3.2.1 Preamble
3.2.2 Principles
3.2.3 Technical Requeirements
3.2.4 Financial Considerations
3.3.1 Introduction and Overview
3.3.2 Key Needs and Priorities for Problem Assessment
Possible Future Actions
3.3.3 Key Needs and Priorities for Problem Response
The Great Lakes Binational Toxics Strategy as a Framework for Action
Program Evaluation to Ensure Accountability
Prevention-Based and Beyond Compliance Programs
Other Issues
3.3.4 Synopses of Background Reports
Atmospheric Transport And Deposition of Persistent Toxic Substances to the Great Lakes (IAQAB)
Use of Mass Balance Modelling and Deposition Monitoring to Assess Relative Pollutant Loadings (WQB)
Assessment of Parties' Progress under Annex 15 in Reducing Emissions of Persistent Toxic Substances (IAQAB)
Applicability of Beyond Compliance Programs to the Great Lakes Binational Toxics Strategy (WQB)


4 Persistent Toxic Substances (Level I and Level II) Identified in the Great Lakes Binational Toxics Strategy
5 Estimated Long-Range Air Transport Potential of Strategy Compounds
6 Examples of Successful Beyond Compliance Initiatives in the Great Lakes Basin


2 1990 MICHTOX Estimates of Fluxes (Green Bay)
3 Total Achieved and Predicted Reductions of the 30 Persistent Bioaccumulative Toxic Substances Targeted for Virtual Elimination by the Chemical Manufacturing Sector under the Voluntary Accelerated Reduction/Elimination of Toxics (ARET) Program
4 Estimated National Dioxin Emissions for 1990 and 1996 for Three Major Source Categories


A portion of the International Air Quality Advisory Board (IAQAB) work during the 1995-1997 priority cycle was determining the extent of transport of persistent toxic substances to the Great Lakes from the atmosphere. Much of this work is summarized in the joint Great Lakes Water Quality Board (WQB) and IAQAB Workshop on Significant Sources, Pathways and Reduction/Elimination of Persistent Toxic Substances discussed in Chapter 3.3.

As part of this priority, IAQAB reviewed emissions from municipal solid waste incinerators and drafted the following policy statement, which was subsequently adopted by IJC. Technical analysis supporting the policy statement is contained in the report A Policy Statement on the Incineration of Municipal Waste. Copies are available upon request from IJC and on the Internet at www.ijc.org/php/publications/html/incin.html(.)


3.2.1 Preamble

The International Air Quality Advisory Board (IAQAB) fully endorses the principle of virtual elimination of persistent toxic substances to the Great Lakes and supports the need to manage municipal solid waste facilities toward this end. It further recognizes that municipal solid waste incinerators are sources of persistent toxic substances which can be transported long distances to or from the Basin and across national boundaries.

The IAQAB emphasizes that incineration is only one of a matrix of options and technologies available to currently address management of municipal solid wastes. Any incinerator application should be viewed in the larger context of an integrated solid waste management approach, which includes life-cycle analysis, with a priority on reduction and recycling initiatives. The IAQAB notes that there is an inherent conflict between the maximization of waste recycling, particularly of combustible fibre such as newsprint and cardboard, and sustainable, stable operation of an incinerator, as removal of such materials from the refuse significantly reduces its properties as a fuel.

The IAQAB recognizes that, if the incinerator option is chosen, facilities can be designed and operated to reduce the amount of toxic materials (including pathogens) in the waste, to concentrate the residual toxics in the ash and to minimize releases of same to the atmosphere. The health implications of release of fine (less than 10 microns) particulate matter from such sources must continue to be considered.

3.2.2 Principles

  1. Consideration or deployment of municipal incinerators should not, in any way, compromise programs for waste reduction and recycling, which must remain the cornerstone of waste management.
  2. Should jurisdictions elect to build new incineration facilities, these, at minimum, should be in full compliance with the USEPA and MOEE requirements. Further, jurisdictions and proponents should recognize that emission control technology is constantly improving and should commit to incorporate such improvements at several points in the life span of any given facility.

In keeping with the principle of virtual elimination, the IAQAB wishes to state four additional principles, namely:

  1. Any further deployment of this technology by any jurisdiction should be done on the basis of a net reduction of emissions of persistent toxic substances, jurisdiction wide, from such facilities. Thus, existing units must be further controlled to new source performance standards or decommissioned by the year 2000. The USEPA regulations and those in some European jurisdictions contain this requirement, which should also be embraced by the Province of Ontario.
  2. The total amount of persistent toxic substances released by incineration facilities in a jurisdiction, defined as the sum of those to the atmosphere and in the residuals, must also be decreased whenever a new incineration facility is permitted.
  3. Compliance with principle iii) also commits individual jurisdictions to the establishment and ongoing maintenance of publicly accessible emission inventories characterizing all regulated operating parameters, emissions and releases from these units.
  4. The operator and regulatory agencies must make a concerted and ongoing effort toward meaningful public involvement in all aspects of the facility. This includes significant public participation in initial selection of the incineration option, development of a comprehensive justification and related environmental assessment, construction and commissioning of the facility, as well as operation and final decommissioning. These considerations must extend beyond the facility to encompass measurement and publication of assessments of environmental quality including extensive ambient air quality monitoring for persistent toxic substances and other pollutants in the adjacent locale.

3.2.3 Technical Requirements

  1. Operating facilities should be required to perform regular comprehensive ambient air and deposition monitoring in the vicinity of the plant and associated ash-disposal location.
  2. Emissions from the facility must be subject to continuous monitoring and manual sampling as provided for in the USEPA regulations. If necessary, further sampling to confirm the size distribution of particulate matter in the emission stream should be conducted.
  3. To the extent practicable for specific sites or waste flows, these units should be designed for extended stable operation, which could be realized, in part, by requiring the incorporation of electrical or other energy generation.
  4. The toxic content of residual ash and particulate should be determined at regular intervals to ensure associated disposal strategies are appropriate for the conditions encountered.
  5. Source, ash residual and localized ambient air quality data should be collected and incorporated into an ongoing performance review program, with provision for effective public oversight.
  6. As an operational principle, Good Management Practice, including rigorous and certified operator training, is a must.

3.2.4 Financial Considerations

While finance is not an area of Board expertise, there is a need to ensure that adequate funds are available for:

  1. continuous monitoring, appropriate maintenance activities and updating of process and control equipment throughout the lifespan of the facility;
  2. support for ongoing independent auditing of operations as part of a public review;
  3. sound decommissioning of both the unit and any associated residual disposal site, including long term monitoring of the integrity of any such site.


3.3.1 Introduction and Overview

The Great Lakes Water Quality Agreement calls for the virtual elimination of inputs of persistent toxic substances. In keeping with this objective, Environment Canada and U.S. Environmental Protection Agency (EPA), in cooperation with the Great Lakes state and provincial governments, developed The Great Lakes Binational Toxics Strategy -- Canada-United States Strategy for the Virtual Elimination of Persistent Toxic Substances in the Great Lakes. Specifically, the strategy commits federal, state and provincial governments to work with other public and private partners toward the goal of virtual elimination of persistent toxic substances resulting from human activity, particularly those that bioaccumulate, so as to protect and ensure the health and integrity of the Great Lakes ecosystem (Environment Canada and U.S. Environmental Protection Agency, 1997).

The International Joint Commission (IJC) identified significant sources, pathways and reduction/elimination strategies for persistent toxic substances as one of its priorities. IJC's International Air Quality Advisory Board (IAQAB) and Great Lakes Water Quality Board (WQB) collaborated on this priority and co-sponsored a workshop on May 21-22, 1997 to jointly evaluate four background reports (synopses of IAQAB reports on air sources and pathways and an evaluation of programs called for under Annex 15 of the Agreement; and synopses of WQB reports on use of mass balance modelling and an evaluation of beyond compliance programs) and identify critical research, assessment and management needs and priorities. Approximately 90 individuals, including researchers, air and water program managers and policy development specialists participated.

The workshop began with plenary presentations on air sources and pathways and the use of mass balance frameworks to assess relative pollutant loadings, followed by a plenary discussion of progress, knowledge gaps and uncertainties. Presentations on an evaluation of programs called for in Annex 15 and on evaluation of beyond compliance programs followed. The workshop then used facilitated breakout sessions to address needs and priorities relative to problem assessment (e.g. research, assessment, monitoring and mass balance modelling) and problem response (e.g. policy and management actions). The workshop concluded with plenary presentations and discussion of the findings and recommendations from each breakout session.

Key findings and recommendations and brief synopses of the four background reports are presented in Chapter 3.3.4. The complete background reports are available upon request from IJC.

Both IAQAB and WQB reiterate the importance of the Agreement and the 1997 binational toxics strategy in making further progress in restoring and sustaining the integrity of the Great Lakes. IJC has significant responsibility to review and evaluate progress under the Agreement. As part of this responsibility IJC should track the Parties' progress comprehensively under the binational virtual elimination strategy.

The May workshop is a good example of necessary research-management dialogue on virtual elimination of persistent toxic substances. IJC is in an excellent position to further such dialogue and facilitate binational cooperation. Examples of high priority areas where IJC could have an value-added impact include:

Greater emphasis should be placed on communicating research-management needs and the value and benefits of programs targeted at control and prevention of persistent toxic substance problems. IJC should continue helping facilitate such communication on a regular basis. Both IJC and the Parties/jurisdictions should work with industries and businesses to quantify the environmental and economic benefits of these programs in order to foster greater application throughout the Great Lakes basin ecosystem.

3.3.2 Key Needs and Priorities for Problem Assessment

Workshop participants considered what scientific issues need further assessment most urgently. In the course of the discussion, the following observations emerged.

Possible Future Actions

The workshop participants determined the following.

3.3.3 Key Needs and Priorities for Problem Response

The Great Lakes Binational Toxics Strategy as a Framework for Action

Workshop participants recognized the importance of the strategy as a framework for action. The strategy provides the systematic and comprehensive framework necessary to target chemicals and the remedial and preventive actions required to protect and ensure the health and integrity of the Great Lakes basin ecosystem (Environment Canada and U.S. Environmental Protection Agency 1997).

Workshop participants also recognized the need for good science as the foundation for good management actions (i.e. problem response initiatives). A good understanding of sources, pathways and processes is necessary in order to help prioritize management actions. Current needs include: enhancing the source inventory and loading data bases; acquiring better information on physical and chemical properties of contaminants; resolving the "old" versus "new" source question (e.g. grasshopper effect); and understanding processes of compound formation, such as dioxin.

It was well recognized that science will never be perfect, nor entirely complete. However, management must not be afraid to take action. Tools are available to prioritize management actions. Workshop participants noted a need for strong, effective leadership for implementation of the strategy. Governments should do more to lead by example. As part of an implementation framework, workshop participants reiterated the importance of strong linkages between research/assessment and management in order to identify and implement pragmatic, ecosystem-effective solutions.

Both Canada and the U.S. have made progress in controlling the input of persistent toxic substances, however, much more needs to be done to meet the goal of virtual elimination. It was suggested that future management actions should be guided by four principles: step-wise, integrated, incremental and accountable.

Regulatory programs continue to be a stimulant for beyond compliance programs. Beyond compliance programs should be targeted at persistent toxic substances. A balance should be achieved between regulatory and voluntary, beyond compliance programs. Prevention-based programs, such as ISO 14000, have tremendous potential to achieve environmental results. Following implementation of management actions, adequate post-project monitoring to evaluate effectiveness and document value and benefits (both environmental and economic) is needed. Such information on the value and benefits of voluntary, beyond compliance and regulatory programs can be used to market "win-win" solutions elsewhere. Recent experience with beyond compliance programs shows that the best environmental successes occur when there is cost savings.

Program Evaluation to Ensure Accountability

Participants agreed that most problem response actions are taken within an adaptive management framework (i.e. assess, set priorities and take action in an iterative process). Consistent with this adaptive management philosophy, participants recognized the importance of evaluating progress in reducing/eliminating persistent toxic substances. Specifically, binational evaluation of progress toward virtual elimination should be undertaken by IJC and its boards and should include all relevant Agreement annexes (e.g. Annex 2, 15). IJC and its boards may want to develop (over a six month period) a plan or strategy to review and evaluate progress toward virtual elimination of persistent toxic substances in a comprehensive fashion. This review and evaluation plan or strategy would include, among other elements, the following:

Participants recognized a number of obstacles to undertaking such a comprehensive review and evaluation of progress:

Although such obstacles exist, participants agreed with the high priority need to undertake binational review and evaluation of progress toward virtual elimination of persistent toxic substances. Benefits include ensuring greater accountability, demonstrating and celebrating progress and making mid-course management corrections.

Prevention-Based and Beyond Compliance Programs

More effort should be placed on fostering prevention-based programs. Federal, state, and provincial governments must ensure that burden of proof to prevent problems is placed on industry. In addition, governments should lead by example through manifesting pollution prevention and materials management initiatives. Within the area of ISO 14000 there is considerable opportunity to build on the environmental management system (EMS) foundation. For example, persistent toxic substances should be addressed as significant environmental aspects within the EMS process.

There is also an opportunity to "broaden the net" and establish more partnerships. For example, organizations like the Council of Great Lakes Industries, Cleveland's Advanced Manufacturing Center, the Canadian Pollution Prevention Centre in Sarnia, Chemical Manufacturers Association, Canadian Chemical Producers' Association and the Society of Environmental Toxicology and Chemistry should be encouraged to participate in and disseminate information on practical initiatives and technologies for pollution prevention and help manifest "win-win" solutions for environment and economy.

Barriers to fostering prevention-based programs include: few incentives for business/industry; low priority to small-medium sized businesses; measurement a low priority; governments do not provide enough recognition to pollution prevention plans and accomplishments; and the command-and-control mindset continues to result in lack of trust. There is considerable opportunity for IJC and governments to work in partnerships with other industrial organizations and professional societies to address these barriers and achieve greater environmental results. Further, since pollution prevention programs have been in place in all jurisdictions for some time, there is need to evaluate and share current information on pollution prevention program efficacy.


Breakout session participants also agreed on the need for effective communication. This workshop was an excellent example of the value and benefits from effective communication among air and water program managers, policy makers, researchers and academic scientists. Such coupling of science and management is a prerequisite for ecosystem-based management. Other opportunities ensuring effective communication on virtual elimination of persistent toxic substances include:

Efforts are needed to clarify roles and responsibilities, promote integration of programs, reach agreement on common goals and indicators and develop a common communication and information strategy (e.g. web-based with adequate linkages).

Other Issues

Workshop participants recognized there are other management response issues that eventually must be addressed. These issues may not be a high priority in the near term, but undoubtedly will require attention in the future. An example would be an evaluation of opportunities to move away from carbon-based fuels. Workshop participants suggested that management must continue to be open to different perspectives and new ideas.

3.3.4 Synopses of Background Reports

Atmospheric Transport and Deposition of Persistent Toxic Substances to the Great Lakes (IAQAB)

Since 1987, the significance of the atmospheric pathway for several contaminants, including PCBs, mercury and lead, has been well established by IJC and others. As one of its principal activities under IJC's priority on transport of persistent toxic substances to the Great Lakes basin, IAQAB commissioned a review (Cohen et al. 1997) of the state of the science regarding the emission, transport and deposition of Level I and Level II contaminants listed in the Great Lakes Binational Toxics Strategy. The strategy is focusses on approximately 27 compounds or classes of compounds as shown in Table 4 (Environment Canada and U.S. Environmental Protection Agency, 1997); 11 of the 12 Level I Substances were identified by WQB as critical pollutants in 1985. The review performed by Cohen and colleagues addressed:

Examination of physical and chemical properties of the strategy pollutants was a significant undertaking, as several are families of compounds, (such as the 209 congeners of PCBs), each with distinct properties. Cohen and colleagues determined that uncertainties and gaps in physical, chemical and/or atmospheric fate data for many of these substances limit the application of modelling and deposition determination techniques to these pollutants.

The potential of individual compounds for long range transport was assessed through consideration of evidence of emissions to the air; indirect indications of transport (such as detection at remote, isolated locations); and a determination of theoretical atmospheric lifetime, including consideration of physical/chemical properties, reactions in the atmosphere and deposition processes. Cohen's ranking (Table 5) indicates several contaminants have a global reach; others could be considered more continental, regional or subregional. Compounds with the longest atmospheric lifetimes include the chlorobenzenes, hexachlorobutadiene and elemental mercury. For these compounds, and possibly several others (e.g. DDT, mirex, hexachlorocyclohexanes, octachlorostyrene, and many of the PCBs), a global accounting may be necessary.

Table 4. Persistent Toxic Substances (Level I and Level II) Identified in the Great Lakes Binational Toxics Strategy.

Critical pollutants identified by WQB in 1985 are indicated with an asterisk (*).

Persistent organic pollutants from CEC Council Resolution #95-5 are identified with a caret (^).


  • Aldrin ^
  • Dieldrin *^
  • Benzo(a)pyrene {B(a)P} *
  • Chlordane ^
  • DDT, DDD, DDE *^
  • Hexachlorobenzene (HCB) *^
  • Alkylated lead *
  • Mercury * and its compounds
  • Mirex *^
  • Octachlorostyrene
  • PCBs *^
  • Dioxins (PCDD; 2,3,7,8-TCDD) *^
  • Furans (PCDF; 2,3,7,8-TCDF) *^
  • Toxaphene *^

NOTE: Hexabromobiphenyl and Pentachlorophenol are listed as POPs on the CEC Council Resolution #95-5 but are not included on the Strategy list.


  • Cadmium and its compounds
  • 1,4-Dichlorobenzene
  • 3,3'-Dichlorobenzidine
  • Dinitropyrene
  • Endrin ^
  • Heptachlor and heptachlor epoxide
  • Hexachlorobutadiene
  • Hexachloro-1,3-butadiene
  • Hexachlorocyclohexane (including alpha, beta, delta, lindane)
  • 4,4'-Methylenebis(2-chloroaniline)
  • Pentachlorobenzene
  • Pentachlorophenol
  • Tetrachlorobenzene (1,2,3,4- and 1,2,4,5-)
  • Tributyl tin
  • Polycyclic aromatic hydrocarbons (PAHs) ^ as a group, including but not limited to:
    • Anthracene
    • Benzo(a)anthracene
    • Benzo(g,h,i)perylene
    • Perylene

    • Phenanthrene

Emission inventories are crucial to the determination of source regions and source-receptor relationships. Major inventories assembled by each country were reviewed. While a source of useful information, not all strategy contaminants were included, nor was there enough information on derivation, spatial and temporal resolution, quality assurance, or parameters (temperature, height, velocity of emission) specific to modelling source-receptor relations to provide input for modelling atmospheric transport.

Specific mercury compounds, as well as pentachlorophenol, PCBs and others need quantification; the treatment of banned or restricted biocides (dieldrin, DDT, mirex, toxaphene) should also be improved. Confidentiality agreements with individual facilities or sectors appear to be a significant hurdle in assembling emission information for modelling. The binational Great Lakes Regional Air Toxics Inventory, currently under development, shows promise and should be assessed more thoroughly as it matures.

The ambient air monitoring programs in the basin can provide an extremely useful set of data for comprehensive models of pollutant fate and transport. However, the list of contaminants monitored should be extended to better embrace Level I and Level II contaminants. While the International Atmospheric Deposition Network (IADN) determines ambient air concentrations and deposition for many of these compounds, others, such as dioxins and dibenzofurans, are not being monitored comprehensively, although some are determined by individual jurisdictional efforts.

Further water column pollutant monitoring and examination of air/water mass transfer processes to better estimate net loadings to and from the lakes are needed. The output of the Lake Michigan Mass Balance Study may address some of these concerns and put the atmosphere contribution in context with those from direct effluent discharge and indirect inputs, such as runoff and sediment resuspension.

Cohen and colleagues, in their consideration of modelling, noted that back-trajectory approaches applied to several of the strategy contaminants identified source regions, such as toxaphene transport from the southeast states. More comprehensive modelling approaches were used for heavy metals, including mercury, and toxaphene, hexachlorobenzene, dioxins and dibenzofurans; however, specific source-receptor relationships were only available in one case (dioxin). Again, improved emissions inventories are needed if specific sources and receptors are to be directly linked. Information on air/surface interactions are among items that must be improved. The grasshopper effect must also be accounted for in modelling several of these pollutants.

Cohen and colleagues concluded with the following recommendations.

  1. The signing of the binational strategy should become the basis for a bilateral (or perhaps trilateral, including Mexico) structured and continual effort addressing source-receptor relationships for those contaminants whose transport to the basin, via the atmospheric pathway, appear to be significant.
  2. This effort should address research on: physical-chemical properties of strategy chemicals/compounds and classes; chemical reaction rates and concentrations of reactants; rates of atmospheric photolysis; vapor/particle partitioning phenomena; wet and dry deposition processes; meteorological processes; development of data sets for model validation; modelling studies of transport; and further consideration of the "grasshopper effect."
  3. Routine deposition and ambient air monitoring efforts in the Great Lakes region should be extended to the balance of Level I substances and several Level II substances, including specific mercury species, alkylated lead, 3,3'-dichlorobenzidine, 1,4-dichlorobenzene, PCDD/PCDF, dinitropyrenes, hexachloro-1,3-butadiene, pentachlorophenol and toxaphene. The addition of 4,4'-methylenebis(2-chloroanaline) and tributyltin compounds to the list of substances monitored might be implemented on a temporary basis to determine the potential significance of the air pathway to Great Lakes loadings for these compounds.
  4. A bilateral (or trilateral) review and coordinated revision to emission inventories should be undertaken, including all appropriate strategy contaminants to a level of quality suitable for use in atmospheric transport models, yielding comparable results and with suitable access to individual source information.
  5. A bilateral (or trilateral) review should be undertaken to:

The focus of this review should be on the identification of models validated as capable of determining linkages between receptors and individual sources and the availability of required input information to support same.

Table 5. Estimated Long-Range Air Transport Potential of Strategy Compounds

1 (High) 2 3 4
1 year or more 1 week-few months Few hours-few days seconds-minutes
(approximate average transport distance associated with half-life)
global 1,000-10,000 km
(possibly global)
100-1,000 km local
  • elemental mercury
  • hexachloro-1,3-butadiene
  • tetrachlorobenzenes
  • pentachlorobenzene
  • hexachlorobenzene
  • particulate mercury
  • mercury dichloride
  • alkylated lead
  • cadmium
  • mirex
  • toxaphene
  • hexachlorocyclohexanes (alpha, beta, delta, gamma)
  • pentachlorophenol
  • octachlorostyrene
  • 3,3'-dichloro-benzidine
  • 1,4-dichlorobenzene
  • PCBs
  • dinitropyrenes
  • benzo[a]pyrene
  • benzo[a]athracene
  • perylene
  • benzo[g,h,i]perylene
  • PAHs (as a group)
  • aldrin (?)
  • heptachlor (?)
  • 4,4'-methylenebis (2-chloroaniline) (?)
  • tributyltin (?)
  • heptachlor epoxide
  • methoxychlor
  • dieldrin
  • endrin
  • phenanthrene
  • anthracene
  • aldrin (?)
  • heptachlor (?)
  • 4,4'-methylenebis (2-chloroaniline) (?)

Note: The (?) indicates that the classification for these substances is less certain and more approximate than for the other substances.

Use of Mass Balance Modelling and Deposition Monitoring to Assess Relative Pollutant Loadings (WQB)

U.S. EPA is using mass balance modelling to evaluate sources, transport and fate of toxic contaminants in the Great Lakes. Mass balance modelling allows prioritization of research and remedial and regulatory actions for water and air quality management. The primary goal of Great Lakes mass balance modelling studies is to develop and improve toxics reduction management tools based on sound, scientific information to guide future toxic load reduction efforts at the state and federal levels.

The mass balance approach requires the quantities of contaminants entering the system, less the quantities stored or transformed within the system, must equal the quantities leaving the system. Once a mass balance for selected contaminants is established and a mass balance model calibrated, additional contaminants can be modelled with limited data.

In a pilot mass balance study by U.S. EPA and the Wisconsin Department of Natural Resources, water-insoluble organic compounds were monitored in Green Bay, Wisconsin from 1988 to 1992 (Figure 2). This pilot study demonstrated the effectiveness of mass balance modelling in quantifying the relative contribution of contaminants and prioritizing management actions.

Figure 2 1990 MICHTOX Estimates of Fluxes (Green Bay)

The first full-scale application of this methodology for toxic pollutants is the Lake Michigan Mass Balance Study (LMMBS), which will serve as the basis of any future mass balance modelling efforts for persistent, bioaccumulative chemicals. The analytical and modelling tools used in the study may be applied to other Great Lakes, Lake Champlain and coastal estuaries. LMMBS monitoring data are expected to be available by the end of 1997 and initial model output by 1998. In addition to LMMBS atmospheric monitoring, U.S. EPA's Great Lakes National Program Office manages, in cooperation with Environment Canada, a binational atmospheric monitoring network, IADN. Information from this network is used in the estimation of air toxics loadings to the lakes.

LMMBS is intended to develop a predictive capability, allowing determination of environmental benefits of specific load reduction scenarios for toxic substances and the time required to realize those benefits. This includes the evaluation of benefits of load reductions from voluntary programs and existing environmental statutes and regulations required under the U.S. Clean Air and Clean Water Acts. For this study, not only were atmospheric concentrations of toxic contaminants monitored by lake, but also concentrations of toxic substances in fish, phytoplankton, sediment and the water in tributaries.

This information is important for improving understanding of key environmental processes governing the cycling and bioavailability of contaminants within relatively closed ecosystems. It can also be utilized to construct a predictive model of contaminant cycling within the system. Processes and rates of processes of air-water or sediment-water transfer of contaminants are required to complete such a model and create a management tool to predict environmental effects of toxics loadings.

LMMBS was designed to predict how contaminant concentrations in the water column and target fish species are affected by loadings from air and water over a 25-year period. Pollutants chosen for the LMMBS model were total mercury, atrazine, trans-nonachlor and PCBs. Additional pollutants were monitored for model development purposes (e.g. nutrients, radionuclides, trace metals, organochlorine pesticides and PAHs). This required a two-year monitoring effort to collect all necessary information for the model.

The computer model developed on these monitoring data is based upon the linked sub-model approach used in the Green Bay Mass Balance Study. It includes the following submodels: hydrodynamics, sediment transport, sediment bed dynamics, eutrophication/sorbent dynamics, contaminant transport and fate and food web accumulation. Linkages were established with atmospheric transport and watershed delivery models to allow simulation of multimedia toxics transport and to relate watershed and airshed management to water quality.

Atmospheric data for the model are coming in part from IADN -- a bilateral effort mandated by Annex 15 of the Agreement. In the U.S., the 1990 Clean Air Act amendments also require establishing one measurement site on each of the Great Lakes. IADN is intended to provide the necessary standardized methods, monitoring data and loadings estimates to assess the relative importance of atmospheric deposition compared to other inputs; determine temporal trends and geographical variations in deposition; and ultimately provide information about sources of these atmospheric pollutants.

IADN has indicated a reduction in lead deposition between 1988 and 1994 as a response to the ban on leaded gasoline in the U.S. and Canada. Arsenic deposition also has decreased.

1994 data for PCBs show a comparative increase in volatilization from the lakes and a decrease in wet and dry deposition to the lakes. The most recent estimates are of a net output of PCBs from the lakes (Hornbuckle et al. 1994), contrary to results obtained in 1988. Lakes Erie and Ontario appear to have the highest loading rates to the air (5,000 and 3,600 kilograms per year, respectively). The high gas transfer rates suggest that the water concentrations should be experiencing a noticeable decline or at least seasonal variation. However no studies on seasonal variation of PCB water concentration have been published (Hornbuckle et al. 1994). In addition, gas transfer rates are among the physical properties having a very high uncertainty associated with them.

PAHs are seen both in gas and particulate phase, but some of the most toxic PAHs are largely found in the atmosphere in the particle phase. Thus, for the most toxic PAHs, dry deposition is the main route of transport into the lakes (Hoff and Brice, 1994). 1994 results also suggest that outgassing of the pesticides lindane, DDT (and metabolites DDD and DDE) and dieldrin appears to occur.

The mass balance model should be responsive to this "two way traffic" of pollutants and further recognition of the Great Lakes themselves as, on occasion, a source of persistent toxic substances to the atmosphere.

Assessment of Parties' Progress under Annex 15 in Reducing Emissions of Persistent Toxic Substances (IAQAB)

Annex 15, added to the Agreement in 1987, recognizes the atmosphere as a significant pathway for persistent toxic substances and outlines the research, surveillance and monitoring and control measures needed to further quantify and reduce such transport. Under IJC's 1995-1997 priorities, IAQAB attempted an assessment of government efforts under Annex 15 toward immediate and forecasted reductions of emissions of persistent toxic substances from identified major sources. This assessment focussed on substances listed in the Great Lakes Binational Toxics Strategy. As shown in Table 4, most of the Level I substances in the strategy were designated as critical pollutants by WQB in 1985 and as persistent organic pollutants by CEC in 1995 (Council Resolution #95-5).

A survey questionnaire was sent to representatives of appropriate federal, provincial and state agencies; 50 percent responded. The limited submitted material indicated that, while the implementation of programs designed to reduce the use of those substances not already subject to a ban was proceeding on several fronts, cumulative quantification of reductions appeared largely unavailable.

In the last decade, the Canadian government has implemented laws, policies and programs designed to reduce emissions of Level I and many Level II substances. All Level I substances are listed in one or more programs or policies for virtual elimination. Most Level II substances are included in programs designed to reduce use, release and generation on a voluntary basis only. An example of results from the voluntary program Accelerated Reduction / Elimination of Toxics (ARET) is presented in Figure 3.

Figure 3 Total Achieved and Predicted Reductions of the 30 Persistent Bioaccumulative Toxic Substances (PBTS) Targeted for Virtual Elimination by the Chemical Manufacturing Sector under the Voluntary Accelerated Reduction/Elimination of Toxics (ARET) Program. (Environment Canada)

Timelines and targets for virtual elimination are being developed for these Level II substances. Endrin and heptachlor are included in Canadian programs designed for virtual elimination. Hexachlorobutadiene, pentachlorobenzene and tetrachlorobenzenes are not targeted for reductions by any federal program or policy in Canada. Any reductions would be achieved with the active participation of the provinces; Ontario is expected to play a prominent role through its commitments under the Canada-Ontario Agreement. The response from Environment Canada included a tabular presentation by contaminant, offering a first estimate of annual emissions, citations of applicable legislation and reduction targets, where available.

While Canadian programs are comprehensive in scope, quantitative tracking of resultant overall emissions reductions with established precision and accuracy is not presently possible due to the lack of a comprehensive emissions database. Environment Canada is developing national inventories of estimated air releases for many substances for this purpose.

Federal and state governments in the U.S. have a variety of laws, policies and programs addressing persistent toxic substances. The United States government has created numerous programs and regulations to collect data regarding point and area emissions, monitoring, wet and dry deposition, loading estimates and the effects of toxic air substances on humans and the environment, as well as supporting modelling studies to better understand the sources and receptors of various pollutants. Together, these programs and policies have significant components concerned with most Level I and Level II substances.

A major federal initiative is targeted toward reducing emissions of mercury, a Level I substance, as detailed in the Mercury Study Report to Congress. As a result, most states implemented mercury reduction programs and can report emissions reductions through collections and proper disposal.

Particularly relevant sections of the Clean Air Act include section 112 (m), the Great Waters Program, under which U.S. EPA and the National Oceanic and Atmospheric Administration have supported deposition monitoring, emission inventory efforts, multimedia modelling and mass balance approaches in particular regions, including the Great Lakes.

Section 112 (c)(6) of the Clean Air Act Amendments of 1990 contains a program particular to seven specific pollutants -- alkylated lead compounds, polycyclic organic matter (including PAHs), hexachlorobenzene, mercury, PCBs, and 2,3,7,8-TCDD and TCDF. Within five years of enactment, source categories accounting for not less than 90 percent of the aggregate emissions of each compound must be listed. Further, it must be determined that these emissions do not violate established health thresholds or they must be subject to further controls not later than 10 years after enactment. Electric utility steam generating units were exempted from specific promulgation requirements.

Emission inventories for the seven specific pollutants, largely using 1990 as a base year, were made available by U.S. EPA in June (1990 Emissions Inventory of Section 112 (c)(6) Pollutants, Emissions Monitoring and Analysis Division, U.S. EPA, Research Triangle Park, North Carolina). Estimated emissions from several source categories were lowered since 1990 due to continued activity toward development of various National Emission Standards for Hazardous Air Pollutants (NESHAPs), as well as further improvements in the precision of the estimates (U.S. EPA 1996). These two developments are reflected in the estimated nationwide dioxin emissions for 1990 and 1996 from three source categories (Figure 4). This ongoing inventory activity should allow further revised nationwide emission estimates for others of these seven Level 1 contaminants.

Figure 4 Estimated National Dioxin Emmissions for 1990 and 1996 for Three Major Source Categories (USEPA)
(Note: 1995 medical waste emissions extrapolated to 1996)

The United States federal Toxic Release Inventory (TRI) encourages recycling and pollution prevention, but is not a tool for enforced reductions in emissions of toxic substances. Most, but not all, persistent toxic substances are included in the TRI emissions data collection requirements.

The United States Federal Insecticide, Fungicide, and Rodenticide Act and the Toxic Substances Control Act are designed to reduce emissions of Level I substances mercury, chlordane, DDT/DDE, hexachlorobenzene PCBs and toxaphene. No information regarding confirmed resultant reductions was returned in response to the survey questionnaire.

The United States also has several federal and state legislative tools designed to develop further programs to reduce the emissions of persistent toxic substances. These include the Superfund Amendments and Reauthorization Act, support for the multi-state Great Lakes Regional Air Toxic Emissions Inventory and the Indiana Department of Environmental Management's Strategic Plan.

In the United States, the structure needed for creation of programs to reduce persistent toxic substances was established. However, for many substances under the binational toxics strategy, current quantitative information is lacking. Information presented at this workshop indicated that this situation was identified by U.S. EPA and is being addressed through improved emissions inventories and standards, including the Great Lakes Regional Air Toxic Emissions Inventory. However, at this time, based on the information made available under this survey, an estimate of quantified reductions for a great majority of Level I and Level II substances cannot be given.

Among the Great Lakes states, there is significant variability in programs regarding air toxics. The Illinois Toxic Air Contaminant Program has the potential to regulate emissions of all Level I and Level II persistent toxic substances except alkyl lead and tributyl tin. No information on quantified confirmed reductions was included in the survey response.

Michigan's Great Lakes Air Toxics Program includes the Michigan Air Toxics Rules requiring best available control technology for all Level I and Level II substances be installed on all new and modified sources. The rules also require source demonstration that impacts of toxic air contaminant emissions are below the health-based screening levels.

New York, Ohio and Pennsylvania all have programs by which new and existing sources of air toxics emissions and appropriate control requirements are reviewed on a case-by-case basis. Ohio and Pennsylvania require best available technology; in Ohio, this regulation applies to all sources, whereas in Pennsylvania, it is required only for new sources. Again, no report of confirmed emissions reductions was given in response to the survey questionnaire.

In addition, the Great Lakes states, U.S. EPA and the Canadian and Ontario governments all support the continued development of the Great Lakes Regional Air Toxics Inventory effort, which should establish the baseline and, if maintained, allow for quantification of regional reductions of several Level I and II substances.

Both Canada and the United States have made marked progress in meeting their commitments under Annex 15 of the Agreement. Detailed assessment of progress under the annex in reducing persistent toxic substances is clearly an iterative process which is, as yet, in its early stages. With the signing of the strategy in April 1997, IJC should continue to track further quantification of emission reductions of Level I and II contaminants over the coming decade.

Applicability of Beyond Compliance Programs to the Great Lakes Binational Toxics Strategy (WQB)

There is no doubt the regulatory programs (i.e. compliance programs) are effective at reducing persistent toxic substance loadings to the Great Lakes, however, further reductions in loadings are required to achieve the virtual elimination goal. A current priority for management agencies is evaluating the potential role that voluntary, beyond compliance programs could play in the virtual elimination of persistent toxic substances.

WQB commissioned a study (Linett 1997) of current success of voluntary compliance programs in Illinois, Ontario, Michigan, Environment Canada and U.S. EPA Region 5. This study found that governments have developed a number of successful voluntary, beyond compliance programs. In general, the jurisdictions are expanding the number and reach of these programs. Additionally, the jurisdictions are actively developing experimental programs that offer program participants incentives in the form of administrative and regulatory flexibility.

Many of these beyond compliance programs have resulted in increasing participation rates and some have documented release reductions (Table 6). Whether these programs can be expanded and targeted to all Level I and II substances is, in part, a function of the contaminant source and how they are being used.

Table 6. Examples of Successful Beyond Compliance Initiatives in the Great Lakes Basin.

Automobile Pollution Prevention Project All Great Lakes states 15% reduction in the overall releases of persistent toxic substances (a reduction of 0.18 kg of release for every vehicle manufactured in U.S. facilities)
Trade Association Partnerships Ontario Automobile Manufacturing - 150,000 tonnes per year reduction
Metal finishing/electroplating - 287 tonnes per year reduction
Automobile parts manufacturing - 660 tonnes per year reduction
Mercury Pollution Prevention Project (which targeted dental offices) Michigan 591 kg of mercury were collected from dental offices in Detroit January-June 1996
Accelerated Reduction / Elimination of Toxics (ARET) Program Canada Over 100 organizations have participated and achieved: a 100% reduction in alkyl lead; a 40% reduction in benzo(a)pyrene; a 52% reduction in HCB; a 100% reduction in octachlorostyrene; and an 89% reduction in dioxins/furans.

Many pesticides are banned in the U.S. and Canada; others are restricted. In addition, many contaminants have no commercial value and are generated as byproducts. Traditional, voluntary, beyond compliance programs, which generally have involved promoting pollution prevention through award, partnership and technical assistance programs, may have limited applicability in addressing these contaminants. Other contaminants, still used in production, services and activities (e.g. cadmium), may be more conducive to traditional, beyond compliance programs. In other cases, such as octachlorostyrene, no intentional commercial production ever existed and the industrial process that generated this contaminant was discontinued in the 1970s. In still other cases (e.g. dioxin and PAHs), the substances are unintentional byproducts of current industrial practices.

In general, larger facilities with environmental health and safety staffs have been open to pollution prevention initiatives. Many costs previously associated with waste treatment and management are avoided. Many smaller facilities require technical assistance to realize the benefits associated with pollution prevention. Facilities may be willing to take further voluntary actions, but they need to realize benefits, such as longer permit terms, fewer reporting requirements and more flexibility in achieving environmental objectives.

New government policies directed at pollution prevention, as well as the threat of regulation, have spurred prevention actions. Regulatory flexibility and economic incentives can result in further reductions of persistent toxic substances. Whether voluntary, beyond compliance programs can generate sufficient reductions to satisfy ambient air level requirements is an open question. Governments should give voluntary, beyond compliance programs the opportunity to work and ensure that these programs are implemented in a cost-effective fashion.

Recommendations to IAQAB from Linett (1997)


Cohen, M., B. Commoner and P. Cooney. 1997. The Transport and Deposition of Persistent Toxic Substances to the Great Lakes. Center for the Biology of Natural Systems, Queen's College, City University of New York.

Environment Canada and U.S. Environmental Protection Agency. 1997. The Great Lakes Binational Toxics Strategy -- Canada-United States Strategy for the Virtual Elimination of Persistent Toxic Substances in the Great Lakes. Toronto, Ontario and Chicago, Illinois, 23 pp.

Hoff, R.M. and K.A. Brice. 1994. Atmospheric Dry Deposition of PAHs and Trace Metals to Lake Ontario and Lake Huron, In Proceedings of the 87th Annual Meeting of the Air and Waste Management Association, vol. 28, Pittsburgh, PA: The Association.

Hornbuckle, K.C., J.D. Jeremaison, C.W. Sweet and S.J. Eisenreich. 1994. Seasonal Variations in Air-Water Exchange of Polychlorinated Biphenyls in Lake Superior. Environ. Sci. Technol. 28:1491-1501.

Linett, R. 1997. Report on Applicability of Voluntary, Beyond Compliance Programs to the Virtual Elimination Strategy. Science Applications International Corporation, McLean, Virginia, 38 pp. Report submitted to the Great Lakes Water Quality Board, International Joint Commission, Windsor, Ontario.

U.S. Environmental Protection Agency. June 1997. Baseline Emission Inventory of the Seven Toxic Air Pollutants required by Section 112(c)(6) of the CAA of 1990. Website:


United States Members Canadian Members
Dr. Gary J. Foley, Co-Chair
Director, National Exposure Research Laboratory (MD-75)
U.S. Environmental Protection Agency
Catawba Building, Progress Center
3210 Highway 54
Research Triangle Park, North Carolina 27709
Dr. Don McKay, Co-Chair
Director, Air Quality Research Branch
Atmospheric Environment Service
Environment Canada
4905 Dufferin Street
Downsview, Ontario M3H 5T4
Mr. Richard S. Artz
Air Resources Laboratory
National Oceanic and Atmospheric Administration
Room 3151, SSMC3, R/E/AR
1315 East West Highway
Silver Spring, Maryland 20910
Dr. David V. Bates
Department of Health Care & Epidemiology
University of British Columbia
MATHER Building
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Vancouver, British Columbia V6T 1Z3
Mr. Harold T. Garabedian
Deputy Director
Vermont Agency of Natural Resource
103 South Main Street
Waterbury, Vermont 05671-0402
Dr. David I. Besner
Executive Director
Corporate Services
New Brunswick Department of the Environment
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Fredericton, New Brunswick E3B 5H1
Dr. Paul J. Lioy
Environmental and Occupational Health Sciences Institute
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Piscataway, New Jersey 08855-1179
Mr. D. Wayne Draper
Associate Director
Transboundary Air Issues Branch
Environment Canada
Place Vincent Massey
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Hull, Québec K1A 0H3
Dr. Kathy Ann Tonnessen
National Park Service
Air Resources Division
P.O. Box 25287
Denver, Colorado 80225-0287
Mr. Edward W. Piché
Environmental Monitoring and Reporting
Ontario Ministry of Environment and Energy
125 Resources Road, West Wing
Etobicoke, Ontario M9P 3V6
Former Member

Dr. J.W.S. Young
SENES Consultants

Section Liaisons

Dr. Joel Fisher
United States Section
International Joint Commission
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Washington, D.C. 20440


Mr. John F. McDonald
Great Lakes Regional Office
International Joint Commission
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Windsor, Ontario N9A 6T3

Mr. Edward A. Bailey
Canadian Section
International Joint Commission
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Ottawa, Ontario K1P 5M1


1 In September 1996, the International Joint Commission endorsed this policy statement as its position on municipal waste incineration.

URL: http://www.ijc.org/rel/boards/iaqab/pr9597.html