To illustrate EPA's approach to PBT pollutants under the PBT Strategy, the draft
Mercury Action Plan is attached. This action plan focuses on regulatory and voluntary actions,
enforcement and compliance, research, and outreach to characterize and reduce risks associated
with mercury. It involves multimedia and cross-office actions, quantitative challenge goals,
stakeholder engagement, international coordination, and long-term emphasis on pollution
prevention. In these ways, the draft Mercury Action Plan is representative of the overall Agency
approach to PBT pollutants.  Nonetheless, mercury is different from other PBT pollutants in
terms of the maturity of EPA's knowledge base and program actions.  Action plans for banned
substances like canceled pesticides or PCBs, or for substances with less well characterized risk
like octachlorostyrene, may differ significantly in substance and format from the action plan for
mercury. Also, as the Agency moves forward in developing action plans for more PBT
pollutants, opportunities will begin to appear for addressing multiple PBTs at a time, through
orchestrated use of available multi-media, sector-based, and place-based approaches.

       Table 1 summarizes the actions within the draft Mercury Action Plan.
Draft - November 16,1998                    Attachment 1 -1


Lead EPA Office
OPPTS, Regions 1
arid 5
Regions 1,5, 10
Region 9, OW
Regions, OAR,
Implement .Municipal Waste Combustion
(MWC) And Medical Waste Incinerator
(MWJ) Regulations '
Promulgate Hazardous Waste Combustion
Facilities Regulations .
Develop Recommendations to Limit
Emissions from Additional Source
Require, coal fired plants to submit
information pertaining to the quantity and
species of mercury emissions.
Issue standard for mercury cell chlorine
Provide States and Tribes with Tools for
Developing and Implementing Enforceable
Total Maximum Daily Loads (TMDL) for
Revise Mercury Water Criterion
Pursue Voluntary Reductions in Industrial
Use and Releases . •
Reduce TRf Reporting Threshold for
Mercury •-•-••
Develop Disposal Options for Hazardous
Wastes Containing Mercury •
Give High Priority to Mercury in International "
Efforts ' . . •
Develop a Mercury Research/Monitoring
Strategy and Implement an EPA Mercury
Research/Monitoring Plan
Develop Options for Addressing
Abandoned Mines Mercury" Problem
Support Regional, State and Local Actions .
to Reduce Mercury - ' • .
• in ncuuue RISKS Trom Mercury
New MWC and MWI units must comply at start
up. Existing MWC units must comply by -:
December 2000, existing MWI units by
September 20O2. • '
Final hazardous waste combustion facilities ~ 1
(incinerators, cement kilns, and lightweight
aggregate kilns) regulations by February 1 999
Proposed Industrial Combustion Coordinated
Rulemaking - end of 2000
Public comment period on proposal notice in
Federal Register closes October 22, 1 998
Proposed rule by November 1 999
• Complete the pilot TMDL for mercury '
by end of CY 1999 . .
• Complete studies on identifying •
sources by tracing emissions by end of
• Initiate the "National Survey of
Chemical Residues in Fish" in FY 1999
Draft human health' criteria methodology by the
end of CY 1 999; final criterion for methyl
mercury by end of CY 2000.
Region 1 ,;is piloting a recognition program for
hospitals that reduce mercury emissions
• Proposed Rule - end of 1998,
• Final Rule - end of 1 999
Advance Notice of Proposed Rulemaking
(ANPRM) in 1999, ' ,
Representation and Leadership .for Heavy Metals
(including mercury) at AMAP Expert and Working
Group meeting, Anchorage, AK, April 20-24, 1998; •
Representation and Leadership at Arctic Council
Meeting, London, UK August 1998 '--•--'
Representing Region 1 in the NEG/ECP Mercury
Action Plan '. , ' •
Draft Mercury Research Strategy - October 30,
1998 '
ANPRM in 1998 :
Ongoing , . ,. , '.••'.'
Draft - November 16,1998
Attachment 1-2

                  EPA Action Plan for Mercury
Draft - November 16,1998
Attachment 1-3


        Mercury has long been known to have toxic effects on humans and wildlife  For
 centuries, mercury miners have had their work time-limited. In the nineteenth century
 observation of toxicity in hatmakers using mercury brought the phraser-mad as hatters" into our
 lexicon. Mercury is a toxic, persistent; bioaccumulative pollutant that affects the nervous
 system. Methylmercury is the chemical species that bioaccumulates in fish.  People who
 consume large amounts of fish are at risk of adverse effects of methyimercury on the nervous
 system. Because the developing nervous system is more vulnerable to mercury toxicity, children
 exposed.to methyimercury through their mother's consumption offish and individuals who. eat
 large amounts, of fish from local waters because of economic or cultural reasons are particularly
 at risk of adverse effects. Mercury is the most frequent basis for fish advisories, represented in
 60 percent of all water bodies with advisories. Forty-one states have advisories for mercury in
 one or more water bodies,  and eleven states have issued statewide mercury advisories.

        Every Environmental Protection Agency (EPA) program, both regulatory and voluntary,
 is concerned with some aspect of exposure to mercury.  Under these programs, the Agency has'
 taken many actions to reduce human and environmental exposure to mercury, but there is still
 more work to be done.  Both the 1995 and 1997 Great Waters Reports to Congress highlighted-
 the risks of mercury in the Great Lakes, Chesapeake Bay, the Gulf of Mexico, Lake Champlain,
 and our coastal waters.  In  April 1997, President Clinton issued an Executive  Order requiring" '
 each federal agency to assess risks that disproportionately affect children, including risks from
 mercury. On April 7,1997, the United States and Canada signed the Binational Toxics Strategy,
 developed under the Great Lakes Water Quality Agreement. The Binational Toxics Strategy sets'
 a challenge of 50 percent reduction by 2006 in the deliberate use of mercury nationwide and-in
 the aggregate of releases to the air nationwide and to the water within the Great Lakes Basin.
                                                  >•    . •  '       • '    .        ,      - • •
        Most recently, on February 19,  1998, President Clinton and Vice President Gore released
 the Clean Water Action Plan, which provides a blueprint for restoring and protecting the nation's
 water resources. The Clean Water Action Plan includes many key actions to ensure that the
 nation's waters support healthy people, including specific actions to address mercury and other
 contaminants. In the Clean Water Action Plan, EPA commits to developing in 1998, a
 multimedia strategy addressing mercury arid other persistent, bioaccumulative and toxic
 pollutants thatcanndt be fully addressed through single media controls and approaches;

        As required by the  Clean Air Act (CAA) Amendments of 1990, in December 1997 EPA
 issued the Mercury Study Report to Congress. The extensively peer-reviewed Mercury Study
 Report to Congress inventories the quantity "of mercury emissions to the air from a numberof
 sources related to human activity; assess"mercury transport and environmental exposure to
 wildlife and human populations; estimates the health and environmental impacts associated with
 this exposure; and describes the technologies  (and associated costs) available  to control these
 mercury emissions. Recent and planned EPA actions will greatly reduce releases of mercury to
. the environment and mercury exposures.  Building on this foundation, more remains to be done.
 Draft - November 16,1998        ...      Attachment 1-4

       The recommendations in EPA '$ Action Plan for Mercury are an example of how the
Agency can work cooperatively across media programs to address persistent, bioaccumulative,
toxic pollutants' that move from land, to air, water and sediment.  "

       As it moves through environmental media, mercury undergoes a series of
complex chemical and physical transformations.  These scientific issues were addressed in the
Mercury Study Report to Congress:      '     -     .     '

              Mercury cycles in the environment as a result of natural and human
       (anthropogenic) activities.  The amount of mercury mobilized and released into the
       biosphere has increased since the beginning of the industrial age. Most of the mercury in
       the atmosphere is elemental mercury vapor, which circulates in the atmosphere for up to
       a year, and hence can be widely dispersed and transported thousands of miles from likely
       sources of emission. Most of the mercury in -water, soil, sediments, or plants and animals
       is in the form of inorganic mercury salts and organic forms of mercury (e.g.
       methylmercury). The inorganic form of mercury,  when either bound to airborne particles
       or in a gaseous form, is readily removed from the atmosphere by precipitation and, is also
       dry deposited, 'As it cycles between the atmosphere, land, and water, mercury undergoes
       a series of complex chemical and physical transformations, many of which are not
       completely understood.

              Mercury accumulates most efficiently in the aquatic food web. Predatory
       organisms at the top of the food web generally have higher mercury concentrations.
       Nearly all of the mercury that accumulates in fish tissue is methylmercury.

              Fish consumption dominates the pathway for human and wildlife exposure to
       methylmercury.  The Mercury Study Report to Congress supports a plausible link
       between anthropogenic releases of mercury from industrial and combustion sources in
       the United States and methylmercury in fish: However, these fish methylmercury
       concentrations also result from existing background concentrations of mercury (which
       may consist of 'mercury from natural sources, as well-as mercury which has been re-
       emitted from the oceans or soils) and deposition from, the global reservoir (which
      '  includes mercury emitted by other countries). Given the current scientific understanding
        of the environmental fate and transport of this element, it is not possible to quantify how
        much of the methylmercury infis~&.consumed by the U.S. population is contributed by
        U.S.  emissions relative to other sources of mercury (such as natural sources and re-
        emissions from the global pool).

               The typical U.S. consumer eating fish from restaurants and grocery stores is not
        in danger of consuming harmful levels of methylmercury from fish and is not advised to

  Draft--November. 16,1998                    Attachment 1-5

      -  limit fish consumption.  The'levelsof' methylmercury found in the mos'tfrequently
.   ,     consumea'commercialfish are low, especially comparedto levels that might be found in
        some non-commercial fish from fresh water bodies that have been affected by mercury
        pollution.  While most U.S. consumers need not be concerned about their exposure to
        methylmercury, some exposures may be of concern.   Those who regularly and frequently
•      , consume large amounts offish -either marine species that typically have much higher
  .      levels'.ofmethylmercury than the rest ofseafood, or freshwaterfishI that have been
       'affected by mercury pollution-are more highly exposed. Because the developing fetus '
    ;    may be the most sensitive to the effects from methylmercury, women of child-bearing age
        are regarded as the population of greatest interest.

               Cost-effective opportunities to deal with mercury during the product life-cycle,
        rather than just at the point of disposal, need.to be pursued. A balanced strategy, which
        integrates end-of-pipe control technologies with material substitution and separation,
        design-for-environment, andfundamental'process change approaches is needed.  In
        addition, international efforts to. reduce mercury emissions as well as greenhouse gases
        will play an important role in reducing inputs to the global reservoir of mercury.   - •

             •    •   .  ~      '        •      -     '     -'••."..         •'.'''  f  .

    .   A successful action plan for identifying and reducing risks from exposure to mercury
requires a new multimedia approach. As first step, EPA has analyzed current regulations,
initiatives,- and programs which manage and control mercury, and has identified a set of cost-  r,
effective options to move toward achieving further reductions. The cross-agency work group
that developed'this Action Plan is continuing to look for opportunities to address mercury
through a more integrated multimedia approach The Agency proposes to take the following
actions, in consultation with other federal  agencies, and with the involvement of states, tribes and
other stakeholders:                                                .

•      Control emissions from air point sources.  EPA has taken several important steps to
        reduce the  levels of mercury and other pollutants,  including reducing emissions from
        municipal waste cornbustors and medical waste incinerators. These actions, once fully
        implemented, will reduce mercury emissions caused by human activities by 50 percent
••  '      from 1990 levels. Several other regulations that will limit mercury emission are under
        development, as well. Actions to reduce emissions of carbon dioxide to control climate
        change will also,have a significant co-benefit in reduced mercury emissions. Additional
        work is being done in EPA's Totaj, Maximum Daily Load (TDML) program to evaluate
        the linkage of air emissions to water quality impacts, to help determine appropriate
        geographically targeted reduction actions. In addition, EPA intends to gather high quality
        emissions data on coal^fired electric generating plants to address current uncertainties
  .      about mercury emissions and support a regulatory action.
 Draft-November 16,1998                   Attachment 1-6

     Revise water quality criteria, and improve measurement of mercury in water. EPA
     will revise its water'quality human health criterion-for mercury and publish new
     analytical methods for measuring mercury levels in water.    .

     Seek reductions in uses of mercury and improve information and citizens' right to
     know. These use-reduction measures will reduce the levels of mercury in waste streams
     as well as the danger of accidental releases. Generally, EPA will look to voluntary rather
     than regulatory approaches to reduce mercury use. Additionally, EPA is considering
     changing the reporting requirements for mercury under the Toxic Release Inventory
     (TRI), which could result in additional reporting of mercury releases.

     Develop an environmentally acceptable disposal method for mercury wastes
     designated as hazardous wastes. Currently, EPA requires that hazardous wastes
     containing high levels of mercury be treated to recover the elemental mercury from the
     waste. This requirement may no longer be the preferred approach in all cases since the
     demand for mercury has been reduced to the point where the supply of recovered mercury
     exceeds it.  Also, there are some air emissions of mercury associated with the recovery
     process. Therefore, EPA is evaluating alternative treatment technologies which would
     permanently stabilize mercury wastes to allow their disposal in hazardous waste landfills.

     Seek reduction in exposure to highly  exposed populations. Because of the long time
     before reductions hi releases will be reflected in lower fish-tissue levels, EPA will
     continue public information and outreach programs, including continued support and
     strengthening of the states' and tribes' fish advisory programs.

     Decrease further environmental contamination from illegal use/disposal of mercury
     through focused compliance monitoring and enforcement of mercury restrictions
     and requirements.  Focus compliance assistance and outreach, monitoring and/or
     enforcement on sectors/sources that are significant contributors of mercury loadings to
     the environment  Where enforcement actions are warranted, use Supplemental
     Environmental Projects (SEPs) to encourage pollution prevention activities or mitigate
     damage. Expand compliance and enforcement activities for direct and indirect
     dischargers of mercury to surface waters.

      Continue international efforts to reduce mercury releases. The global circulation of
      mercury requires concerted efforts by all countries to solve the mercury problem in any
      one country.                                                             .

      Perform and support further research on all aspects of the mercury problem. A
     .research strategy is being developed that will permit targeting of federal and other
      research on the most important data gaps.                                .
Draft--November 16,1998                    Attachment 1-7

       Support regional, state, tribal and local actions to reduce mercury. Slate, Tribal and
       local governments play a key role in achieving mercury reductions. EPA will support  '
       state andlocal efforts through funding, information sharing, and coordination. For  -...-.
       example, EPA will expand outreach to publicly-owned treatment wprks about preventing
       mercury pollution in sewage discharges.       •                  ' '

       The list below provides inore detail about the most significant actions that EPA is
undertaking to deal with ^problem of mercury exposure. It is not an exhaustive list, and many
other EPA activities related to mercury, will continue. For further information ori these or other
mercury activities, please contact the offices involved..                               :  -..

1.     Air Regulations

       Municipal Waste Combustion Regulation                             .
                                    v        • . ' '             •'.••'•..          "''•••
       The.Clean Air Act requkes EPA to establish stringent emission limits for new and
existing municipal waste combustion (MWC) units and medical waste incinerators (MWI). The
limits are to be based on "maximumiachievable cpntrol technology" (MACT) and must address a
range of pollutants including organic emissions (such as dioxin and furans), acid gases emissions
(such as SO2, HC1, and NOJ, and metal emissions (including cadmium, lead, and mercury).

       EPA established the emission limits for MWCs in December 1995. New MWC units
must comply at start-up and existing MWC units must comply by December 2000. The control
system used at MWCs is acid gas/PM scrubbing to reduce organic emissions, acid gas emissions,
and metals emissions, other than mercury. To control mercury, the scrubbing system is s
supplemented with activated carbon injection.  A number of acid gas/PM scrubbing systems with
carbon injection have been installed and other retrofits are underway: Available data indicates
the controi.systems achieve over 90% mercury control. At the same time, battery, manufacturers
are reducing the mercury content of batteries which will also reduce the -mercury emissions.
Based on available data, overall mercury emissions from  MWCs were estimated to b&54 tons
per year (tpy) in 1990, were reduced to 29 tpy  in 1995, and will be jess than 5 tpy when all
retrofits are completed.             :                                            .
              " '  . - •        ,  !'    .-•'," ".""''-'
Office :      Office of Air and Radiation, Office of Enforcement and Compliance Assurance

Milestones:   New MWC units must comply  at start-up and existing MWC units must comply
              by December 2000.                                ,            ;, :     ;
 Draft -November 16,1998          _..;_    Attachment 1-8

•	t;!	„!•*
            Medical Waste Incinerators Regulations             .

            EPA set emission limits for MWIs in September 1997. New MWI units must comply at
     start-up and existing MWI units must comply by September 2002. The most common control
     system used at MWIs is a wet scrubbing system that reduces organic emissions, acid gas
     emissions, and metals emissions, including mercury.  Where MWTs are controlled with dry
     scrubbing systems, activated carbon must be injected for mercury control. Based on available
     data, overall mercury emissions from MWIs were estimated to be 50 tpy in 1990, were reduced
     to 16 tpy in 1995 (primarily as a result of state regulations), and will be less than 1 tpy when the
     MWI regulations are fully implemented.

     Office:              Office of Air and Radiation, Office of Enforcement and Compliance

     Milestones:   New MWI units must comply at start up and existing MWI units must comply by
                   September 2002.
            Promulgate Hazardous Waste Combustion Facilities Regulations'

            Section 112 of the Clean Air Act requires the Agency to promulgate regulations for the
      control of hazardous air pollutants emissions from specified source categories, including several
      types of combustion units that burn hazardous waste. In April 1996, EPA proposed emission
      standards for incinerators, cement kilns, and light weight aggregate kilns that bum hazardous
      waste. This proposal, which the Agency anticipates finalizing in December, 1998, requires the
      sources to control mercury emissions, as well as other hazardous air pollutants. Since the
      proposal, the Agency has received extensive public comment, including new emissions data and
      comments on the methodology used to estimate mercury emissions from these facilities.

             As required by the Clean Air Act, the final mercury standard will embody the maximum
      degree of reduction in emissions taking into consideration, as appropriate, the cost of achieving
      the emissions reduction. This strict, protective mercury standard will be based on mercury
      feedrate control (in the hazardous waste) and possibly also on other air pollution control
      technologies. The final rule is expected to achieve a substantial overall reduction in mercury
      emissions from these hazardous waste combustion facilities.

      , Office:               Office of Solid Waste, Office of Enforcement and Compliance Assurance

      Milestones:   Final hazardous waste combustion facilities (incinerators, cement kilns, and
                    lightweight aggregate kirns) regulations will be promulgated by February 1999.
       Draft-November 16,1998                   Attachment 1-9

       Develop Recommendations to Limit Rmi^iong from Additinri? 1

       Based m part on the recommendations of a Federal Advisory Committee, EPA is
developing regulations to limit emissions of hazardous air pollutants, including mercury, and
criteria pollutants for the following five source categories: industrial, commercial, and  *
institutional boilers; process heaters; industrial, commercial, and'other non-hazardous solid waste
combustors (excluding municipal waste combustors and medical waste incinerators); gas
turbines; and stationary internal combustion engines.
                     Office of Air and Radiation
Milestones;,   Proposed regulations by end of 2000
       Mercury Emissions from Power Plants                         .       '     J

       Emissions from coal-fired electric power plants. represent me largest source category of
mercury emissions to the atmosphere. EPA has just completed a repSr? to "Cohgreiss that  .
examines technologies and strategies to control mercury emissions frorn this sourc^ While there
are currently no cost effective control technologies for mercury that aB" commercially ivallable
for utility boilers, some may become available in a few years. .With implementation of the new
National Ambient Air.Quality Standards for fine participate matter and ozone, and the second
phase of the acid rain program,  EPA expects to see a reduction of mercury emissions from utility
boilers. Actions that power plants may take to reduce their emissions of the greenhouse gases
that are responsible for climate  change could also reduce mercury emissions from utilities. These
reductions will occur largely as powerplants switch to cleaner fuels and use fuels more  •'-'

       EPA intends to gamer high quality emissions data about coal-fired electric generating
plants to address current uncertainties about mercury emissions and support a regulatory action.
To accomplish this, the Agency is requesting comments on a proposal to require all cdal-fired
powerplants above 25 MWto-provide the results of analysis to determine the mercury content of
the coal they are burning. M addition a sample of plants would be required td-perfdim stack ~
testing for quantity and species'Of mercury emissions. The inforiftatiofiTobtained!fronlthK'effdrt
will allow EPA to'calculate the amount and species of mercury emitted' by^eachreoal>fired plant
above 25 MW., This information will be available to the public.               ;
                     Office of Air and Radiation
 Milestones:   Public comment period on notice closes on October 22, 1998

              After OMB approval, EPA will send put letters requiring emissions information in.
     .       '-*. the fall of 1998,         :.. .  ••    r                          .
Draft --November 16,1998,
                                            Attachment 1-10

       Promulgate Emissions Standard for Chlorine Production Facilities

       EPA is developing a rule that would limit mercury emissions from plants that produce
chlorine using the mercury cell method.  The rule will include emissions limits based on control
technology and on management practices.

Office:        Office of air and Radiation

Milestones:   Proposed standard-November, 1999
              Final standard - November, 2000.      '   -                    .
2.     Linking Air'Emissions to Water Quality Impacts to Prioritize Control Actions

       EPA will combine tools in the Clean Air Act and Clean Water Act to foster an air
deposition/water quality management approach with state and local partners, including providing
states and tribes with tools for developing and implementing total maximum daily loads (TMDL)
for mercury from air deposition.  EPA is also working on improving methods to identify
sources by developing ways to trace pollutants back to sources, distinguishing between.
anthropogenic and natural sources, and attributing atmospheric  loads to particular sources.

        The goal of the TMDL pilot project is to demonstrate how to develop a TMDL for a
waterbody that receives mercury from air deposition.  The project will evaluate how to access
and use existing air and water data to develop the TMDL, as well as how existing air and water
modeling methods can be used.  The project will also examine linkages between the Clean Air
Act and Clean Water Act, and specifically, what state, local, tribal, or federal regulatory
authorities that can be used to modify source air emissions to meet needed loading reduction

       To evaluate progress and emerging problems, EPA needs an updated information base on
levels of mercury and other persistent,, bioaccumulative toxics in fish. EPA will conduct a
"National Study of Chemical Residues in Fish". This survey will evaluate the incidence and
severity of mercury and other persistent, bioaccumulative toxicants in fish downstream of
suspected problem areas and in background areas. EPA will work in partnership with state and
tribal Departments of Health and Environmental Protection to carry out the study.

Office:  '           Office of Air and Radiation, Office of Research and Development, Office
                     of Water, Office otEnforcement and Compliance Assurance

•Milestones:   Complete the TMDL for mercury by end of 1999
              Complete studies on identifying sources by tracing emissions by end of 2000
              Initiate the "National Survey of Chemical Residues in Fish" in FY 1999.
 Draft-November 16,1998     .              Attachment 1-11

 3.     Revision of Mercury Water Quality Criterion

    •  :. Under theClean Water Act, EPA estabHshes water quality criteria, that are used by states
 and tribes to establish enforceable water quality standards. Water quality standards may reflect a
 variety of site-specific considerations.  Water quality standards are reflected in permitsfor
 dischargers tq surface, waters and in a variety of other regulatory actions.  -•

        the current national water quality criterion for mercury uses a method for estimating
..fish-tissue levels, the bioconcentration factor (BCF), Which does not include biomagnification in
 the food chain.  EPA subsequently published a water quality criterion for mercury in the Great
 Lakes basin which is based on use of a bioaccumulation factor (BAF), which does include
 biomagnification in the food chain.                            ..--/•

        The Office of Water (OW) is accelerating development of a revised water quality human
 health criterion for mercury* which will reflect two major elements:

 •      A revised Human Health Methodology - this provides for use of BAFs rather than BCFs,
        and improved means for estimation of fish consumption;"                   ':

 ••      An updated human health risk assessment

 The combined effect of these changes will be to make the criterion more reflective of sound
 science and current risk assessment practice; The preferred approach .to the revised criterion will  ;
 be a methylmercury fish level to be used with measured fish tissue methylmercury levels. States .
 and tribes which elect to depart from the. preferred approach will be referred to defaults which
 will include mercury and memylmercury water levels.  These water levels are likely to be more
 stringent than the Current criterion. The direct effect of a more stringent water quality criterion
 may be to include new or more stringent discharge limits for direct dischargers to surface water
 (both industries and municipalities).  Currently, direct water discharges are believed to be small
 compared to input from air deposition.  Nonetheless, limits oh direct discharges may be an
 important part of achieving mercury reduction goals.  In parallel with the revision of the water
 quality criterion, OW will be revising its required analytical method to be more sensitive (below
 the new criterion level) and less subject to sample contamination. Together, these changes will
 lead to a more precise measure of  mercury levels in water discharges and to more effective water
 quality-based effluent limits when the discharges are contributing to exceedances of water
 quality standards. EPA expects that permittees will most likely first consider pollution
 prevention to find and control sources of mercury into the wastewater, rather than end-of-pipe      -
 treatment to meet limits.       ,     \_~,;-  -..

        Indirectly, but no less importantly, revision of the water quality criterion will contribute
 to EPA's efforts to integrate assessment of watersheds and airsheds in order to target air
 pollution control and other activities to reduce mercury levels in water and ultimately, in fish and
 the humans and animals that eat fish.                                        '

 Draft--November 16,1998                   Attachment 1-12          .

      . With the release of the Mercury. Study Report to Congress, the Agency committed to
participate in an interagency review of recent human data on methyhnercury. This review will
concentrate on  levels of exposure to mercury associated with subtle neurological endpoints and
is aimed at achieving consensus among Federal agencies on estimates of human risk.  A
workshop is scheduled for November 1998.  In addition, Congress has required an 18-month
National Academy of .Sciences study and recommendation on the reference dose for methyl

Office:-             Office of Water                                        '

Milestones:    Draft.human health criteria methodology by the end of calendar 1999.

             • Peer review of application of new methodology to methyl mercury completed by

              Final development of mercury criterion in 1999.

4.      Pursue Voluntary Reductions in Industrial Use and Releases

       Mercury consumption in the United States is attributable primarily to a few categories  of
products and  processes, including the manufacture of chlorine and caustic soda, wiring devices
and switches, measuring and control instruments, dental amalgam and laboratories. EPA is
pursuing a number of voluntary reduction initiatives in these industrial uses and releases of  •
mercury.  Ongoing and planned mercury reduction actions include:

•      collaboration with the chlor-alkali industry to achieve a 50 percent reduction in mercury
       use and releases by this sector by 2005, a commitment made by this industry, through its
       representative, the Chlorine Institute. In addition, EPA will work with the industry to
       develop unproved estimates of releases from this sector;

•      outreach to hospitals, including Veterans Administration hospitals and other public and
       private hospitals to encourage them to discontinue purchases of mercury-containing
        devices and products and to properly dispose of existing mercury. In addition, EPA will
        explore opportunities to work with the American Hospital Association, other medical
        facilities, dentists, and veterinary clinics on reducing use and release of mercury;

 •       outreach to manufacturers and users of mercury switches and relays on mercury-free

 •      outreach to the utility industry to encourage implementation of voluntary efforts to
        control mercury release, including elimination of the use of mercury-containing
        equipment, and exploration of potentially cost-effective options such as fuel-switching

 Draft--November 16,1998         .           Attachment 1-13

        andoptimization for mercury-reduction of controls whose primary purpose is reducing
        emissionsof other pollutants; and    "             •                      :.
       collaboration with laboratories on reduction of mercury use. As part of this effort, EPA
       will work with other standard-setting bodies to address mercury pollution prevention
       opportunities through revisions to approved analytical methods and directions for
       laboratory use, handling and recycling or proper disposal of mercury.
           ' '         -             '            ~  .     .':'•'''             • ' \"
 Office:              Office of Prevention, Pesticides, and Toxic Substances, Regions 1 and 5

 5.     Reduce Reporting Threshold for Mercury Under Section 313 of the Emergency
       Planning and Community Right-tb-Know Act (EPCRAV

       Mercury and mercury compounds are currently listed under section 313 of EPCRA and
reports are received from facilities that manufacture, process,  use, release into the environment,  '
or otherwise manage as waste mercury and mercury, compounds. These reports are made
available to the public through the Toxics Release Inventory (TRI). However, to date the reports
have come from a fairly small number of large sources, such  as. chlor-alkali plants.  In 1997 the
categories of industrial facilities required to report under EPCRA section 313 were expanded'to
cover, among others, electric utilities, and hazardous waste treatment, storage and disposal (TSD)
facilities.  Combustion of fossil fuels for energy has been identified as a major source of
mercury. • Therefore, the facilities expansion could result in significant increases in reporting of
mercury under EPCRA section 313.              .       .:   ...
                                         '      " -  •       '   ". • •     ,"-—''•_,        *_
       It is likely that, to  date, few reports on mercury releases have been received under
EPCRA section 313 because reporting thresholds have been too high to. capture mercury releases
from many covered facilities. In order to ensure that reporting on mercury under EPCRA section
313 will be fully effective, especially taking into account releases from industrial facilities newly
subject to EPCRA section 313, EPA is considering reducing the repbrting threshold for mercury.
EPA can reduce reporting thresholds from the levels set out under EPCRA section 313 as long as
the new threshold "shall obtain reporting on a substantial majority of total releases of the
chemical at all facilities subject to the requirement of this section." EPA is currently reviewing
 data on mercury in light of the criteria established in the statute for revision of the TRI reporting

       EPA expects to propose a rule lowering the reporting thresholds for chemicals that persist
 and bioaccumulate (including mercury ard mercury compounds) by the end of 1998. A final rule
 is expected by the end of 1999. Reporting under the final rule would be expected to begin in
 2000, with the first reports covered by the new rule released in 2001.               :

 Office:              Office of Prevention, Pesticides, and Toxic Substances

/Draft-November 16,1998;                   Attachment 1-14    .      -      V
• i

Milestones:   Proposed Rule - end of-1998
              Final Rule-end of 1999
6.     Develop Disposal Options for Hazardous Wastes Containing Mercury

       Current'waste treatment standards for many hazardous wastes containing mercury are
based on recovery of mercury through retorting. EPA is planning to evaluate other options
because 1) the supply of recycled mercury is increasing while the demand is decreasing and 2)
there are concerns over potential emissions from retorting. In addition, for organic hazardous
wastes which contain mercury, the current treatment standards are often based .on incineration,
which also raises concerns over air emissions;                                           . .

       Therefore, EPA is considering an Advance Notice of Proposed Rulemaking .(ANPRM) to
revise its hazardous waste treatment standards to include alternatives based on permanent
stabilization of mercury. These alternatives could also apply, to elemental mercury. The Agency
hopes to issue this ANPRM in 1999.

'Office:              Office of Solid Waste                         .

Milestones:   ANPRM in 1999
 7.     Give High Priority to Mercury in International Efforts

       Mercury's ability to be cycled globally poses both a challenge and an opportunity to the
 U.S. As long as mercury is produced, used and released into the environment in other countries,
 the U.S. will be on the receiving end of some mercury, thus reducing the overall impact of our
 domestic mercury control measures. Yet, this problem represents a real opportunity for the U.S.
 to demonstrate leadership internationally on mercury risk characterization and risk reduction.

        EPA is participating in bilateral and international fora to encourage the cooperative
 development and use of relevant scientific and technical information about mercury.  These fora
 include the U.S.-Canada Great Lakes Binational Toxics Strategy, the North American
 Commission for Environmental Cooperation (CEC) and its Sound Management of Chemicals
 Initiative, the U.N. Economic Commissipn for Europe's Convention on Long-Range
 Transboundary Air Pollution (LRTAP) and  its legally-binding protocol on mercury and other
 heavy metals, the Organization for Economic Cooperation and Development (OECD) and its
 programs on heavy metals risk management and the elimination of environmentally adverse
 economic subsidies, the Arctic Monitoring and Assessment Program (AMAP), and the New
 England Governors/Eastern Canadian Premiers (NEG/ECP) Mercury Action Plan.         .
  Draft --November 16,1998                   Attachment 1-15


        On AP^V7,1997, the United States and Canada signed the Great Lakes Binational Toxics
        fc Them^>- emissions reduction,goal of the.binational strategy is detailed on page 2 of
     action plan. At the present time the EPA and Environment Canada are working with all
 industrial sectors that release mercury, States, Tribes, environmental groups and the public, to
 help identify and undertake specific mercury reduction activities.

        Under the CEC Resolution #95-5 mercury was identified  as one of the first four
 chemicals selected for the Sound Management of Chemicals Initiative, A North American
 Regional Action Plan (NARAP) on mercury has been developed that establishes a number of
 cooperative initiatives among Mexico, Canada, and the United States to improve the scientific
 understanding of the mass balance of mercury in North America, to promote pollution prevention
 actions across the continent, and to assist Mexico in capacity building.  By June of 1999, phase II
 of the NARAP will be completed.  It will establish specific actWoriented commitmerits for
 activities addressing mercury use and reductions.

       ,In February 1998 the U.S.and other Parties to the U.N. Economic Commission for
 Europe's Convention on Long-Range Transboundary Air Pollution (LRTAP) concluded
 negotiations on a legally-binding protocol ;6n mercury arid other heavy metals.  The protocol
 includes obligations to control mercury emissions from stationary sources and to establish and
Deport mercury emissions inventories. It also contains obligatory and voluntary provisions
 regarding the use of mercury hi products. The U.S.  can take a number of steps to encourage
 other ECE countries to comply with the protocol.

       Through the Arctic Monitoringand Assessment Program and other international
 initiatives, the U.S. is collaborating with other countries to better characterize and understand the
 international or transboundary nature of mercury sources, transport, deposition and fate. In
 addition, the U.S. will continue to encourage other countries to undertake domestic mercury risk
 reduction measures, with a focus on pollution prevention approaches: This could involve
 working bilaterally on a gdvernmenfc-to-government basis and multilaterally through the OECD,
 the LRTAP 'Convention or other international fora.

       On June 8,1998 The New England Governors/Eastern Canadian Premiers signed a
 resolution concerning mercury and its impacts on the environment. In addition, the Governors
 and Premiers adopted the Mercury Action Plan which has as its regional goal, "the virtual,
 elimination  of the discharge of anthropogenic mercury into the environment" TheNEG/ECP
 has established a task force, which includes the New England states, the Eastern Canadian
 Provinces', to coordinate and implement the Mercury Action Plan.The action plan identifies 45
 specific actions to reduce mercury emissions. Including emission reduction targets from specific
 source categories; such as municipal waste combustors, medical waste incinerators, sludge
 incinerators, utility and non-utility boilers, industrial and area sources and source reduction and
 safe waste managementof mercury.                         '..•••.-               '  "'-."'"
 Draft - November 16,1998
Attachment 1-16

 Office:       .       Office of International Activities, Office of Prevention; Pesticides, and
                     Toxic Substances, Office of Research and Development, Regions 1, 5, and

 Milestones:   Representation for Heavy Metals (including mercury) at AMAP Expert and
              Working Group Meeting, Anchorage AK, April 20-24,1998

              Representation For Mercury at the Arctic Council Senior Officials meeting,
              London, UK, August 1998                                   .

              Signing of LRTAP Heavy Metals Protocol, Denmark, June 1998'

              Development and implementation of cooperative mercury monitoring programs
•  '            with other Arctic countries

              By June of 1999, phase II of the CEC NARAP will be completed.

           •   The Mercury Task force will report back to the NEG/ECP Committee of the
              Environment hi June 1999.                        •
 8.     Develop a Mercury Research/Monitoring Strategy and Implement an EPA Mercury
        Research/Monitoring Plan

        The Office of Research and Development (ORD), in cooperation with scientists from
 EPA program offices and regions, will develop a mercury research/monitoring strategy to
 facilitate coordination and communication on mercury-related research plans and projects
 among organizations in the public and private sectors, including other Federal agencies, state
 governments, academia and industry. This brief strategy document will be developed using as its
 basis the risk-based framework in the Mercury Study Report to Congress and will include the
 following summary information:    .

 (1)    description of research needed to better assess potential health and ecological risks, to
        more completely document exposures, and to better manage such risks, and

 (2)    description of ongoing EPA research activities, including various modeling and
        monitoring studies, e.g., in South Florida and in the Great Lakes region and participation
        in international fora, e.g, the North American Task Force on Mercury (pursuant to the
        North American Commission on Environmental Cooperation established under NAFTA).

        The strategy will identify the scientific and technical information needs and priorities for
  research in the relevant areas. Some of the research areas that may be addressed are: emission
  characterization, atmospheric transport arid" fate, deposition, fate in terrestrial and aquatic media,
  Draft.-November 16,1998
Attachment 1-17

 *.',•.•••_• •.•-;_•• • ; -,\.,f-^;.C-Vr"iK*: '"'^--f^';-^-, ^ •\S'l'••'••'•  . :,  • •• • • - •'••• ••.-', . '•'.'•,• • ,i\ 'rft\-;...'f'. ;..:•• >. TrtV. -'">"- :V..,;>"':**.--• •;%;•• «j*
  bip^umulatipn;; ecplogicafctoxicrtv, health effects^ exposure, monitdrihg, risk communication;
  and nskman^e^ent-relatedprevention, control, and remediation of mercury and mercury
  compounds. OJRuiitiated the strategy development.effort in January 1998 and wm make
  available a drap that is ready for peer review by October 30,1998.

         Based on the mercury research/monitoring strategy, ORD and other EPA offices  in
  cooperation with the greater scientific community, will develop and implement an EPA'
  research/monitoring plan.  The plan will build oh ongoing research efforts in the areas of
  mercury fate and transport modeling and monitoring, assessment methods development for
  health and ecological impacts, risk communication, and advances in pollution prevention and
  other nsk management technologies and approaches. The plan will include consideration of the
  following research areas:        .. •  .*'•                                             .

         the development and evaluation of emission control technology for coal-fired utilities and
         other mercury emitters in support of the Office of Air  and Radiation (OAR) and the
         Office of Solid Waste and Emergency Response (OS WER) programs. This effort will
         include attention to speciation issues, control option costs and the ultimatedisposal of the
         mercury-contamingwastes resulting from^e control options. '"
- -i.     .-••.••'""'  '         '      ..."..   ' '..''•  -•'  "•'  "'.'•.'•'   '    •     "'   "   '    •'-•
 *       the development of iate, transport and transformation data in support of Office of Water
         (OW) determinations of total maximum^^  daily loads (TMDLs) for mercury.

         the provision of deposition monitoring technology to determine the effectiveness of
         control options.

  •       the virtual elimination of the use of mercury in products and unproved management of
         mercury wastes in support of the Office of Prevention, Pesticides, and Toxic Subsfences
         (OPPTS), OSWER, and the Regions.

         the refinement and improvement of health and environmental risk assessments for
         mercury that reflect evaluation of recent studiesof healthand environmental effects of,
         mercury exposure, with particular attention to sensitive sub-pbpuiations, e.g., the
         developing fetus and children,, to support risk-based decision-making.

         Work under this plan will include research conducted in-house by ORD, as well as a
  component ofextramural.research supported through ORD's Science To Achieve Results
  (STAR) grantsprogram,  i

  Office:    .          Office of Research and Development

  Milestones:   Draft mercury research strategy-October 30,1998                       -
  Draft -.-November 16,1998           ..      Attachment 1-18

9.     Develop. Options For Addressing Abandoned Mines Mercury Problem

       Mercury at abandoned mine sites is a problem faced by many western States. The
mercury at the abandoned mine sites is either from abandoned mercury mines (No active
mercury mining occurs in the United States), or from gold and silver mining sites, where
mercury was either used as an amalgamation agent in historic large scale placer mining and
traditional hard rock mining operations, or from recent small scale "recreational" placer mining
operations, which continue to flourish in the western states.
                                     i    •        •        .....••
       To address the potential for mercury, contamination of watersheds that drain these
abandoned mine sites, EPA will support efforts to fully research the extent and nature of this
problem, including efforts to, characterize and map the sites, and study watershed impacts
downstream. EPA will also support efforts to locate responsible parties where feasible. EPA
will also assist in the cleanup and remediation of sites, undertaken by "Good Samaritans" as
defined by the law in different States. EPA will consider whether it would be appropriate for
certain abandoned sites to be issued NPDES permits, or general storm water permits, where such
permits are not currently required or have not been issued.             •

       Disposal options will also need to be developed for the disposal of mercury contaminated
mining wastes. Currently the common options are to cover the site soils with clean soil, paving,
or some other material, or to excavate and transport the contaminated soil to an offsite landfill.
Another alternative for small and large sites that should be considered is permanent stabilization
of mercury.  This has been proposed for an ANPRM in 1998, and the ANPRM could be required
to address the potential use of permanent stabilization as a disposal method for mine wastes,
including a study of its scientific feasibility and costs.  Another alternative to control mercury
disposal at small "recreational" placer mining sites, may be to provide specially marked and
designed disposal containers for use in small scale placer mining, and education on how and why
these containers should be used. Methods to safely dispose these containers must also be
developed and implemented.

Office:  '            Region 9, Office of Water

 Milestones:    ANPRM in 1998                  '                            ;'.' '
 10.    Support Regional, State and Local Actions to Reduce Mercury

        State and local governments are~vital to the achievement of mercury reductions.  They
 have a central role to play in outreach to the business community and to the general public about
 the importance of properly disposing of mercury-containing products and the alternatives to such
 products. In addition to this important pollution prevention role, State and local governments
 have developed innovative mercury reduction laws and regulations that supplement, and in some

 Draft— November 16,1998                   Attachment 1-19

 cases provide jmoo^l ft*, national efforts. EPA .supports S
 ol mercury re^ucfroa projects, provision of information abbut mercury sources an^redtiction  •
 opportunities, and coordination of joint efforts. This support will be expanded under .:
 implementation of the Great Lakes Binationai Toxics Strategy.

 Funding Support; EPA supports State and local efforts through grants to worthwhile projects
 Examples of current projects funded by EPA include: an exploration in Minnesota of innovative
 ways to regulate the release of mercury comprehensively, including fiom currently-unregulated
 sources, such as a mercury emissions "cap-and-trade" program; State mercury task forces, which
 are bringing together stakeholders to make and ^^ implementrefiommendations for sectors that use
 or release mercury;' mercury "clean sweeps" that collect and properly dfepdse of household and
 small business stores of unneeded Mercury; mercury pretreatment programs at sewage treatment
 districts; investigation of use of mercury in ethnic practices, and a variety of outreach efforts to
 small business. State business outreach efforts funded by EPA include a program to encourage
 heating, ventilation, and air conditioning contractors and suppliers to promote the use of non-
 mercury thermostats and to properly dispose of mercury thermostats that they replace, and
 outreach to hospitals and other medical care facilities to encourage thern to avoid or limit the use
 of mercury-containing products and to properly manage me disposal of existing mercury. EPA
 will contiriueto fund Stateand local projects ; that create innovative ways to reduce mercury or^
    follow a path of proven success.                         ,:         .•'.- ,"; ••'...- •'•-•••.'•',..
       In addition, EPA will work with states to incorporate mercury reduction activities into the
day-to-day, work of state environmental agencies by making these activities a priority in
Environmental Performance Partnership Agreements (EnPPAs). EnPPAs define the working
relationship among state environmental agencies and describe the work that state agencies will
do with federal funds.   .   :      .            .                    .

Information and Coordination: EPA also plays an important role by providing information and
.facilitating information exchange about mercury among States. Currently, this function; is most
highly developed among the Great Lakes States, where EPA leads a Mercury Workgroup that
promotes information exchange about mercury and encourages cooperation among local, state  !
and federal agencies in their mercury reduction efforts. The workgroup has allowed participants
to help each other develop more effective programs for the control of mercury, and has helped
educate participants on the latest mercuryrrelated research.  Italso provides a fbrurafi^ '•-.-
coordination of inercury-related work among staffwith responsibilities fbrdifferentK  \.  /
environment media. The workgroup ^^ seeks to reduce mercury releases in the Great Lakes states
through the regulatory process and through voluntary pollution prevention programs. Activities
that the workgroup engages in : include: identification of mercury sources; identification of
       * For uisfance, Michigan's Mercury; Pollution PreventioaTasfe Force secured ffie^^
 commitment of the auto indusuy to eliminate theuseof mercury switches used for convenience
 'lighting.'.- ';   .'-/JSv   .'":"/:•'.• "^\ -.'_'•   "''•.•:'/•    -  :,;:';.-;;',-.^:/:'.-'.-".:.'-:
 Draft - November 16,1998>
Attachment 1-20
                                                                                             - "-A-

alternatives to mercury use; refinement of public outreach information and materials;
commenting on draft legislation and regulation; development of conferences, and updates on
mercury-related research.

       EPA will expand this role nationally under implementation of the Binational Toxics
Strategy, with a Mercury Web Site and list-server to disseminate information about mercury
sources and reduction opportunities more broadly, including to State and local governments
outside of the Great Lakes basin. This effort will include publicizing model pollution prevention
programs that State, Tribal and local governments can adopt.

       In addition, EPA will support State, Tribal and local efforts to educate the public on
appropriate ways to reduce mercury exposure. As part of this effort, EPA will continue to
provide State, Tribal and local agencies with technical assistance in the development of fish
consumption advisories that reflect local mercury levels and local fish consumption patterns, and
which balance the risks of exposure to mercury with the health benefits of including fish in the
'diet.                                         :        .              -                 .

       Finally, the mercury reduction work undertaken through the Binational Toxics Strategy
•will be coordinated, as much as possible, with other ongoing national, binational, trilateral and
international efforts, such as the Commission for Environmental Cooperation (CEC).

Legislation and Regulation.: Under the Binational Toxics Strategy, EPA plans to compile and
disseminate information on model State, Tribal and local mercury-related legislation and
regulation. In addition to the pollution prevention programs described above, individual States
have developed legislation or regulations prohibiting incineration or landfilling of mercury-
containing lamps and other devices, phasing out the use of mercury hi dairy manometers and
other products, and requiring manufacturers  of mercury relays  to develop take-back programs.
Publicizing these innovative laws and regulations will provide a possible model for other
governments to follow.                                       .      .    •      .

        Recently, Region 5 has begun to coordinate with States on possible expansion of the
"Universal Waste Rule" to cover additional mercury-containing wastes beyond the thermostats,
batteries and pesticides encompassed by this regulation.  Inclusion in the Universal Waste Rule
can streamline waste handling requirements and encourage the safe disposal or recycling of
 mercury-containing products. EPA will consider expansion of this effort on a national basis.

        EPA will assist States hi adoption of regulations to control mercury emissions from
 medical waste incinerators and municipaXwaste combustors, and will work with States and
 sources to .develop schedules for compliance with the regulations.

 Assistance to Sewage Treatment Works: Local sewage treatment works will play an important
 role in mercury reduction through implementation of pretreatment programs that encourage or
 require industrial users and households to limit mercury discharges. EPA has funded model

 Draft-November 16,1998                   Attachment 1-21



                                    la Duluth, Minnesota and Detroit, KKs-I
        compendium of mercury pollution prevention information useful for pretreatment program
        managers. EPA^will provide information to sewage treatment works nationwide on different
        strategies to reduce mercury releases. These strategies could be considered for development of.
        required pollutant minimization programs, and State and/or Federal compliance assistance
        efforts. This outreach to sewage treatment works could be part of a multi-media .approach for
        municipalities, including mercury reduction opportunities for all municipal 'Vastestreams":
        wastewater, solid waste, and ak emissions.

        Compliance Monitoring and Enforcement!  Decrease furthetenvironmental contamination from
        illegal use/disposal of mercury through focused compliance monitoring and enforcement of
        mercury restrictions and requirements. Focus compliance assistance and outreacli, monitoring
        and/or enforcement ort sectors/sources which are significant contributors of mercury loadings to
        the environment  Where enforcement actions are warranted, use Supplemental Environmental
        Projects (SEPs) to encourage pollution prevention activities  or mitigate damage;.

              To further the Agency's goals to protect and enhance public health- and me environment,
        in applicable circumstances EPA advocates the inclusion of Supplemental Environmeiital
        Projects (SEPs) in the settlement of environmental enforcement actions. A SEP is aa       r
        environmentally beneficial project which a defendant agrees to undertake as part of such a
        settlement, but which the defendant is not otherwise legally required to perform. This may
        include cleaning up a damaged area beyond the regulatory requirements or providing some
        additional protection not required by regulation or statute. A defendant's willingness or ability to
        perform a SEP is considered as a factor in establishing the final penalty paid by the defendant
        EPA particularly encourages  SEPs in communities where there are environmental justice
        concerns, to help ensure that persons who spend significant portions of their time in areas, or
        depend on food and water sources located near where violations have occurred, are protected.
Regions, Office of Air and Radiation, Office of Solid Waste,-Offidef of
Water, Office of Enforcement and Compliance Assurance;
        Draft - November 16,1998
                       Attachment 1-22

      .  '      •                       References

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

U.S. Environmental Protection Agency (1993). Deposition of Air Pollutants to the Great Waters:
1st Report to Congress. EPA-453-R-93-055

U.S. Environmental Protection Agency (1997). Deposition of Air Pollutants to Great Waters: 2nd
Report to Congress. EPA-453-R-97-011.                   .   .

U.S. Environmental Protection Agency (1996). Environmental Goals for America with
Milestones for 2005, Draft for Government Review.

U. S. Environmental Protection Agency and Agency for Toxic Substances Disease Registry
(1996). National Alert on Metallic Mercury Exposure.           .

U. S. Environmental Protection Agency (1997). Mercury Study Report to Congress. EPA-452-R-
97-003-009.                                              .

U. S. Environmental Protection Agency (1997).  EPA's Strategic Plan. EPA/190-R-97-002.

U. S. Environmental Protection Agency (1998) The Utility Air Toxics Report to Congress.

CEC (1998). Final Mercury North American Regional Action Plan.
.Draft-November 16,1998   ,               Attachment 1-23