensure that their decisions are based on the best current scientific information, the Agency and its partners are working to improve their measurement of the health of the Great Lakes ecosystem and to sharpen their integration and analysis of environmental data. In the past, EPA has often relied on administrative statistics, such as numbers of permits, grants, and enforcement actions, as surrogate measures of effectiveness. In the future, the Agency will increasingly assess environmental progress by monitoring water, land, and air conditions and by monitoring biological responses of plants and animals to these conditions. Biological measures of well-being could include the balance between pollution- tolerant and pollution-sensitive species, or the balance between algae-grazing and predator fish. The foundation of the Agency's strengthened monitoring effort will be the Environmental Monitoring and Assessment Program (EMAP), which is a national program that gauges the health of our Nation's ecosystems. One ecosystem that EMAP will study will be the Great Lakes.

Recently, the following steps have been taken to assess the health of the Great Lakes:

• In 1991, EPA put into service a new 180 foot long research vessel, the Lake Guardian. This ship can sample water quality to the deepest depths of the Great Lakes and bottom sediments to a depth of 40 feet. The ship was named through a contest among elementary school students around the Great Lakes.

• Since 1989, EPA has sponsored a major study and demonstration program--the ARCS program--to assess contaminated Great Lakes bottom sediments, test promising remedial technologies, and develop guidance on addressing such contamination. Through 1992, EPA had assessed five Areas of Concern, identified treatment technologies to be tested at each, and demonstrated these in the field.

• In 1991, EPA established three master stations to monitor atmospheric deposition of toxic contaminants. Between them, the United States and Canada now have one master station on each of the Great Lakes.

• During 1992, EPA, Wisconsin, and partners concluded analytic aspects of their study of the sources, paths, and fates of several toxicants in Green Bay. The study has provided valuable lessons for whole- lake analyses in support of LAMPs.

• As part of the LAMP processes, ecosystem objectives are being developed for each of the Lakes.

• EPA, the Fish and Wildlife Service, and States continue to monitor targeted toxic contaminants across several fish and wildlife species.

• In 1992, EPA bought a high performance computer that will be placed in Bay City, Michigan, for modelling of the Great Lakes, including hydrodynamic processes, air deposition, pollutant loadings, and sedimentation. This will be an early step toward establishing an environmental center at the head of Saginaw Bay that will be dedicated to scientific study of the Lakes.

• EPA is also working to strengthen its integration and analysis of environmental data on the Great Lakes. Through its various programs, the Agency collects data on air and water pollution, hazardous waste sites, pesticides, drinking water, radiation, and the health effects of pollutants. Much of this information is obtained pursuant to separate laws and is narrowly focused to serve these mandates. In general, it is difficult to integrate these data to obtain a comprehensive view of total pollutant releases by a facility and surrounding ecological conditions. Such an overview would assist decisionmaking for permits and enforcement. Accordingly, the Agency is working to increase the availability of environmental data to support decisionmaking by Federal, State, and local governments aand to make information more accessible to the public.

Cooperation with Canada

EPA and States are taking advantage of all opportunities to work with their counterparts in Canada. Canadian representatives have been invited to ARCS program meetings to keep apprised of U.S. findings regarding technologies to address contaminated sediments. Canadian observers have also been invited to attend meetings concerning the Water Quality Initiative. In addition, EPA and States are working with Canadian counterparts on RAPs for shared Areas of Concern and on LAMPs for shared Lakes. The two nations are also sponsoring joint activities, such as the symposium on pollution prevention and their binational Lake Superior Initiative, mentioned previously.