A Multimedia Strategy
for Priority Persistent, Bioaccumulative, and
            toxic (PBT) Pollutants
                  Prepared By
     The USEPA Persistent, Bioaccumulative and
        Toxic Pollutants (PBT) Plenary Group


     The USEPA Office Directors Multimedia and
            Pollution Prevention Forum
               November 16, 1998


       The PBT Plenary Group is comprised of program and technical experts from seven EPA •
Program Offices (i.e., the Office of Air and Radiation; the Office of Enforcement and
Compliance Assurance; the Office of International Activities; the Office of Prevention,
Pesticides and Toxic Substances; the Office of Research and Development; the Office of Solid
Waste and Emergency Response, and the Office of Water), the Great Lakes National Program
Office, and the Regions. OPPTS chairs the group. The mission of the Plenary Group is to  •
develop the PBT strategy and identify and resolve issues associated with strategy
implementation.                                           '...".

       The Office Directors' Multi-Media and Pollution Prevention (M2P2) Forum was
established by Deputy Administrator Fred Hansen in 1997 to examine a variety of multi-media
and pollution prevention issues. The PBT Strategy is a central focus of the M2P2 Forum. More
than 20 of EPA's program offices and regions are represented in the Forum. The Office of
Prevention, Pesticides and Toxic Substances (OPPTS) and the Office of Water currently co-chair
the Forum.
 Draft PBT Strategy                           ii                          November 16, 1'998

                              .,  TABLE OF CONTENTS
            "     -. '.

       ... .

 I.   PURPOSE   ....................	.....;•.      '',-

•II.   GOAL ...,....,	•••,..,.................

 III.   FOUNDATION AND GUIDING PRINCIPLES .........                                0
                                                •••••••.	• •	 . 2.
         '-            -.'".-,          -.'=.'"    .      . -           *
•IV.   APPROACH TO PBT RISK REDUCTIONS  .........                         •        o
                                               	'•••••ปซ••	,	  ฃ

         JActivities Underway or Planned for Near-Term Action'.'. ..". v . . . : .  ...',            3
         Strategy Elernents ..	;	 ....•..; ; ..."                 6
         ..1. Develop and Implement National Action Plans ....... .". , .'.....,..  '''"'•• '..     Q
         2. Screen and Select More Priority PBT Pollutants for Action '. ...........        Q
         3. Prevent the-Introduction of New PBT .Pollutants  ..................'...-    9
         4. Measure Progress by Linking Activities to Environmental Results  . . . !' ; . . . '. • .. .  .10

 V.  MANAGING FOR SUCCESS . . . . ...........................                12

         ^Managing the Implementation of the Strategy ....-........;.. . .  ...  .....     12
         Establishing Linkages Among Current Program Efforts	....'...'   14
         ^Stakeholder Involvement" . ...... . .... .  . . . . ...;..;........ {\          ^5

 REFERENCES   	.;:....;,.'                          '''.'':        -    .      17
 GLOSSAL	:.......,	'............'.'/.'.'.'/.'.[]['.;;.;;;;;;;;;;;-.;;;   \9

 APPEND\X;;A --  GPRA Goals and Objectives supported by the PBT Strategy . ... . . . .  Appendix A-l
 APPENDIX B -  Status of Developments on Bmational Toxics Strategy. Level 1  '
         'Substances. . . ; . .	...>.;..... .'. . . ... ;/...;. . . .:	Appendix B-1

     ATTACHMENT 1. DRAFT MERCURY ACTION PLAN .................. Attachment t-1
 Draft PBT Strategy
November 16, ''1998 '

                                EXECUTIVE SUMMARY
Purpose and Goal
                                            .                 "      '              *
    The goal of this strategy is to further reduce risks to human health and the
environment from existing and future exposure to priority persistent, bioaccumulative, and
toxic (PBT) pollutants.

    The U.S. Environmental Protection Agency (EPA) has developed this draft strategy to
overcome the remaining challenges in addressing priority PBT pollutants. These pollutants pose
risks because they are toxic, persist in ecosystems, and accumulate in fish and up the food chain.
The PBT challenges remaining stem from the pollutants' ability .to travel long distances, to
transfer rather easily among air, water, and land, and to linger for generations, making EPA's
traditional single-statute approaches less than the full solution to, reducing risks from PBTs.  Due
tq a number of adverse health and ecological effects, linked to PBT pollutants ~ especially
mercury, PCBs, and dioxins -- it is key for EPA to aim for further reductions hi PBT risks. "The
fetus and child are especially vulnerable.  EPA is committing, through this strategy, to create an
enduring cross-office system that will address the cross-media issues associated with priority
PBT pollutants.

Building on a Strong Foundation

    This strategy reinforces and builds on existing EPA commitments related to priority PBTs,
such as the 1997 Canada- U.S. Binational Toxics Strategy (BNS), the North American
Agreement on Environmental Cooperation, and the recently released Clean Water Action Plan.
EPA is forging a new approach to reduce risks from and exposures to priority PBT pollutants
through increased coordination among EPA national and regional programs. This approach also
requires the significant involvement of stakeholders, including international;, state, local, and
tribal organizations, the regulated community, environmental groups, and private citizens.

Approach to PBT Reductions                     .

1.  Develop and Implement National Action Plans for Priority PBT Pollutants. EPAis
     initially  focusing action on the 12 BNS Level 1 substances: aldrih/dieldrin, benzo(a)pyrene,
     chlordane, DDT, hexachlorobenzene, alkyl-lead, mercury and compounds, mirex,
     octachlorostyrene, PCBs, dioxins and furans, and toxaphene.  EPA is developing action
     plans that will use the full range of its tools to prevent and reduce releases of these 12 (and
     later other) PBTs. These tools include international, voluntary, regulatory, programmatic,
     remedial, compliance monitoring and assistance, enforcement, research, and outreach tools.
     EPA will analyze PBT pollutant sources and reduction options as bases for grouping
     pollutants, activities, and sectors to maximize efficiencies in achieving reductions. EPA will
     integrate and sequence actions within and across action plans, and will seek to leverage
     these actions on international and industry-sector bases.
 Draft PBT Strategy                          .  iv                       .   November 16, 1998

    Activities ready for near-term action include:

     V    Conduct process-specific and pollution prevention (P2) projects un'der the mercury'
          action plan, including regulatory actions to reduce mercury and voluntary reductions -
          through potential partnerships with various industries (e.g., chloralkali industry,
          hospitals using mercury-containing products').              •                 '  -
     *     Focus enforcement and compliance assistance activities nn PRT^ analy^ng   -.
          compliance within PBT-related sectors for problems and opportunities.. Select
:         industries/sectors, or-regulations that wouldbenefit from focused compliance
          attention/assistance.. Target actions with high potential to reduce PBT releases.
    ,*     Develop or revise" water quality criteria for mercury and other priority PRT^ and
          revise methodology for mercury water quality criteria.
    *     Conduct research and analysis on PBTs."especially nn mPrri.ry^micgjon controi
          approaches for coal-fired utility boilers, and on the transport, fate, arid risk
          management of mercury. Develop P2 options for preventing mercury/dioxin risks
          from industrial combustion.
    .*•     EPA is actively engaged in international efforts hevond the RNS to reduce PBT risks.
          including the recently negotiated Persistent Organic Pollutants (POPs) and Heavy
          Metals protocols to the UN Economic'Commissiqri for Europe's Long Range
          Transboundary Air Pollution Convention, the preparation for the upcoming
          negotiation of a global POPs convention under UN Environmental Program auspices,
          and the Regipnal Action Plans on DDT, chlordane, PCBs, and mercury developed
          under auspices of the. North American Commission for Environmental Cooperation.
           ซ      •-     •                   '   •       • •      ^           _ .    •  ,      '
2.     Screen and Select More Priority PBT Pollutants for Action.  Beyond the BNS Level 1
       substances, EPA will select additional PBT pollutants for action. EPA will apply
       selection criteria in consultation with a technical panel.  Candidate chemicals will be ,
       those highly scored .by EPA's  Waste Minimization Prioritization Tool and other
       chemicals of high-priority to EPA offices.  EPA will seek internal and external comment
       on the proposed selection methodology in 1999.

3.     Prevent Introduction of New PB Ts., EPA is acting to prevent new PBT chemicals from
       entering commerce by: (a) proposing criteria for: requiring testing/restrictions on new
       PBT chemicals; (b) developing a rule to control attempts to re-introduce out-of-use PBT
       chemicals into commerce;  (c)  developing incentives to reward the development of lower-
       risk chemicals as alternatives to PBTs; and (d) documenting how PBT-related screening
       criteria are taken into account for approval of new pesticides and re-registration of old
       pesticides.,     '           ''_                                   ;     • '        ,

4.     . Measure Progress. EPA is defining measurable objectives to assess progress.. EPA will
       use direct .and indirect progress measures, including: (a) human health or environmental
    .   indicators (such as National Health and Nutritional Examination Surveys and a national
       study of chemical residues in fish); (b) chemical release, waste .generation or use
       indicators (such as enhancing the Toxics .Release Inventory and using other release

 Draft PBT Strategy        '    .   .             v          .                'November 16, 1998

       reporting and monitoring mechanisms); and, (c) program activity measures (such as EPA
       compliance/enforcement data).

Mercury -- An Action Plan Example

       EPA's PBT Strategy is a living document that supports the development and
implementation of action plans on priority PBTs. Attached to the strategy is EPA's draft,
Mercury Action Plan.  It illustrates an action plan that is national and even international in
scope, and describes the kinds of actions EPA may take to reduce risks posed by other priority
PBT pollutants. Each substance or group of substances will present its own set of action
  Draft PBT Strategy
                                            vi                          November 16, 1998


        A' key purpose of this strategy is to overcome the remaining challenges in addressing
 priority persistent and bioaccumulati've toxic (PBT) pollutants. EPA has a long history of,   -
: successful programs in. controlling PBT pollutants - pollutants that are toxic, persist in the
 environment, and bioaccumuiate in food chains, and thus pose.'risks to human health and
 ecosystems. The challenges remaining on PBT pollutants stem'from the fact that they transfer
 rather easily'among air, water, and land, and span boundaries of programs, geography, and
 generations, making single-statute approaches less than the full solution, to reducing these risks.
 To achieve further reductions, a multi-media approach is necessary. Accordingly, EPA is
 committing, through this strategy, to create an enduring cross-office system that will address the
 cross-media issues associated with priority PBT pollutants,

        Many single-medium offices have established a sequence of activities aimed at further
 reducing PBT risks within their media. To better address the cross-media aspects of PBT
 pollutants, however, EPA programs must integrate their work across media more thoroughly and
 align their domestic and international activities more effectively. The intention of this strategy is
 to make the whole of the Agency's efforts on PBT pollutants more than the sum of its parts.
 EPA will coordinate its use of statutory authorities and resources to maximize public health and
 environmental protection.  Environmental results anticipated from implementing this strategy
 will derive from stronger multi-media coordination among national and regional EPA programs,
 and through the significant involvement of stakeholders.

        (jroups outside EPA also-recognize the need for a cross-program, multi-media approach
 to environmental problems like PBTs. Recommendations consistent with this strategy are in
 three recent reports: (a) the 1998 Natural Resources Defense Council Report, "Contaminated
 Catch - The Public Health Threat from Toxics in Fish" (prevent persistent pollution, control
 pollutants that cross media);  (b) the National Academy of Public Administration's 1995 Report,
 "Setting Priorities, Getting Results - A New Direction for EPA" (set priorities by risk, integrate
 'efforts across media/statutes); and, (c) the Organization for Economic Cooperation and
 Development's (OECD) 1996 Report, "Environmental Performance Review of the United
 States" (coordinate/integrate EPA chemical programs with EPA media programs).


        The goal of this strategy must be measurable in terms of environmental results. EPA's
 strategic goal is to identify and reduce risks to human health and the environment from

 Draft PBT Strategy   ,         '      "      1           ,          "•;    November16, 1998

current and future exposure to priority PBT
pollutants.  PBTs are associated with a range of
adverse human health effects, including effects on
the nervous  system, reproductive and
developmental problems, cancer, and genetic
impacts.  People who eat large amounts of fish
from local waters contaminated with certain
PBTs are at risk for adverse effects. The
developing fetus and young child are at particular
risk for developmental problems.  Birds and
mammals at the top of the food chain are also at
risk. The most famous example is the serious
decline of the bald eagle in the 1960's because the
fish they ate contained DDT.  The DDT did not
kill them or make them sick, but it did make their
eggshells so thin it seriously threatened their
ability to reproduce.

Characterizing Chemicals as
Persistent, Bioaccumulative, and

      This strategy characterizes
PBT chemicals as those that partition
primarily to water,, sediment or soil,
and are not removed at rates adequate
to prevent their bioaccumulation in
aquatic or terrestrial species..
Chemicals characterized as suspected
persistent bioaccumulators typically  .
have been confirmed as such based on
accepted test methods. Follow-on
toxicity testing leads to their
identification as persistent and
bioaccumulative toxic chemicals.
       Building on a Strong Foundation. This strategy reinforces and builds on an existing
federal commitment to deal with PBT pollutants. EPA's commitment to control, remediate, and
prevent releases of PBTs (such as lead, mercury, PCBs, and DDT) is reflected in efforts that span
25 years. Among EPA's current commitments on PBTs are the 1997 Canada-U.S. Strategy for
the Virtual Elimination of Persistent Toxic Substances in the Great Lakes (Binational Toxics
Strategy or BNS), its cross-Agency Task Forces on lead, mercury, and dioxin, its Waste
Minimization National Plan, its Contaminated Sediment Management Strategy, its recently
announced Clean Water Action Plan, and the PBT emphasis in its new Chemical Right-to-Know
program announced by the Vice President in April 1998.

         Identifying and managing PBT pollutants is a priority for key international-
organizations at both regional and global levels.1 Recognizing that many PBTs circulate at '**•
regional and even global scales, nations find they must cooperate to reduce PBT risks.  Often**
 spurred by U.S. Government leadership, these international organizations are developing and
 implementing risk reduction measures ranging from technical assistance programs to build
.institutional capacities for dealing with PBTs to legally-binding international agreements for
 phasing out production and use of selected PBTs.
        1 PBT pollutants are addressed by such fora as the North American Commission for Environmental
 Cooperation (CEC), the UN Economic Commission for Europe Convention on Long Range Transboundary Air
 Pollution (LRTAP), the Arctic Council, the UN Environment Program (especially its negotiations on.a global
 Persistent Organic Pollutants Convention), and the Intergovernmental Forum on Chemical Safety (IFCS).
  Draft PBT Strategy
                                                                         November 16, 1998

 -      .  Guiding Principles. EPA will follow these principles in carrying putlts PBT strategy:

 *:      Address problems- on multi-media bases through integrated use of all Agency tools
         Coordinate with and build on relevant international efforts.
 *       Coordinate with relevant Federal programs and agencies.   -••'•'•             •   '
 *       Emphasize cost-effectiveness (e.g., amount-ofTBT removed per dollar spent)    '
        >Involve stakeholders.                                            .        .
         Emphasize use of innovative technologies and pollution prevention. •:             "
 *  •   -  Protect vulnerable sub-populations.                    •'  "•-'•••    '
 *       Base decisions on sound science.                 .                         .    •
         Use measurable objectives and assess performance (see page 10 on GPRA).


.        Four elements are central to EPA's PBT strategy. They are: (1) developing and
 implementing national action plans for priority PBT pollutants using the full range ofEPA tools
 to achieve risk reduction; (2) screening and selecting more priority PBT pollutants for action-
.(3) preventing :the introduction, of new PBT pollutants into commerce; and, (4) measuring  '
 progress by linking activities to environmental results. All of these elements require a
 heightened level of multi-office integration in planning, budgeting, and implementation  Figure
 1  on  page 7 shows the framework EPA is using to carry Out .these elements.   . •           :

    ••    Below is a description of activities being undertaken in 1998-1999. Following that is a
 more detailed explanation of each of the four strategy elements.

 Activities Underway or Planned for Near-Term Action2

        Offices abbreviated in parentheses are funding the stated.activity.  Generally, all other
 offices are also participating:                  .                     ' '."

 •      Develop and Integrate National Action Plans.
        *   Support/build upon evolving BNS Level 1 action plans as bases for developing     Y
            national action plans on 12 Level 1 pollutants (as listed on p. 6) (GLNPO OIA OW
            --Fall 1998-ongoing).          .  .          '             ,             '
    /     *  • Focus on appropriate risk, use, and release reduction actions, and sequence them as
            needed for implementation. When possible, group chemicals for action to achieve
           '• efficiency and consistency (Fall/Winter 1998-ongoing).      <
         Office abbreviations'for this se'ction are OAR (Office of Air arid Radiation), OEC A (Office of
  Enforcement and Compliance Assurance), OIA (Office of International Activities), OPPTS (Office of Prevention,
  Pesticides, and Toxic Substances), ORD (Office of Research and Development), OSWER (Office of Solid Waste'
 .and Emergency Response), OW (Office of Water) andGLNPO (Great Lakes National Program.Office).  "
                                                                         i    '
                       1           ' . •       "".      '     ' '   ,     '  '             ' .  '

  Braft PBT Strategy        '.                /3               ,             November. 16, 1998

       >• •   Align work and roles across Headquarters and Regional programs to prepare for
           implementing action plans (OPPTS, OSWER, Regions -- Fall 1998 - ongoing).

•      Engage Stakeholders Nationwide (OPPTS).
       ป•    Engage stakeholders on (1) draft strategy, (2) development/implementation of action
           plans, and (3) criteria for selecting more PBTs for action (Fall 1998 -- ongoing).

•      Implement Process-Specific and Pollution Prevention (P2) Projects Under Draft
       Mercury Action Plan (OAR, OECA, OPPTS, -OS WER, O W, Regions).
       >    Use regulatory authorities to reduce mercury emissions.  (Recently-final municipal
           waste combustor and medical waste incinerator rules will get significant reductions.)
          . Evaluate linkages between air emissions and water quality impacts for targeted,
           regulatory action.  Develop pollution prevention (P2) guidelines and incentives in
           rulemakings addressing mercury (Summer 1998 arid ongoing).
       >    Seek voluntary reductions in uses of mercury through partnerships with the chlor-
           alkali industry, hospitals using mercury-containing products, laboratories, and
           manufacturers and users of mercury switches (Fall 1998 and ongoing).
       >  '  To improve citizens' right-to-know on mercury, seek to lower the reporting'
  ,  ,       threshold for.mercury under the Toxics Release Inventory, which could lead to more
           reporting of mercury releases (end of 1998).

•      Focus Enforcement and Compliance Assurance Activities on PBTs (OECA, Regions,
       Winter 98/99 - ongoing).
       *•    Analyze compliance within PBT-related sectors to identify problems and
           opportunities for action.
       *•    Select industries, sectors, or regulations that  would benefit from focused compliance
           attention and/or assistance.
       >    Target actions with best potential to reduce PBT releases.
       >•    Develop Supplemental Environmental Projects and models to use with enforcement
           actions to enhance P2/reduction opportunities.                      .

ป      Identify PBT chemicals to measure national reductions in hazardous wastes (OS W,
       *•   Using the Waste Minimization Prioritization Tool and  selection criteria reflecting
           Resource Conservation and Recovery Act (RCRA) concerns, publish a draft  RCRA
           PBT List hi a Federal Register notice (early  November 1998).
       >• .  Hold stakeholder meetings to discuss criteria (Fall 1998).
       -   Finalize and release list of RCRA PBT chemicals (Winter 1998/99).

 •     Develop or Revise Water Quality Criteria for mercury and  other specific priority PBTs.
       Revise methodology for mercury water quality criteria. (OW, Spring 1999)

 •     Support International Efforts beyond the Binational Toxics Strategy (OAR, OECA,
       OIA, OPPTS, ORD, OSWER, OW, 1998 and ongoing).

 Draft PBT Strategy                            4                          November 16, 1998

       >   Support the North American Commission for Environmental Cooperation's (CEC)
           Sound Management of Chemicals work program, including the implementation of "
           the Regional Action Plans on DDX, chlordane, PCBs? and mercury.   ;
       •> •  Promote the early implementation of the Persistent Organic Pollutants (POPs) and
           Heavy Metals Protocols recently negotiated under the UN ECE's Convention on  '
           Long Range Transboundary Air Pollution.        "            •
       *   Provide leadership in the negotiations on a global POPs convention under the
           auspices of the UN Environment Program.                 "•-'.'
    .   *   Continue working with developing countries to phase o,ut use of lead in gasoline.

•      Conduct Research and Analysis oti PBTs (ORD, OAR, OPPTS,  OS WER, OIA,
       Regions, 1999 and ongoing).                     ••                •'    '  •  .
       *   Develop/promote mercury emission control approaches for coal-fired utility boilers':
       >•  . Conduct research on mercury and POPs transport, fate, and risk management.
       ••   Use P2 tools (Design for the Environment tools, environmental accounting materials
           management, etc.) in voluntary components of action plans.
       *••  Develop and improve test methodologies for environmental persistence.
       *•   Coriduct Science Workshops on mercury and emerging PBTs.
       >   Develop P2 options for mercury and dioxin risks from industrial combustion.
       ป•   Publish "Status and Needs" paper on use of bioaccumulation data to assess sediment
           quality (Fall 1998).

•      Screen and Select Additional Priority PBTs for Action (OPPTS, OS WER, Regions).
       *   Finalize Waste Minimization Prioritization Tool for use in prioritizing PBTs
           (Summer 1998).
       *   Catalog chemicals and modify data systems as needed (Fall 1998 -ongoing).
       >••   Select chemicals beyond the Level 1 list (1999).     ;   .    -           •.      .  •

•      Prevent the Introduction q/'New PET Chemicals (OPPTS-led).
       ป•   Propose criteria for requiring testing/restrictions on new PBTs (Fall 1998).
    ..ป•_•  Develop rule to-control ' re-introducing out-of-use PBTs into commerce (1999).
       >   Develop incentives to reward development of lower-risk alternatives to PBTs
           (Ongoing).                                                 ...
       *   Document how PBT screening criteria are taken into acc9unt when approving new
           pesticides and re-registering existing ones (Fall 1998).

•      "Measure Progress (OAR, OECA, OPPTS, OS WER, OW, OIA, Regions).,
       >   Help develop National Health and Nutrition Examination Surveys to analyze .U.S.
           population for pesticides/dioxin in serum, and mercury in blood/hair (Summer '98).
 .     '.*•-•  Begin working with the National Institutes of Health (NIH) to monitor PBTs in fetal
           cord blood of Alaskan native groups (Fall 1998-ongoing).
       >   .Design and peer review National Study of Chemical Residues in Fish for estimating
 .          trends in environmental measures (1998-early 1999). Begin sampling in 1999.
        >•   Propose.a rule adding dioxins/possibly other PBTs to the Toxics Release Inventory
         • (TRI); lower reporting thresholds for dioxins and PBTs listed on TRI (end of 1998).

 Draft PBT Strategy.  '                          5         .           '       November 16, 1998

           Update air emission inventory, especially for dioxin/mercury sources (Fall 1998 -  '
           ongoing), and support coal sampling and stack testing for mercury at utilities (Fall
       *•   Design activity measures (1999).

Strategy Elements

       1.  Develop and Implement National Action Plans

       Developing National Action Plans.  In this strategy, EPA is affirming the priority given
by the United States and Canada to the Level 1 substances under the Binational Toxics Strategy
(BNS), and making these substances the first focus for action.  The Level 1 substances are:   ,  .

         aldrin/dieldrin                       mercury and compounds     •
         benzo(a)pyrene                      mirex
         chlordane                           octachlorostyrene            '  ,
         DDT(+DDD+DDE)                  PCBs          .
         hexachlorobenzene                   PCDD (Dioxins) and PCDF (Furans)
         alkyl-lead                      „    toxaphene     ...

       EPA is focusing on these substances first because the BNS reduction goals for them are
national, and most of these substances are already targets of existing and pending international
agreements. EPA believes there is much to gain by building on the efforts of its Great Lakes
National Program Office (GLNPO) and EPA Region 5 to virtually eliminate these PBT
pollutants in the Great Lakes Basin.

       EPA will use the work plans being developed by BNS multi-stakeholder work groups as
starting points for national action plans under this strategy. The BNS framework relies heavily
on stakeholder involvement, and has a preference for voluntary action when adequate to meet
BNS goals. BNS work plans will likely yield regionally-specific model actions that can serve as
foundations for national action plans under this strategy. EPA is evaluating whether, for the
Level 1 substances, assembling national workgroups (or some other configuration) to involve
Regions and complement  BNS workgroups may help in the timely development of national
action plans.  For a-summary of linkages between this strategy and the BNS, see page 15.

        National action plans will draw on the full array of EPA statutory authorities and
 national programs. EPA  may use regulatory action where voluntary efforts are insufficient.
 EPA will likewise pursue, in the short-term or longer-term as appropriate, actions for
 enforcement of and compliance with current regulations, international coordination, place-based
 remediation of existing PBT contamination, research, technology development and monitoring,-
 community and sector-based projects, and use of outreach and public advisories. EPA will focus
 on action, while bearing hi mind the need to address uncertainties and data gaps through data
 .collection and scientific and technical research. EPA will sequence activities to lay any
 groundwork necessary for longer-term action.

 *Draft PBT Strategy                  "      '   9                   .        NOvember16,1998

                      Strategy Elements Framework
                               Candidate Pool of
                                                      with Binational
                                                      Toxics Strategy
                                                        on Level 1
 Screen &
Select PBTs
 for Action
Fill PBT
                                 Action Plans
                               • Define measurable
                                Define roles &
                                allocate resources
                                 & Evaluate
                     Introduction of
                      New PBTs
Draft PBT Strategy
     Figure 1.

                                 1  November 16, 1998

       The. Draft Mercury Action Plan in Attachment 1 illustrates how EPA can coordinate the
.use of its tools to achieve reductions for a PBT pollutant. This plan represents EPA's preferred
approach, since it involves multi-media and cross-office actions, quantitative challenge goals,
stakeholder engagement, international coordination, and long-term emphasis on pollution
prevention. Such an action plan is possible because EPA has extensive knowledge of and a
mature program on mercury, more so than for most other PBT pollutants. Action plans for
banned substances like canceled pesticides or PCBs, or substances with much less risk
characterization like octachlorostyrene, will differ substantially from the draft mercury action
plan. EPA has begun implementing some reduction activities for mercury.  See the next section
and Appendix B for the status of developments on all 12 BNS Level 1 substances.

       Maximizing Opportunities for Integration. As EPA develops action plans, it will align
program efforts and integrate actions across media.  Whenever possible, EPA will address groups
of pollutants rather than individual pollutants, to prevent or reduce risks for multiple pollutants at
the same time. As individual action plans mature, EPA may see opportunities to integrate
activities hi ways that achieve greater cost savings in amounts of each PBT removed per dollar
spent. EPA may also be able to identify facility-wide pollution prevention and technology
transfer opportunities for specific industry sectors. Maximizing opportunities for integration will
avoid transferring problems across media or to chemical substitutes!

       Implementing PBT Reduction Actions.  Some of the activities being planned for the 12
BNS Level 1 substances-are already reasonably well outlined. This is especially true for
mercury, as noted above on pages 4 and 6.  What follows highlights some of the activities on
some of the other 11 substances on the BNS Level 1 list.

ป•    .  EPA will prepare a BNS status report by December 31, 1998 on the use or release of
       chlordane, DDT, aldrin-dieldrin, mirex, and toxaphene from sources that enter the Great
       Lakes Basin. EPA will continue "Clean Sweeps"3 in the Great Lakes Basin, and will seek
       to extend Clean Sweeps on a national basis.  EPA will work with Mexico to reduce
       DDT/dSftrdane reliance, speed registration of reduced-risk pesticides, and encourage
       states' promotion of biological controls through State Management Plans.

>      EPA will prepare a BNS status report by December 31, 1998 on alkyl-lead to confirm no
       use in automotive gasoline. EPA will encourage stakeholder minimization of use/release
       from aviation and racing sources in the Great Lakes  Basin, and will seek to extend these
      . efforts on a national basis.            .

>      EPA will publicly release the fina| Dioxin Reassessment hi Spring 1999.
        3 Agricultural "Clean Sweeps" is a popular term for waste pesticide collections undertaken at State and
 local levels to dispose of pesticides that are suspended, canceled, or no longer fit for use. States conduct Clean
 Sweeps as a prudent investment to avoid potential spills- and costly clean-up.

 Draft PBT Strategy                            8                           November 16, 1998

          2.     Screenand Select More Priority PBT Pollutants for Action

          Looking beyond its initial focus on the BNS Level 1 substances;"the Agency 'will screen
.and select additional PBT pollutants for action. It is likely that the opportunities Yor pollution  '
  -/prevention; will.be greater for the additionally selected PBT pollutants; EPA will use a primary '
   and secondary screening process to make these selections.

          Primary Screening: Preliminary Criteria. EPA: will apply a primary, screening process
   to candidate PBT pollutants. EPA is defining candidate pollutants as (a)  those highly scored by
   EPA's Waste Minimization Prioritization fool (WMPT) for human or ecological, concern, and
   (b) other high-priority chemicals for EPA headquarters and regional .program offices. The
   .WMPT prioritizes chemicals based on their cumulative persistence, bioaccumulation, and  .
   chronic human and ecological toxicity. The purpose of the primary screen is to reduce the.
  . number of candidate pollutants under consideration. A chemical will pass the primary screen if it
   meets at least one of the following criteria:                                       '

  .        •••    The chemical is currently produced within the U.S. or impprted;        >••
          •      The chemical is being released to the environment; ."..             •
  "•      •.• •    The chemical is generated/managed in waste; or             •         .
          •      The chemical has been detected in the environment at levels of concern (as- yet
                 undefined).  •':' •   . .  ;;               . .

          Secondary Screening:  Ranking Criteria and Technical Panel EPA will then use
   secondary criteria to rank those PBT pollutants that pass the primary screen. EPA's Office
   Directors and the PBT Plenary Group are developing the.secondary criteria. EPA is carefully
   crafting these criteria to represent its priorities and will define them, in part, by the availability of
   sound scientific and technical data.  The criteria will be related to  PBT characteristics (especially
   hazard), potential exposure, pollution  prevention opportunity, and suitability for an EPA-wide
   national focus (including-potential for grouping chemicals for action).  EP'A will apply the
   secondary criteria in consultation with a technical panel which, in turn, may consult with a .
   network of experts to ensure that chemical selection is based on sound science.  Details about the
   selection criteria, process, and technical panel remain under development.              '       -:

   ,     ;  The proposed methodology will undergo internal and external review in 1999.  The
   methodology and decisions will also be periodically reassessed as more data become available
   that may affect EPA's selection process.            ,                  .             '
                         -.               '               ~                       ป
                               •           . •. -   •               •         . .      "•.••('
          3.     Prevent the Introduction^ New PBT Pollutants

          EPA will be taking four actions to prevent.new PBT chemicals from entering commerce,
  1 using authorities'under the Toxics Substances Control Act (TSCA) and the Federal Insecticide,
   Fungicide and Rpdenticide Act.         "                                          .
    Draft PBT Strategy                      .      9                          -November 16, 1998

•      EPA will propose a'PBT category for screening new chemicals, to enhance EPA's ability
       to evaluate the potential risks of new PBTs and to use testing requirements and other
       restrictions as necessary to protect the public.  Under its TSCA-based New Chemicals
       Program, EPA groups new chemicals with shared structural and toxicological properties
       into categories.  These categories allow submitters of Premanufacture Notices and EPA
       reviewers to benefit from accumulated data and decisionai precedents.' If EPA identifies a
       new substance as .being in the PBT category, EPA will evaluate the potential health or
       environmental concerns associated with the category, and the potential exposures and
     . releases of the new chemical. If EPA concludes the new substance may pose an
       unreasonable risk to human health or the environment, EPA may require testing and
       restrictions.          .                 ...

•      EPA will develop a significant new use rule to control attempts to re-introduce out-of-use
       PBT chemicals into commerce. This rule will apply to PBTs previously hi commerce but
       not being manufactured, as identified from updated reporting on U.S. production,
       including polychlorinated terphenyls and hexachlorobenzene.

•      EPA is developing  incentives to reward the development of lower-risk chemicals as
       alternatives to existing, higher-risk PBT chemicals.  EPA will create these  incentives
       through its New Chemicals Program and its green chemistry'activities.

ซ      EPA will document how PBT-related screening criteria are taken into account for  •
       approval of new pesticides and re-registration of existing ones. EPA will seek acceptance
       of these criteria by  international organizations working on persistent organic pollutants
       (POPs), including the OECD chemical/pesticide program, the Binational Toxics Strategy,..
       the IFCS, and the CEC.

       4.     Measure Progress:  Link Activities to Environmental Results

       EPA will measure progress on actions under this strategy through:  (1) environmental or
human health indicators, (2) chemical release, waste generation, or use indicators,  or (3)
programmatic output measures.  EPA believes that tying its indicators of progress  to
environmental results through real world measures (e.g., reduced levels of PBTs in human blood
or fish tissue)  will encourage the Agency and its stakeholders to think creatively about how to
achieve the progress  in risk reduction that both seek.

       This approach to measuring progress meets the requirements of the Government
Performance and Results Act of 1993 (GPRA). GPRA requires federal agencies to define
measurable goals and objectives, measure progress, and report accomplishments.  Appendix A
shows that the goal of this strategy matches EPA's goals and objectives under GRPA, including
.Goal # 1 clean air, Goal # 2 clean and safe water, Goal # 4 preventing pollution and reducing   .
 risk, Goal # 6 reducing global and cross-border environmental risks, Goal # 8 sound science, and
 Goal # 9 credibly deterring pollution and increasing compliance with the law.
 Draft PBT Strategy                            10'                          November 16, 1998

       EPA will use the following measures to track progress m reducing risks from PBT
pollutants, as shown,in Figure 2.  EPA will evaluate and use other progress measures as-
appropriate.          :                                                           .

•      Human Biomarkers.  EPA will use the National Health and Nutrition Examination    ,
       Surveys (NHANES) as its primary measure of human exposure. Conducted by the
       CDC's National Center for Health Statistics (NCHS), NHANES trace the health and .
       nutritional status of U!S. civilians.  Surveys use adult, youth, and family questionnaires,
       followed by standardized physical examinations. The primary NHANES objective is to
     ,  obtain national population health and nutrition parameters; using suitably precise
   ,    estimates for age, gender, and race/ethnicity (whites, blacks, and Mexican-Americans).
       EPA expects NHANES IV to analyze most Level 1 substances. EPAihas worked with
       NCHS to add analysis for mercury in blood and hair for some survey participants. EPA
       also will begin working with NIH and other U.S. government entities to conduct fetal
       cord blood monitoring for PBTs in Alaskan native groups.           ..

•      Food Chain/Environmental Measures, A cornerstone of the measurement effort will
       be a National Study of Chemical Residues in Fish.  This EPA study will statistically
       evaluate the incidence and severity of mercury and other PBT residues in fish, both
       downstream from suspected problem areas and in background areas. On a national basis,
       the study will calculate concentrations, of priority PBT chemicals hi fish. On a regional '
       basis, it will also calculate concentrations of some .other PBT'chemicals in fish. The
       study will-allow for estimating trends over time.  EPA will work with.State Departments
       of Health and Environmental Protection* coordinating with state fish advisory programs
       to help fill data needs identified in the survey. Study design and peer review will be
       completed in fiscal  year 1998 (FY98) or early FY99.  Sampling begins in FY99 and
     .. concludes, in Summer FY01. Study results will be available in FY02..

*      Environmental Release Data. To help characterize trends in*environmental releases and
       waste management, EPA intends to propose a rule to add dioxins and possibly other PBT
       substances to the Toxics Release Inventory (TRI). This rule will .also propose lowering
       repprtirig thresholds for PBT chemicals ~ some already listed on TRI, like mercury and
     '  mercury compounds, and some being added, like dioxins.  Lowering reporting thresholds
       could increase reporting of PBT chemicals and thereby enhance TRI's value for tracking
       progress in  reducing PBT pollution. Plans are to propose the.TRI PBT rule by close of
       1998. EPA expects a final rule by the end of 1999, with reporting to begin in 2000. The
       first public  release of the data obtained through the TRI PBT rule would.be in 2001.

       Reductions of volumes of hazardous wastes containing PBTs will also be measured using
       the 1991 Biennial Reporting System4 data-as a baseline on hazardous waste generation
       4 The Biennial Reporting System contains data on hazardous waste generation and management for
 facilities regulated by the Resource Conservation and Recovery Act (1976). EPA collects the data every two years
 pursuant to the Hazardous and Solid Waste Amendments of 1984, and publishes it in the Biennial RCRA Hazardous
 Waste Report.               . •         '

-Draft PBT Strategy                           11                         .November 16, 1998

       trends. Reductions of specific high-priority PBT chemicals in hazardous wastes will also
       be measured using TRJ data.  Reductions of chemicals in hazardous wastes is one
       indicator of whether the reductions are occurring at the source, prior to generation of
       hazardous wastes. EPA will use these methods to report progress on reducing PBTs in
    ,   hazardous wastes by 50% by 2005, a subobjective under GPRA Goal 4 (see discussion of
       GPRAonpage 10).  .

       Beyond TRI, EPA Will also evaluate the results ofongoing monitoring programs, such as
       the Integrated Atmospheric Deposition Network and those used by other Federal agencies
       like the U.S.  Geological Survey. EPA will also evaluate and support improving outputs
       from international monitoring and modeling programs. These include national emission
       inventories and related modeling of long-range transboundary fluxes, conducted pursuant
       to the POPs and heavy metals protocols to the UN ECE's Convention on Long Range "
       Transboundary Air Pollution.

•      Activity Measures.  EPA will also use PBT-related activity measures, especially at the
       start, since risk reductions might not be readily apparent in the short term.  Activity
       measures include negotiation and implementation of international agreements; Federal or
       State compliance assistance; public/industry workshops and educational outreach-
       pollution prevention agreements or other voluntary activities by the regulated community;
       focused compliance monitoring and enforcement; and regulatory and. permitting changes.

                            V. MANAGING FOR SUCCESS

       To manage the effort under this strategy, EPA will  rely on sustained senior-level support,
a strong organizational structure for coordination, sustained resources, a well-defined framework
for carrying out the  elements of this strategy, and stakeholder involvement.

Managing the Implementation of the Strategy

       EPA is using the following organizational structure to coordinate and sequence activities
under this-strategy.   •                                   •                   .

ป     The PBT Plenary Group, a body of EPA personnel instrumental in developing this
       strategy, will be responsible for integrating actions across Agency programs and
       recommending action priorities. This group will forward its recommendations to the
       Office Directors for decisions. It will also help track progress toward the strategy's goals.

 •     EPA's Office Directors' Multi-Media and Pollution Prevention Forum will define actions
       to be taken each fiscal year, based on Plenary Group recommendations.  The Forum will ,
       . also incorporate these actions into EPA's program planning process, and evaluate
       progress on activities towards the strategy's goal.
 • Draft PBT Strategy
                                           .12                          November 16, 1998

                                       '•.Figure 2

                        A Continuum of Activities that
                       Measure Environmental Results
 • Blood
 1 Urine
 1 Tissue
                                 • Most Level 1 substanced included
                                 • Direct measure of, human exposure
                       Food chain/
• Fish tissue
• Animal tissue
• Sediment
*• Water column
                                • Direct measure of ecological effect
                                . • Close link to human exposure
                                ..• Applicable to many PBTs  '
                                 1 Proposed addition of dioxin
                                  Lower thresholds for other PBTs':,..-.
                                  Data from international inventories-available
lease Data X
• Emissions
• Disposal- '.
Measures ' ' . .
• Education '
• International outreach •
• Stakeholder Meetings
• Compliance monitoring
and enforcement
                                • Easily. measured
                                • Only available measure at times
" Draft PBT Strategy
                                                                    November 16, 1998

•      Program and Enforcement Offices at the Headquarters and Regional levels will
       implement defined actions with the support of ad-hoc groups such as the Mercury Task
       Force and Dioxin Assessment Group. EPA has also established a network of Regional
       PBT contacts to facilitate .these efforts at the Regional level.

Establish Linkages Among Current Program Efforts

       Establishing linkages among programs is key to achieving the goal of this strategy.

       Linkages with the Canada - U.S. Binational Toxics Strategy. EPA is coordinating its
implementation of this strategy with that of ihe Binational Toxics Strategy. These efforts
mutually contribute to the success of one another, as summarized in Table 1.
                                    i              '.-''•               ,   •

Table 1. Relationship Between the PBT  Strategy and Binational Toxics Strategy
Stnatwjrval Stratsgy
Initial focus on Level 1 substances
Much of the focus is regional in scope for water,
and national in scope for air.
Establishes quantitative challenge goals for virtual
elimination of Level 1 substances
Progress tracking and accountability related to
specific reduction (use/release) goals.
Identify key stakeholders and bring stakeholders'
current technology to light
Specifies coordination with international efforts to
ensure consistency • . .
, P8TStratซg*
Initial focus on Level 1 substances. 'Will
select additional substances, providing a basis
for BNS implementation decisions on Level 2
National in scope for all media, including
Everglades, Gulf of Mexico, Chesapeake Bay,
Lake Champlain.
Provides scientific support for deciding
whether more action is needed after challenge
goals are met.
Builds on use/release tracking of BNS and
expands progress tracking to measures closer ,
to human and ecological levels and effects. .
Coordinates research on new technologies and
provides Agency tools such as environmental
accounting, models, etc.
Expands coordination with international efforts .
       Linkages with International Chemical Management Efforts.  To the extent that
 international voluntary activities and legally-binding agreements result in meaningful PBT risk
 reductions in other countries, these international steps would be a positive complement to this
 strategy.  Likewise, domestic actions implemented by this strategy could serve as models for
 other countries. A number of international efforts in which EPA participates, including those
 listed below, are relevant to. this strategy,        .                                     •

 *•   '  The North American Commission for Environmental Cooperation (CEC), made up of the
        U.S., Canada, and Mexico, is conducting a-Sound Management of Chemicals Program.
  Draft PBT Strategy
November 16, 1998

. V •     Through CEC, the U.S. is working to implement Regional Action Plans on DDT
        chlordane, PCBs, and mercury, v         '-
        EPA is! continuing long-standing efforts to provide technical assistance to developing
        countries to eliminate the-use of lead in gasoline.
->.,  '.  EPA is supporting the implementation of the Persistent Organic Pollutants (POPs) and
        Heavy Metal Protocols to the.UNECE's LRTAP Convention.
 >      EPA is a key US government participant in the ongoing negotiations of a global POPs
        Convention under UNEP auspices.

        Linkages with the Waste Minimization National Plan.  EPA is coordinating this strategy
 with its Waste Minimization National Plan which EPA launched four years ago  Supporting this
 National Plan is EPA's GPRA subobjective to "reduce the most persistent, bioaccurnulative  and
 toxic chemicals in hazardous waste 50% by the year 2005." In furtherance of the Plan and this '
 subobjectiye, EPA: (1) has developed the Waste Minimization Prioritization Tool; (2) is
 proposing this fall and finalizing this winter a list of those PBTs of most concern for tracking  - ,
 national reductions in hazardous,wastes; (3) is using the RCRA Implementation Plan and its
 guidance/on core measures for National Environmental Performance Partnerships with states to
 reinforce the PBT reduction goals for hazardous wastes; and, (4) will be finalizing methods this
 year to measure reductions of PBTs in hazardous wastes 'and reductions of hazardous wastes
 containing PBTs. The PBT  Strategy will likewise be making use of the Waste Minimization
 Prioritization Tool and will, seek consistency with other activities of the Waste Minimization
 National Plan to the maximum extent possible.

        Linkages with Sector- and Community-Based Efforts. The chemical-based PBT
 Strategy is complementary to sector-based and place-based approaches. Aspects of this strategy
 -. assessing risk, overcoming single-medium approaches in establishing national baseline
 regulations and policies, targeting research, controlling more PBTs from entering commerce,
 creating incentives for safer  substitutes, and facilitating coordination with U.S. and international
 agencies - can serve the needs of sector- and place-based approaches. Indeed,, constructive
 collaboration can occur among all three approaches.

        EPA, with the Common Sense Initiative Council, is developing a Sector-Based Action
 Plan to integrate the sector-based approach into core Agency operations. The Plan will, among
 other things, identify objective criteria for selecting future sector-based opportunities. EPA's
 regulatory framework already starts with "source categories" of releases to air, water, or land,
 and may serve as a point of reference. This PBT strategy may also be able to identify source'
• categories by use or release of chemicals or chemical groups.  Once a sector could be earmarked.
 for significant PBT use or release, then-sector-based.and chemical-based approaches could use
 complementary analysis and stakeholder outreach to tackle PBT problems on a sector-basis.
        ' '. -  '   J    ;          '         '         -,                 '  '    -      '•'''.'
        EPA also seeks to implement Community-Based Environmental Protection (CBEP), a
 place-based, coUabprative, multi-media, and multi-disciplinary approach to environmental     .'
 protection. Embracing principles of ecosystem management and sustainable development, it
 convenes  stakeholders within a geographic area to identify local concerns (including urban

- Draft PBT Strategy                     •,15      ,      '   •  -V ' .    November 16,  1998

sprawl, shrinking biodiversity, and remediation of in-place PBT contaminants), set priorities and
goals, and forge comprehensive solutions.  CBEP promotes integration of EPA programs and .
activities to complement and enhance community decision-making. Regional activities on the
Chesapeake Bay and Great Lakes exemplify the CBEP approach and are also integral to the PBT
Strategy (งgg Table 1).          .

       Linkages with EPA Regional Programs.  EPA Regional programs are essential to
implementing this strategy.  Among the roles they may take on are the following:

          •  Participating in,GLNPO or national work groups as appropriate.
            Identifying geographic sources and sinks of priority PBTs.                    ..
            Participating in the chemical selection process.
            Assuming lead responsibilities for action plan development teams.
            Managing region-specific projects during action plan implementation.
            Promoting compliance assurance and enforcement efforts.
            Supporting States and Tribes in addressing PBT issues in their jurisdictions.
            Carrying out PBT-related actions under EPA's National Waste Minimization Plan..

Stakeholder Involvement

       Building on the stakeholder involvement begun under the Binational Toxics Strategy is
essential to this strategy.  EPA's Region 5 and GLNPO are successfully engaging state and tribal
program partners, industry, environmental groups, and others in taking actions on Level 1
substances.  For example, the Council of Great Lakes Industries has helped educate and bring to
the table other industries and sectors to identify possible voluntary actions. In cooperation with
EPA, the National Wildlife Federation has begun mercury and dioxin reduction projects at Great
Lakes hospitals. EPA will build on these efforts to engage stakeholders in areas of the country
beyond the Great Lakes Basin.

            EPA will seek' stakeholder input on this draft strategy, the development and
implementation of specific action plans for PBT pollutants, and the criteria for selecting more
PBTs for risk reduction action, EPA will make Federal Register announcements of meetings in
Washington, DC and EPA regional city locations for stakeholders to comment on the draft
 strategy. EPA will invite State and tribal representatives  to join the teams that develop the action
 plans, and will invite all others to review and comment on draft action plans. EPA will also
 invite all interested partners to join in developing voluntary agreements with EPA, agreements
 EPA considers essential to reaching the goal of this strategy.

        For answers to general questions about the PBT Strategy or to find out who to contact
 regarding particular aspects of the PBT Strategy, please contact Sam Sasnett, (202)260-8020,  .
  Draft PBT Strategy
                                            16                         November 16, 1998


 CEC (1997). DRAFT Mercury North American Regional Action Plan,  www.cec.org

 The Great takes Binational Toxics Strategy:  Canada - U.S. Strategy for the Virtual Elimination
 of Persistent Toxic .Substances in the Great Lakes (1997).  www.epa.gov/grtlakes/bns/strategy '  '

 National Academy of Public Administration, Washington, D.C. (1995).  Setting Priorities
 Getting Results — A New Direction for EPA.

Natural Resources Defense Council (1998). Contaminated Catch.— The Public Health Threat
 from Toxics in Fish.   .             , ".     '   '             .

Organization for Economic Cooperation and Development (1996). Environmental Performance
Review of the United States. OECD Publications Center:  (202)785r6323
 t                                                        t             •          i
U. S. Environmental Protection Agency (EPA) (1998). The Study of Hazardous Air Pollutant
Emissions from Electric Utility Steam Generating Units -- Final Repprt to Congress. Volumes 1
and 2. EPA-453/R-98-004a and EPA-4,13/R-98-004b.'

U. S. E.P.A. and U.S. Department of Agriculture (1998). Clean Water Action Plan:  Restoring
and Protecting America's Waters. EPA-840-R-98-001.

U. S. E.P.A. (Sept 1997). EPA's Strategic Plan. EPA/190-R-97-002

U.S. E.P.A. (1997). Deposition of Air Pollutants to Great Waters: 2nd Report to Congress
EPA-453-R-97-011.  ,             '                  -          .         . •'  ;   .  '.

U.S. E.P.A. (1997). EPA's  Contaminated Sediment Management Strategy.  EPA-823-R-98-001.

U. S. E.P.A. (1997).  Mercury Study Report to Congress. EPA-452-R-97-003-009.

U.S. E.P.A. (Dec, 1996).  Environmental Goals for America with Milestones for 2005, Draft for
 Government Review.          '.-'.-.                   .      •

 U. S. E.P.A. and Agency for Toxic Substances Disease Registry (1996). National Alert on
 Metallic Mercury Exposure.

 U.'S. E.P.A. (1994). RCRA Waste Minimization National Plan (draft). OSW 530-D-44-001.

 U.S. E.P.A.  Biennial RCRA Hazardous Waste Report (1991 data) list of large-quantity
 generators in the United States.
 Draft PBT Strategy                        ,,17                        ,, November 16, .1998

U.S. E.P.A- (1993). Deposition of. Aft Pollutants'to the Great Waters: 1st Report to, Congress.
EPA-453-R-93-055.       '                            '

EPA Air Docket:    (202)260-7548
EPA Water Docket:  (202)260-3027
EPA RCRA Docket: (703)613-9230
  Draft PBT Strategy '                       .18                         November 16. 1998


BNS       June 1997 Canada-U.S. Strategy for the Virtual Elimination of Persistent Toxic
           Substances in the Great Lakes (also referenced as.'"Binational Toxics Strategy").
CEC       North American Commission for Environmental Cooperation
GLNPO    EPA's Great Lakes National Program Office  '       •
GPRA     Government Performance in Results Act of 1993                 ••'.-•.-
IFCS       Intergovernmental Forum on Chemical Safety
LRTAP Convention - the UN.ECE's  Convention on Long Range Transbbundary Air Pollution
NHANES,  National .Health and Nutrition Examination Surveys
NIH       National Institutes of Health (U.S. Department of Health and Human Services)
OAR       EPA's Office of Air and Radiation
QECA     EPA's Office of Enforcement and Compliance Assurance       •           .'
OECD,    Organization for Economic Cooperation and Development
OIA       EPA's Office of International Activities                           .
OPPTS  .  EPA's Office of Prevention, Pesticides, and Toxic Substances
ORD       EPA's Office of Research and Development             '
OSWER  '  EPA's Office of Solid Waste and Emergency Response         "       •
OW       EPA's Office of Water                    .    .   ,".
P2         Pollution prevention
PBTs       Persistent, bioaccumulative, and toxic pollutants
POPs Protocol - the Persistent Organic Pollutants Protocol negotiated under the UN ECE's
           LRTAP Convention                                         ,
RCRA     Resource Conservation and Recovery Act
TRI       Toxics Release Inventory
UN ECE    United Nations Economic Commission for Europe
UNEP     United Nations Environment Program
WMPT '    Waste Minimization Prioritization Tool
 Draft PBT Strategy           '              19...                      .November 16, 1938

             APPENDIX A

GPRA Goals and Objectives Supported by
           the PBT Strategy
               Appendix A-1

Table A-1.  The PBT Strategy Will Help Meet G6als and Objectives Stated in EPA's
             Strategic Plan                  " ..           '  •                         •  ,
 EPA Strategic Pjan Goals and  Objectives
     GPRA Goal 1:  Clean Air
     *  By 2010, improve air quality for Americans living in areas that do not meet the National Ambient Air
        Qual.ty Standards (NAAQS) for ozone and paniculate matter (PM).              '      MmDlenl ซT
     •  By 2010, reduce air toxics emissions by 75 percent from .1 993 levels to significantly reduce the risk
        to Am.er.cans of cancer and other serious adverse health effects caused by airborne toxics
     •  By 2005, .mprove air quality for Americans living in areas that do not meet the NAAQS for carbon
        monoxide, sulfer dioxide, lead, and nitrogen dioxide.
     •  By 2010, ambient sulfates and total sulfur deposition will be reduced by 20-40%; from 1980 levels
        due to reduced sulfur dioxide emissions from utilities and industrial.sources. By 2000 ambient
        nitrates and total nitrogen deposition will^be.reduced by 5-10% from 1980 levels due to reduced•
        emissions of nitrogen-oxides from utilities and mobile sources.                                 •-
     GPRA Goal 2:  Clean and Safe Water                        '.'  •          .^~"	
     • By 2005,,protect, human health so that 95 percent of the population served by community water
       systems .will receive water that meets drinking water standards; consumption of contaminated fish
       and shellfish will be reduced, and exposure to niicrobjal and other forms of contamination in waters
       used for recreation will be reduced.
     • Conserve and enhance the ecological/health of the nation's (state, interstate/and tribal) waters and
       aquatic ecosystems - rivers and streams, lakes, wetlands, estuaries, coastal areas, oceans, and
       groundwater - so that 75 percent of waters will support healthy aquatic-communities, by 2005
     • - By 2005, pollutant discharges from key point sources and nonpoint source runoff will be reduced by
       at least 20 percent from 1992 'evels.  Air deposition of key pollutants impacting water bodies will" be
     ,  reduced.       '               •                           -•'                                  ,
     GPRA Goal 4: Preventing Pollution and Reducing Risk in Communities. Homes, Workplaces and
                  Ecosystems                                                     '        •
     • By 2005, public and ecosystem risk from pesticides will be reduced through migration to lower-risk
       pesticides and pest management practices, improving education of the public  and at-risk workers,
       and forming "pesticide environmental stewardship" partnerships with pesticide user groups.
     • By 2005, the number of young children with high levels of lead in their blood  will be Significantly
       reduced from the early 1990's.                     .  '                         •           •
     • By 2005, of the approximately 2,000 chemicals and 40 genetically, engineered microorganisms
       expected to enter commerce each year, we will significantly increase the introduction by industry of
       safer or "greener" chemicals, which will decrease the need for regulatory management by  EPA.
     • By 2005, 1 5 million more Americans will live "or work in homes., schools, or office buildings with .
       healthier indoor air than in 1994.                  ,    <         :      • ,     ,
     • By 2005, reduce, by 25% (frdm 1992 levels) the quantity of toxic pollutants released, disposed  of,
      • treated, or combusted for energy recovery..  Half of this reduction will be achieved through poilutio'n
       prevention practices.      ,  •
     • By 2005; EPA and its partners will increase recycling and decrease the quantity and toxicity of waste
       generated.                 ^      .          -            '•'....'.                •,,.
     • By 2003, 60% of Indian  Country will be assessed for its environmental condition, and Tribes and
       EPA will be'implementing plans to address priority issues.	    ,  •'  ' •
                                            Appendix A-2

Table A-1. The PPT Strategy Will. Help Meet Goals and Objectives Stated in EPA's
             Strategic Plan  (Continued)
 EPA Strategic Plan Goals and Objectives
     GPRA Goal 6: Reduction of Global and Cross-Border Environmental Risks
     •  By 2005, reduce transboundary threats to human health and shared ecosystems in North America,
        including marine and Arctic environments, consistent with our bilateral and multilateral treaty
        obligations in these areas,  as well as our trust responsibility to tribes.
     •  By 2000 and beyond,  US greenhouse gas emissions will be reduced to levels consistent with
        international commitments agreed under the Framework Convention on Climate Change, building on
        initial efforts under the Climate Change Action Plan.
     •  By 2005, ozone concentrations in the stratosphere will have stopped declining and slowly begun-the
        process of recovery.                                                                  .   '
     •  By 20O5, consistent with international obligations, the need for upward harmonization of regulatory
        systems, and expansion  of toxics release reporting, reduce the risks to U.S. human health and
        ecosystems from selected toxics (including pesticides) that circulate in the environment at global and
        regional scales. Results  will include a 50%. reduction of mercury emissions from 1990 levels in the
        United  States.  Worldwide levels of lead in gasoline will be below. 1993 levels.
     •  By 2005, increase the application of cleaner and more cost-effective environmental practices and
        technologies in the U.S.  and abroad through international cooperation. '
     GPRA Goal 8: Sound Science, Improved Understanding of Environmental Risk, and Greater Innovation
                   to Address Environmental Problems                    '  •
     •  By 2008, provide the scientific understanding to measure, model, maintain, or restore, at multiple
        scales, the integrity and sustainability of ecosystems now and in the future.
     •  By 2008, improve the scientific basis to identify, characterize, assess, and manage environmental
        exposures that pose the greatest health risks to the American public by developing models and
        methodologies to integrate information about exposures and effects from multiple pathways.
     •  By 2008, establish capability and mechanisms  within EPA to anticipate and identify environmental or
        other changes that may portend future risk, integrate futures planning into ongoing programs; and
        promote coordinated preparation for and response to change.
     •  By 2006, develop and verify improved tools, methodologies, and technologies for modeling,
        measuring, characterizing, preventing, controlling, and cleaning up contaminants associated with high
        priority human health and environmental problems.
     •  Provide services and capabilities, including appropriate equipment, expertise, and intramural support
        necessary to enable ORD  to research innovative approaches to current and future environmental
        problems and improve understanding of environmental risks.
     •  By 2005;  EPA will increase the number of places using integrated, holistic partnership approaches,
        such as community-based environmental protection (CBEP), and quantify their tangible and
        sustainable environmental results in places where EPA is directly involved.
     •  By 2005,  test innovative  facility- and sector-based strategies to achieve improved environmental
        protection, and make successful approaches broadly available.  .
     •  By 2005,  Regions will have demonstrated capability to assess environmental conditipns in their
        Region, compare the relative risk of health and ecological problems, and assess the environmental
        effectiveness of management action in priority geographic areas. •       • •
     •  Conduct peer reviews and provide guidance on the science underlying Agency decisions.
     •  Incorporate innovative approaches to environmental management into EPA programs, so that EPA
        and external partners achieve greater and'more cost-effective public health and environmental
      1 protection.
      GPRA Goal 9:  A Credible Deterrent to Pollution and Greater Compliance with the Law.
      •  Identify and reduce significant non-compliance in high priority program areas, while maintaining a
         strong enforcement presence in all regulatory program areas.          .
      •  Promote the regulated communities' voluntary compliance with environmental requirements through
        ' compliance incentives and assistance programs.            	•	
                                             Appendix A-3

                   APPENDIX B
Status of Developments on Binational Toxics Strategy
                Level 1 Substances
                     Appendix B-1





Mercury ai



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Activity is occurring in all National
EPA, through its draft mercury acti
work group activities, and the PBT
coordinated and complement each
have begun with a focus on volunt
the attached draft Mercury Action

ge goal is, by 2006, 50% reduction
use and 50% reduction in release
-activity sources. Draft action plan
Many activities ongoing, with the
oup initiating others.
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partners to better quantify dioxin/fi
representative developing countries
ge goal is 75% reduction in releases
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ction plan after public release of its
Reassessment, due Spring 1 999, an
t draft Cross-Media Dioxin Strategy.
the BNS work group will begin
duction efforts. EPA is addressing
ns in the negotiation of the global
ntion, which began 6/98.
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Appendix B-2




tegy Level 1 Substances . .

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EPA heavily regulates PCBs. Problems include disposing of collecte
PCBs, remediating contaminated sediments, and motivating other
countries (e.g., Russia) to reduce risks from PCBs. Two rules (one
complete, one nearly so) will further facilitate industry's remediation
disposal, and replacement -of PCBs. Tlie BNS work group is pursuin
voluntary reductions through expanding Region 5's PCB phase dowi
program, encouraging national replication of the phase down progra
clean sweep pilot in Chicago, and encouraging a national PCB reduc
effort. International capacity building efforts for PCB identification,
management, and disposal are underway and will grow in volume ar
importance with the negotiation and conclusion of the UNEP POPs
convention. • ' '

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used in electrical equipment by 20(
workgroup is developing a work pie
national action plan is expected in
will address PCBs in the implement
LRTAP POPs protocol and the nego
UNEP POPs convention, which beg
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EPA will continue clean sweeps to reduce stockpiles in GL Basin, an
work with stakeholders and GL states (NEPPS process) to reduce
pesticide reliance. The possible contribution of long range transport
U.S. loadings is a significant issue to be resolved. OPP will work wi
Mexico to reduce DDT/chlordane rfeliance, speed reaistration of redu
risk pesticides, and work with GLNPO to foster states' promotion of
biological controls through State Management Plans. OPPTS and 01
will lead the EPA component of the U.S. delegation to the UNEP POI
negotiations. -
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EPA will submit "confirmation of no use in automotive gasoline" rer.
under BNS by 12/31/98, broaden stakeholder involvement, encoura
stakeholder minimization of use/release from other sources (e.g.,
aviation, racing), and track efforts to develop unleaded alternatives
aviation and racing fuel. The OECO risk management program and
EPA's efforts to promote phasing out use of lead in gasoline are
ongoing. i

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Benzo(a)pyrene is a polycyclic aromatic hyrdocarbon, a subset of
polycyclic organic matter (POM), which is a large class of substance
that are by-products of incomplete combustion. POM is an area
needing more research. In the LRTAP POPs context, B(a)P will be u
as one of several indicators for overall releases of PAHs, with the
intention of ultimately reducina such releases.
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Appendix B-5