PRELIMINARY ASSESSMENT OF CONTAMINATED GROUND WATER DISCHARGE TO GREAT LAKES TRIBUTARIES by Michael J. Barcelona, Ph. D. Interim Chairperson, Dept. of Chemistry, WMU Kalamazoo, MI 49008 and Kevin D. Lund, PE, CPG, Senior Geologist, Michigan Department of Environmental Quality, Remediation and Redevelopment Division, Livonia, MI 48152 A White-Paper Proposal to the USEPA Great Lakes Center for Environmental and Molecular Sciences, Western Michigan University, Environmental Institute and Altarum Institute PRELIMINARY ASSESSMENT OF CONTAMINATED GROUND WATER DISCHARGES TO GREAT LAKES TRIBUTARIES PROBLEM DEFINITION This proposal has been prepared to perform a focused, preliminary assessment of the magnitude of contaminated ground water discharge to the Great Lakes. In addition to permitted NPDES (National Pollution Discharge Elimination System) discharges to rivers and streams tributary to the lakes there are numerous non-point sources which have proved difficult to estimate. There have been many pieces of legislation designed to address these problems. The Clean Water Act (CWA) identifies non-point sources of pollution as due to the action of rain, snow melt or irrigation waters which pick up pollutants and transport them in surface or ground waters. Section 319 of the CWA addresses these sources in a three stage process which includes: 1) conduct statewide assessments of waters which may be impaired by non-point sources, 2) develop non-point source management plans for impaired or threatened waters, and 3) award funds to States (and Tribes) to implement EPA approved non-point source management programs. There has been very little work done on the assessment of the groundwater transport of non-point source pollution. It is recognized that contaminated sediments are a significant non-point source to the Great Lakes. However, ground-water discharges through coastal and river sediments to the Great Lakes have yet to be included in Lakewide Management Plans. (USEPA, 2000) These Plans transition from phase 1 (impaired use areas/problem definition) through phase 2 (source and risk assessment) to phase 3 (risk and impairment reduction strategies to restore beneficial uses). Progress is reported every two years. Michigan's progress is reported in its Water Quality and Pollution Control Report. (MDEQ-SWD, 2002) The contaminants of most frequent concern include: PCB's, organic compounds, Hg, and nutrients. The types of potential sources to be considered in this proposal are shown in Table 1 (below). Table 1 Potential Ground Water Sources of Pollution to the Great Lakes Direct: Ground Water Contaminant Plume Discharges to the Great Lakes Indirect: Ground Water Contaminant Plumes Discharges to tributary rivers and streams (e.g. Brownfields, Remedial Action Plan- GSI (Ground Water Surface Water Interface) Sites) Ground Water Discharge through contaminated river, coastal, lacustrine or harbor sediments There are two major obstacles to the assessment of the first two potential sources (above) of contaminants to the Great Lakes. The first is an accurate estimate of the number and magnitude of direct or indirect contaminant discharge sites. Many of these sites have been diagnosed by the use of GSI calculations. Monitoring of the ground water is required by these programs, but no actual surface water verification of concentrations in the receiving water body is required. (MDEQ, 1998) 1 The second obstacle is the calculation of the contribution of contaminated ground water discharge relative to total discharge to the lakes. We have participated in attempts to conduct these measurements particularly for evidence of oxidation-reduction of contaminants which can undergo reactions consequent with degradation or mobile chemical species production. (Dean et al., 1999, Lendvay et al., 1998) The results have been encouraging, but much work remains to be done. The GSI assumptions with regard to mixing zones are more likely valid for direct discharges to the Great Lakes than to inland lakes or rivers. The importance of the third source noted above is very difficult to assess since the bulk of the sediment contamination resides as sorbed, low solubility organic compounds (e.g. PCB’s). It may be that in the absence of episodic resuspension of fine sediments, this source may not contribute significantly to the total non-point discharge of the Great Lakes. However, there are major concerns in small limited catchment lakes and in contaminated river reaches where pore water from contaminated sediments could carry breakdown or reduction products. (MDEQ SWD, 2002) Data on discharges of contaminated ground water to surface at known Superfund, RCRA (Resource Conservation and Recovery Act), state remedial, and “Brownfield” sites would be the most accessible to researchers. In the Great Lakes Basin, however, there are probably more than 5,000 such sites and the task of cataloguing alone could be overwhelming. We propose to develop and apply detailed cumulative contaminant and discharge data criteria for at least one of Michigan’s fourteen Areas of Concern (AOC’s), ten of which are wholly within Michigan borders. There are forty-three AOC’s in the Great Lakes Basin where water quality has caused beneficial use impairments. In this sense our “white-paper” would constitute a probe into relative source contributions at known areas or locations contributing to use impairment in the Great Lakes Basin. WHITE PAPER WORK PLAN The specific goals of this project are to: select a subset of Michigan sites which are representative of direct and indirect sources of contaminated ground water discharge in a single watershed; collect available data on contaminant types, concentration levels; mixing zones (for GSI sites); and estimate the high/low flow contributions of contaminants to the total river discharge or inland lake volume. If we can locate desirable, accessible locations in the white paper work, it would be useful under full proposal support to measure actual discharges of contaminated ground water in the hyporheic zone where discharge may have an adverse impact on wildlife before adequate mixing can occur (i.e. in sediment pore waters). These data would then be placed in a Microsoft Access database which eventually could be referenced with other data in the Michigan Geographic Data Library. The state datasets, some of which have been constructed recently under the Map Michigan Initiative, include Michigan Department of Environmental Quality data on surface and ground water quality, Unified Watershed Assessments and Fish Contaminant Monitoring Program among others. Two principal hypotheses would be explored in the initial “white-paper” assessments. 2 1) Multiple sources of contaminated ground-water discharge to a particular tributary river can significantly contribute to degradation of surface water quality. 2) The potential for significant effects of ground-water discharge of contaminants increases during low-flow conditions when ground-water base flow contributes proportionally more to total discharge. The test of these hypotheses in an area of known degraded water quality would allow us to determine whether further investigation at the basin wide or watershed level assessment is warranted. In other words, if the impact of known ground water discharges relative to other sources is insignificant in a degraded lake, river reach, or tributary stream then it is unlikely that isolated sites materially contribute to overall lake loadings or TMDL'S (Total Maximum Daily Loadings). If on the other hand, the potential impacts are significant, this could lead us to modify GSI criteria, TMDL'S unified watershed assessments, and conduct more focused activities in the state’s Fish Contaminant Monitoring Program. Conceivably this could lead to improved methodologies to choose locations for monitoring exposure assessment, health impacts and remediation activities. We expect to choose at least one contaminated inland lake and a river search which is in one of the identified Areas of Concern. The emphasis would be on contaminants which are known to be toxic to fish and humans and may undergo reactions/microbial breakdown to toxic species. (e.g. perchloroethyleneTCEDCEvinyl chloride, Hg (II) to methylmercury). At this time, we propose to focus on an inland lake with a contamination problem and evaluate the relative contributions of recognizable sources. Candidate lakes include: Whites Lake (PCE and Hg) and Torch Lake (Cu) among others highlighted in: Evans and Creal, 1991; Creal and Wuycheck, 2002; Sills, 1992; Long et al, 2001, Aiello and Smith, 2002. Whites Lake is sufficiently contaminated to be considered an AOC itself. Candidate river reaches, all AOC's, would be on the Kalamazoo or Saginaw River or potentially one of the rivers in Southeast Michigan for which intensive data collection has been conducted (Lundgren et al, 1993). DATA COLLECTION AND ANALYSIS For each of the candidate sites, data collection from MDEQ would be conducted to identify: known sites, GSI status, and potential contribution to dissolved contaminant discharge with an emphasis on reactive, toxic, chemical species (e.g. Hg+, Hg++ or methyl-Hg) Then, from the list of candidate sites, the inland lake and river reach with the most extensive contaminants and discharge data would be selected for more in depth analysis of annual contribution to contaminant loading and seasonal or high/low water variability in total loadings. These values would be compared to existing or proposed TMDL's. Recommendations would be made for improved monitoring, GSI calculation assumptions, or management options. The results of all the data collection and analysis would be highlighted in the white paper. Justification for the more an in depth evaluation, including budget and work plan for data 3 collection and modeling of actual loads at the most interesting site would be included towards preparation of a full proposal. The white paper support would be for a summer student and travel at $5000. PROPOSAL SCOPE AND MAGNITUDE At this point we expect that at least one, if not both, of our white paper hypotheses will be borne out for a limited subset of sites, given that we have picked sites which are or could be Areas of Concern. The primary issue remaining once hypothesis 1 is borne out is an estimation of the actual load of contaminant discharge over time would be important to both human and environmental exposure reduction efforts. We expect to better enable the MDEQ and other regulatory agencies to assess the threat and how best to reduce it. The principal limitation to current regulatory efforts at GSI's is that the sites are dynamic not static as permit calculations assume. The effects of chemical and microbial reactions in shallow sediments and the hydrodynamics of receiving waters are important. Integrated reactive transport modeling would have to be done if the data will support it. A number of investigators have proposed more complex, but realistic computational models of GSI sites. (RTDF, 2002) Among the presenters at this meeting, Dr. Brewster Conant of the University of Walterloo has expressed an interest in collaboration of this nature. He may be called upon for preparation of the proposal should the white paper assessment prove to be successful since he is aware of some of the problems associated with this work. (LaBolle et al, 2003) Assuming that the white paper effort is successful, we would expect to prepare a two year work plan for: 1) the parallel collection of additional more temporally dense, chemical and hydrologic data (parallel with an MDEQ effort if possible), 2) preliminary hydrologic model application and calibration, 3) integration of the chemical and hydrologic dynamics of the GSI condition in either a combined chemical reaction/transport model or stepwise application of reaction path/transport models and 4) projection and comparison of measured versus modeled discharge and contaminant load estimates. Support would be requested principally for: limited PI time ( 5% per year), student support and sampling and analysis support. The total request would be $50,000/year in direct costs. 4 REFERENCES Aiello, C. and J. Smith. 2002. Water Chemistry Trend Monitoring Project 1998-1999. Michigan Department of Environmental Quality, Surface Water Quality Division. Report #MI/DEQ/SWQ-02/025 Creal, W. and J. Wuycheck. 2002. Clean Water Act Section 303(d) List: Michigan Submittal for 2002. Report #MI/DEQ/SWQ-02/013 Dean, S.M. J.M. Lendvay, M.J. Barcelona, P. Adriaens and N.D. Katapodes Installing MultiLevel Sampling Arrays to Monitor Ground Water and Contaminant Discharge to a Surface Water Body. Ground Water Monitoring and Remediation, 18, 4, 90-96, 1999 Evans, E., M. Wilson, and W. Creal. 1991. Assessment of Mercury Contamination in Selected Michigan Lakes, 1987-90: Historical Trends, Environmental Correlates, and Potential Sources. Michigan Department of Natural Resources, Surface Water Quality Division. Report #MI/DNR/SWQ-91/106 Great Lakes Environmental Center 2001. Water Quality Monitoring of Saginaw Bay and Grand Travers Bay, Final Report. Report #MI/DEQ/SWQ-01/017 Jones, R.J. and K. Gerald 1999. Reference Site Sediment Chemistry Report for Wadable Streams, 1994, 1997, and 1998. Michigan Department pf Environmental Quality, Surface Water Quality Division, Report #MI/DEQ/SWQ-99/060 LaBelle, E.M., Ayman Ahmed and G.E. Fogg (2003) Review of the Integrated Ground Water Surface Water (IGSM model). Ground Water, 41, 2, 238-246. and Lendvay, J.M., W.A. Sauck, M.J. Barcelona, D.H. Kampbell, J.T. Wilson and P. Adriaens, 1998 Geophysical Characterization Redox Zonation, and Contaminant Distribution at a Ground Water/Surface Water Interface, Water Resources Research, 34, 12, 3545-3549, 1998. Long, D.T., J.P. Giesy, S.J. Simpson, and J.D. Fett. 2000. Inland Lake Sediment Trends: Sediment Analysis Results for Five Michigan Lakes. Final Report 1999-2000. Michigan State University. Report #MI/DEQ/SWQ-01/030 Lundgren, R. 1993. Ambient Water Monitoring in Michigan: Concentration and Loading Trends in the Detroit River and Great Lakes Tributaries, 1969-1991. Michigan Department of Natural Resources, Surface Water Quality Division. Report #MI/DEQ/SWQ-93/054 MDEQ-SWD, 2002, Water Quality and Pollution in Michigan 2002 Section 305(b) Report. Michigan Department of Environmental Quality Surface Water Quality Division, April 2002. (MI/DEQ/SWQ-02/024) MDEQ-ERD, 1998, Environmental Response Division Memorandum #17 Instructions for Obtaining Determinations on Mixing Zone Based Ground Water Surface Water Interface Criteria for Inclusion in Remedial Action Plans and Monitoring Compliance with Criteria for Discharges of Ground Water Contaminants to Surface Water. September 8, 1998 RTOF, 2002. Sediment Remediation Technologies Development Forum, Oct 2002. Sills, R. 1992. Mercury in Michigan's Environment: Causes and Extent of the Problem. Michigan Department of Natural Resources, Surface Water Quality Division. USEPA. 2000. Lake Michigan Lakewide Management Plan (LaMP 2000). Produced by TetraEM Inc., Chicago 5 Tech