United States
                 Environmental Protection
                 Agency
EPA-HQ-OPPT-2005-0013

http://www.epa.gov/mercury/roadmap/htm
  July 2006

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TABLE OF CONTENTS
ERA'S ROADMAP FOR MERCURY







LIST OF TABLES AND FIGURES                                    ii




EXECUTIVE SUMMARY                                          3




INTRODUCTION                                             15




I.  ADDRESSING MERCURY RELEASES                              21




II.  ADDRESSING MERCURY USES IN PRODUCTS AND PROCESSES            35




III. MANAGING COMMODITY-GRADE MERCURY SUPPLIES                 43




IV. COMMUNICATING TO THE PUBLIC ABOUT MERCURY EXPOSURE RISKS     47




V  ADDRESSING INTERNATIONAL MERCURY SOURCES                  53




VI. CONDUCTING MERCURY RESEARCH AND MONITORING               63




APPENDIX                                                 75




ENDNOTES                                                79

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ii - EPA's Roadmap for Mercury
   LIST OF TABLES AND FIGURES


   FIGURE 1. THE MERCURY CYCLE                                       16

   TABLET.  NATIONAL AIR EMISSIONS ESTIMATES FOR MERCURY             22

   FIGURE 2. AIR EMISSIONS DATA FOR MERCURY                           24

   FIGURE 3. TOTAL 2001 U.S. MERCURY USE IN PRODUCTS                   36

   FIGURE 4. U.S. MERCURY PRODUCT AND PROCESS USE TRENDS             37

   FIGURES. WHERE ARE MAN-MADE MERCURY EMISSIONS ORIGINATING?       53

   FIGURE 6. MAN-MADE AIR EMISSIONS OF MERCURY: DISTRIBUTION BY
           REGION IN 1990 AND 2000                                   54

   FIGURE?. GLOBAL MERCURY USE, 2000                                 55

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                                                                         Executive Summary - 3
         EXECUTIVE
          SUMMARY
OVERVIEW
Mercury is a naturally occurring element.
It enters the environment as a result of
natural sources (such as volcanoes) and
human activities (such as industrial com-
bustion and mining). Mercury is wide-
spread in the U.S. and global environ-
ment. Human activities have increased the
amount of mercury that is available in the
atmosphere; in soils and sediments; and in
lakes, streams, and oceans.

Significant progress has been made to date
to reduce industrial emissions of mercury
in the U.S., as well as to reduce or elimi-
nate the amount of mercury used in
various processes and products. Most of
the large industrial sources of mercury
emissions are sites where mercury is
emitted as a byproduct of combustion
processes. Other major sources of mercury
include industrial processes and products
that use mercury deliberately, such as
certain chlor-alkali chlorine manufactur-
ing processes, batteries, lamps, and mea-
suring devices such as thermometers.
Mercury is also released through mining
practices, sewage discharge, and metal
refining operations. When mercury is used
in a product, most releases occur during
manufacturing or disposal. In the U.S.,
there are over 100 manufacturing pro-
cesses that use some form of mercury.1

While elemental mercury is toxic to
humans when it is ingested or inhaled,
EPA is most concerned about methylmer-
cury, as it is a potent form of mercury and
it is the form to which humans primarily
are exposed. Methylmercury  can be
formed from other deposited mercury by
microbial action in sediment and soils.
Once formed, methylmercury can be
taken up by aquatic organisms and
bioaccumulates up the aquatic food web.
While all forms of mercury can
bioaccumulate, methylmercury generally
accumulates to a greater extent than other
forms of mercury.2

Mercury Sources
The primary sources of mercury releases
to air, water, soils, and sediments  can be
grouped into four categories:

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4 - EPA's Roadmap for Mercury
             1.  New releases from naturally-occurring
                sources (such as volcanic activity and
                weathering of rocks)

             2.  Re-releases of historic mercury previ-
                ously deposited through natural and
                anthropogenic processes in soils,
                sediments, water bodies, landfills, and
                waste tailings/piles (also called "re-
                emitted sources")

             3.  New releases of mercury impurities
                from combustion of fossil fuels, and
                from smelting of metals such as gold
                and zinc

             4.  New releases resulting from uses of
                mercury in products and manufactur-
                ing processes such as chlor-alkali
                manufacturing

             Exposure Pathways
             In the United States, humans are exposed
             to methylmercury mainly by consuming
             fish that contain methylmercury. Aquatic
             ecosystems respond to changes in mercury
             deposition in a highly variable manner as a
             function of differences in their chemical,
             biological, and physical properties. De-
             pending on the characteristics of a given
             ecosystem, methylating microbes convert a
             small but variable fraction of the inorganic
             mercury in the sediments and water
             derived from human activities and natural
             sources into  methylmercury. Methylmer-
             cury is the only form of mercury that
             biomagnifies in the food web.  Concentra-
             tions of methylmercury in fish are gener-
             ally on the order of a million times the
             methylmercury concentration in water. In
             addition to mercury deposition, key factors
             affecting methylmercury production and
             accumulation in fish include the amount
             and forms of sulfur and carbon species
             present in a given water body. Thus, two
             adjoining water bodies receiving the same
deposition can have significantly different
fish mercury concentrations.3

While the primary pathway of human
exposure to  mercury is through eating fish
containing methylmercury, individuals
may also become exposed to harmful
levels of elemental mercury vapor found
indoors in work places and in homes.
When exposed to air, elemental mercury
vaporizes and can be inhaled. The number
of individuals exposed in the U.S. in this
way is very small.

Fish Consumption Advice
Fish and shellfish are an important part of
a healthy diet, since they contain high
quality protein and other essential nutri-
ents, are low in saturated fat and contain
omega-3 fatty acids. A well-balanced diet
that includes a variety of fish and shellfish
can contribute to heart health and
children's proper growth and develop-
ment. EPA and the U.S. Food and Drug
Administration (FDA) have issued fish
consumption advice to help consumers
understand the connection between the
risks of methylmercury and the benefits of
fish.

Research shows that most people's fish
consumption does not cause a health
concern. Elevated methylmercury in the
bloodstream of unborn babies and young
children may harm the developing ner-
vous system, impairing the child's ability to
learn and process information.4 However,
certain sub-populations are at higher risk
than the general population because of
their routinely high consumption of fish
and shellfish (e.g., tribal  and other subsis-
tence fishers and their families who rely
heavily on locally caught fish for the
majority of their diet). Mercury concentra-
tions in fish vary widely. While local
freshwater fish also contain methylmer-

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                                                                             Executive Summary - 5
cury, the majority of fish species consumed
in the U.S. are ocean species and the
methylmercury concentrations in these
species are primarily influenced by the
global mercury pool. Fish that are higher
in the food chain—such as king mackerel,
swordfish, tilefish, and shark—have much
higher methylmercury concentrations
than fish that are lower in the food chain.

The major tool for reaching and educat-
ing affected populations has been through
fish consumption "advisories" or warnings
issued by states, tribes, and the FDA. In
March 2004, EPA and FDA issued a joint
federal fish advisory for mercury in fish
and shellfish. The advisory provides advice
for women who  might become pregnant,
women who are  pregnant, nursing moth-
ers, and young children (see Appendix for
the entire FDA/EPA joint advisory).5
Additional EPA outreach actions aimed at
reducing risks from  mercury are discussed
in Chapter IV.

Continuing Research on  Sources of
Exposure
U.S. mercury deposition is from domestic
man-made sources and from global
sources, including natural, re-emitted, and
international man-made sources. EPA has
estimated that over  three-quarters (83
percent) of the mercury deposited in the
U.S. originates from international sources,
with the remaining  17 percent coming
from U.S. and Canadian sources.6 These
figures include mercury from natural and
re-emitted sources. This estimate is based
on an advanced, state-of-the-science
modeling assessment of atmospheric fate,
transport, and deposition of mercury.
EPA's modeling indicates that a substantial
variation in mercury deposition occurs
across the U.S. with domestic sources
influencing mercury deposition much
more in the eastern U.S. and global
sources being a more significant contribu-
tor to mercury deposition in the west,
where relatively few domestic sources exist.
The scientific community's understanding
of mercury atmospheric chemistry is
evolving and there remain uncertainties
regarding the simulation of mercury in
atmospheric chemistry models. EPA
continues to work to advance the state of
the science on mercury chemistry and fate
and transport modeling.7

EPA has analyzed various scientific ques-
tions relating to the primary fish-to-
human exposure route, including key
scientific questions described in Chapter
VI. EPA recognizes that there remain
scientific uncertainties associated with
some of these questions, and is committed
to continuing to work to advance the
science in these areas.

Reducing Exposure by Addressing
Mercury Releases and Uses in the
U.S. and Internationally
EPA's long-term goal is to reduce risks
associated with mercury. EPA recognizes
that to reduce the risks associated with
mercury, the Agency must first understand
what contributes to the risk and what the
appropriate mechanisms of risk reduction
might be. EPA will take action to identify
exposed populations, minimize exposures
through outreach efforts, and appropri-
ately reduce anthropogenic releases. As
part of its strategy, EPA will assess mercury
sources of concern and will: focus on uses
that would lead to risk, where cost-effec-
tive substitutes exist; promote reducing
mercury in processes and products where
benefits of such reductions would justify
costs, even where cost-effective substitutes
do not exist; and work to identify and
encourage development of alternatives  to
essential uses of mercury that lead to risk.
EPA will also work with its federal partners

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6 - EPA's Roadmap for Mercury
             to address risks associated with manage-
             ment and disposal of excess supplies of
             commodity-grade mercury in the U.S. In
             addition, EPA will support the efforts of
             other countries to take action to address
             risks associated with global mercury
             pollution by developing and implementing
             partnerships with international organiza-
             tions, non-governmental organizations,
             and the private sector.

             Six Areas of Focus in EPA's Roadmap
             for Mercury
             EPA's Roadmap focuses on six key areas,
             with the overarching goal of reducing
             health risks associated with mercury
             exposure. EPA will reduce risk by:

             1.  Addressing mercury releases to the
                environment

             2.  Addressing mercury uses in products
                and processes

             3.  Managing commodity-grade mercury
                supplies

             4.  Communicating risks to the public

             5.  Addressing international mercury
                sources

             6.  Conducting mercury research and
                monitoring

             Success in reducing risks associated with
             mercury exposure and mercury pollution
             in the domestic and global ecosystem will
             depend on pursuing all six of these actions
             simultaneously. The actions described in
             the Roadmap will be implemented over a
             number of years. EPA will periodically
             assess progress and make needed changes
             based on new information, successful
             efforts,  and emerging needs. EPA will
report on its progress, as well as on any
major changes in direction from the
current Roadmap.

ABOUT THIS REPORT
Over  the past decade, addressing mercury
risks to the environment and human
health has been a focus for EPA. Interna-
tional, national, and local efforts to reduce
mercury releases and uses have grown and
are yielding impressive results. For ex-
ample, overall U.S. mercury air emissions
have been reduced by 45 percent since
1990,8 and mercury use in products and
processes decreased 83 percent between
1980  and 1997.9 In  1997, U.S. man-made
emissions contributed to approximately 3
percent of the global mercury pool.10

In 1998, EPA issued a draft Mercury Action
Plan for public comment as part of its
effort to address priority persistent and
bioaccumulative toxic pollutants. The
Agency received extensive comments on
the 1998 draft and held subsequent
meetings with states and tribes, munici-
palities, industry, and environmental
groups, including a series of "listening
sessions" in 2003. Stakeholders provided
very useful input on those aspects of the
mercury issue on which they believed the
Agency should focus its efforts. EPA also
created an agency-wide workgroup to
develop a new action plan, now called
EPA's Roadmap for Mercury (Roadmap).

Major offices at EPA are continuing to
work  to better understand the sources of
mercury and how it impacts human
health and the environment. The
Roadmap describes the Agency's most
important actions to reduce both mercury
releases and human exposure to mercury.
Creating the Roadmap has enabled the
Agency to maximize coordination of its

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                                                                            Executive Summary - 7
many diverse efforts, with the goal of
improving EPA's mercury program. In
addition to providing a roadmap for EPA,
this report provides important informa-
tion about mercury to other federal
agencies, to our partners in state, tribal,
and local governments, and to the public.

SUMMARY OF THE ROADMAP

Human Health and Ecological Effects
Mercury exposure can cause a number of
adverse effects on human health. These
effects can vary depending on the form of
mercury to which a person is exposed and
the level and length of exposure. The
primary way humans are exposed to
methylmercury is  through eating fish
containing methylmercury. Research
shows that most people's fish consumption
does not cause a health concern. Methyl-
mercury exposure can cause neurological
impairment. The fetus and very young
children are more sensitive to methylmer-
cury than adults. Methylmercury in the
mother's body passes to the fetus and may
accumulate there. There is evidence in
adults that the organic form of mercury,
methylmercury, also affects other systems.
Specifically, some studies suggest that
prolonged exposure to methyl-mercury,
especially at higher levels, can harm the
heart, kidneys, and immune system.
However, additional studies are needed to
better categorize the effect of methylmer-
cury on these health endpoints.11

In the United States, human populations
most  highly exposed to methylmercury are
those  that eat fish and shellfish containing
methylmercury in excess of the recom-
mendations contained in the joint U.S.
FDA and EPA consumer advisory "What
You Need to Know About Mercury in Fish
and Shellfish." Fish and shellfish are an
important part of a healthy diet because
they contain protein and other essential
nutrients. Although nearly all fish and
shellfish contain traces of mercury, re-
search shows that most people's fish
consumption does not cause a health
concern.  However, elevated levels of
methylmercury in the bloodstream of
unborn babies and young children may
harm the developing nervous system,
impairing the child's ability to learn and
process information.12 Fish that are higher
in the food chain—such as king mackerel,
swordfish, tilefish, and shark—have higher
methylmercury concentrations than fish
that are lower on the food chain. Mercury
concentrations in commercial fish vary
widely.13 The majority offish species
consumed in the U.S. are ocean species
and the methylmercury concentrations in
these species are primarily influenced by
the global mercury pool.14

While the primary pathway of human
exposure to mercury is  through eating fish
containing methylmercury, individuals
may also become exposed to harmful  levels
of elemental mercury vapor found indoors
in workplaces and in homes. When ex-
posed to air, elemental mercury vaporizes
and can be inhaled. The number of
individuals exposed in the U.S. in this way
is very small.

Fish-eating birds and mammals and their
predators are at risk for greater exposure
to mercury than other  animals. Methyl-
mercury has been found in eagles, otters,
and endangered Florida panthers.15 De-
pending on the level of exposure, effects of
methylmercury exposure on wildlife can
include mortality, reduced fertility, slower
growth, and abnormal  behavior that
affects survival.16 Fish development and
reproduction may also be altered by the
levels of methylmercury found in water
ecosystems.

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8 - EPA's Roadmap for Mercury
             I. Addressing Mercury Releases
             Air
             Addressing mercury releases to the air is
             important because mercury in the air can
             be deposited to water, converted to meth-
             ylmercury, and taken up by fish. The U.S.
             has made significant progress  in the
             reduction of industrial emissions of mer-
             cury to the air. In the last 15 years, EPA
             has focused most of its mercury reduction
             efforts on large point sources  of air emis-
             sions, such as municipal waste combustors,
             medical waste incinerators, hazardous
             waste combustors, and more recently,
             industrial boilers and chlor-alkali facilities.
             With the March 2005 completion of final
             regulations for coal-fired power plants, the
             Agency now has Clean Air Act (CAA)
             standards in place limiting mercury air
             releases from most major known indus-
             trial sources in the U.S.

             In addition to implementing these stan-
             dards, the  Agency, under the  CAA Area
             Source program, is in the process of
             addressing certain smaller point sources
             that emit mercury.17 Under the CAA
             Residual Risk program,18 the Agency is
             evaluating the remaining risks, if any,
             from sources for which EPA has previously
             issued emissions standards under CAA
             §112(d). Mercury is one of several  hazard-
             ous air pollutants that EPA will be investi-
             gating under these programs.

             Water
             The majority of mercury in U.S. waters,
             particularly in the eastern U.S., results
             from air deposition from a variety of
             sources including man-made,  natural re-
             emitted legacy mercury, and global deposi-
             tion.19 States, tribes, and EPA's air and
             water programs are working together to
             address mercury air deposition issues that
             affect water quality and mercury concen-
             trations in fish. EPA has strengthened its
modeling tools to better identify sources of
mercury deposition; relate changes in air
deposition to mercury concentrations in
fish; and ultimately determine the best
mercury reduction strategies. EPA will
continue to further characterize mercury
discharges to water and will issue guidance
on implementation of its methylmercury
water quality criterion. EPA will work with
its partners to  develop tools and ap-
proaches for identifying mercury  impair-
ments and developing mercury total
maximum daily loads (TMDLs) in water
bodies.

Mercury can also be released directly to
water from wastewater treatment plants,
industrial facilities, and from current and
historic mining activities (particularly in
the western  U.S.). The Association of
Metropolitan Sewerage Agencies (AMSA,
now known as the National Association of
Clean Water Agencies) estimated that
about 36 percent of mercury entering
publicly owned treatment works is dis-
charged from dental offices due to mer-
cury in  waste dental amalgam. Mercury
discharges from dental offices far  exceeded
all other commercial and residential
sources, each of which was below  10
percent.20 EPA regions and states  are
working with dental offices to encourage
collection of dental amalgam before it
enters the waste stream. In addition,
wastewater treatment plants are beginning
to implement  best management practices
for collecting mercury from other indus-
trial sources. EPA is providing guidance to
wastewater treatment plants on how to
characterize sources of mercury to the
collection system and how to develop
mercury minimization measures where
appropriate. Mercury in the wastewater
collection systems may come from the
medical sector, dental offices, schools, and
certain  industries. EPA and the states also

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                                                                              Executive Summary - 9
are modifying surface water discharge
permits to incorporate more stringent
requirements in mercury discharges,
where appropriate.

Land
Mining is the largest source of mercury
releases directly to the land in the U.S.21
Mining releases occur as a result of exist-
ing mining operations for gold, zinc, and
silver; the smelting of zinc and other
metals and runoff from waste tailings; and
from abandoned gold, silver, and mercury
mines. The Toxics Release Inventory
(TRI) reporting indicates these types of
releases to land are large in scope and
appear to be  increasing. Of the 5.14
million pounds of mercury released to
land, 1.4 million pounds is placed in
surface impoundments and 3.7 million
pounds is placed directly on the land in
waste piles. Less than 1,000 pounds goes to
landfills.22 Most of these releases are not
generally considered as environmentally
harmful as releases to air, however, be-
cause the mercury may be less mobile and
less likely to reach surface waters and fish.

However, in certain areas of the western
U.S., mining runoff/erosion to sediments
can be the primary source of mercury in
fish in local waters. The 2004 TRI data
indicate increases in reported releases
from mining.23 For more details on the
TRI, see Section I, Addressing Mercury
Releases. As a result, EPA is placing a
higher priority on efforts to understand
the risk associated with mercury releases
to land from mining and take appropriate
action.

II. Addressing Mercury Uses in Prod-
ucts and Processes
Addressing uses of mercury in products
and industrial processes is a component of
preventing human exposure from mer-
cury releases to air, water, and land.
Historically, the largest U.S. uses of mer-
cury were in batteries, chlor-alkali manu-
facturing, and paint.24 Mercury use has
now been eliminated in most batteries and
in paint. Today in the U.S. the largest
industrial use of mercury continues to be
in chlor-alkali manufacturing,  while the
dominant uses in products are in electrical
and measuring devices.25

Many states, tribes, and local governments
have been leaders in reducing mercury
use. States have passed legislation calling
for restrictions, bans, and labeling of
mercury-containing products, as well as the
removal and collection of mercury con-
taining devices from the waste stream.
States and local governments continue to
initiate their own use reduction and
collection programs from schools, hospi-
tals, and laboratories to encourage the
proper disposal and recycling of mercury.

EPA's long-term goal is to reduce risks
associated with mercury. EPA recognizes
that to reduce the risk associated with
mercury, the Agency must first understand
what contributes to the risk and what the
appropriate mechanisms of risk reduction
might be. EPA will take action to identify
exposed populations, minimize exposures
through outreach efforts, and  appropri-
ately reduce anthropogenic releases. As
part of its strategy, EPA will assess mercury
sources of concern and will: focus on uses
that would lead to risk, where  cost-effec-
tive substitutes exist;  promote reducing
mercury in processes and products where
benefits of such reductions would justify
the costs, even where cost-effective substi-
tutes do not exist; and work to identify
and encourage development of alterna-
tives to essential uses of mercury that lead
to risk. EPA will also work with its federal
partners to address risks associated with

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10 - EPA's Roadmap for Mercury
             management and disposal of excess supplies
             of commodity-grade mercury in the U.S.

             EPA will explore both regulatory and
             voluntary programs looking at substitutes
             for mercury in products. The Agency will
             promote the procurement of non-mercury
             products by federal agencies. EPA is build-
             ing a national database of information on
             mercury use in products. EPA will continue
             its successful voluntary partnerships,  such as
             the Hospitals for a Healthy Environment
             program—its project with the health  care
             industry to eliminate  the use and purchase
             of mercury-containing medical devices and
             instruments.26 The Agency also will con-
             tinue to work with the U.S. Chlorine
             Institute to  monitor mercury use in the
             remaining mercury-cell chlor-alkali plants
             in the U.S.

             III.  Managing Commodity-Grade Mer-
             cury Supplies
             Elemental mercury is  used in many prod-
             ucts and processes, and is sold as a commod-
             ity on the global market. In recent years,
             approximately one-half of the current
             world mercury supply has come from
             mercury mines in Spain, Algeria, and
             Kyrgyzstan. (The Spanish mine has recently
             ceased mining operations.) The other half
             comes from the recycling of mercury from
             discarded mercury-containing products and
             other wastes, mercury recovered as a
             byproduct from mining of gold and other
             metals, and mercury supplies from the
             closure of mercury-cell chlor-alkali  plants.27

             As industry finds alternatives to uses  of
             mercury, and as mercury-cell chlor-alkali
             plants phase out the use  of mercury in
             their processes, EPA expects that there will
             be an excess supply of elemental commod-
             ity-grade mercury on  the global market in
             the near future. As a  result, there will be
an increasing need for safe storage of
excess mercury supplies.

Many states and local governments are
now encouraging public and private
collection programs for both bulk el-
emental mercury and discarded mercury-
containing products. The Environmental
Council of the States (EGOS) has indi-
cated that states do not have the re-
sources or desire to store surplus mercury,
and are looking to the federal govern-
ment to address this issue.28

The issue of whether the federal govern-
ment, states, or the private sector should
take responsibility for storing commodity-
grade mercury supplies is an important
and complex policy decision. In 2006,
EPA will work with other federal agencies
to initiate a process with technical experts
and interested parties to discuss options
for addressing the expected mercury
surplus. EPA continues to evaluate op-
tions for  disposal of mercury supplies,
and published a report in April 2005 on
the technical and economic feasibility of
selected land disposal technologies in a
monofill.29

IV. Communicating to the Public
About Mercury Exposure Risks
The Agency will increase its risk commu-
nication and outreach activities to help
people avoid or reduce their exposure to
mercury. In the U.S., the greatest  mer-
cury exposure to the general population
is from eating fish and shellfish contain-
ing high  levels of methylmercury.  Fe-
tuses, nursing infants, and young children
are at greatest risk because of their
developing nervous systems. The primary
tool for reaching and educating affected
populations has been through fish con-
sumption advisories issued by states and
tribes. In addition, in 2004, EPA and

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                                                                            Executive Summary -11
FDA issued a joint fish consumption
advisory for mercury that helps consumers
understand the benefits of fish consump-
tion, the risks of consumption to certain
sub-populations, and mercury levels in
certain fish.30

Many consumers are not aware of poten-
tial indoor mercury risks in schools,
homes, and the workplace.  Misuse  or
accidental breakage of some products can
create indoor air health risks and exposure
to dangerous levels of mercury.

The Agency will make it a priority to
provide consumers with reliable risk
information about mercury exposure so
that they can make informed choices
about the fish they eat and  the products
they use. EPA's most recent effort has
been the January 2005 launching of its
consolidated website on mercury.31 The
Agency will develop informational  materi-
als; support and build upon existing state,
tribal, and local outreach campaigns; and
maintain its centralized mercury website
with helpful information on all aspects of
mercury. EPA will also conduct public
awareness evaluations of the effectiveness
of existing outreach campaigns.

V. International Mercury  Sources
EPA has estimated that over three-quar-
ters (83  percent) of the mercury deposited
in the U.S. originates from international
sources, with the remaining 17 percent
coming from U.S. and Canadian sources.
These figures include mercury from
natural and re-emitted sources.  This
estimate is based on an advanced, state-of-
the-science modeling assessment of atmo-
spheric fate, transport, and deposition of
mercury. EPA's air quality modeling
indicates that a substantial variation in
mercury deposition occurs across the U.S.,
with domestic sources influencing mercury
deposition much more in the eastern U.S.
and global sources being a more significant
contributor to mercury deposition in the
west, where relatively few domestic sources
exist.32 The scientific community's under-
standing of mercury atmospheric chemis-
try is evolving and there remain uncertain-
ties regarding the simulation of mercury in
atmospheric chemistry models. EPA
continues to work to advance the state of
the science on mercury chemistry and fate
and transport modeling. A number of key
international emission sources contribute
to global cycling and deposition of mercury
via air pathways, including: coal-fired
combustion sources; mining and metals
production, such as smelting;  mercury-cell
chlor-alkali manufacturing facilities; and
combustion or incineration of waste
products containing mercury.33

EPA is currently participating in a wide
range of bilateral, regional, and interna-
tional programs and agreements to address
mercury releases and uses and the resulting
exposure around the globe. At the twenty-
third session of the  UNEP Governing
Council, which was held in Nairobi,
Kenya, February 21-25, 2005, delegates
agreed to further develop the UNEP
Mercury Program and to support the
efforts  of countries to take action to
address global mercury pollution.  Govern-
ments agreed to develop and  implement
partnerships with international organiza-
tions, non-governmental organizations,
and the private sector to reduce the risks
that result from the release of mercury to
the environment. The partnerships
created will leverage resources, technical
expertise, technology transfer, and infor-
mation exchanges to provide  immediate,
effective action that will result in tangible
reductions of mercury use and emissions.34

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12 - EPA's Roadmap for Mercury
            EPA is building on existing bilateral,
            multilateral, and international agree-
            ments. In addition, EPA will build collabo-
            rative partnerships under UNEP with
            industries and environmental groups to
            bring technical expertise and assistance to
            address the global mercury problem. EPA
            plans to work with its international
            partners to reduce risks associated with
            mercury emissions from large point
            sources such as coal-fired power plants,
            chlor-alkali facilities, and artisanal gold
            mining; to reduce mercury use in products
            internationally (including mercury-con-
            taining batteries) where there are cost-
            effective opportunities to reduce risk; to
            increase risk communication; to address
            the issue of commodity-grade mercury on
            the international market; and to  research
            global fate and transport of mercury.

            VI. Conducting Mercury Research and
            Monitoring
            In 2000, EPA's Office of Research and
            Development (ORD) published its Mer-
            cury Research Strategy,35 which outlined a
            strategic approach for the Agency's mer-
            cury research program. The purpose of
            the Agency's mercury research is to
            develop information that will reduce
            scientific uncertainties currently limiting
            the Agency's ability to assess and manage
            risks posed by  mercury and methylmer-
            cury.

            Research results support EPA's air, water,
            waste, and toxics programs in their ongo-
            ing regulatory  and non-regulatory efforts
            to address mercury. ORD will continue to
            pursue its long-term goals to reduce health
            risks associated with mercury and to better
            understand the transport and fate of
            mercury in the environment. The major
            near-term emphasis of the  mercury
            research program will continue to be
            focused on science and technology related
   To access this document
   electronically and to
   monitor the  status of
   Roadmap activities  visit
   www.epa.gov/mercury.
to the control of coal-fired power plant
mercury emissions.

In addition to research, scientifically sound
mercury monitoring programs are essen-
tial for assessing the effectiveness of
current regulatory and voluntary pro-
grams and for tracking health and envi-
ronmental trends. Much progress has
been made in recent years by EPA and
others to establish routine monitoring and
reporting systems to collect data on
mercury releases  and contamination. EPA
is continuing to track and report data on
mercury in four areas:  air emissions,
ambient air, air deposition, and fish tissue.
The Agency will utilize the Centers for
Disease Control and Prevention (CDC)
data on mercury in human blood and hair
samples. EPA will also continue to work
with others to monitor other mercury
releases and ambient concentrations. The
Agency plans to use various existing
databases for tracking overall progress in
reducing mercury exposure. In addition,
EPA will continue to seek improvement in
monitoring methods and databases for
mercury.

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                                                                                           Executive Summary -13
ENDNOTES
1.   EPA, 1999a. 1999 National Emissions Inventory Documentation and Data—Final Version 3.0. Accessible at:
     www.epa.gov/ttn/chief/net/1999inventory.html.

2.   EPA, 2005c. U.S. Environmental Protection Agency. National Listing of Fish Advisories. Fact Sheet, Sep. 2005. EPA-823-F-05-
     004. Accessible at:  http://epa.gov/waterscience/fish/advisories/fs2004.pdf.

3.   RIA, Regulatory Impact Analysis, Clean Air Mercury Rule. EPA, 2005. Accessible at: http://epa.gov/ttn/atw/utility/TSO
     112final.pdf.

4.   NRC, 2000. National Research Council. Toxicological Effects of Methylmercury. Committee on The Toxicological Effects of
     Methyl-mercury, Board on Environmental Studies and Toxicology. Accessible at:
     http://books.nap.edU/books/0309071402/html/l.html.

5.   EPA and FDA, 2004. What You Need to Know About Mercury in Fish and Shellfish. EPA-823-F-04-009. Accessible at:
     www.epa.gov/waterscience/fishadvice/advice.html.

6.   EPA, 2005a. Technical Support Document, Revision of December 2000 Regulatory Finding on the Emissions of Hazardous Air
     Pollutants From Electric Utility Steam Generating Units and the Removal of Coal- and Oil-Fired Electric Utility Steam Generat-
     ing Units from the §112(c) List: Reconsideration, Oct. 21, 2005. Accessible at: www.epa.gov/ttn/atw/utility/TSC-112finaL.pdf.

7.   A Community Multiscale Air Quality (CMAQ) modeling run was performed to estimate the impact of global sources on U.S.
     deposition estimates. For this analysis, all non-U.S. mercury input species to the model were set to zero. By comparing the results
     of this analysis with the 2001 Clean Air Mercury Rule (CAMR) base case run, which included all U.S. and global mercury species,
     the percent of total mercury deposition attributable to global sources can be estimated. The model estimated that over 80 percent
     of total mercury deposition in the U.S. is attributable to global sources.

     Due to the evolving nature of mercury modeling science, such deposition estimates have associated uncertainties. For example, it
     remains difficult to distinguish between the natural emissions of mercury and the re-emission of previously deposited anthropo-
     genic mercury and there remains uncertainty in the scientific community concerning the atmospheric processes that control the
     oxidation state of atmospheric mercury. Thus, further advances in the current understanding of mercury chemistry could
     potentially lead to changes in the modeling parameters and assumptions governing the mercury chemistry in the models and
     therefore, changes in the estimate of the fraction deposited in the U.S. attributable to global sources.

8.   EPA, 1999a. U.S. Environmental Protection Agency.  1999 National Emissions Inventory Documentation and Data—Final Version
     3.0. Accessible at: www.epa.gov/ttn/chief/net/1999inventory.html.

9.   Jasinski, S.M. 1994. The Materials Flow of Mercury in the United States. U.S. Bureau  of Mines, Information Circular 9412.
     Accessible at: http://pubs.usgs.gov/usbmic/ic-9412/.

10.   EPA, 1999a, and UNEP 2002. United Nations Environment Programme. Global Mercury Assessment. Accessible at:
     www.chem.unep.ch/mercury/report/GMA-report-TOC.htm.

11.   CDC, 2005. Centers for Disease Control. Mercury, pp. 45-51 in Third National Report on Human Exposure to Environmental
     Chemicals.  Accessible at: www.cdc.gov/exposurereport/3rd/downloads.htm.

12.   NRC, 2000. National Research Council. Toxicological Effects of Methylmercury. Committee on The Toxicological Effects of
     Methyl-mercury, Board on Environmental Studies and Toxicology. Accessible at:
     http://books.nap.edu/books/0309071402/html/Lhtml.

     EPA, 2001a. Reference Dose for Chronic Oral Exposure (RfD)—Methylmercury, last revised 7/21/01. Integrated Risk Information
     System (IRIS). Accessible at: www.epa.gov/iris/subst/0073.htmSreforal.

13.   FDA. U.S. Food and Drug Administration.  Mercury in Fish: FDA Monitoring Program. For information, see:
     www.cfsan.fda.gov/ frf/seamehg2.html.

14.   EPA, 2005a. Technical Support Document, Revision of December 2000 Regulatory Finding on the Emissions of Hazardous Air
     Pollutants From Electric Utility Steam Generating Units and the Removal of Coal- and Oil-Fired Electric Utility Steam Generat-
     ing Units from the §112(c) List: Reconsideration, Oct. 21,  2005. Accessible at: www.epa.gov/ttn/atw/utility/TSC-112final.pdf.

15.   EPA, 1997. Mercury Study Report to Congress. EPA-452/R-97-003, December 1997. Accessible at:
     www.epa.gov/ttn/oarpg/t3/reports/volumel/pdf.

16.   EPA, 1998.  Study of hazardous air pollutant emissions from electric utility steam generating units—Final Report to Congress.  EPA-
     453/R-98-004a&b, February 1998.

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14 - EPA's Roadmap for Mercury





        17.  EPA. Area Source Standards. For information, see: www.epa.gov/ttn/atw/urban/arearules.html.

        18.  EPA. Residual Risk Program. For information, see: www.epa.gov/ttn/atw/rrisk/residriskpg.html.

        19.  EPA, 1997.

        20.  LWA, 2002. Larry Walker Associates. Mercury Source Control and Pollution Prevention Evaluation, Final Report, March 2002,
            amended July 2002. Prepared for: Association of Metropolitan Sewerage Agencies. Accessible at:
            www.amsa-cleanwater.org/advocacy/mercgrant/finalreport.pdf.

        21.  EPA, 2005b. 2003 Toxics Release Inventory (TRI) Public Data Release eReport, May 2005. Accessible at:
            www.epa.gov/tri/tridata/tri03/2003eReport.pdf.

        22.  EPA, 2005b.

        23.  EPA, 2005b.

        24.  Jasinski, S.M., 1994. The Materials Flow of Mercury in the United States. U.S. Bureau of Mines, Information Circular 9412.
            Accessible at: http://pubs.usgs.gov/usbmic/ic-9412/.

        25.  Lawrence, Bruce, 2001. Bethlehem Apparatus Company, Inc. Personal communication, June 22, 2001.

        26.  H2E. Hospitals for a Healthy Environment. For information, see: www.h2e-online.org/.

        27.  Maxson, PA., 2004. Mercury Flows Report: Mercury Flows in Europe and the World, The Impact of Decommissioned Chlor-
            alkali Plants. European Commission. Accessible at:
            http://europa.eu.int/comm/environment/chemicals/mercury/pdf/report.pdf.

        28.  Quicksilver Caucus, 2003. Mercury Stewardship Storage of Mercury, Review Draft, February, 2003. Accessible at:
            www.sso.org/ecos/Quick%20silver%20documents/RD%20QSC-STOR%20Mar-03.pdf.

        29.  EPA, 2005f. Economic and Environmental Analysis of Technologies to Treat Mercury and Dispose in a Waste Containment
            Facility. See: www.epa.gov/ORD/NRMRL/pubs/600r05157/600r05157.pdf.

        30.  EPA and FDA, 2004. What You Need to Know About Mercury in Fish and Shellfish. EPA-823-F-04-009. Accessible at:
            www.epa.gov/waterscience/fishadvice/advice.html.

        31.  EPA. Mercury Web site. For information, see: www.epa.gov/mercury/.

        32.  EPA, 2005a.

        33.  UNEP, 2002. United Nations Environment Programme. Global Mercury Assessment. Accessible at:
            www.chem.unep.ch/mercury/Report/GMA-report-TOC.htm.

        34.  UNEP, 2005. Results of the Governing Council's discussions on chemicals management, including mercury programme, at its
            23rd session in February,  2005. Accessible at: www.chem.unep.ch/mercury/GC23-results.htm.

        35.  EPA, 2000. Mercury Research Strategy.  EPA-600-R-00-073. Accessible at:
            http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=20853.

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                                                                               Introduction-15
          EPA'S  ROADMAP FOR MERCURY:
                                 Introduction
         Mercury is a naturally occurring
         element. It enters the environ-
         ment as a result of natural
sources (such as volcanoes) and human
activities (such as industrial combustion
and mining). Mercury is widespread in the
U.S. and global environment. Human
activities have increased the amount of
mercury that is available in the atmos-
phere; in soils and sediments; and in lakes,
streams, and oceans.

While elemental mercury is toxic to
humans when it is ingested or inhaled,
EPA is most concerned about methyl-
mercury, as it is  a potent form of mercury
and it is the form to which humans
primarily are exposed. Methylmercury can
be formed from other deposited mercury
by microbial action in sediment and soils.
Once formed, methylmercury can be
taken up by aquatic organisms and
bioaccumulates up the aquatic food web.
While all forms of mercury can
bioaccumulate, methylmercury generally
accumulates to a greater extent than other
forms of mercury.
Methylmercury accumulates in fish tissue,
which may then be consumed by people
and wildlife. Mercury concentrations in
fish vary widely. Fish that are higher in
the food chain—such as king mackerel,
swordfish, tilefish, and shark—have much
higher methylmercury concentrations
than fish that are lower on the food chain.
The majority of fish species consumed in
the U.S. are ocean species and the meth-
ylmercury concentrations in these species
are primarily influenced by the global
mercury pool.

Local freshwater fish also contain methyl-
mercury.  States monitor their waters by
sampling fish tissue for persistent pollut-
ants that bioaccumulate. States issue their
advisories and guidelines voluntarily and
have flexibility in what criteria they use
and how the data are collected. As a result,
there are  significant variations in the
number of waters tested, the pollutants
tested for, and the threshold for issuing
advisories.Based on self-reporting, the
national trend is for states to monitor
different waters each year, generally
without retesting waters monitored in

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16 - EPA's Roadmap for Mercury
                      FIGURE 1. The Mercury Cycle4
                                           Reemitted
                                         anthropogenic
                                          and natural
                   Reemitted
                 anthropogenic
                  and natural
            previous years.1 Forty-four states, one
            territory, and two Indian tribes have
            issued fish consumption advisories recom-
            mending that some people limit their
            consumption of fish from certain water
            bodies as a result of methylmercury found
            in fish.2 Human-caused mercury emissions
            have dropped 45 percent in this country
            since 1990.3 EPA has not monitored
            natural mercury emissions in this country,
            which may also have changed over the
            same period.

            Mercury Sources
            The primary sources of mercury releases
            to air, water,  soils, and sediments can be
            grouped into four categories:

            1.  New releases from naturally-occurring
                sources (such as volcanic activity and
                weathering of rocks)
2.  Re-releases of historic mercury previ-
    ously deposited through natural and
    anthropogenic processes in soils,
    sediments, water bodies, landfills, and
    waste tailings/piles (also called "re-
    emitted sources")

3.  New releases of mercury impurities
    from combustion of fossil fuels, and
    from smelting of metals such as gold
    and zinc

4.  New releases resulting from uses of
    mercury in products and manufactur-
    ing processes such as chlor-alkali
    manufacturing

Human Health Effects
Mercury exposure effects can vary depend-
ing on the form of mercury to which a
person is exposed and the level and length
of exposure. The  primary way humans are
exposed to methylmercury is through

-------
                                                                                    Introduction-17
eating fish containing methylmercury.
Research shows that most people's fish
consumption does not cause a health
concern. However, elevated methylmer-
cury in the bloodstream of unborn babies
and young children may harm the devel-
oping nervous system, impairing the
child's ability to learn and process infor-
mation. There is some evidence that
exposures to methylmercury may result in
genotoxic or immunotoxic effects. Other
research suggests that reproductive,  renal,
cardiovascular, and hematologic impacts
may be of concern. However, additional
studies are needed to better characterize
the effect of methylmercury on these
endpoints.5

While the primary way humans are
exposed to methylmercury is through
eating fish containing methylmercury,
individuals may also become exposed to
harmful levels of elemental mercury vapor
in homes and workplaces. When exposed
to air, elemental mercury vaporizes and
can be inhaled. Exposures from improper
handling of mercury in schools, laborato-
ries, and manufacturing plants; from
accidental mercury spills; or in cultural
and ritualistic uses can result in severe
effects. Very small  amounts of elemental
mercury (even a few drops)  can raise
indoor air concentrations of mercury to
harmful levels. The longer people breathe
the contaminated air, the greater the risk
to their health. At high  exposures elemen-
tal mercury vapors can produce severe
lung,  gastrointestinal, and nervous system
damage. The number of individuals
exposed in this way in the U.S. is very
small.

Ecological Effects
Birds and mammals that eat fish and their
predators are at risk for greater exposure
to methylmercury than other animals.
Methylmercury has been found in eagles,
otters, and endangered Florida panthers.
The 1997 Mercury  Study Report to Congress
provides some data that suggest some
highly-exposed wildlife species are affected
by methylmercury.6 Depending on the
level of exposure, effects of methylmercury
exposure on wildlife can include mortality,
reduced fertility, slower growth and
development, and abnormal behavior that
affects survival.7

Reducing mercury releases to the air is
important because airborne mercury can
travel short and long distances; be depos-
ited on  land and water resources locally,
nationally, regionally, and globally; and
lead to  elevated methylmercury levels in
fish. EPA estimates that since the begin-
ning of the industrialized period, total
global atmospheric mercury burden has
increased by a factor  of between two and
five.8 Figure 1 illustrates the physical cycle
of airborne mercury  from natural and
anthropogenic sources as it is deposited to
land and water and re-released.

U.S. mercury deposition is from domestic
man-made sources and from global
sources, including natural, re-emitted, and
international man-made sources. EPA has
estimated that over three-quarters (83
percent) of the  mercury deposited in the
U.S. originates  from  international sources,
with the remaining 17 percent coming
from U.S. and Canadian sources.9 These
figures include  mercury from natural and
re-emitted sources. This estimate is based
on an advanced, state-of-the-science model-
ing assessment  of atmos-pheric fate,
transport, and deposition of mercury. Air
emissions of mercury from combustion
and industrial processes are the largest
contributor to U.S. emissions. EPA's air
quality modeling indicates that a substan-
tial variation in mercury deposition occurs

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18 - EPA's Roadmap for Mercury
            across the U.S., with domestic sources
            influencing mercury deposition much
            more in the eastern U.S. and global
            sources being a more significant contribu-
            tor to mercury deposition in the west,
            where relatively few domestic sources exist.
            The scientific community's understanding
            of mercury atmospheric chemistry is
            evolving and there remain uncertainties
            regarding the simulation of mercury in
            atmospheric chemistry models. EPA
            continues to work to advance the state of
            the science on mercury chemistry and fate
            and transport modeling.10

            Reducing Mercury Exposure
            To further reduce risks associated with
            mercury, EPA's priority activities focus on
            six key areas:

            1.  Addressing mercury releases to the
                environment

            2.  Addressing mercury uses in products
                and processes

            3.  Managing commodity-grade mercury
                supplies

            4.  Communicating risks to the public

            5.  Addressing international mercury
                sources

            6.  Conducting mercury research and
                monitoring

            EPA will continue to pursue regulatory and
            voluntary actions that will reduce risks
            associated with mercury.  EPA's long-term
            goal is to reduce risks associated with
            mercury. EPA recognizes that to reduce
            the risks associated with mercury, the
            Agency must first understand what con-
            tributes to the risk and what the appropri-
            ate mechanisms of risk reduction might
be. EPA will take action to identify ex-
posed populations, minimize exposures
through outreach efforts, and appropri-
ately reduce anthropogenic releases. As
part of its strategy, EPA will assess mercury
sources of concern and will: focus on uses
that would lead to risk, where cost-effec-
tive substitutes exist; promote reducing
mercury in processes and products where
benefits of such reductions would justify
the cost, even where cost-effective substi-
tutes do not exist; and work to identify
and encourage development of alterna-
tives to essential uses of mercury that lead
to risk. EPA will also work with its  federal
partners to address risks associated with
management and disposal of excess
supplies of commodity-grade mercury in
the U.S. In addition, EPA will support the
efforts of other countries to take action to
address risks associated with global mer-
cury pollution by developing and imple-
menting partnerships with international
organizations, non-governmental organiza-
tions, and the private sector. As we work
on these short and long-term plans, EPA
will continue to work with federal part-
ners to continue to educate the public
about the risks of exposure from dietary
and non-dietary sources.

State, Tribal, Local, and International
Government Collaboration with EPA
In order to achieve reductions risks from
mercury exposure, EPA will continue to
collaborate with its state, tribal, and local
government partners. As co-regulators
with EPA, states have been actively en-
gaged in a range of programs and partner-
ships to reduce  mercury uses, releases, and
exposure and to conduct mercury moni-
toring activities. In many cases, states and
local governments have been leaders in
mercury reduction efforts. EPA will build
on these efforts and, where appropriate,

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                                                                                     Introduction-19
help state and local governments replicate
successful efforts.

In May of 2001, a coalition of state govern-
ment environmental association leaders
formed the Quick-silver Caucus (QSC) in
order to provide a forum for states to
work together, and with EPA, to develop
collaborative holistic approaches for
reducing mercury in the environment.  In
addition, the Environmental Council of
the States (EGOS), an association of state
environmental agency leaders, has passed
a number of resolutions over the past
several years that address mercury issues,
many of which are also addressed in the
Roadmap. EPA and states are continuing to
work together  on mercury issues under a
cooperative agreement with EGOS.

EPA is also working with tribes to develop
new activities that will help the Agency
make progress toward attainment of  EPA's
long-term goals of "fishable waters" and
"edible fish." Tribal community members
who follow traditional diets and lifestyles
may face greater risk from locally-caught
fish than do members of the  general
population due to the prevalence of
locally-caught fish and shellfish in their
diets. EPA will work with tribes to improve
the quality of water and sediments in
order to improve fish tissue concentra-
tions in tribal waters.

EPA will also continue to collaborate  with
other federal agencies involved in domes-
tic and international mercury issues,
including the U.S. Food and Drug Admin-
istration; the Centers for Disease Control
and Prevention; and the Departments of
Energy, Defense, and State.

In addition, partnering with the interna-
tional community is of great importance
to furthering global mercury reductions.
The majority of fish species consumed in
the U.S. are ocean species and the meth-
ylmercury concentrations in these species
are primarily influenced by global mercury
contributions.11 Also, even domestic
freshwater and estuarine fish in many
parts of the  U.S. may contain methylmer-
cury as a result of contributions from
international sources in addition to domes-
tic sources.

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20 - EPA's Roadmap for Mercury

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                                                              I. Addressing Mercury Releases - 21
                        I. ADDRESSING
                   MERCURY  RELEASES
OVERVIEW
Significant progress has been made to date
to reduce industrial emissions of mercury
in the U.S., as well as to reduce or elimi-
nate the amount of mercury used in
various processes and products. Most of
the large industrial sources of mercury
emissions are sites where mercury is
emitted as a byproduct of combustion
processes. Other major sources of mercury
include industrial processes and products
that use mercury deliberately,  such as
certain chlor-alkali chlorine manufactur-
ing processes, batteries, lamps, and mea-
suring devices such as thermometers.
Mercury is also released through mining
practices, sewage discharge, and metal
refining operations. When mercury is
used in a product, most releases occur
during manufacturing or disposal. In the
U.S., there are over 100 manufacturing
processes that use some form of mercury.1

In the last 15 years, EPA focused most of
its mercury reduction efforts on large
point sources of air emissions such as
municipal waste combustors, medical
waste incinerators, hazardous waste com-
bustors, and more recently, industrial
boilers and chlor-alkali facilities. With the
March 2005 completion of EPA final
regulations for coal-fired power plants, the
Agency now has standards in place limit-
ing mercury air releases from most major
known industrial sources in the U.S.

In the next 10 years, in addition to imple-
menting the regulatory standards in place,
the Agency's efforts to reduce mercury
pollution will focus on three  areas in
particular: smaller sources and industrial
uses that collectively contributed over  20
percent of the nation's mercury air re-
leases in 1999 ;2 understanding and ad-
dressing mining releases that in some
areas of the
western U.S. are
the major
sources of
mercury pollu-
tion to water
and land; and
international
emissions which
continue to

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  22 - EPA's Roadmap for Mercury
              contribute to the mercury deposited in the
              U.S. EPA's strategy for addressing these
              three areas will include, where applicable,
              a combination of regulatory and voluntary
              approaches to reduce mercury releases to
              air, land, and water, coupled with efforts to
              address the use of mercury in products and
              processes. As the U.S. continues to address
              domestic mercury use and releases, it will
              also promote international efforts to
 TABLE 1. National Air Emissions Estimates for Mercury3
Source Category
1990 (tons)    1999(tons)f    % reduction
Utility Coal Boilersb
51.1
47.9a
6%
Industrial Boilersb
 12.0
12.0
0%
Medical Waste Incinerators
49.7
1.6
97%
                                 address mercury use and emissions abroad
                                 as discussed further in Section V on
                                 international mercury efforts. (Note: The
                                 Roadmap generally uses metric tons when
                                 discussing global mercury use and emis-
                                 sions. However, U.S. air emissions are
                                 reported in English tons.  One English ton
                                 is equivalent to 0.9070 metric tons.)
Releases to Air
Sources. When the 1990
Clean Air Act Amendments
passed, more than half of U.S.
mercury air emissions came
from just three source catego-
ries: coal-fired power plants,
municipal solid waste combus-
tors, and medical waste
incinerators.  The major air
emissions source categories
are shown in Table 1.
Municipal Waste Combustion    56.7
             4.9
              91%
Hazardous Waste Incinerators'3  6.6
             6.6
              0%
Chlorine Production
 10.0
6.5
30%
Electric Arc Furnaces0
6.9
NA
NA
Gold Mining
3.4°
11.5
NA
Other6
23.5
21.6
6%
Total
219.9
112.6
45%
a 1990 estimate derived using a different methodology.
bRegulations for these categories finalized after 1999.
cElectric Arc Furnaces data not available for 1999. The 2002 estimate is
 10 tons per year.
dThe 1990 emissions estimate is a preliminary estimate and is based on back
 calculations and assumptions using data from 1999 along with information
 about types of processes, production rates, and ores used in 1990
 compared to 1999.
e Other includes, but is not limited to such items as, Portland cement production
 -2.36 tons per year (tpy), pulp and paper production-1.69 tpy,  and over 219
 miscellaneous industrial processes.
f7 ton equals 0.9070 metric ton.
Progress to date. EPA's Clean
Air Rules. Medical waste
incinerators and municipal
solid waste combustors are
now subject to stringent
control standards that require
facilities to reduce mercury
emissions by over 90 percent
from  1990 levels. These
efforts have contributed to
reducing overall mercury
emissions to the air by about
45 percent (from 220 tons in
1990 to 113 tons in 1999-see
Figure 2).

EPA's recently promulgated
Clean Air Mercury Rule
(CAMR) is part of a suite of
regulatory actions that will
dramatically improve
America's air quality. CAMR
directly regulates mercury
emissions from coal-fired

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                                                                  I. Addressing Mercury Releases - 23
power plants. Among other things,
CAMR requires compliance with a two-
phase nationwide cap on mercury emis-
sions. The first phase cap (effective in
2010) is 38 tons per year ("tpy"), and the
second phase cap (effective in 2018) is 15
tpy. Once fully implemented, CAMR will
result in about a 70 percent reduction in
mercury emissions from domestic coal-
fired power plants, which is a reduction
from a 1999 baseline of 48 tons.4

In addition to CAMR, the Agency re-
cently issued another rule called the Clean
Air Interstate Rule (CAIR) that addresses
the transport of pollution across state
borders in the eastern U.S. CAIR will
result in the deepest cuts in sulfur dioxide
and nitrogen oxide emissions in more
than a decade. Although affected States
retain flexibility to decide how to achieve
the sulfur dioxide and nitrogen oxide
emissions reductions required by CAIR,
EPA has concluded that obtaining the
reductions from power plants is highly
cost-effective. EPA therefore anticipates
that affected States will meet their emis-
sion reduction obligations by controlling
power plant emissions through the two-
phase cap-and-trade approach provided in
the final CAIR, the first phase of which
occurs in 2010 and the second in 2015.
EPA also concluded that the technologies
that most cost-effectively achieve sulfur
dioxide and nitrogen oxide emission
reductions for power plants are scrubbers
for sulfur dioxide and selective catalytic
reduction for nitrogen oxide. These
technologies, once implemented,  not only
reduce sulfur dioxide and nitrogen oxide,
they provide important reductions of
mercury emissions from coal-fired power
plants. Thus, CAIR and CAMR work
together and provide a flexible multi-
pollutant approach for reducing sulfur
dioxide, nitrogen oxide, and mercury
What is EPA's National Emissions Inventory
(NEI)?

Section 112 of the 1990 amendments to the
Clean Air Act (CAA) presents a list of
Hazardous Air Pollutants (HAPs), also called
air toxics, which includes mercury and
mercury compounds. In 1993, EPA began
developing the National Toxics Inventory (NTI).
This database has been expanded and is now
called the National Emissions Inventory (NEI).
The NEI is a national repository of emissions
inventory data for HAPs. The emissions data
and estimates cover major, area, and mobile
sources, and include estimates of emissions
at the national, regional, county, and facility-
specific levels.

The 1999 NEI generally serves as the national
baseline inventory forthis Roadmap because it
includes HAP emission data supplied by 36
states in addition to data gathered while
developing Maximum Achievable Control
Technology (MACT) standards and Toxics
Release Inventory (TRI) data. More information
on the NEI, including summary data and
documentation, can be obtained at
http://www.epa.gov/ttn/chief/index.html.
emissions from power plants. From a
legislative perspective, the President's
proposed Clear Skies legislation, if en-
acted, would require a mandatory 70
percent annual cut in power plant pollu-
tion (NOx, SOx and mercury) when fully
implemented.5

In addition, §112 (f) of the Clean Air Act
(CAA) required EPA to complete a Report
to Congress that includes a discussion of
methods EPA would use to evaluate the
risk remaining after the application of
Maximum Achievable Control Technology
(MACT) standards. These are known as
residual risks. EPA published the Residual
Risk Report to Congress in March 1999.6
The Agency continues to evaluate the
remaining residual risks, if any, for a

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24 - EPA's Roadmap for Mercury
      FIGURE 2. Air Emissions Data for Mercury
                                                       U 1990 (TRY)
                                                       • 1999 (TRY)
                                                       • Projected by 2020 (TRY)
                            Medical
                            Waste
                           ncineration
 Municipal
  Waste  Hazardous
Combustion  Waste
        ncineration
                                                    Chlorine
                                                    Production
            Utility Coal
             Boilers
                                                                              Other8
                                                        1990

                                                      1999
Projected by 2020
(except utility coal boilers)3
      ^Fifteen tons per year will be acheived when full implementation of the Clean Air Mercury Rule is achieved,
      which may exceed 2020.
      ^Growth in this sector is being offset by regulation.
      °ElectricArc Furnaces data not available for 1999. The 2002 estimate is 10 tons per year.
      dThe 1990 emissions estimate is a preliminary estimate and is based on back calculations and
       assumptions using data from 1999 along with information about types of processes, production
       rates, and ores used in 1990 compared to 1999.
      eThese projected emissions do not account for reductions from non-regulatory actions described
       elsewhere in the Roadmap.
      f7 ton equals 0.9070 metric ton
             number of source categories for which
             EPA has issued MACT standards. In the
             context of that review, EPA will evaluate
             the hazardous air pollutants (HAPs)
             emitted by each source category, including
             mercury.


             Regional initiatives have also resulted in
             substantial reductions in air emissions of
             mercury. For example, EPA's Region 9
                           office and the State of Nevada entered
                           into an innovative collaboration with four
                           of the largest gold mining companies in
                           Nevada to reduce mercury emissions
                           associated with gold mining.7 The Volun-
                           tary Mercury Emission Reduction Pro-
                           gram set a goal to reduce mercury emis-
                           sions by 50 percent by 2005, and has
                           already surpassed this goal. In 2004, the
                           program participants reported a 75

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                                                                  I. Addressing Mercury Releases - 25
percent reduction from the baseline year.
This is a reduction of 15,702 pounds of
mercury from the baseline emissions of
21,098 pounds.8

Future focus. The Integrated Urban Air
Toxics Strategy, which was published in
the Federal Register in 19999, is an impor-
tant element in EPA's national air toxics
program. The strategy outlines actions to
reduce emissions of air toxics, as well as
assessment activities to improve EPA's
understanding of the health and environ-
mental risks posed by air toxics in urban
areas. One major component of the
Urban Air Toxics Strategy is the Area
Source Program.10 Area sources are
smaller sources that can cumulatively emit
significant amounts of hazardous air
pollutants.

The 1999 Strategy identifies 33 hazardous
air pollutants, including mercury, that
EPA determined  posed the greatest threat
to public health in the largest number of
urban areas. The Strategy further identi-
fies 30 of those 33 HAP as being emitted
by area sources. Finally, the Strategy
identifies the 70 categories of industry
sectors (i.e., source categories) that repre-
sent 90 percent of the aggregate emissions
of the 30 identified HAP emitted by area
sources. To date, EPA has issued standards
for  16 of the  70 source categories and is
currently collecting data and information
for  many other source categories.

Electric Arc Furnaces (EAFs)—one of the
area source categories that the Agency is
currently evaluating—emitted about 10
tons of mercury in 2002.n In EAFs,
mercury is emitted through the stack
when ferrous scrap containing mercury
switches and other materials contami-
nated with mercury are melted. Many of
these mercury-containing switches are
found in scrap automobiles—over 200
million of these switches were installed in
vehicles from 1974 to 2002. Although
mercury switches were eliminated from
new vehicles at the end of 2002, mercury
switches will remain in the steel scrap
supply for the next 10 to 15 years. The
steel industry recycles about 12 to 14
million end-of-life vehicles each year, and
vehicles retired in 2003 had 8.5 million
mercury-containing switches.12 The EPA air
toxics program has identified EAFs as a
priority sector and currently intends to
propose emissions standards for that
source category in 2006.

Releases to Water
Sources. The majority of mercury in
surface waters from human activity in the
U.S. is the result of air deposition, both
from international and domestic sources.
Mercury in surface waters can also occur
naturally. Mercury can be released directly
to surface waters from municipal  sewage
treatment plants, also called Publicly-
Owned Treatment Works (POTWs), and
non-municipal facilities (e.g., industrial and
federal facilities).  Point source discharges of
pollutants to surface waters are required to
have National Pollutant Discharge Elimi-
nation System (NPDES) permits.13 On a
national basis, these mercury discharges to
surface waters are significantly smaller
than nationwide inputs to water from air
deposition. In some areas, particularly in
the western states, mercury resulting from
past mining practices (specifically  mercury,
silver, and gold mining) are significant
sources of contamination to water bodies.14

EPA's Toxics Release Inventory (TRI)
provides information on mercury releases
to land, air, and water. (See box on page
27). Based on the EPA TRI data, total
quantities of mercury discharged to surface
waters have declined steadily from 2000 to

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26 - EPA's Roadmap for Mercury
             2004.15 From 2000 to 2001 the decline was
             over 25 percent; from 2001 to 2002 nearly
             32 percent; from 2002 to 2003 4 percent;
             from 2003 to 2004 nearly 59 percent and
             from 2000 to 2004 nearly 38 percent. TRI
             data for 2004 indicate that surface water
             releases of mercury totaled approximately
             694 pounds (0.31 metric tons). An addi-
             tional 219 pounds (0.10 metric tons) per
             year of mercury effluent is estimated  from
             POTWs.16

             Clean Water Act requirements. Under
             the Clean Water Act, states and authorized
             tribes must have water quality standards in
             place that define the designated uses and
             acceptable levels of pollutants for each
             water body under their jurisdiction. For
             mercury, EPA has published a national
             methylmercury ambient water quality
             criterion for protection of human health.
             This is a fish tissue concentration of 0.3
             parts per million of methylmercury, based
             on EPA's 2001  Reference Dose (RfD) for
             methylmercury and consumption rates.17
             EPA's RfD is an estimate, with uncertainty
             spanning perhaps  an order of magnitude,
             of a daily oral exposure  to the human
             population (including sensitive groups) that
             is likely to be without an appreciable risk
             of deleterious effects during a lifetime.18

             When pollutant levels exceed water quality
             standards,  state water quality program
             managers must take action to reduce
             pollutant loadings. An initial step in this
             process is the development of a TMDL for
             a water body. The TMDL is the maximum
             daily amount of a pollutant that can enter
             a water body and still ensure that the
             water meets applicable water quality
             standards.  TMDLs also  allocate the allow-
             able pollutant loads between the point and
             non-point sources of a pollutant.19 Over
             8,000 individual water bodies are identi-
             fied as impaired (not meeting water quality
standards) due to mercury contamination
and will require mercury TMDLs,20 and
44 states, 1 territory, and 2 tribes have
fish consumption advisories due to mer-
cury contamination.21 States and EPA
have been discussing how to best address
mercury in their water bodies, since
mercury can travel from sources out-of-
state and from international sources and
be deposited on local waters. Developing
TMDLs that identify reductions from local
sources alone is unlikely to result in
attainment of water quality standards in
many water bodies.

Progress to date. Because past analytical
methods could not detect mercury at the
level of current water quality standards in
many effluents, there are limited data on
low-level mercury discharges to water from
point sources. To address the critical data
gap, EPA recently developed a new more
sensitive analytical method for use in
water discharge permits.22 As NPDES
permits are reissued, they should require
use of this more sensitive method where
appropriate. Requiring use of this analyti-
cal  method will improve EPA's under-
standing of the significance of point
source mercury contributions to surface
waters, and will provide necessary data for
EPA and states to determine whether
surface water discharge permits need to
include mercury effluent limits.

As noted earlier, the states, tribes, and
EPA's air and water programs are working
together on how to address mercury
pollution in TMDLs and water permitting
programs, particularly mercury from  air
sources. To date, mercury TMDLs have
been developed for over 250 water bodies
in 19 states.23 Many of these TMDLs
identify needed reductions in air deposi-
tion of mercury. TMDLs such as those in
Georgia and California also incorporate

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                                                                  I. Addressing Mercury Releases - 27
mercury characterization and minimiza-
tion provisions for water discharge
(NPDES) permit holders. To assist states in
developing mercury TMDLs, EPA has
conducted two pilot projects in coopera-
tion with Florida and Wisconsin to exam-
ine approaches that could be used in
developing TMDLs for water bodies
impaired by atmospheric mercury.

Within the Great Lakes basin, the states
have adopted water quality standards to
implement the Water Quality Guidance
for the Great Lakes System, including a
mercury criterion of 1.3 nanograms per
liter (ng/1), based on protection of fish-
eating wildlife.24 Initial results in POTW
effluent using the low level analytical
method have averaged around 4 ng/1, and
it is expected that most POTWs will not
meet this criterion.25 As a result, EPA
expects the states in the Great Lakes
region (EPA Regions 2, 3 and 5) will be
utilizing statewide or individual variances
from applicable water quality standards,
which will involve setting mercury limits
in NPDES permits based on a lowest
technically achievable concentration, and
requiring the POTW to implement a
Pollutant Minimization Program (PMP) to
address mercury-contributing sectors
within its system. Region 5 has developed
a PMP guidance document to promote a
consistent approach to PMPs throughout
its states.

EPA has provided sophisticated air model-
ing results to states to better identify the
mercury contributions to water bodies
from different air sources and geographic
areas. The Agency has developed analyti-
cal tools that can be used to estimate the
impact of air emission and deposition
reductions on freshwater fish tissue con-
centration. These tools relate changes in
mercury air emission and deposition rates
EPA's Toxics Release Inventory (TRI)

In 1986, the U.S. Congress enacted the Emergency Planning
and Community Right-to-KnowAct (EPCRA) and in 1990
passed the Pollution Prevention Act (PPA). Section 313 of
EPCRA and §6607 of PPA require certain industrial facilities to
submit reports each year on the amounts of toxic chemicals
released or otherwise managed as waste. Amounts released
are reported separately for air, land, water, and offsite disposal.
The reported information is compiled and presented annually as
the Toxics Release Inventory (TRI).

In 1998, several new industry sectors were required to file
reports for the first time. The new sectors included metal
mining, electric utilties and hazardous waste treatment
facilities. These new TRI reports have improved EPA's
understanding of releases of mercury and mercury compounds.
In 2000, the TRI program reduced the use threshold that
triggers  mercury reporting from 10,000 pounds to 10 pounds.
As a result, small  users of mercury and mercury compounds
are now required to report. TRI information and mapping
capability can be publicly accessed atwww.epa.gov/triexplorer.

In this document,  "TRI releases" referto quantities of mercury-
or mercury compound-bearing wastes that are released into the
environment or otherwise disposed, and include, but are not
limited to, releases to air, water and land, and to landfills,
surface impoundments and underground injection. Even though
disposals may be subject to regulatory and permitting
requirements, disposal of mercury in waste to landfills, surface
impoundments and underground injection is termed a "release"
underTRI.
to changes in mercury fish tissue concen-
trations.26 By using such methods during
the development of a TMDL, states may
be able to determine how much of a
reduction in air deposition is needed in
order to meet water quality standards, and
whether other actions in addition to
anticipated air deposition reductions will
lead to achievement of the water quality
standard.

The Clean Water Act directs EPA to
develop national technology-based regula-
tions placing limits on the pollutants that
are discharged by categories of industry to
surface waters (termed "effluent guide-

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28 - EPA's Roadmap for Mercury
             lines") or to POTWs (termed "pretreat-
             ment standards"). Pretreatment standards
             ensure that pollutants do not pass through
             or interfere with the safe and effective
             operation of these POTWs. CWA §307(b)
             requires that EPA revise or establish
             pretreatment standards from time to time,
             as control technologies, processes, operat-
             ing methods, or other alternatives
             change.27 As part of its pretreatment
             standards review process, EPA is reviewing
             industrial sources of mercury for potential
             technology-based options for controlling
             mercury discharges to POTWs. In addi-
             tion, POTWs are beginning to implement
             best management practices for collecting
             mercury from other industrial sources.

             Many states have initiated efforts to reduce
             mercury in wastewater by focusing on the
             dental sector. Mercury in dental wastewa-
             ter can be removed by relatively inexpen-
             sive amalgam separators and/or by using
             other pollution prevention practices.
             Amalgam separators currently on the
             market can capture more than 95 percent
             of the mercury particles in wastewater.28 In
             addition to outreach and education to
             dentists on safe handling and disposal
             practices for mercury-containing dental
             amalgam, some local efforts  are offering
             incentives to encourage the use of amal-
             gam separators. For example, the city of
             San Francisco, California has a goal of
             installing amalgam separators in all 900
             dental offices located in the city and is
             offering assistance and incentives to dental
             offices least able to afford the separators—
             specifically those serving low-income
             communities.29

             Future focus. EPA will continue to work
             with its state and tribal partners to  identify
             approaches to TMDLs for water bodies
             impaired by atmospheric mercury in order
             to make progress toward achieving state
water quality standards. Potential ap-
proaches include regional-scale TMDLs
and approaches which take into account
comprehensive state mercury reduction
programs.

Releases to Land
Sources. TRI provides the best single
source of information on releases of
mercury to land. Based on TRI,30 the total
amounts of mercury that were released to
land decreased by about 18 percent be-
tween 2002 and 2003 (from 2,554 to
2,079 metric tons per year). Although
these amounts are relatively large, based
on existing information, such releases are
generally not considered to be as environ-
mentally harmful as releases to air because
the mercury may be less mobile and less
likely to reach surface waters and fish.
Nevertheless, because of the large quanti-
ties of mercury in waste being placed on
the land, it is prudent for EPA to conduct
further investigations to determine the
risks associated with these releases.

The vast majority of U.S. land releases are
the result of mining activities. Mercury is
no longer mined domestically in the U.S.,
but is a byproduct of metals mining,
particularly gold mining. The 2004 TRI
data indicate that 2079  metric tons of
mercury were released to the land. Of
that, 1.461  million pounds were released
to "other surface impoundments"31 and
2.620 million pounds were released to
"other land disposal".32 Three metal
mining facilities accunted for over 74
percent of the total mercury land releases
in 2004. The majority of TRI land releases
is due to gold, silver, and zinc mining, and
may continue to rise over  the next few
years due to increased gold production.

The Agency is beginning to investigate
and characterize mercury releases and

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                                                                  I. Addressing Mercury Releases - 29
risks from mine tailings and mining
processes, as well as other land releases.
EPA plans to use the latest TRI data to
evaluate trends for how mercury is being
released to land.

A small percentage of releases to land
reported in TRI are not related to mining
activities. The majority of these releases is
attributed to the disposal of mercury in
waste in hazardous or non-hazardous
regulated landfills or surface impound-
ments.

Progress to date. EPA has made substan-
tial progress reducing the volume of
mercury-containing devices disposed of in
landfills since 1990. This progress is largely
due to the  Battery Act33 which places
limits on mercury used in batteries. The
promulgation of the Municipal Incinera-
tor Rules34 also helped reduce the amount
of mercury going into the waste streams
by limiting mercury emissions from these
incinerators, which in turn encouraged
localities to begin collection and recycling
programs for mercury-containing devices.
The Universal Waste Rule35 is another
example of a regulation helping to facili-
tate proper management of mercury-
containing devices to keep them out of
incinerators and landfills. In August 2005,
EPA finalized its proposal to add mercury-
containing devices (e.g., thermometers
and switches)  to the federal Universal
Waste Rule.36 For these widely-generated
hazardous wastes, this rule streamlines
entry into the waste management system,
encourages recovery and recycling, and
keeps wastes out of the municipal waste
stream. States and localities have made
substantial progress promoting recycling of
discarded mercury-containing products.
Many states are also involved in banning
certain mercury-containing devices and
actively promoting the use of mercury
substitutes, where available.

Future focus. Because there is a steady
increase in reported land releases, the
Agency will expand its efforts to better
characterize and address land releases of
mercury from the mining sector.  The
Agency intends to evaluate these releases
to determine whether further action is
needed.

Using the latest TRI data, EPA will con-
tinue to analyze long-term trends  and
monitor sectors that are not addressing
their mercury releases to assess appropri-
ate voluntary or regulatory avenues for
addressing mercury releases.

EPA will continue to address mercury
releases at remediation sites with signifi-
cant mercury contamination consistent
with the priorities set by the Superfund
National Priorities List37 and the RCRA
Corrective Action baseline for high-
priority facilities.38 EPA will continue to
coordinate with states to assist in cleaning
up serious spills of mercury in order to
protect public health. In addition, EPA is
looking into mercury issues associated with
abandoned mines relative to downstream
water quality.

EPA will continue to work toward reduc-
ing risk associated with mercury from the
nation's waste streams and from potential
releases to land by promoting cost-effective
reductions in mercury use in products and
processes and by promoting the collection
and recycling of discarded mercury-con-
taining products.

State, Tribal, and  Local Government
Release Reduction  Efforts
Many state, tribal, and local governments
have been leaders in addressing mercury

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30 - EPA's Roadmap for Mercury
             releases. States have developed innovative
             mercury release and use reduction laws
             and regulations that supplement, and in
             some cases provide a model for, national
             efforts.

             For example, the state of Maine passed a
             law requiring removal of mercury conve-
             nience lighting switches from automobiles
             prior to crushing the automobiles for scrap
             metal.39 The purpose of the legislation is
             to reduce mercury releases from Electric
             Arc Furnaces (EAFs) used to melt scrap
             metal for steel production. The source of
             mercury from EAFs has been determined
             to be mercury components contained in
             the scrap metal melted by such furnaces.
             Scrap automobiles are the largest mercury-
             containing feedstock for these furnaces.40
             Several other states are pursuing their own
             auto switch removal programs,  including
             Pennsylvania, New York, New Jersey,
             Illinois, Colorado, Washington, Oregon,
             and Idaho. As a result of this state leader-
             ship, auto manufacturers no longer install
             mercury switches for convenience lighting
             and are actively investigating ways to keep
             mercury out of vehicles. In addition, EPA
             is engaging in discussions with various
             stakeholders, including auto dismantlers,
             shredders, steel makers, auto manufactur-
             ers, environmental groups, and states, with
             the aim of developing a collaborative
             national approach to removing mercury
             switches from the large inventory of autos
             in use today prior to their disposal, crush-
             ing, and smelting.

             States, tribes, and local governments have
             played a key role in outreach to the busi-
             ness community and to the general public
             about the importance of properly dispos-
             ing of mercury-containing products and
             about alternatives to such products. Many
             states  and local governments have spon-
             sored  mercury collection programs for
businesses and households. For example,
cities such as San Francisco, California,
and states, such as Florida and New
Hampshire, are conducting outreach to
dentists on the proper handling and
disposal of mercury-containing dental
amalgam, including efforts to promote
increased use of dental amalgam separa-
tors that reduce  the amount of mercury
discharged  into the POTWs from dental
wastewater.


Priority Activities for Addressing
Mercury Releases
•   Standard for Coal-Fired Power Plants
    - On March 15, 2005, EPA finalized
    the Clean Air Mercury Rule which
    establishes standards of performance
    for electric power  plants based on a
    market-based cap-and-trade methodol-
    ogy. This rule will  build on EPA's
    Clean Air Interstate Rule (CAIR) to
    significantly reduce emissions from
    coal-fired power plants. The standards
    address mercury air  emissions from
    new and existing coal-fired electric
    utility steam generating units. When
    fully implemented, these rules will
    reduce power plant emissions of
    mercury from 48 tons per year to 15
    tons per year, a reduction of nearly 70
    percent.41 Timeline: CAMR will reduce
    emissions from 48 tons to 31 tons beginning
    2010 and declining thereafter until emissions
    are reduced to  15 tons when the program is
    fully implemented

•   MACT Standard for Industrial
    Boilers - EPA promulgated a MACT
    standard for mercury air emissions
    from industrial boilers in September
    2004. This effort should result in a 17
    percent reduction in mercury emis-
    sions from this sector since 1990.
    Timeline: Implementation by 2007

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                                                              I. Addressing Mercury Releases - 31
MACT Standard for Hazardous
Waste Combustors - In October
2005, EPA published emission stan-
dards for mercury and other hazard-
ous air pollutants for incinerators,
cement kilns, lightweight aggregate
kilns, industrial/commercial/institu-
tional boilers and process heaters, and
hydrochloric acid production furnaces
that burn hazardous waste. An interim
standard that took effect in 2003 has
already reduced mercury emissions
from levels in 2000 for incinerators,
cement kilns, and lightweight aggre-
gate kilns. The final MACT standard
is estimated to further reduce mercury
air emissions from all hazardous waste
combustors by an additional 39 per-
cent (from 2.4 tons/year to 1.5 tons/
year).42 Timeline: Implementation by 2008

MACT Standard for Chlor-Alkali
Sector - In December 2003, EPA
promulgated a rule  to regulate emis-
sions of mercury from mercury-cell
chlor-alkali plants.43 Mercury-cell
chlor-alkali plants produce chlorine
and caustic soda (used to neutralize
acidic compounds) using mercury cells.
The rule will also require rigorous
work practice standards that will
reduce mercury emissions from fugi-
tive sources. Although EPA is not able
to accurately quantify the reductions
associated with these work practice
standards, the requirements will
reduce mercury air emissions industry-
wide. Timeline: Implementation by Decem-
ber  2006

MACT Standard for Iron and Steel
Foundries - In 2004 EPA issued a
final rule to reduce  toxic air emissions,
including mercury,  from iron and steel
foundries. Iron and steel foundries
melt scrap, ingot, and other forms  of
iron and steel and pour the resulting
molten metal into molds to produce
shaped products. The rule includes
emission limits for manufacturing
processes and pollution prevention-
based requirements to reduce air toxics
from furnace materials and coating/
binder formulations. Implementation
of the rule is expected to reduce
mercury emissions by 1.4 tons—an 80
percent reduction from current lev-
els.  Timeline: Implementation by 2007

Area Source Program - Under the
Urban Air Toxics Strategy, EPA is
developing standards to control emis-
sions of toxic air pollutants (hazardous
air pollutants or HAP)  from area
sources. Area sources are those sources
that emit less than 10 tons annually of
a single HAP or less than 25 tons
annually of a combination of HAP.

The Clean Air Act (CAA) requires
EPA to identify a list of at least 30
HAP that pose the greatest potential
health threat in urban  areas, and in
the 1999 strategy, EPA  identified 33
such pollutants. Of those 33 identified
pollutants, EPA determined that 30
stem from area source emissions.
Through three separate listings (includ-
ing a list in the Urban Air Toxics
Strategy), EPA has identified a total of
70 area source categories which repre-
sent 90 percent of the  aggregate
emissions of the 30 listed area source
HAP. Of these  70 area source catego-
ries, 16 have been regulated, and EPA
is currently collecting data and infor-
mation for many  other source catego-
ries. Timeline: Ongoing

Rule on Electric Arc Furnaces (EAFs)
- In 2006, EPA plans to propose a
comprehensive rule for steel mills that

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32 - EPA's Roadmap for Mercury
                use EAFs to address emissions of
                mercury, lead, and other metals and
                organic hazardous air pollutants. EPA
                will also pursue voluntary programs in
                parallel with the development of
                regulations to ensure mercury emis-
                sions reductions. These actions collec-
                tively should greatly reduce mercury air
                emissions from EAFs and other scrap
                consumers  over the course of the next
                10 years. Timeline: Propose rule in 2006

                Mercury Automobile Switches -
                Many pre-2003 domestic passenger
                vehicles have mercury-containing
                switches in convenience light assem-
                blies and anti-lock braking systems
                (ABS). Building on and coordinating
                with successful state and local automo-
                tive switch  removal efforts, EPA hopes
                to develop  a partnership with automo-
                bile dismantlers, scrap shredders,
                steelmakers, and the automotive
                industry to remove mercury switches
                from scrapped autos in the U.S. prior
                to disassembly, shredding, and melting
                in steelmaking furnaces. Timeline: 2006

                Characterize Mining Releases - EPA is
                examining  the issue of mercury-
                bearing materials being placed on land
                at active gold mines and any subse-
                quent releases which are not covered
                by TRI (air, surface, water, or ground
                water) associated with that placement.
                An effort is underway to assess the
                releases and their potential impact to
                determine if further action is war-
                ranted. Timeline: 2006

                Characterize Mercury Discharges to
                Surface Water - As mentioned in the
                progress to date section, EPA recently
                developed a new analytical method for
                use in water discharge permitting
                programs that will improve EPA's
understanding of point source mer-
cury contributions to surface waters.
Based on that information, EPA is
providing guidance to Publicly Owned
Treatment Works (POTWs) on how to
characterize sources of mercury to the
collection system and how to develop
mercury minimization measures where
appropriate. Mercury in POTW
collection systems may come from the
medical sector, dental offices, schools,
and certain industries. EPA is continu-
ing to explore opportunities for
pollution prevention in the dental
sector and other sources. Timeline:
Ongoing

Issue Mercury Water Quality  Crite-
rion Implementation Guidance - EPA
currently intends to issue implementa-
tion  guidance to states and tribes for
the fish-tissue-based mercury water
quality criterion and how to incorpo-
rate it into  permits and TMDLs. Once
states and tribes adopt the water
quality criterion into their water
quality standards, officials can incorpo-
rate appropriate controls where
necessary into TMDLs and watershed
management decisions. State environ-
mental officials can incorporate
appropriate controls where necessary
into  permits and enforce these re-
quirements. Timeline: 2007

Improve Tools for Tracking Mercury
in Fish Tissue - EPA continues to
improve its models for tracking
methylmercury  in fish tissue and air
deposition trends.45 EPA will also
begin to estimate the expected effec-
tiveness of proposed Hg source reduc-
tion  activities in terms of reduced fish
tissue methylmercury concentrations.
This effort  may involve the continued
evolution of the Mercury Maps model-

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                                                              I. Addressing Mercury Releases - 33
ing framework, and its integration
with sophisticated air deposition
model outputs (e.g., CMAQ [Commu-
nity Multiscale Air Quality]). In addi-
tion, EPA will continue to refine its air
emission inventories to provide an
assessment of emission reductions
gained through implementation of its
regulatory programs. Timeline: To be
determined

Develop Alternative Approaches and
Tools for Identifying Mercury Impair'
ments and Developing Mercury
TMDLs - EPA will work with states,
tribes, and stakeholders to determine
how best to use TMDLs to provide a
basis for reducing mercury releases to
water, including those from air deposi-
tion, to meet state water quality
standards and Clean Water Act goals.
EPA will provide updated mercury
deposition modeling results to states
for use in TMDLs, including the
major sources of mercury deposition
to each  state. EPA will also evaluate
approaches for identifying mercury
impairments  and developing mercury
TMDLs, such as regional-scale TMDLs
and approaches that acknowledge
strong state mercury reduction pro-
grams, in order to make progress
toward attaining state water quality
standards. Timeline: Ongoing

Promote The Proper Collection and
Recycling of Dental Office Amalgam
Waste - EPA is currently developing a
dental office  amalgam recycling
program called its "gray bag" program.
This program will assist dentists in
properly collecting and managing
dental amalgam wastes generated in
their offices to minimize mercury
releases to air, land, and water. This
program also will ensure that dental
amalgam is sent to responsible recy-
clers who can adequately minimize
mercury releases by keeping the
amalgam waste out of the wastewater
stream and out of municipal and
medical incinerators. Timeline: In 2006

Fluorescent Lamp Recycling - EPA is
administering a grant program to
increase the recycling rate of mercury-
containing lamps. Grants are used to
create lamp recycling outreach pro-
grams targeting commercial and
industrial users of mercury-containing
lamps. State environmental agencies,
tribes, non-profit organizations, lamp
manufacturers, and recyclers are all
partners in implementing this pro-
gram. EPA is currently providing
national coordination of these efforts
as well as technical expertise on regula-
tory issues. EPA will build upon the
results of this grant program to in-
crease the national rate of bulb recy-
cling. EPA is also working with Re-
gions and states to  develop guidance
on the conditions under which drum
top crushing of waste lamps can be
permitted without  unacceptable
mercury releases or danger  to person-
nel who operate the crushers. Timeline:
In 2006

Analyze Sectors and Trends for
Mercury Releases in the TRI/NEI
Databases - EPA will continue to
evaluate the "other" smaller sources, as
appropriate, that cumulatively release
significant amounts of mercury to the
environment. EPA will monitor
existing data on how mercury is
managed onsite and/or off-site and
will examine potential sectors for
expanding voluntary mercury reduc-
tion programs. Timeline: Ongoing

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34 - EPA's Roadmap for Mercury

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                                      II. Addressing Mercury Uses in Products and Processes - 35
  II.  ADDRESSING MERCURY  USES IN
         PRODUCTS AND PROCESSES
OVERVIEW
Addressing uses of mercury in products
and processes is a component of prevent-
ing mercury releases to air, water, or land.
These releases may occur during manufac-
turing and industrial processes, or during
the disposal or recycling of mercury-
containing products and wastes. Address-
ing mercury use in products also reduces
the demand for mercury by product
manufacturers, thereby reducing  demand
for new mercury mining. Mercury mining
still occurs in other countries and causes
further releases to the global environ-
ment. Addressing demand for and use of
mercury is critical to breaking the cycle of
    Uses Can Contribute to Releases

    Mercury use in products can lead to
    mercury releases through:

    •  Manufacturing of product
    •  Spills/breakage
    •  Recycling/collection
    •  Disposal
mercury being transferred
from one  environmental
medium to another.

EPA's long-term goal is to
reduce risks associated with
mercury. EPA recognizes
that to reduce risks associ-
ated with  mercury, the
Agency must first under-
stand what contributes to
the risk and what the
appropriate mechanisms of
risk reduction might be.
EPA will take action to
identify exposed popula-
tions, minimize exposures through out-
reach efforts, and appropriately address
anthropogenic releases. As part of its
strategy, EPA will assess mercury sources of
concern and will: focus on uses that would
lead to risk, where cost-effective substitutes
exist; promote reducing mercury in pro-
cesses and products where benefits of such
reduction  would justify the cost, even
where cost-effective substitutes do not
exist; and  work to identify and encourage

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   36 - EPA's Roadmap for Mercury
 FIGURE 3. Total 2001 U.S. Mercury Use in Products2

                    Total: 245 metric tons

                    17 metric tons
                       7%
            D Wiring Devices and
              Switches
                                   or 12 percent of overall
                                   mercury use by U.S. indus-
                                   try.3
        34 metric tons
           14%
103 metric tons
   42%
21 metric tons
   9%
• Measuring and Control
  Instruments
D Dental
  and Supplies
D Electric Lighting
D Other
                  69 metric tons
                     28%
                development of alternatives to essential
                uses of mercury that lead to risk.

                Sources. In  1980, the three largest U.S.
                industrial uses of mercury were in batteries
                (1,052 metric tons), the chlor-alkali manu-
                facturing process (358 metric tons), and
                paint (326 metric tons).1 Mercury use in
                products accounted for an estimated 245
                metric tons in 2001. As Figure 3 illustrates,
                the dominant use of mercury in products
                in 2001 was  in switches and wiring devices
                at 42 percent (103 metric tons), followed
                by measuring and control devices at 28
                percent (69 metric tons), dental amalgam
                at 14 percent (34 metric tons), and electri-
                cal lighting at 9 percent (21 metric tons).

                Mercury is also found in laboratories,
                including school science labs. Breakage or
                spillage  of mercury supplies and mercury-
                containing lab equipment creates the
                potential for inhalation exposure to
                airborne mercury indoors. Mercury in
                schools  can pose a significant exposure
                concern for children and adults.

                In 2001, the largest use of mercury in
                manufacturing processes was by the chlor-
                alkali industry (producers of chlorine and
                caustic soda), estimated at 38 metric tons,
            Progress to date. Over the
            past two decades there has
            been a dramatic drop in
            mercury use by industries in
            the United States, decreasing
            83 percent between 1980 and
            1997, from 2,225 metric tons
            to 381 metric tons (see Figure
            4).4 This reduction in use was
            due in large part to state and
            congressional limits placed on
mercury use in batteries, EPA's regulatory
ban on mercury in paint, closure of some
mercury-cell chlor-alkali manufacturing
plants, and progress made under the U.S./
Canada Great Lakes Binational Toxics
Strategy, a voluntary agreement which set
forth a goal of 50 percent reduction in the
deliberate use of mercury nationwide by
2006.5

The lamp industry has made significant
progress in reducing use of mercury. The
National Electrical Manufacturers Associa-
tion  (NEMA) reported that its members
have significantly reduced use of mercury
in lamps while increasing their production
of lamps.  In 1990, NEMA estimates that
its lamp members used 23.6 tons of
mercury in slightly fewer than 500 million
mercury-containing lamps. After a con-
certed effort to reduce mercury use, this
mercury usage declined to 7 tons by 2003.
In the same timeframe, sales by NEMA
lamp members have increased to 650
million mercury-containing lamps. The
Association of Mercury and Lamp Recy-
clers reports that lamp recycling has
increased  from fewer than 10 million
lamps in 1990 to 156 million lamps in
2003.6

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As a result of a voluntary commitment to
mercury reduction made by the U.S.
Chlorine Institute under the Great Lakes
Binational Toxics Strategy, the chlor-alkali
industry has made significant progress in
reducing its mercury use since 1995. The
U.S. Chlorine Institute's Ninth Annual
Report to  EPA showed a 91 percent
reduction  between 1995 and 2005 in
mercury used in the U.S. production of
chlorine and caustic soda, after adjusting
for shut down facilities.7

EPA's Hospitals for a Healthy Environ-
ment (H2E) program is a partnership
among EPA, the American Hospital
Association (AHA), the American Nurses
Association, and Health Care Without
Harm to encourage hospitals to eliminate
the use and purchase of mercury-contain-
ing products such as measurement and
control devices.8 Under H2E, these health
                                          II. Addressing Mercury Uses in Products and Processes - 37
care facilities have pledged to eliminate
mercury use and waste whenever possible
by 2005 and to reduce all types of waste by
2010.

State, Tribal,  and Local Government
Use Reduction Efforts
Many state, tribal, and local governments
have been leaders in reducing mercury
use. States have developed innovative
mercury use and release reduction laws
and regulations that supplement, and in
some cases provide a model for, national
efforts. For example, all of the New
England states have adopted legislation to
reduce mercury use in products.9

States, tribes, and local governments have
played a key role in outreach to the busi-
ness community and to the general public
about the importance of properly dispos-
ing of mercury-containing products and
                                       Dental amalgam        • Other
                                       Measuring devices    D Switches and relays

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38 - EPA's Roadmap for Mercury
             about alternatives to such products. Many
             states and local governments have spon-
             sored mercury collection/replacement
             programs for businesses and households
             for products such as mercury thermom-
             eters. They have also made special efforts
             to educate and encourage hospitals and
             schools to eliminate the use of mercury
             and mercury-containing products. For
             example, over the past few years, the
             northeast states, in  conjunction with the
             eastern Canadian provinces, have collected
             over 2,000 pounds  of mercury from
             cleanout efforts at over 200 schools.10
             These efforts have been key to the
             progress made to date on reducing mer-
             cury use in school science laboratories.

             Likewise, several states such as Maine,
             Texas, and localities such as Alameda
             County, California have built green
             purchasing requirements that specify the
             use of non-mercury alternatives into their
             state procurement systems.

             Future focus. During the next ten years,
             EPA will focus on uses that would lead to
             risk, where cost-effective substitutes exist;
             promote reducing mercury in processes
             and products where benefits of such
             reductions would justify the costs, even
             where cost-effective substitutes do not
             exist; and work to identify and encourage
             development of alternatives to essential
             uses of mercury that lead to risk by work-
             ing with state and tribal partners, industry,
             and non-governmental organizations. The
             Agency's use reduction activities will be
             conducted in the context of the global
             market for commodity-grade elemental
             mercury and the need for global use
             reductions. (See Section III for further
             discussion of the mercury commodity
             market.) EPA will continue to support and
             build on successful  state and local efforts by
             funding selected mercury projects, provid-
ing information about mercury sources
and reduction opportunities, and coordi-
nating joint efforts to further progress on
addressing mercury use. EPA will also
continue to work with other countries and
international organizations to address
global demand for and use of mercury as
discussed further in Section V on interna-
tional mercury sources.

Need for a National Mercury Use
Database
Reliable and publicly available data on
mercury use is a prerequisite to gauging
the success of EPA initiatives to reduce the
use of mercury. In 1998 the U.S. Geologi-
cal Survey discontinued its annual report-
ing of mercury use, due to low voluntary
response from mercury-using manufactur-
ers. More recently, other limited sources
of mercury use information have
emerged: (1) the U.S. Chlorine Institute's
annual report to EPA on mercury usage by
the chlor-alkali industry;11  and (2) the
Northeast Waste Management Officials'
Association's (NEWMOA) database on
mercury-containing products, housed in
NEWMOA's Interstate Mercury Educa-
tion and Reduction Clearinghouse
(IMERC).12 The IMERC database contains
annual data (beginning with 2001) re-
quired from manufacturers by the states of
Connecticut, Maine, New Hampshire, and
Rhode Island on national sales of specific
mercury-containing products that are sold
in these four states. The IMERC database
is updated every three years. The base year
for data is 2001; companies are required
to report on 2004 data in 2005. EPA is
evaluating how best to build upon this
information as it is developing its database
for mercury use in products and processes
nationwide. A national use database will
enable EPA and its partners to evaluate
the effectiveness of its outreach activities.

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                                           II. Addressing Mercury Uses in Products and Processes - 39
Priority Activities for Reducing Mer-
cury Uses
To further progress in reducing risks
associated with mercury use, EPA will
continue to pursue a number of priority
activities. These activities are based on
considerations of the quantity of mercury
used by specific industry categories; oppor-
tunities to provide national leadership;
and opportunities to work in partnership
with industries, other federal agencies,
state, tribal and local governments,  other
institutions, and public interest groups.

Industrial Processes
•  Track Reductions by Mercury-Cell
   Chlor-Alkali Facilities -  EPA will
   continue to monitor the use of mer-
   cury by the chlor-alkali industry
   through the EPA/US. Chlorine
   Institute voluntary agreement on use
   reporting for the remaining U.S.
   mercury-cell chlor-alkali  plants.
   Timeline: Ongoing through 2006

Mercury-Containing Products
•  Further Reduce Risks Associated with
   Mercury Use Using TSCA Authori-
   ties and Voluntary Mechanisms - EPA
   will focus its new reduction  efforts on
   switches, relays, and measuring devices
   because these sectors represent the
   majority of mercury  use in products,
   and cost-effective alternatives are
   available for many uses in these
   categories. EPA will conduct a prelimi-
   nary market analysis of mercury
   switches, relays, and measurement
   devices to identify candidate product
   manufacturers to partner with the
   Agency to reduce mercury use. Build-
   ing upon successful state regulatory
   programs, EPA will pursue further use
   reductions in this product area using
   TSCA and voluntary mechanisms.
Timeline: Proposed auto switch significant
new use rule in 2006

Develop Database to Track Reduc-
tions in Mercury Use by Key Sectors
- EPA is compiling and assessing
information on mercury use and
substitutes from existing data sources.
The Agency will explore using various
mechanisms to improve the  compre-
hensiveness and reliability of its na-
tional database on mercury use, supply,
and substitutes. This information also
will allow  EPA to evaluate the effective-
ness of its outreach activities on mer-
cury-containing products. Timeline: Data
collection is ongoing; database in 2007

Promote Procurement  of Non-
Mercury Products by Federal Agen-
cies - EPA is compiling a list of alterna-
tive non-mercury products with a
special emphasis on those that contain
non-mercury switches, relays, and
measuring devices. EPA will compile
and convey information—such as
federal, state, and local bid specifica-
tions—to federal purchasers using its
Environmentally Preferable Products
(EPP) Database.13 The intent is to
harness the large federal buying power
to increase demand for  non-mercury
products. EPA will also make such
information available to other inter-
ested purchasers, including state,
tribal, and local governments; large
industrial  purchasers currently using
mercury switches and relays (such as
manufacturers of cars, airplanes, and
appliances); institutional purchasers
such as hospitals and schools; and
individual consumers. Timeline: Ongoing

Partner with Automobile Manufactur-
ers to Eliminate Mercury - EPA will
work with the auto manufacturers  on

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40 - EPA's Roadmap for Mercury
                additional mercury use reduction and
                elimination of mercury from products,
                such as high-intensity discharge (HID)
                headlights. EPA will provide auto
                manufacturers with information on
                non-mercury alternatives to auto
                components through its Green Suppli-
                ers Network, an EPA partnership
                effort with manufacturers and their
                supply chains.14 Timeline: Enhance partner-
                ship efforts on auto products in 2006

                Reduce Mercury in Health Care
                Facilities - EPA will continue partner-
                ships with the American Hospital
                Association (AHA), the American
                Nurses Association, and Health Care
                Without Harm to encourage hospitals
                to eliminate the purchase of mercury-
                containing products such as measure-
                ment and control devices, and properly
                dispose of mercury-containing products
                currently in health care facilities. EPA
                will expand these efforts by recruiting
                additional facilities. Timeline: Recruit
                2,000 new facilities by 2007

                Promote Mercury Reduction in
                Schools - Building upon the successful
                work of the mercury-in-schools projects
                throughout the country by states and
                EPA regions, EPA will continue to
                work with school administrators and
                policy makers to promote the substitu-
                tion  of mercury with environmentally
                preferable chemicals through procure-
                ment policy guidelines and the use of
                green chemistry; the removal of
                elemental mercury, mercury reagents,
                and mercury waste products from
                school laboratories; the replacement of
                mercury-containing devices with safer
                non-mercury-containing devices in all
                school facilities; and the use of soft-
                ware to educate school maintenance
                workers and decisionmakers about
potential environmental hazards in
schools and ways to reduce them. EPA
is developing a handbook, "Chemical
Management for Schools: Recom-
mended Actions for Administrators,"
which will help schools safely manage
chemicals, including mercury. This
guidance will help school officials
ensure the health and safety of the
students and school employees.
Timeline: Finalize Chemicals Management
Document in 2006

Schools Chemical Cleanout Cam-
paign (SC3) - Existing stocks of out-
dated, unknown, excessive or unneces-
sarily hazardous chemicals—are present
in schools across the country. These
chemicals can pose safety and health
risks to students and staff, and a
number of widely reported incidents
involving such chemicals have resulted
in school closures and costly clean-ups.
To reduce the number of these inci-
dents, the Agency has initiated the
Schools Chemical Cleanout Campaign
(SC3)15 which promotes removal of
existing stocks of hazardous chemicals
from secondary schools; safe chemical
management; and  national awareness.
The ultimate goal of the SC3 is to
create a chemically safer school envi-
ronment in which chemicals are
purchased wisely, stored safely,
handled by trained personnel, used
responsibly, and disposed of properly.
In the summer of 2004, EPA launched
ten SC3 pilots, one in each EPA
region. EPA provided funding for an
additional eight pilots in 2005. Out-
reach materials are now available on
the website at www.epa.gov/sc3.
Timeline: Ongoing

Promote Mercury Product  Use
Reduction Partnerships - Many

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                                       II. Addressing Mercury Uses in Products and Processes - 41
current mercury uses in products have
cost-effective, mercury-free alterna-
tives. EPA is currently inviting compa-
nies to voluntarily commit to mercury
product use reduction and phaseout
goals and to become partners in EPA's
National Partnership for Environmen-
tal Priorities (NPEP) Program. As a
component of these partnerships, EPA
is promoting mercury-containing
product take-back/recycling programs
and providing technical assistance to
industry in achieving their NPEP
goals. Timeline: Ongoing

Promote the Mercury Challenge -
EPA is currently inviting companies to
commit to  establish inventories of
mercury; remove  mercury and mer-
cury-containing equipment from their
plants; and institute purchasing poli-
cies to  reduce mercury use. This
mercury challenge is a component of
the NPEP program.16

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42 - EPA's Roadmap for Mercury

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                                            I. Managing Commodity-Grade Mercury Supplies - 43
        III.  MANAGING  COMMODITY-
          GRADE MERCURY SUPPLIES
OVERVIEW
The Agency expects that an excess supply
of elemental, commodity-grade mercury
will emerge on the market over the
coming years as various secondary sources
of mercury—especially the expected phase-
out of mercury-cell chlor-alkali plants-
overtake a shrinking demand for mercury-
containing products and industrial use of
mercury. As a result, there will be an
increasing need to safely  manage mercury
supplies for the long term. Ultimately, it
will be important to look at ways to perma-
nently "retire" most supplies of mercury
that will eventually have little or no
economic value. EPA estimates  that
current world demand for mercury is
approximately 2,000 metric tons per year
(mt/yr). Although highly variable from
one year to the next, the  amount of
mercury available in commerce globally is
also estimated at 2,000 mt/yr.1  Other
estimates prepared for the European
Union (EU) indicate that the global
mercury supply may be over 3,300 metric
tons.2 It is important to note that supply
and demand numbers  for countries
outside the U.S. and Europe are very
rough estimates. In the absence of efforts
to retire mercury supplies, there is a
danger that supplied mercury will find uses
that have already been banned or elimi-
nated in some countries, particularly in
the developing world, possibly leading to
unnecessary releases.

Sources, In recent years, approximately
one-half of the world mercury supply has
come from mercury mines in Spain,
Algeria, and Kyrgyzstan
(although Spain is no
longer mining mercury).
China has also mined
mercury to meet its domes-
tic demand.3 There have
been no active mercury
mines in the U.S. since
1990. The remaining half
of the world's mercury
supply comes from second-
ary sources, such as indus-
trial wastes and scrap
products, as byproduct
from gold mines in the
U.S. and abroad, and from

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44 - EPA's Roadmap for Mercury
             closing mercury-cell chlor-alkali plants.
             The secondary mercury produced from
             these other sources is price-insensitive
             because the mercury results from environ-
             mental regulations and polices that require
             or encourage recovery (e.g., RCRA land
             disposal restrictions),  and from industrial
             process conversions to non-mercury
             processes. Environmental regulations and
             polices that require mercury recovery can
             override the market's natural tendency
             over the long term to match supply with
             demand. Whereas the long-term trend for
             mercury mining has been one of decline,
             secondary production has remained
             relatively constant. It may even increase as
             mercury continues to be recycled/recov-
             ered and more mercury-cell chlor-alkali
             plants close, thereby making more mer-
             cury available to the secondary market.

             The most significant factor driving the
             timing of a global mercury surplus is the
             rate at which remaining U.S. and interna-
             tional mercury-cell chlor-alkali plants close
             and liquidate their stocks of some 22,000
             metric tons. Of these stocks, mercury-cell
             chlor-alkali plants in the U.S. account for
             about 2,600 metric tons of mercury
             stocks.4 Mercury-cell chlor-alkali plants are
             being closed at the end of their useful life
             in the U.S. and abroad due to the
             industry's conversion to non-mercury
             technologies, a shrinking customer base,
             and high energy costs.

             Progress to date. The Department of
             Defense (DoD) has mercury stocks that are
             being stored. The  DoD has 4,436 metric
             tons of mercury in its strategic stockpile.
             DoD has sold some of its mercury stocks in
             the past, but since 1994 DoD has been
             storing its mercury in response to requests
             from EPA, states, and non-governmental
             organizations (NGOs). On April 30,  2004,
             the Defense National Stockpile Center
(DNSC) published its final Mercury
Management Environmental Impact
Statement regarding the disposition of its
mercury.5 The DNSC decided to store its
mercury at one location for at least a 40-
year period. In addition, the Department
of Energy has a known supply of 1,306
tons of mercury.

State and local governments have pro-
moted public and private collection
programs for both bulk elemental mer-
cury and discarded mercury-containing
products. Some businesses are also collect-
ing unwanted mercury or mercury-con-
taining products (e.g., thermostats). The
total amount of mercury collected
through these programs is unclear. Most
of this mercury is sent to retorters, and it
is likely that the supply of mercury will
increase due to successful collection
programs and efforts to eliminate mercury
from schools, laboratories, and businesses.

The Environmental Council of the States
(EGOS) and the Quicksilver Caucus
(QSC), a coalition of state associations
concerned with mercury pollution, have
indicated that states do not have the
resources or desire to manage surplus
mercury for the long term and are look-
ing to  the federal government to address
this issue.6 Environmental groups and the
U.S. Chlorine Institute are also looking to
the federal government  to address or
assume responsibility for all private sector
commodity-grade mercury that exceeds
U.S. demand.

In addition, EPA's Office of Research and
Development conducted research and
published a report in 2005 on the techni-
cal and economic feasibility of selected
land disposal technologies in a monofill
context, as compared to above-ground
storage for elemental mercury.7

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Future focus. The issue of whether the
federal government, states,  or the private
sector should take responsibility for
managing commodity-grade mercury
supplies from state and private sources is
an important policy decision. Decisions
regarding the disposition of commodity-
grade mercury should be made in light of
the global mercury market; data and
research needs; public policy, statutory,
and economic considerations; and the
views of Congress, states, tribes, and non-
governmental organizations.

Ultimately, it will be important to look at
ways to permanently "retire" non-federally
owned or managed commodity-grade
mercury that will eventually have little or
even negative economic value. Disposal of
commodity-grade mercury would require
regulatory changes, as current regulations
under the Resource Conservation and
Recovery Act (RCRA) require high con-
centration mercury wastes to be retorted
for mercury recovery and reuse.8

Additional information on mercury
supplies and flows would allow for more
informed policy choices and decisions on
this issue, and to better estimate when the
global mercury surplus may occur. EPA,
states, tribes, and the private sector must
continue efforts, domestically and interna-
tionally, to address exposure, potential
reduction strategies, and the quantity of
mercury that will ultimately need to be
stored or land disposed permanently.
                                                  I. Managing Commodity-Grade Mercury Supplies - 45
   information gaps on annual produc-
   tion and use of commodity mercury.
   Timeline: 2006

Safe Storage Practices for Disposal of
Mercury
•  Establish a Process to Address Mer-
   cury Surplus Issues - In 2006, EPA
   will work with other agencies to
   initiate a process with technical experts
   and interested parties to discuss op-
   tions for addressing the expected
   mercury surplus over the next 10-30
   years, and how to encourage the phase-
   out of mercury mining abroad.
   Timeline: Initiate discussion in 2006
Priority Activities for Addressing
Mercury Supplies
Address Data Gaps on Mercury Supplies
•   Publish Initial Report and Assemble
    Existing Data on Domestic and Global
    Commodity Mercury Production and
    Use - EPA will explore with industry
    and other federal agencies ways to fill

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46 - EPA's Roadmap for Mercury

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                              IV. Communicating to the Public about Mercury Exposure Risks - 47
               IV.  COMMUNICATING
             TO THE  PUBLIC  ABOUT
          MERCURY  EXPOSURE  RISKS
OVERVIEW
While the Agency is pursuing regulatory
and voluntary activities aimed at industrial
reduction of mercury releases and uses,
EPA will also increase its risk communica-
tion and outreach activities to help people
avoid or reduce their exposure to mercury
in the near term. The most common way
people in the U.S. are exposed to mercury
is by eating fish containing methylmercury
(an organic mercury compound). Con-
sumption of fish with higher methylmer-
cury levels can lead to elevated levels of
methylmercury in the bloodstream of
unborn babies and young children and
may harm their developing nervous
system.1 The primary tool for reaching
and educating affected populations has
been through  fish consumption advisories
issued by states, tribes, and FDA. For
example, in March 2004, EPA and FDA
issued a joint federal fish consumption
advisory for mercury in fish and shellfish
that helps consumers understand the
benefits of fish consumption, the risks of
consumption to certain sub-populations
(e.g., groups with routinely high consump-
tion), and mercury levels in certain fish.
Fish and shellfish are an important part of
a healthy diet, since they contain high
quality protein and other essential nutri-
ents, are low in saturated fat, and contain
omega-3 fatty acids. A well-balanced diet
that includes a variety of fish and shellfish
can contribute to heart health and
children's proper growth and develop-
ment. Research shows that most people's
fish consumption does not cause a health
concern.

EPA and FDA have issued fish consump-
tion advice to help consumers understand
the connection between the benefits of
fish and possible risks of methylmercury

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  48 - EPA's Roadmap for Mercury
             What You Need to Know About
              Mercury in Fish and Shellfish

         U.S. Food and Drug Administration and
         U.S. Environmental Protection Agency
                      Advice for
   Women Who Might Become Pregnant, Women Who Are
       Pregnant, Nursing Mothers, and Young Children
1.   Do not eat:
    • Shark
    • Swordfish
    • King Mackerel
    • Tilefish

They contain high levels of mercury.

2.   Eat up to 12 ounces (2 average meals) a week of a variety
    offish and shellfish that are lower in mercury.
    • Five of the most commonly eaten fish that are low in
     mercury are shrimp, canned light tuna, salmon, pollock,
     and catfish.
    • Another commonly eaten fish, albacore ("white") tuna has
     more mercury than canned light tuna.  So, when choosing
     your two meals offish and shellfish, you may eat up to 6
     ounces (one average meal) of albacore tuna perweek.

3.   Check local advisories about the safety offish caught by
    family and friends in your local lakes, rivers and coastal
    areas.

    If no advice is available, eat up to 6 ounces (one average
    meal) perweek offish you catch from local waters, but
    don't consume any other fish during that week. Follow
    these same recommendations when feeding fish and
    shellfish to your young child, but serve smaller portions.

    For more information, please visit:
    www.epa.gov/waterscience/fishadvice/advice.html
    (See full text of Joint Fish Advisory in Appendix A)
              exposure. Elevated methylmercury in the
              blood stream of unborn babies and young
              children may harm the nervous system,
              impairing the child's ability to learn and
              process information. Certain sub-popula-
              tions may be at higher risk than the
              general population because of their rou-
              tinely high consumption of fish and
shellfish (e.g., tribal and other subsistence
fishers and their families who rely heavily
on locally caught fish for the majority of
their diet).

Although people are exposed to methyl-
mercury via the dietary route, there are
also some non-dietary sources of mercury
exposure. Many consumers are not aware
that mercury has been used for years in
common household products such as
thermostats. Releases from the manufac-
ture of mercury-containing products and
inappropriate disposal of these products
have contributed to mercury  entering the
environment and ultimately the food
chain. Misuse of or accidental breakage of
some products can create indoor air
health risks and expose consumers to
dangerous levels of mercury. In addition,
certain cultural or religious uses of mer-
cury may also result in harmful mercury
exposure. The number of individuals
exposed in the U.S. in this way is very
small.

The Agency will make it a priority to
provide consumers with reliable risk
information about mercury exposure so
that they can make informed choices
about the fish they eat and the products
they use.

Progress to date. EPA has directed most of
its mercury risk communication activities
toward raising awareness about dietary
practices. The FDA-EPA national advisory,
What You Need to Know About Mercury in
Fish and Shellfish, provides advice for
women who might become pregnant;
women who are pregnant; nursing moth-
ers; and young children.2 This advisory
represents the first time FDA and EPA
have combined their advice into a single
uniform advisory. During the summer
and fall of 2004, the two agencies distrib-

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                                   IV. Communicating to the Public about Mercury Exposure Risks - 49
uted brochures about the advisory to
approximately 200,000 medical providers
in the U.S.

In September 2005, EPA sponsored the
Eighth Annual National Forum on
Contaminants in Fish ("Fish Forum"). The
forum provided an opportunity for people
who have an interest in the subject of
advisories, from both the public and
private sectors, to discuss scientific and
policy issues, risks and benefits, and
communication strategies associated with
exposure to chemical contaminants in
sport- and subsistence-caught fish and
shellfish. In September  2005, the 13th
straight year, EPA released its National
Listing of Fish Advisories, a summary of
information on locally-issued fish adviso-
ries and safe-eating guidelines.3 This
information is provided to EPA annually
by states, territories, and tribes.

States and tribes issue fish consumption
advisories if elevated concentrations of
chemicals such as mercury are found in
local fish. States monitor their waters by
sampling fish tissue for persistent pollut-
ants that bioaccumulate. States issue their
advisories and guidelines voluntarily and
have flexibility in what criteria they use
and how the data are collected. As a
result, there are significant variations in
the number of waters tested, the pollut-
ants tested for,  and the  threshold for
issuing advisories. Based on self-reporting,
the national trend is for states to monitor
different waters each year, generally
without retesting waters monitored in
previous years.4 As new  waters are tested
and results are added to previous years'
findings, the number of fish advisories
continues to rise. EPA makes information
on the fish advisories, as well as Fish
Forum proceedings, easily accessible to the
public on its website.
Although most of EPA's risk communica-
tion efforts have been directed to increas-
ing awareness of mercury in the food
chain, the Agency has also investigated
non-dietary sources of mercury exposure
about which the public should be aware.
Risk communication has been conducted
in conjunction with mercury reduction
activities, such as school clean-outs or
thermometer collection programs. In
many cases, critical  mercury outreach to
schools and communities would not
otherwise occur without EPA assistance.
For example, EPA's Region 6 has identi-
fied a particular need for such support in
communities on the U.S./Mexico border.

EPA's national  efforts on mercury risk
communication have been aimed at
making information widely available to
the public and at co-sponsoring national
conferences that bring together people
from across the country to share informa-
tion on mercury risk communication. A
unique exposure concern is raised by
ritualistic  use of mercury in certain cul-
tural communities.  For this reason, in
January 1999, EPA  and the U.S. Agency
for Toxic Substances and Disease Registry

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50 - EPA's Roadmap for Mercury
            (ATSDR) convened the Task Force on
            Ritualistic Uses of Mercury to recommend
            an appropriate course of action regarding
            the use of elemental mercury as part of
            certain folk practices and religious tradi-
            tions. The Task Force prepared a report in
            2002 which recommended approaches
            that rely primarily on community outreach
            and education activities to inform mercury
            suppliers and the public about mercury's
            risks, and encourage the use of safer
            alternatives.5

            In January 2005,  EPA launched its consoli-
            dated website on mercury, www.epa.gov/
            mercury.6 This new website, organized by
            subject matter and geographic region,
            provides one location to find information
            about mercury in a useful format for the
            American public. Because the most  effec-
            tive  mercury risk communication activities
            will  be carried out at the state and local
            level, another important contribution to
            mercury risk communication is the  provi-
            sion of grants, cooperative agreements,
            and other types of funding for state, tribal,
            and local mercury risk communication
            activities.

            States, tribes, and local governments have
            also conducted outreach activities in
            conjunction with most of the mercury
            collection programs mentioned in Sections
            I and II on addressing mercury releases
            and uses in processes and products. In
            order to get a high rate of participation in
            these voluntary programs, it is important
            to educate the public on the risks of
            mercury exposure, the need for proper
            disposal of mercury-containing products,
            and the availability of safe, non-mercury
            alternatives. For example, in an innovative
            project, the state  of Minnesota trained a
            dog to locate mercury in buildings by sense
            of smell. Minnesota's Mercury-Free  Zone
            Program is modeled after  a Swedish
program that uses dogs to detect mercury
in schools.7 Schools that take the mercury-
free pledge are eligible to receive a visit
from Clancy the mercury dog. Clancy has
received media coverage which has raised
general awareness of the dangers of
mercury and the need to dispose of
mercury responsibly. States, tribes, and
local governments are in the best position
to develop material tailored to local
populations. For example, the state of
Washington is using an EPA grant to
conduct a survey of fish consumption
among Asian/Pacific Islander populations
in the Puget Sound region. As part of this
project, the state will identify community
groups to educate these populations in a
culturally sensitive manner by tailoring
messages and translating documents.

Future focus. As long as mercury is
present in the environment and in food
and consumer products, consumers will
need reliable risk information about
mercury exposure; about making in-
formed choices regarding the benefits of
fish consumption, the risks of consump-
tion for certain groups, and mercury levels
in certain fish; and about the purchase,
use, and disposal of mercury-containing
products and mercury-free alternatives.
EPA will continue to provide support for
national and local outreach and education
programs on the effects of mercury and
consumer choices. EPA will also support
risk communication and outreach efforts
about mercury through its international
activities and programs.

Priority Activities for Mercury Risk
Communication
•   Continue Assistance in Implementing
    Fish Advisories - EPA will continue to
   work closely with FDA to implement
   the 2004 joint EPA-FDA national fish
   advisory for methylmercury across the

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                                IV. Communicating to the Public about Mercury Exposure Risks - 51
U.S. EPA will also work with FDA to
continue targeted outreach efforts to
the U.S. medical community to pro-
vide information on dietary risks of
methylmercury exposure, and ways
that medical professionals can help
patients and their families reduce
exposure to mercury while maintain-
ing a healthy diet. EPA will continue
to assist the states and tribes with
development and communication of
their fish advisories through the
National Forum on Contaminants in
Fish (held every 15-18 months),
updating of risk communication
guidance documents, and updating the
National Listing of Advisories.
Timeline: Ongoing; Biennial Fish Forums

Maintain Centralized Mercury Portal
Website - EPA will provide up-to-date
information on all aspects of the risk
of mercury exposure through food
consumption and product use by
maintaining its electronic Mercury
Portal Website, which will be EPA's
primary mechanism for communicat-
ing with the public about mercury.
Timeline: Ongoing

Assist State, Tribal, and Local Govern-
ment Mercury Outreach Activities -
EPA will continue to assist and support
state, tribal, and local government
efforts to conduct mercury risk com-
munication and outreach, research
and mitigation activities addressing
important routes  of mercury exposure,
and actions that can be taken by
individual consumers to reduce mer-
cury exposure and pollution. Timeline:
Ongoing

Outreach Activities to Consumers on
Mercury-containing Products and
Mercury-free Substitutes for Use in
the Home - Building upon the infor-
mation already available from states
and other groups about consumer
products that contain mercury,  EPA
will develop an inventory of mercury-
containing products and mercury-free
substitutes. EPA will also identify
information gaps. EPA will make the
information available on its website.
Timeline: 2006

Outreach to Health Professionals and
Health Care Associations - Health
professionals are an important partner
in the dissemination of mercury risk
information. EPA is working to edu-
cate health professionals about a
variety of children's environmental
health issues, including mercury. For
example, EPA is coordinating an
interagency effort to work with the
Pediatric Environmental Health
Speciality Units to provide pediatric
consultative services covering mercury
and other key concerns for children's
environmental health. EPA will also
partner with health care associations
and universities to disseminate mer-
cury risk information and increase
proper mercury disposal in health care
facilities. Through the Hospitals for a
Healthy Environment (H2E) program,
EPA and its regions will continue to
work with universities to educate
future  health professionals in proper
disposal of chemicals in hospitals.
Timeline: Ongoing

Outreach to Schools on the Need to
Remove Mercury - As part of its
national project to work with science
teachers, curriculum developers,
facilities managers, and pollution
prevention professionals to promote
mercury reduction in  schools, EPA will
work to make  school officials and staff

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52 - EPA's Roadmap for Mercury
                aware of the risks of exposure to
                mercury and the availability of mer-
                cury-free alternatives. This includes the
                use of software to educate school
                decisionmakers about potential  envi-
                ronmental hazards in schools and ways
                to reduce them. Timeline: Ongoing

                Conduct Public Awareness Evaluation
                for Dietary Issues - To better educate
                the U.S. public on how to make
                informed dietary choices, FDA,  with
                assistance from EPA, is conducting
                surveys to evaluate how well the U.S.
                public understands the effects of
                methylmercury exposure from eating
                certain fish and shellfish. Timeline:
                Surveys conducted and completed during
                2006/2007

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                                           V. Addressing International Mercury Sources - 53
    V. ADDRESSING INTERNATIONAL
                MERCURY SOURCES
OVERVIEW
EPA is actively engaged and collaborating
with international organizations and
partners to address risks associated with
mercury uses, releases, and exposure. As
previously discussed, the greatest mercury
exposure to the
general population is
from eating fish
containing methyl-
mercury, including
marine fish. EPA has
estimated that over
three quarters (83
percent) of the
mercury deposited
in the U.S. origi-
nates from interna-
tional sources (with
the remaining 17
percent coming
from U.S. and
Canadian sources).
These figures in-
clude mercury from
natural and re-
emitted sources.
This estimate is
                 based on an advanced, state-of-the-science
                 modeling assessment of atmospheric fate,
                 transport, and deposition of mercury.
                 EPA's modeling indicates that a substantial
                 variation in mercury deposition occurs
FIGURE 5. Where are Man-Made Mercury Emissions Originating?1
                    1995, metric tons per year.

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54 - EPA's Roadmap for Mercury
               FIGURE 6. Man-Made Air Emissions of Mercury: Distribution by Region in 1990 and 20003
                                   1990                                         2000
                             Total: 1,181 metric tons                            Total: 2,269 metric tons
                                     South America
                                        62 tons
                                          3%
                                         North America
                                           261 tons
                                            14%
                                       Europe
                                       627 tons
                                        33%
  Asia
1204 tons
  52%
 South America
 __^, 92 tons
     4%

  North America
    202 tons
      9%
 Europe
239 tons
 11%
                                                                                Australia
                                                                                125 tons
                                                                                  6%
             across the U.S., with domestic sources
             influencing mercury deposition much
             more in the eastern U.S. and global
             sources being a more significant contribu-
             tor to mercury deposition in the west,
             where relatively few domestic sources exist.
             The scientific community's understanding
             of mercury atmospheric chemistry is
             evolving, and there remain uncertainties
             regarding simulation of mercury in atmo-
             spheric chemistry models. EPA continues
             to work to advance the state of the science
             on mercury chemistry and fate and trans-
             port modeling.2 International collabora-
             tion is critical to refining our understand-
             ing of global mercury sources,
             international transport pathways, and
             environmental impacts, and most impor-
             tantly, for addressing the adverse impacts
             of mercury on human health and the
             environment globally.

             Sources. A number of key international
             emission sources contribute to global
             cycling and deposition of mercury via air
             pathways, including: coal-fired combustion
             sources; mining and metals production,
             such as smelting; mercury-cell chlor-alkali
manufacturing facilities; and combustion
or incineration of waste products contain-
ing mercury. The United Nations Envi-
ronment Program (UNEP) estimates that
the total global emissions of mercury
(anthropogenic and natural to the atmo-
sphere) range from 4,400 to 7,500 metric
tons per year.4 EPA estimates that 50-70
percent of current global anthropogenic
atmospheric emissions come from fuel
combustion, and much of this is from
China, India, and other Asian countries.5
Coal consumption in Asia is expected to
grow significantly over the next 20 years.
This source of mercury emissions may
grow substantially if left unaddressed.6
Small-scale "artisanal" gold and silver
mining is an important mercury emissions
source in numerous Asian, South Ameri-
can, and African countries. Atmospheric
mercury emissions from artisanal gold
mining have been estimated by UNEP  to
be about 300 metric tons per year,7 but
some experts estimate  that total mercury
releases from artisanal gold mining are
between 650 and 1,000 metric tons per
year on a global basis.8 An estimated 13
million people in 55 countries work and

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                                                      V. Addressing International Mercury Sources - 55
are affected by occupational exposures in
artisanal mining.9

Using data presented in the 2002 United
Nations Environment Program Global
Mercury Assessment, EPA has calculated
that mercury-cell chlor-alkali factories are
the third largest source of atmospheric
mercury releases to the global environ-
ment. While the number of mercury-cell
chlor-alkali facilities has been greatly
reduced in the United States and Europe
over the last two decades, the process is
prevalent in many parts of the world
including Russia, several South American
countries, and India, which is estimated to
have the most plants of any developing
country.10 EPA estimates that there may
be 135-170 mercury-cell plants globally,
with half located in developing countries.11
Global estimates for mercury use in
processes and products range from  2,000-
3,400 metric tons per year.12 Mercury-cell
chlor-alkali facilities are among the
principal users of mercury in the
world. In addition to industrial
uses, mercury has been used in
numerous products, including
household appliances, electronics,
batteries, automobile switches,
dental amalgam, and thermom-
eters. While mercury use in pesti-
cides, fungicides, paints, and most
batteries has been banned or
phased-out in the U.S. and other
developed countries, these uses are
continuing in developing coun-
tries. For example, battery produc-
tion accounts for an estimated one
third of global mercury use  in
products (see Figure 7).13
         and international programs and agree-
         ments to address mercury uses, releases,
         and the resulting exposure around the
         globe. These include:

          •   U.S./Canada Great Lakes Binational
             Toxics Strategy, which provides a
             framework for actions to reduce or
             eliminate mercury and other persis-
             tent toxic substances. The Strategy sets
             forth challenge goals to reduce mer-
             cury use by 50 percent and to reduce
             releases by 50 percent by 2006 (from
             the 1990 baseline). The use goal has
             been met. The releases goal  has  almost
             been met. Mercury releases  have
             decreased by 47 percent. By  2006,
             additional regulations and voluntary
             activities are expected to reduce  mer-
             cury emissions by at least 50 percent,
             meeting the release goal as well.14

          •   New England Governors/Eastern
             Canadian Premiers Regional Mercury
FIGURE 7. Global Mercury Use, 2000
                             Total: 3,386 metric tons
         Measuring and Control
              166 tons
                5%
              Lighting
              91 tons
                3%
             Other uses
              175 tons
                5%

 Electrical control & swtiching
       154 tons
        4%
                        Dental amalgam
                          272 tons  ~~
Progress to date. EPA is currently
engaged in the implementation of
a wide range of bilateral, regional,
      Small-scale gold & silver
        mining (artisanal)
           650 tons
            19%

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56 - EPA's Roadmap for Mercury
                Action Plan, which establishes long-
                term and short-term regional mercury
                reduction goals. The plan addresses
                mercury emission reductions; source
                reduction and safe waste management;
                outreach and education; and research,
                analysis and strategic monitoring. Due
                to successfully reaching the goal of 50
                percent reduction of emissions by
                2003, the Governors and Premiers are
                now working on meeting a 75 percent
                reduction goal for emissions by 2010.15

                Commission for Environmental
                Cooperation (CEC) North American
                Regional Action Plan for Mercury,
                which aims to reduce man-made
                mercury releases to the North Ameri-
                can environment through appropriate
                international and national  initiatives
                to amounts that are attributable to
                naturally-occurring levels and fluxes.
                The U.S. has made considerable
                progress in implementing the provi-
                sions of the plan regarding mercury air
                emissions; processes, operations, and
                products; and waste management; as
                well as  research, monitoring, model-
                ing, and inventories; and communica-
                tion activities.16

                United Nations Economic Commis-
                sion for Europe (UNECE) Convention
                on Long-range Transboundary Air
                Pollution Protocol on Heavy Metals is
                a legally-binding agreement that
                targets emissions of cadmium, lead,
                and mercury. The U.S. is a party to the
                Heavy Metals Protocol, which went
                into effect in December 2003. The
                protocol aims to cut emissions from
                industrial sources, combustion pro-
                cesses, and waste incineration through
                application of best available technolo-
                gies and emission limit values for new
                and existing stationary sources. The
protocol also requires mandatory
mercury concentration limits for
certain types of batteries, and encour-
ages parties to consider various man-
agement measures to address use of
mercury in other products. The U.S.
meets the provisions of the Heavy
Metals Protocol.17

UNEP Mercury Program, which was
created at the February 2003 meeting
of the United Nations Environment
Program (UNEP) Governing Council.
The United States government was
instrumental in providing much of the
initial funding and leadership for the
creation of the UNEP Mercury Pro-
gram. This  program is based on the
key finding of the 2002 UNEP Global
Mercury Assessment that there is
sufficient evidence of significant global
adverse impacts from mercury and its
compounds to warrant international
action to reduce the risks to human
health and the environment. Sup-
ported by the 130 nations attending
the Governing Council meeting, the
UNEP Mercury Program endorses
immediate actions to reduce mercury
uses and releases, assist developing
countries to create mercury emissions
inventories, raise awareness, and
provide technical assistance. The U.S.
government has been involved in all
of these efforts, and has funded the
majority of the UNEP Mercury Pro-
gram to date. EPA funded technical
staff to work in the UNEP Mercury
Program for two years, provided
technical review of UNEP draft
mercury guidance, and sent experts to
conduct training at the UNEP regional
mercury workshops.18

At the twenty-third session of the
UNEP Governing Council, which was

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                                                  V, Addressing International Mercury Sources - 57
held in Nairobi, Kenya, February 21 -
25, 2005, delegates agreed to further
develop the UNEP Mercury Program
and to support the efforts of countries
to take action to reduce mercury
exposure, releases, and uses. The
Governing Council urged govern-
ments, intergovernmental and non-
governmental organizations, and the
private sector to develop and imple-
ment partnerships in a clear, transpar-
ent, and accountable manner to
reduce the risks of mercury to human
health and the environment.19

The U.S. initiated five mercury part-
nerships for: (1) artisanal and small-
scale gold mining; (2) chlor-alkali
manufacturing; (3) products; (4) coal
combustion; and (5) fate and transport
research. EPA held consultative meet-
ings with other countries and domestic
and international stakeholders on the
first three partnerships in 2005. The
partnerships created will leverage
resources, technical expertise, technol-
ogy transfer, and information ex-
changes to provide immediate, effec-
tive action that will result in tangible
reductions of mercury use and emis-
sions.
     20
United Nations Industrial Develop-
ment Organization (UNIDO) Global
Mercury Project, which provides
training on best management practices
to reduce occupational exposures, to
reduce emissions, and to reduce the
amount of mercury used in small-scale
"artisanal" gold and silver mining
operations around the world. EPA has
provided funding and technical exper-
tise to assist in this effort.21

Arctic Mercury Project, which was
developed in the context of the Arctic
    Council Action Plan (ACAP) and the
    Arctic Monitoring and Assessment
    Program (AMAP). EPA has worked to
    strengthen capacity building and
    technical cooperation programs
    among the Arctic countries, particu-
    larly to assist Russia in the develop-
    ment of Russia's mercury action
    plan.22 In 2005, two ACAP mercury
    reports were issued. The first, an
    "Arctic Mercury Releases Inventory,"
    summarizes current releases, usage,
    and disposal of mercury within all
    eight Arctic countries. The second, an
    "Assessment of Mercury Releases from
    the Russian Federation," represents
    the first comprehensive assessment of
    mercury releases at the national level
    by that country. With the cooperation
    of the Russian authorities, a limited
    number of point sources in the Rus-
    sian Federation are being evaluated in
    terms  of their potential as sites for
    mercury demonstration projects. The
    Agency is coordinating U.S. federal
    government  involvement, which
    includes the  U.S. Geological Survey,
    Department of Energy, Department of
    State,  and National Oceanic and
    Atmospheric Administration.

Future focus. EPA will continue to work
with the U.S. Department of State and
other federal agencies to provide interna-
tional leadership in addressing mercury in
international fora, including the CEC,
UNECE, Arctic Council, and UNEP.
Consistent with  the 2005 UNEP Govern-
ing Council Decision on mercury, the goal
of the U.S. government is to reduce
human and ecosystem risks associated with
the use and emissions of mercury from
international  sources.  Global mercury
reductions can be accomplished by address-
ing all major aspects of the global  mercury
problem and collaborating on the develop-

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58 - EPA's           for Mercury
            ment of partnerships and specific results-
            oriented projects to reduce mercury uses
            and emissions nationally, regionally, and
            globally. It is critical to more fully engage
            developed and developing countries,
            industry, environmental groups, interna-
            tional organizations, and funding institu-
            tions to bring needed technical expertise
            and financial resources to address the
            global mercury problem.

            Priority Activities to Reduce Global
            Mercury Sources and  Releases
            The following is a  list of important compo-
            nents to an international approach to
            facilitate global reductions in mercury use,
            releases, and exposure, followed by brief
            descriptions, and EPA's priority actions in
            each area. These activities build upon and
            complement existing actions under UNEP,
            UNECE, Arctic Council, UNIDO, and
            multi-lateral and bilateral agreements, and
            may include the development of or partici-
            pation in specific partnerships and projects
            in the following areas:

                 •   Increase international awareness of
                    mercury risks and risk communica-
                    tion approaches

                 •   Improve global understanding of
                    international emissions sources,
                    releases and transport mechanisms

                 •   Address mercury emissions from
                    point sources

                 •   Address mercury use in products
                    and processes where there is an
                    opportunity to reduce risk

                 •   Address mercury supply issues

                 •   Improve management of mercury-
                    containing wastes and surplus
                    mercury
Increase International Awareness of
Mercury Risks and Risk Communica-
tion Approaches - There is a need to
enhance international awareness and
understanding of mercury sources
(national, regional, and global) and
risks to the general public. It is impor-
tant to develop and share key health
messages and methods regarding
exposure from dietary sources (e.g.,
fish consumption advisories, testing
methods, and protocols  for determin-
ing the level of mercury  in fish) and
non-dietary sources (e.g., consumer
products) and the need to use mercury
alternatives.

EPA will work with its federal, state, non-
governmental, and international partners
to:

•   Share sampling and  analysis
    protocols that have been devel-
    oped to determine the level of
    mercury in fish. Timeline: Ongoing

•   Support international outreach
    efforts to communicate risk.
    Timeline: Ongoing

Improve International Understand-
ing of Global Emissions  Sources,
Releases, and Transport Mechanisms
- International cooperation has
helped shape understanding of mer-
cury cycling on local, regional, and
global scales, and determine the effects
of mercury exposure on  human
health. Working with international
partners is critical to improving
understanding of mercury's global
impacts. Areas of collaboration will
include transport and fate research;
development of production, use,
source, and emissions data.

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                                                     V, Addressing International Mercury Sources - 59
   EPA will work with its federal, state, non-
   governmental, and international partners
   to:

   •   Coordinate monitoring research
       and measurement work in Asia
       and elsewhere. Timeline: Ongoing

   •   Continue to conduct high altitude
       research in the U.S. to continue to
       transect with ongoing long-range
       transport monitoring in other
       parts of the world by the U.S. and
       other countries. Timeline: Ongoing

   •   Develop and implement
       workplans with UNEP,  United
       Nations Institute for Training and
       Research (UNITAR) and other
       countries for assessment/inventory
       of mercury emissions and use.
       Timeline: 2006

   •   Support the development of a
       global partnership on mercury fate
       and transport research.  Timeline:
       Initiate in 2006

•  Address Mercury Emissions from
   Point Sources - Mercury is emitted to
   the air from combustion of fossil fuels,
   metal production, mining,  mercury-
   cell chlor-alkali plants, waste incinera-
   tors, zinc smelters, and other point
   sources. International efforts to build
   on a number of existing techniques to
   reduce mercury emissions from these
   point sources by sharing information
   and expertise on air control technolo-
   gies and multi-pollutant approaches
   will be key.

   EPA will work with other federal agencies
   and departments to:
 •   Build on bilateral agreements to
    improve inventories and introduce
    control technologies in China,
    India, and Russia. Timeline: Ongoing

 •   Achieve reductions of global
    mercury emissions from the coal-
    fired power sector through volun-
    tary partnerships. Timeline: Initiate
    in 2006

 •   Raise awareness and knowledge of
    the applicability, effectiveness and
    cost of newly emerging mercury
    and multi-pollutant control tech-
    nologies. Timeline: Ongoing

 •   Coordinate with the Chinese
    government, the private sector,
    Japan, and Canada to follow up on
    the workshop conducted in
    Beijing,  China in November 2005
    to provide information on coal-
    fired power plant multi-pollutant
    strategies and mercury control
    techniques, and to establish mecha-
    nisms to ensure continued infor-
    mation exchange with China and
    other countries. Timeline: Ongoing

 •   Review data on emissions from
    international large-scale metals
    mining operations in areas with
    high mercury content ore and
    explore options for transfer of EPA
    Region 9's Mining Voluntary
    Partnership Program. Timeline:
    2006/2007

Address Mercury Use in Products
and Processes - Mercury is used
globally in a variety of products and
industrial processes. For most products
and processes, there are cost-effective

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60 - EPA's Roadmap for Mercury
                alternatives available that could replace
                mercury, which would reduce demand
                and emissions. There is a need for
                several sector-oriented approaches,
                including: (1) developing an industry
                partnership on chlor-alkali best man-
                agement practices to reduce mercury
                use and emissions in countries or
                regions that use  or emit the largest
                amounts of mercury; (2) reducing
                global demand for commodity-grade
                mercury through the use of invento-
                ries and partnering with national and
                international stakeholders to share
                information and approaches for
                mercury reductions and substitutes,
                particularly for measuring devices,
                batteries, and products used in the
                health care sector; and (3) promoting
                artisanal mining techniques that are
                safer and that eliminate or reduce the
                input of mercury.

                EPA will work with its federal, state, non-
                governmental, industry,  and international
                partners to:

                •   Develop a multi-stakeholder global
                    partnership on mercury-cell chlor-
                    alkali sector. The partnership
                    would include pilot projects;
                    information  exchange on best
                    management practices and conver-
                    sion to non-mercury processes; and
                    use reporting, to reduce mercury
                    releases from facilities that use or
                    emit the largest amounts of mer-
                    cury, including facilities in Mexico,
                    India and Russia. Timeline: Initiated
                    in 2005

                •   Develop a multi-stakeholder global
                    partnership for reducing or elimi-
                    nating mercury use in products
                    where there  are cost-effective
    substitutes through pilot projects
    and activities, such as:

 •   Sharing information and ap-
    proaches for mercury reductions
    and substitutes (e.g., batteries and
    other products).

 •   Conducting a mercury product
    workshop to build capacity in
    Mexico and other countries in the
    Caribbean, Central and South
    America through the CEC Mer-
    cury Task Force (U.S., Canada, and
    Mexico) in Merida, Yucatan,
    Mexico in 2006.

 •   Developing country-specific use
    inventories, e.g. the Americas,
    Africa.

 •   Transferring successful reduction
    programs, such as EPA's successful
    Hospitals for a Healthy Environ-
    ment program and the  U.S. Green
    Suppliers Network to other coun-
    tries, e.g., China. Timeline: Initiate in
    2006

 •   Expand upon the UNIDO work
    on best  management practices for
    artisanal mining to develop a
    multi-stakeholder global partner-
    ship on  artisanal and small-scale
    gold mining to address use, expo-
    sure, and releases from  this sector.
    Activities include the development
    of pilot projects, training, and
    monitoring, among others.
    Timeline: Initiated in 2005

Address Mercury Supply Issues -
Given declining demand in many
developed countries, ongoing primary

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                                                  V, Addressing International Mercury Sources - 61
mercury mining, and growing global
supplies from secondary sources, prices
for mercury are expected to decline. A
global mercury market surplus is
expected by 2020 (but may occur
earlier), keeping the price of mercury
low and potentially discouraging its
safe storage and management, the
implementation of best management
practices, substitution, and phase-out.
The 2005 Governing Council Deci-
sion 23/9 requests that the UNEP
prepare a report on mercury supply,
trade, and demand information for
consideration of possible further
action. The Decision also requests
governments, the private sector, and
international organizations to take
actions to reduce risks posed on a
global scale by mercury in products
and processes, such as considering
curbing primary mercury production
(mining) and introduction of mercury
into commerce.

EPA will work with the U.S. Department
of State, other federal agencies, and
international partners to:

•  Share U.S. data on mercury
   imports and exports with  UNEP.
   Timeline: 2006

•  Explore mechanisms for facilitat-
   ing the phase-out of primary
   mercury mining.  Timeline: Initiate in
   2007

Improve Management of Mercury'
Containing Wastes and Surplus
Mercury - Mercury-containing wastes
present significant challenges, where
municipal, hazardous, and medical
waste management systems are ill-
equipped to separate mercury from
the waste stream. In addition, the
global supply of commodity-grade
mercury will increase as various sec-
ondary sources of mercury overtake
the shrinking demand. There will be
an increasing need to safely manage
mercury supplies for the long term.
Actions may include: (1) sharing
information on successful approaches
and best management practices for
storage of commodity-grade mercury
and safe treatment, retorting, and
disposal of waste, including discarded
mercury-containing products; (2)
coordinating waste  management
activities with the Basel Convention's
capacity-building program for waste
management to avoid duplication and
to leverage resources;23 and (3) as
technologies come on-line, building
capacity to create waste disposal/
recycling programs for mercury-
containing batteries, lamps, scrap
metal, etc.

EPA will work with its federal and state
partners, non-governmental organizations,
and international partners to:

•   Share  U.S. best management
    practices for automobile switch
    removal, collection, and recycling
    programs. Timeline: 2006

•   As previously discussed in the
    Commodity section of the
    Roadmap, EPA will establish a
    stakeholder process to  address the
    mercury surplus issue. Timeline:
    Initiate in 2006

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62 - EPA's Roadmap for Mercury

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                                           VI. Conducting Mercury Research and Monitoring - 63
         VI.  CONDUCTING  MERCURY
       RESEARCH  AND  MONITORING
MERCURY RESEARCH  OVERVIEW
There is much mercury research under-
way to investigate the occurrence and
impact of mercury in the environment.
EPA is actively engaged in a variety of
research activities. In 2000, EPA's Office
of Research and Development (ORD)
published its Mercury Research Strategy,1
which provides broad strategic directions
for EPA's  mercury research program.

The overarching goal of the research
strategy is to provide information and
data that reduce scientific uncertainties
limiting the Agency's ability to assess and
manage mercury and methylmercury
risks. The strategy provides a rationale
and framework for setting future mercury
research priorities, which are reflected in
EPA's Mercury Research Multi-Year Plan
(MYP) covering the period 2002-2010.2
This implementation plan contains long-
term goals to: (1) reduce and prevent
release of mercury into the environment;
and (2) understand the transport and fate
of mercury from release  to the receptor
and its effects on the receptor.
In conducting its mercury research pro-
gram, ORD's in-house efforts are coupled
with those of its Science to Achieve Results
(STAR) Grants Program,3 which sponsors
extramural research on many topics by
academic institutions and other not-for-
profit entities. In addition, some of EPA's
research is undertaken in cooperation with
other organizations such as the U.S.
Department of Energy (DOE) and the
U.S. Geological Survey (USGS). Important
coordination occurs among federal agen-
cies and state, tribal, and local govern-
ments, through science forums such as the
EPA/USGS  Mercury Roundtable.4 It is
also important to note that additional

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64 - EPA's Roadmap for Mercury
             mercury research activities are conducted
             by EPA headquarters and regional offices
             that are not described in ORD's Mercury
             Multi-Year Plan.

             The primary exposure route addressed in
             the ORD Mercury Research Strategy
             involves fish consumption where deposited
             mercury is converted to methylmercury in
             water bodies, consumed by fish, and then
             accumulated in mammals, including
             humans that eat fish. Within the context
             of this primary exposure route, EPA has
             analyzed various scientific questions,
             including the following.

             Key Scientific Questions
             •  How much methylmercury in fish
                consumed by the U.S. population is
                contributed by U.S. emissions relative
                to other sources of mercury (such as
                natural sources, emissions from  sources
                in other countries,  and re-emissions
                from the global pool)? How much, and
                over what time period, will levels of
                methylmercury in fish in the U.S.
                decrease due to reductions in environ-
                mental releases from U.S. sources?

             •  How much can mercury emissions
                from coal-fired power plant boilers and
                other combustion systems be reduced
                with innovative mercury-specific and
                multi-pollutant control technologies?
                What is the relative performance and
                cost of these approaches compared to
                currently available technologies?5

             •  What is the magnitude of contribu-
                tions of mercury releases from non-
                combustion sources? How can the most
                significant releases be minimized?6

             •  What critical changes in human health
                are associated with exposure to envi-
   ronmental sources of methylmercury
   in the most susceptible human popula-
   tions? How much methylmercury are
   humans exposed to, particularly
   women of child-bearing age and
   children among highly-exposed popula-
   tion groups? What is the magnitude of
   uncertainty and variability of mercury
   and methylmercury toxicokinetics in
   children?7

•  What are the most effective means for
   informing susceptible populations of
   the health risks posed by mercury and
   methylmercury contamination of fish
   and seafood?8

EPA based the proposed and final §112(n)
Revision Rule and the Clean Air Mercury
Rule on the current state of the science.9
In the context of these rules, EPA, among
other things, identified the pertinent
health endpoints associated with methylm-
ercury contamination, considered the
primary exposure pathways for ingestion
of methylmercury, analyzed mercury
control technologies, and considered the
effectiveness and costs associated with
reducing mercury emissions from coal-
fired power plants. EPA recognizes that
there remain scientific uncertainties
associated with some of the above-noted
questions and is committed to continuing
to work to advance the science in these
areas.

Progress to date. Research results provide
important information to support EPA's
air, water, waste,  and toxics programs in
their ongoing efforts to address mercury.
In recent years the major emphasis of
research activities has been to support
EPA's regulatory efforts to control mer-
cury from coal-fired power plants, and to
increase the Agency's understanding of

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                                                 VI. Conducting Mercury Research and Monitoring - 65
mercury fate and transport. The following
are major research results from the period
2001-2004.

EPA researchers have developed the
methodology and instrumentation to
make semi-continuous ambient measure-
ments that distinguish among mercury
forms—elemental gaseous mercury, diva-
lent mercury (also referred to as reactive
gaseous  mercury [RGM]), and particulate
phase mercury. The resulting speciated
data have improved the understanding of
atmospheric transport and fate  and
enhanced the ability to attribute the
relative  contributions of local, regional,
and global sources of mercury to domestic
and global deposition.10

EPA has produced a state-of-the-science
atmospheric simulation model which
incorporates the current understanding of
chemical and physical processes involving
mercury, including complex interactions
with other atmospheric pollutants. This
model uses highly efficient formulations
and numerical methods, and has recently
been used to simulate a full year of atmo-
spheric  mercury transport and fate over
most of North America. Notwithstanding
these recent advances in modeling atmo-
spheric  fate, transport, and deposition of
mercury, there remain difficult  scientific
challenges to resolve. The Agency is
currently working with international
groups to better quantify atmospheric
chemistry kinetics in Community
Multiscale Air Quality (CMAQ) and to
readily assess the impacts of these model
adjustments to the fate, transport, and
deposition of mercury.11

EPA has developed and tested mass bal-
ance models that use speciated atmo-
spheric  mercury deposition fluxes to
calculate expected watershed mercury
loadings, water body concentrations, and
concentrations in fish. EPA's STAR grant
research program, in addition to its
research in other areas, has furthered the
understanding of the reduction-oxidation
balance between aquatic mercury and
atmospheric mercury, and the effect of
this cycling on the total mercury presence
in freshwater and marine systems.

EPA's research program has provided
extensive support to Agency program
offices and the Administrator on mercury
control technologies, including:

•  Several comprehensive reports  that
   document the development, cost and
   effectiveness  of various mercury-
   specific control technology options
   (including sorbent injection), and
   evaluate co-control reductions that can
   be achieved using existing technologies
   including sulfur dioxide (SO2) scrub-
   bers and selective catalytic reduction
   (SCR)-based nitrogen oxide (NOx)
   emissions control systems;12

•  A White Paper, placed in EPA's coal-
   fired power plant rulemaking regula-
   tory docket, summarizes the status of
   control technology options and out-
   lines what can be achieved in the
   future using various alternative mer-
   cury removal technologies. This White
   Paper was updated to support EPA's
   Office of Air and Radiation and
   enable stakeholders to identify optimal
   management approaches.13 In particu-
   lar, these research results provide state
   agencies, industry, and others with the
   most current technology performance
   and cost information to inform their
   implementation decisions.

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66 - EPA's Roadmap for Mercury
             EPA has developed a report describing the
             impact of selected mercury control tech-
             nologies on the characteristics of coal
             combustion residues and how selected
             utilization/disposal practices impact the
             fate of mercury residues. As part of this
             effort, ORD has  generated a standard
             protocol that will be used to establish the
             leaching and thermal stability for the
             range  of environmental conditions that
             coal combustion  residues are exposed to
             during storage, land disposal, and use in
             commercial applications.14

             EPA has evaluated the performance of
             continuous emission monitors (CEMs) for
             coal-fired power plant boilers as one
             possible tool for measuring total and
             speciated forms of mercury emitted from
             plants under different operating condi-
             tions.15 Based on that evaluation, the
             Agency has concluded that CEMs are
             suitable regulatory tools. EPA's evaluation
             entailed a series of pilot-scale combustion
             experiments, representing realistic coal-
             fired power plant boiler measurement
             environments, that allowed controlled
             investigation of specific measurement
             issues  associated with mercury CEM
             operation. Measurement results were
             obtained rapidly  so that timely feedback
             could  be provided to the monitor manu-
             facturers in order to optimize their instru-
             ments. The improvements accomplished
             during the pilot-plant tests resulted in
             these same mercury CEMs participating in
             three full-scale utility boiler field evalua-
             tions that demonstrated their perfor-
             mance and capabilities. These results  also
             apply to hazardous waste incinerators.

             EPA has conducted a literature review to
             assess  mercury methylation processes  in
             aquatic sediments to inform selection and
             implementation  of risk management
             strategies. This provided the technical
foundation for subsequent products
including a literature review of the sources
and remediation of mercury-contaminated
sediments and a model for evaluating the
effects of remedial actions on mercury
speciation and transport.16 This work
demonstrated how the introduction or
exclusion of oxygen via risk management
strategies impacted the fate and transport
of mercury in sediments.

EPA has evaluated the effectiveness of
several risk management strategies to
address mercury-contaminated sediments,
including dredging, capping, and moni-
tored natural recovery. Work has focused
on the Lavaca Bay, Texas Super-fund site.

EPA,  as part of its effort to develop treat-
ment alternatives for waste from sites
contaminated with mercury mining
wastes, has completed a study describing
leaching profiles of mercury-containing
waste rock and roaster tailings from a
Superfund site in California.17 These
results were used to predict the fate and
stability of mercury present, and will be
used to assess the suitability of any appli-
cable  remediation  treatment.

To support EPA's efforts to address issues
associated with the long-term storage of
mercury, the Agency has: (1) completed  a
report that describes a systematic method
for comparing options for the long-term
management of surplus elemental  mer-
cury in the U.S.,18 and (2) collected infor-
mation on state-of-the-art practices for
macro-encapsulation and micro-encapsula-
tion of mercury-contaminated hazardous
wastes.

EPA has evaluated the effectiveness of
some existing and future risk communica-
tion tools in a variety of formats, using 18
focus groups. Results show clear age,

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                                                 VI. Conducting Mercury Research and Monitoring - 67
gender, and risk-related trends, which
indicate that different risk communication
tools will be required for each of these
audiences, and that no one tool will be
optimally effective across the board. The
results of this work will be published in
2006/2007, and will add to the body of
work outlining risk communication as an
important tool for reducing environmen-
tal risk and protecting human health.

EPA is working with states to conduct
research on fish tissue. For example,
Region 8 has collected over 500 fish
samples over the last three years from the
Cheyenne River Sioux Tribal  lands in
stock ponds and in the Cheyenne,
Moreau, and Missouri Rivers. Data from
Region 8 showed that fish from small
ponds  have high levels of methylmercury.
This may be a function of a
biogeochemically favorable environment
for methylmercury production (i.e.,
methylation of elemental mercury) in
these environments, although further
research is needed to confirm this hypoth-
esis.

Region 8 has also used the data to deter-
mine Exposure Point Concentrations
(EPC)  for several species.19 The regional
office is working with the tribe to make
recommendations on fish stocking  in
stock dams, and also on  recommendations
about how many meals per  month should
be eaten for each species according to the
mercury EPC for that species.

Future focus and priority activities. EPA
will continue to support the long-term
goals described in the Mercury Multi-Year
Plan and this Roadmap. The major empha-
sis of the mercury research program will
continue to be the control of utility
emissions, because utilities represent the
most significant source of mercury release
to the atmosphere in the United States.

•   Toxic Metals Fate Report - EPA will
    develop a report on the fate of toxic
    metals from land disposal and com-
    mercial use of coal combustion resi-
    dues from plants equipped with multi-
    pollutant control technologies.
    Timeline: 2008

•   Sources of Mercury Emissions - EPA
    will develop information on sources of
    mercury emissions including the
    regional/global atmospheric fate and
    transport of such emissions. Timeline:
    2008
           How EPA Will Track
        Progress and Key Trends

1.   Air Emissions
    •   National Emissions Inventory (EPA)
       •   EPA's primary source for air
           emissions data
    •   Toxics Release Inventory (EPA)

2.   Ambient Air and Air Deposition
    •   Mercury Deposition Network (MDN)
       (joint federal/state program)
    •   New England Mercury Monitoring
       Network (joint EPA/state program)
    •   Long Range Transport Monitoring
       (joint EPA/NOAA activity)

3.   Water Quality/Fish Tissue
    •   National Fish Tissue Study (baseline
       study) (EPA)
    •   National Listing of Fish Advisories
       (EPA)
    •   National Coastal Assessment
       ecological monitoring (EPA)
    •   Commercial fish monitoring (FDA)

4.   Human Biomonitoring
    •   National Health & Nutrition
       Examination Survey (CDC)

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68 - EPA's Roadmap for Mercury
             •  Integrated Multimedia Modeling -
                EPA will develop an integrated multi-
                media modeling framework for the
                scientific understanding of mercury.
                Timeline: 2010


             There are many ongoing monitoring
             projects and programs that measure
             mercury in various media. These projects
             and programs are conducted by other
             federal agencies, states and tribal govern-
             ments, and  in academia. Access to routine,
             ongoing monitoring information is
             needed to track environmental and health
             trends and to measure program effective-
             ness.

             A basic strategy for routine mercury
             monitoring is  to focus on the most effi-
             cient points to monitor along the major
             transport and exposure path of air-to-
             water-to-fish-to-humans, in order to deter-
             mine trends in environmental and health
             levels and whether they are responding to
             control and reduction measures. Based on
             this mercury transport and exposure path,
             the four most important media of concern
             are: (1) air emissions,  (2) ambient air and
             air deposition, (3) fish tissue, and (4)
             human tissue. The Centers for Disease
             Control and Prevention (CDC) collects
             data on human tissue, which includes
             blood, hair, and urine. Data on emissions
             and deposition allow EPA to detect
             changes quickly that reflect  program
             activities with great relevance to long-term
             health and the environment. Data on fish
             and human tissue  allow EPA to measure
             longer-term changes that are slower to
             respond to control measures but are better
             indicators of environmental quality and
             human health. EPA will continue to work
             with other federal agencies,  states, and
             tribal governments to coordinate and
             enhance data  collection for these four key
indicators of long-term trends and pro-
gram results for mercury.

Progress to date. Much progress has been
made by EPA and others to establish
monitoring and reporting systems to
collect data on mercury releases and
contamination. During the last five years,
in particular, EPA has encouraged and
supported increased national monitoring
of mercury in both fish tissue and human
blood and hair samples, which is discussed
in more detail below. The following
discussion provides information on cur-
rent monitoring programs conducted or
supported by EPA, and on recent EPA
reports that  highlight significant new data
from various mercury monitoring activi-
ties.

Air Emissions Monitoring
Atmospheric transport is the primary
focus for mercury monitoring and model-
ing, as  it is the dominant means for
cycling mercury from anthropogenic
sources, such as coal-fired power plant
combustion  sources, into other media.
Emissions inventories provide information
about the sources of mercury, and the
relative contributions of those sources  to
total releases. Routine air emissions
monitoring is needed to track long-term
trends  of mercury emissions over time and
geographic space in the U.S. Such infor-
mation is essential to evaluating the
success of EPA's programs for reducing
mercury air emissions from specific
sources.

Two key EPA reporting efforts for air
emissions are the National Emissions
Inventory (NEI) and the Toxics Release
Inventory (TRl). These databases have been
modified and improved over time so that
the Agency has the latest information
necessary to measure program effective-

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                                                VI. Conducting Mercury Research and Monitoring - 69
ness and track environmental trends. (For
further information, see Section I.)

Ambient Air and Air Deposition Moni-
toring
Both ambient air monitoring and air
deposition networks provide information
on mercury once it has been emitted. This
monitoring information is needed to track
long-term mercury contamination  in
ambient air,  and to provide input to
ongoing research and modeling activities
to improve scientific understanding of
mercury transport and fate in the environ-
ment; stationary and mobile sources of
mercury; and the relative contributions of
those sources to total mercury releases to
the environment.

Major routine monitoring activities for
mercury in ambient air and air deposition
include the following:

•   Mercury Deposition Network
    (MDN)X - Formed in 1995, the MDN
    is part of the National Atmospheric
    Deposition Program/National  Trends
    Network (NADP/NTN), a nationwide
    network  of over 70 precipitation
    monitoring sites that collect weekly
    data on the chemistry of precipitation
    for monitoring of  long-term geo-
    graphical and temporal trends. The
    network  is a  cooperative effort among
    state  agricultural experiment stations,
    the U.S.  Geological Survey, U.S.
    Department of Agriculture, EPA, and
    numerous other governmental and
    private entities. Information from the
    MDN is being used to develop a
    national  database of weekly concentra-
    tions of total mercury in precipitation
    and the seasonal and annual flux of
    total  mercury in wet deposition.
    However, there are some gaps in the
    current geographic coverage of MDN
which may limit the analysis. Also, the
MDN does not collect data on dry
deposition for either elemental or
divalent mercury. At present, no
adequate field routine measurement
method exists. EPA and others recog-
nize that dry deposition data are
important—in some areas such data are
as important as wet deposition in
understanding total deposition. For
these reasons, EPA announced in
December 2005 a request for propos-
als to stimulate development of such
methods.

New England Mercury Monitoring
Network - EPA and the New England
states have established a mercury
monitoring network. A number of
monitoring field studies have been
initiated in New England to measure
mercury deposition and ambient
concentration of atmospheric mer-
cury. These studies provide baseline
information on mercury deposition to
support regional efforts to control
mercury contamination and to evalu-
ate  the ecological effects of mercury
contamination.

Long Range Transport Monitoring -
EPA, in collaboration with the U.S.
National Oceanic and Atmospheric
Administration (NOAA), is working
with other countries on characteriza-
tion, modeling, and speciation of
ambient and source level mercury
related to mercury  emissions transport
and deposition on  local, regional, and
global scales. As part of this effort,
high and low altitude monitoring is
being conducted at various sites,
including Mauna Loa, Hawaii. (For
further information, see Section V.)

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70 - EPA's Roadmap for Mercury
             Fish Tissue  Monitoring
             Monitoring of fish tissue provides essential
             information about the levels of mercury
             consumed by  the human population.
             Routine monitoring of marine and fresh-
             water fish consumed in the U.S. diet is
             needed to  track trends in the level of likely
             mercury exposure by the U.S. population,
             as well as trends in mercury concentrations
             in fish in U.S. water bodies over time and
             geographic space.  Information  on mercury
             concentrations in  fish tissue from U.S.
             water bodies is essential to evaluating the
             success of EPA's programs for addressing
             mercury releases from air, water,  and land
             sources. EPA has recently developed a new
             water quality criterion for mercury that is
             based on the amount of mercury found in
             fish tissue  rather than the amount in
             water bodies.  Fish tissue data are  also
             needed as  input to research and modeling
             activities to improve scientific understand-
             ing of mercury transport and fate in the
             environment;  sources of mercury in water
             bodies; and the relative contributions of
             those sources  to total mercury releases to
             the  environment.

             Many governmental organizations provide
             important monitoring data on  fish, such as
             FDA's commercial fish monitoring pro-
             gram.21 EPA's  major monitoring activities
             include the following:

             •  EPA's National Lake Fish Tissue
                Study22 -  The National Study of
                Chemical  Residues in Lake Fish Tissue
                (or National Lake Fish Tissue Study) is
                being conducted by EPA's Office of
                Water  (OW). It is a one-time screening-
                level study to sample contaminants in
                fish tissue in freshwater lakes and
                reservoirs  in the contiguous U.S.,
                including  mercury as well as other
                chemicals. EPA will use the study
results to develop the first national
estimates of the mean concentrations
of mercury and 267 other chemicals in
lake fish, to define a national fish
contamination baseline to track
progress of pollution control activities,
and to identify areas where contami-
nant levels are high enough to war-
rant further investigation. Sampling
has been conducted for four years at a
total of 500 locations, or about  125
sites annually. EPA has worked with 47
states, three tribes and two other
federal agencies to collect fish for the
study. While planning for the study
began in 1998, fish sampling began in
2000 and ended in November 2003.
EPA has released  all 4 years  of raw
data to the public. Agency analysis of
the cumulative 4-year data set will be
completed, and the final report will be
completed in December 2006.

EPA's National Listing of Fish AdvisO'
ries23 - This database contains all fish
advisory information provided to EPA
by the states, tribes, and Canada. It
also contains information on mercury
in fish tissue that states and  tribes
collect as part of their fish advisory
programs. States monitor their  waters
by sampling fish tissue for persistent
pollutants that bioaccumulate. States
issue their guidelines voluntarily and
have flexibility in what criteria they
use and how the data are collected. As
a result, there are significant variations
in the number of waters tested, the
pollutants tested for  and the threshold
for issuing advisories. Based on  self-
reporting, the national trend is  for
states to monitor different waters each
year, generally without retesting waters
monitored in previous years. States
issue fish consumption advisories to

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                                                 VI. Conducting Mercury Research and Monitoring - 71
   the public if elevated concentrations of
   chemicals such as mercury are found
   in local fish. EPA makes information
   about fish advisories easily accessible to
   the public on its website.

•  EPA's Ecological Monitoring to
   Characterize the Condition of U.S.
   Estuarine Resources - As part of its
   National Coastal Assessment, EPA's
   Office of Research and Development
   seeks to characterize the ecological
   condition of U.S. estuarine resources
   through the collection and analysis of
   fish tissue for mercury (and various
   other contaminants) from estuaries
   throughout the U.S., at about 35-100
   sites per year for each of twenty-three
   coastal states and Puerto Rico. The
   National Coastal Assessment data is a
   relatively  new program in the Office
   of Research and Development, which
   is beginning to provide information
   on fish tissue toxics concentrations
   from selected U.S. estuaries. ORD is
   currently  reviewing these data to
   determine their usefulness for integra-
   tion with existing EPA approaches for
   assessing fish tissue mercury concentra-
   tions and their changes over time due
   to both emissions and deposition
   changes.

States are also actively engaged in moni-
toring fish levels of methylmercury in
their waters. For example, the Alaska
Department of Environmental Conserva-
tion has been conducting a multi-year
study of safety of fish and seafood re-
sources in Alaska waters with respect to
contaminants. EPA Region 10 secured
funding for Alaska to perform additional
PBT organic analyses, including methyl-
mercury, and a final report is pending.
This monitoring project is ongoing.
Human Biomonitoring
Routine monitoring of human tissue
samples is needed to track long-term
trends in the levels of mercury exposure of
people in the U.S. over time and geo-
graphic space. CDC collects data on
human tissue, including blood, hair, and
urine. Such human biomonitoring may be
the most meaningful long-term indicator
of the effectiveness of programs for
reducing risks associated with mercury
releases and exposure. It is also useful in
setting priorities for future research and
for risk communication strategies and
activities to reduce mercury exposure in
the short-term.

The level of methylmercury in blood is the
best available indicator of human exposure
to methylmercury through fish consump-
tion. Mercury blood levels in women of
childbearing age is an especially useful
indicator of mercury exposure, since this
measure indicates both the actual exposure
of adult women and the potential for
exposure of fetuses through the transfer of
maternal blood through the placenta.
Other types of human tissue have been
sampled for mercury such as hair, but so
far they have  been found less useful than
blood levels. At the present time there is
insufficient understanding of the relation-
ship of mercury in blood and hair to
mercury levels found in these other
tissues.24

The only source of nationwide informa-
tion on methylmercury in humans is the
National Health and Nutrition Examination
Survey (NHANES), which is conducted by
the U.S. Centers for Disease Control and
Prevention (CDC) with financial support
from EPA and other agencies. NHANES is
a continuous survey of the health and
nutritional status of the civilian, non-

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72 - EPA's Roadmap for Mercury
            institutionalized U.S. population, and data
            are released and reported in 2-year cycles.25

            In 1999 NHANES began measuring
            mercury levels in blood, hair, and urine
            for the first time in a national sample of
            childbearing-aged women and in children
            aged 1-5 years in the U.S. The CDC's
            report, published in 2003, provided the
            first nationally representative estimates of
            U.S. women's and  children's exposures to
            mercury based on biologic measures.26

            In November 2004, the CDC published
            an updated summary of NHANES data for
            the four-year period 1999 to 2002.27 These
            updated findings confirm that blood
            mercury levels in women of childbearing
            age are usually below levels of concern, but
            that approximately six percent of child-
            bearing-aged women had levels at or above
            EPA's Reference Dose (RfD).

            CDC plans to continue this NHANES
            mercury monitoring in future years.
            NHANES 2005-2006 will include mea-
            surements of mercury species (methyl,
            ethyl, and inorganic) in blood in order to
            define more precisely the exposure to
            various sources of mercury.  Blood mercury
            levels will be measured in persons (male
            and female) one-year and older, while
            urinary mercury will be measured in
            persons six years of age and older.28

            Recent EPA Reports Utilizing Mercury
            Monitoring Data
            •   America's Children and the Environ'
                ment: Measures of Contaminants,
                Body Burden,  and Illness29 - Pub-
                lished in February 2003, this is EPA's
                second report on trends in environ-
                mental factors  related to the health
                and well-being  of children in the U.S.
                The report brings  together, in one
                place, quantitative information from a
   variety of sources to show trends in
   levels of environmental contaminants
   in air, water, food, and soil; concentra-
   tions of contaminants measured in the
   bodies of children and women; and
   childhood illnesses that may be influ-
   enced by exposure to environmental
   contaminants. This second report
   provides mercury information for the
   first time. The section on body bur-
   dens includes a new measure of
   mercury in the blood of women of
   child-bearing age, using NHANES
   data. A new section on emerging issues
   presents information about important
   aspects  of children's environmental
   health for which data had recently
   become available, including mercury
   in fish as an important source of
   mercury exposure for people in the
   U.S.

•  EPA's Draft Report on the Environ'
   ment 200330 - Published in June 2003,
   the report presents EPA's first national
   picture  of the U.S. environment,
   including mercury contamination.
   This report was the first step in the
   Agency's Environmental Indicators
   Initiative, launched in  November
   2001, which seeks to identify better
   indicators that EPA can use to measure
   and track the state of the environ-
   ment and support improved environ-
   mental  decisionmaking.

Future focus and priority activities. EPA
will continue to need reliable sources of
routine  mercury monitoring data. Since
monitoring activities are resource inten-
sive,  EPA will continue its current strategy
of focusing primarily on monitoring for a
small number of key environmental and
health indicators, and to leverage re-
sources by looking for opportunities to
collaborate with other governmental and

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                                                VI. Conducting Mercury Research and Monitoring - 73
non-governmental entities where appro-
priate. In addition, the Agency plans to
publish the following documents:

•   Final Results of EPA's National Lake
    Fish Tissue Study - The final report
    will be published in 2006. EPA will use
    the study results to develop the first
    national estimate of mean concentra-
    tions for mercury and 267 other
    chemicals in fish, to provide a baseline
    to track progress of pollution control
    activities, and to identify areas where
    contaminant levels are high  enough to
    warrant further investigation.

•   EPA's Report on  the Environment
    2007 - Under EPA's Environmental
    Indicators Initiative, the Agency will
    continue working to identify better
    indicators that EPA can use to measure
    and track the state of the environ-
    ment and support improved environ-
    mental decisionmaking. The next
    report to present  a national picture of
    the U.S. environment, planned for
    publication in 2007, will be providing
    additional emphasis on mercury
    indicators and information.

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74 - EPA's Roadmap for Mercury

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                        Appendix-75
APPENDIX

-------
76 - EPA's Roadmap for Mercury
                                                                                  o
                                                                              c >

                                                                              1
                                                                              o

                                                                              5
                                                                                      >-


                                    |_L §

-------
                                                                                                                                                      Appendix-77
     .,,';.'•-..•»;;,    B,,.*~
   •'••  '"-'   'iy'"V'*",   I,.11.'.'.!."...".
                                                                                      nc li-
                                               .  111. l/inellls
   I * Do not eat;
      » Shark
      • Sword fish
      » King Mackerel
      • Tile R»li
   1,cy com.Mn high
   •vcls ill' mereurv.
                               *&•» Eitt up to 12
         up to 1'2 ounces (2 average meals) a week of a
variety of fish ami shellfish that are lower in mercury.
j • Cheek local advisories about
the safety ol Uslt caugnt by laittilv
and friends in your local lakes,
rivers, and eosistal area.1*.
                these K^me rtcommfriclalions \vhim feeding fish and Mhclin^h to your young child, hut serve smaller |
                                               Visit she Food and Drug Administration's Food Safety Website www.cfs^n.fda.^ov or
                                               the ErsvironrnentiSl  Protection Agency'^ Fish Advisory Website www.epa.gov/ost/flsh
                                               for a listing df irwrcury levels in fish.
I  frequently/\s
  requently /"\5ked V^fuesttons about Mercury in PLtb am) Slxllfi.fb:
             \ \	1     vvhat i,t mercury?
                                                                        I  e)t?n 't ,1?? t:bf fish I cat in the aikLtifry,
                                                                        What ,(/««<« / <)<>?
                        Mercury occur, naturalK in ihe envirunmem
                        and can .ilsi. lie released into I he air through
                        in.lustri.il pollution. .Mereurv falls from I he air
                        and .-an .ic.-umulalc in streams ..ml oceans .mil       v  I,  „   ,',,   , „, |.l i „ t   I I  ,. i  i i I „


                        iinliorn I.aliy .mil young eliil.l. i'mli ..Iworh d.e
                        inellivlmcmirv as ihev'f.-c.l ill ihcxe waters am
                                                                       II   HI  • ml in  , uiloiminin  ,l» ul l!u k-.l  in llu
                                                                         , i< i  |.|M~. I  i li ,, i  . LI  11  ih  I  [)\ ',..1  i,c

                                                                       I  l'\ i  (' sit   ,t  .    | I0   o t li  I,

                                                                       Vv/fat about fab ,itick,» ant} fa.it firm)
                       \ "m a ii'timan wba entild have children
                       trttt I'm not pregnant - MI it'j&t/ *tbontt) 1 be
                       fanctrne& about tnellnffitterctiri/?
                       If v-ou regularly e.ii tvpes of fish lh.it .ire high in
                       mcihylniercin-v. i, ran accumulate in vo.tr Ithuid
                       stream over time. Motli.vliiwrcury is removed

                       year lor die le.elt. to cJrop signilicandy. Thus, it


                       women who are ?
                       Nearly .ill  lish and shellfish contain traces <>l
Note.                 meihylmercurv-. I low-ever, iarjrcr  lish thai have
If**, I*,*,,,«,„;„„., ,„•    liml '""S" '"«' ""- l"Sl'«'>-els of
ttiak vu\v Imn exfavtl   mc'"> '""'•"ly '" •"'*'" ' "">' \'} '•" '"""' ""'"•'
/,, lmf „„„«„„,. „(        '" —'«'-" " • 1 "«•' '-"'if I -<> 1-vor.ihsl,
w/W*«-.-y -w ««-    A"k- k"« m;«'u'rel ••""' lil"nsl" r"«-1|"-
A,*;*^*^'       e™«M "*. '>"-' w«"i'-''  .»•> "i»'Hi»i-
   -,,tr»,,,,,*,*fe       m"-v k' <'""'" "' ''"• """"'""- 'vcommetidvil l-y
                       1'LIA and IvI'A.
                                                                        Fish sticks and "l.isl-Iond" san.hvifhcs are commonly
                                                                        made from lish thai are low in mercury.

                                                                         1 h? ath'ic? abaitt canned tuna LI in the aihrLwry,
                                                                        but n'bat\t tbf advice about tuna ,*teak,*?
                                                                        Wbal if / fat mure than the recamniettd
                                                                        amount of fab ant) jbcUjit'b in a week?
                                                                        OIK- wvi-k's cl li.Ji dm-* nut .lunge
                                                                                 r?^ /*?**/ information abtnit the .ttljehf iff
                                                                        fifth cautjbt recreatitftlaliy by jamity iff" frtendi?

                                                                        Relore you go lishing. check yctur Kishing Kegulalions
                                                                        Riuiklet  lor information .iluiui recreational^- caught
                                                                        lish. You ran also .-nnt.-ici your local health ilepartmeiii
                                                                        for inl'nrmation ahoui loca'l advisories. You need 10
                                                                        check loc-.-d advisories ln.-c.iuse some kinds nl' lish and
                                                                        shellfish caught in vour local  waters mav have higlwr or
                                                                        inw-h  k.wer thtiu .iVerage levels ,.1 m,-,v',,rv. Tins"
                                                                        dej-cuih. on (he levels ..riiK-rcui-y in I he iv'aier in which
                                                                        ihe  lish are e.iuehl. Those fish willl much lower  levels

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78 - EPA's Roadmap for Mercury

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                                                                                                        Endnotes - 79
Introduction
1.   "EPA Releases 12th Annual National Listing of Fish Advisories." Press release. August 24, 2004.

2.   EPA, 2005c. U.S. Environmental Protection Agency. National Listing of Fish Advisories. Fact Sheet, Sep. 2005. EPA-823-F-05-
     004. Accessible at:  http://epa.gov/waterscience/fish/advisories/fs2004.pdf.

3.   Table 1: National Air Emissions Inventory for Mercury. Source: EPA, 1999a.

4.   Figure 1: The Mercury Cycle. Adapted from EPA, 1997. Mercury Study Report to Congress. EPA-452/R-97-003, December 1997.
     Accessible at: www.epa.gov/ttn/oarpg/t3/reports/volumel.pdf.

5.   EPA, 2001a.

     NRC, 2000. National Research Council. Toxicological Effects of Methylmercury. Committee on The Toxicological Effects of
     Methylmercury, Board on Environmental Studies and Toxicology. Accessible at:
     http://books.nap.edU/books/0309071402/html/l.html.

6.   EPA, 1997. Mercury Study Reprot to Congress. EPA-452/R97-003, December 1997. Accessible at:
     www.epa.gov/ttn/oarpg/t3/reports/volumel.pdf.

7.   EPA, 1997.

8.   EPA, 1997.

9.   EPA, 2005a. Technical Support Document,  Revision of December 2000 Regulatory Finding on the Emissions of Hazardous Air
     Pollutants From Electric Utility Steam Generating Units and the Removal of Coal- and Oil-Fired Electric Utility Steam Generat-
     ing Units from the §112(c) List: Reconsideration, Oct. 21, 2005. Accessible at: www.epa.gov/ttn/atw/utility/TSC-112finaL.pdf.

10.   A Community Multiscale Air Quality (CMAQ) modeling run was performed to estimate the impact of global sources on U.S.
     deposition estimates. For this analysis, all non-U.S. mercury input species to the model were set to zero. By comparing the results
     of this analysis with the 2001 Clean Air Mercury Rule (CAMR) base case run, which included all U.S. and global mercury
     species, the percent of total mercury deposition attributable to global sources can be estimated. The model estimated that over 80
     percent of total mercury deposition in the U.S. is attributable to global sources.

     Due to the evolving nature of mercury modeling science,  such deposition estimates have associated uncertainties. For example, it
     remains difficult to distinguish between the natural emissions of mercury and the re-emission of previously deposited anthropo-
     genic mercury and there remains uncertainty in the scientific community concerning the atmospheric processes that control the
     oxidation state of atmospheric mercury. Thus, further advances in the  current understanding of mercury chemistry could
     potentially lead to changes in the modeling  parameters and assumptions governing the mercury chemistry in the models and
     therefore, changes in the estimate of the fraction deposited in the U.S. attributable to global sources.

11.   EPA, 2005a.


I. Addressing  Mercury Releases
1.   EPA, 1999a. 1999 National Emissions Inventory Documentation and Data—Final Version 3.0. Accessible at:
     www.epa.gov/ttn/chief/net/1999inventory.html.

2.   EPA, 1999a.

3.   Table 1: National Air Emissions Inventory for Mercury. Source: EPA, 1999a.

4.   President's Clear Skies Legislation of 2003.  For information,  see: www.epa.gov/air/clearskies/.

5.   EPA. Clean Air Act rules on mercury emissions. For information on EPA's activities to control power plant emissions, see:
     www.epa.gov/mercury/control_emissions/index.htm.

6.   EPA, 1999b. Residual Risk Report to Congress. EPA 453/R-99-001, March 1999. Accessible at:
     www .epa .gov/ttn/oarpg/t3/reports/risk_rep .pdf.
     For information about EPA's Residual Risk  Program, see: www.epa.gov/ttn/atw/rrisk/residriskpg.html.

7.   EPA. Nevada Mining Partnership  Program.  For information,  see: www.epa.gov/Region9/cross_pr/innovations/mining.html.

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80 - EPA's  Roadmap for Mercury
        8.   EPA, 2004a. 2003 Report on Success of Voluntary Mercury Reduction Program (VMRP) with Nevada Gold Mines, October,
            2004. Accessible at: www.epa.gov/region9/toxic/niercury/goldrnine.pdf.

        9.   64 Federal Register 38705, 7/19/99.

        10.  EPA. Area Source Standards. For information, see: ww.epa.gov/ttn/atw/urban/arearules.html.

        11.  Ecology Center, 2001. Ecology Center, Great Lakes United, and University of Tennessee  Center for Clean Products and Clean
            Technologies. Toxics in Vehicles: Mercury. Accessible at: www.cleancarcampaign.org/pdfs/toxicsinvehicles_mercury.pdf.

        12.  The estimate is based on data gathered from industry by EPA during the initial phase of EAF area source rulemaking which is still
            under development.

        13.  EPA. National Pollutant Discharge Elimination System (NPDES) Permits. For information about this program, see:
            http://cfpub.epa.gov/npdes/.

        14.  Alpers, C.N. and M.P. Hunerlach, 2000. Mercury contamination from historic gold mining in California. USGS Fact Sheet FS-
            061-00. Accessible at: http://ca.water.usgs.gov/mercury/fs06100.html.

        15.  EPA, 2005b. 2003 Toxics Release Inventory (TRI) Public Data Release eReport, May, 2005. Accessible at:
            www.epa.gov/tri/tridata/tri03/2003eReport.pdf.

        16.  EPA, 2005b.

        17.  EPA, 2001b. Water Quality Criterion for the Protection of Human Health: Methylmercury. EPA-823-R01-001. Accessible at:
            www.epa.gov/waterscience/criteria/methylmercury/.

        18.  EPA, 2001a.

        19.  40 Code of Federal Regulations 130.7.

        20.  These statistics were compiled from data received by EPA and available on its Total Maximum Daily Loads (TMDL) webpage
            accessible at: http://oaspub.epa.gov/waters/national_rept.control.

        21.  EPA, 2005c.

        22.  EPA, 2001b.

        23.  These statistics were compiled from data received by EPA and available on its TMDL webpage accessible at:
            http://oaspub.epa.gov/waters/nationaLrept.control.

        24.  40 Code of Federal Regulations 132 Table 4.

        25.  The average was developed by EPA based on effluent data reported by the EPA Region 5 states: Illinois, Indiana, Ohio, Michigan,
            Minnesota and Wisconsin. States discuss effluent data in reports on their web sites. For example:
            Michigan: www.michigan.gov/deq/0,1607,7-135-3313_3686_3728-11384-OO.html.
            Wisconsin: http://dnr.wi.gov/org/caer/cea/mercury/potw.htm.
            Minnesota: www.pca.state.mn.us/water/tmdl/tmdl-mercuryplan.html.

        26.  Cocca, P. 2001. Mercury Maps:  National Report on Human Exposure to Environmental Chemicals. Publication No. 01-0379.

        27.  Clean Water Act (Federal Water Pollution Control Act, as amended) §307(b); 33 United States Code § 1317.

        28.  LWA, 2002. Larry Walker Associates. Mercury Source Control and Pollution Prevention Evaluation, Final Report, March 2002,
            amended July 2002. Prepared for: Association of Metropolitan Sewerage Agencies. Accessible at:
            www.amsa-cleanwater.org/advocacy/mercgrant/finalreport.pdf.

        29.  San Francisco Public Utilities Commission. For information about the San Francisco Dental Mercury Reduction Program, see:
            http://sfwater.org/main.cfm/MC_ID/4/MSC_ID/85.

        30.  EPA, 2005b.

        31.  Surface impoundments include natural topographic depressions, man-made excavations and diked areas that primarily are made
            of earthen materials and which hold liquid wastes. These uncovered areas are commonly used to volatilize and/or  settle materials.
            Other surface impoundments  are surface impoundments other than those which are authorized under the Resource
            Conservation and Recovery Act (RCRA) to accept hazardous waste for disposal.

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                                                                                                      Endnotes - 81
32.  Other land disposal is the disposal of the toxic chemical to land at the facility that does not fall into one of the other on-site
     land release categories found in Section 5.5.1 through 5.5.3 of the TRI Form R. Other disposal includes such activities as
     placement in waste piles and spills or leaks. Data from Section 5.5.4 on the TRI Form R.

33.  Mercury -Containing and Rechargeable Battery Act, 42 United States Code 14301, and EPA Universal Waste Rule. For informa-
     tion,  see: www.epa.gov/epaoswer/hazwaste/id/univwast/regs.htm.

34.  EPA.  Municipal Incinerator Rules. For information about Large Municipal Waste Combustors, see:
     www.epa.gov/ttn/atw/129/mwc/rimwc.html.
     For information about Small Municipal Waste Combustors, see: www.epa.gov/ttn/atw/129/mwc/rimwc2.html.

35.  EPA.  Universal Waste Regulations. For information,  see: www.epa.gov/epaoswer/hazwaste/id/univwast/regs.htm.

36.  70 Federal Register 45508, 8/5/05.

37.   EPA.  Superfund National Priorities List. For information on NPL Site Listing Process, see:
     www.epa.gov/superfund/sites/npl/npl_hrs.htm.

3 8.  EPA.  RCRA Corrective Action Program. For information on the program, see:
     www.epa.gov/epaoswer/hazwaste/ca/backgnd.htmS5.

39.  Maine. An Act to Prevent Mercury Emissions When Recycling and Disposing of Motor Vehicles. Provision to remove mercury
     switches found at Sec. 3.38 Me.Rev.Stat.Ann.tit.  §1665-A.3. Accessible at:
     http://janus.state.me.us/legis/ros/lom/LOM120th/5Pub651-700/Pub651-700-05.htm.

40.  Ecology  Center, 2001.

41.   EPA,  2005d. Clean Air Mercury Rule (CAMR) and Clean Air Interstate Rule (CAIR). For information, see:
     www.epa.gov/air/mercuryrule/.

42.  69 Federal Register 21198, 4/20/04.

43.  68 Federal Register 70903, 12/19/03.

44.  69 Federal Register 21906, 4/22/04.

45.  Cocca, P. 2001.

     64 Federal Register 38705, 7/19/99.


II. Addressing Mercury Uses in Products and Processes
1.    Jasinski,  S.M., 1994. The Materials Flow of Mercury in the United States. U.S. Bureau of Mines, Information Circular 9412.
     Accessible at: http://pubs.usgs.gov/usbmic/ic-9412/.

2.    Figure 3: Total 2001 U.S.  Mercury Use in Products. Source:  Lawrence, Bruce, 2001. Bethlehem Apparatus Company, Inc.
     Personal communication, June 22, 2001.

3.    Lawrence, 2001 and The  Chlorine Institute, Inc., 2-006.

4.    Figure 4: U.S.  Mercury Product and Process Use Trends. Sources: For 1980 through 1997: USGS. U.S. Geological Survey.
     Minerals Yearbook: Mercury, 1994-2001. Accessible at: http://minerals.usgs.gov/minerals/pubs/commodity/mercury/. For 2001:
     Lawrence, 2001 and The  Chlorine Institute, Inc., 2006.

5.    Environment Canada and EPA, 1997. The Great Lakes Binational Toxics Strategy. Accessible at:
     www.epa.gov/glnpo/p2/bns.html.

6.    Environment Canada and EPA, 2004. Great Lakes Binational Toxics Strategy 2004 Annual Progress Report. Accessible at:
     http://binational.net/bns/2004/index.html.

7.    The Chlorine  Institute, Inc., 2006. Ninth Annual Report to EPA for the Year 2005, May 15, 2006. Accessible at:
     www.epa.gov/region5/air/mercury/9thcl2report.pdf.

8.    H2E. Hospitals for a Healthy Environment. For information, see: www.h2e-online.org/.

9.    For information about legislation to reduce mercury in the New  England states, see: IMERC. Interstate Mercury Education and
     Reduction Clearinghouse at: www.newmoa.org/newmoa/ntdocs/prevention/mercury/imerc.cfm.

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82 - EPA's Roadmap for Mercury
       10.  Conference of New England Governors and Eastern Canadian Premiers, 2002. Summary of School Mercury Programs in New
            England and Eastern Canada. August 2002. Accessible at: www.cap-cpma.ca/images/pdf/eng/10-mtf_school_survey_e.pdf.

       11.  The Chlorine Institute, Inc.,  2006.

       12.  IMERC. For information, see: www.newmoa.org/Newmoa/htdocs/prevention/mercury/imerc.cfm.

       13.  EPA. Environmentally Preferable Purchasing, Database of Environmental Information for Products and Services. For informa-
            tion, see: http://yosemitel.epa.gov/oppt/eppstand2.nsf/Pages/Homepage.htmnOpen.

       14.  EPA. Green Suppliers Network. For information, see: www.epa.gov/p2/programs/gsn.htm.

       15.  EPA. Schools Chemical Cleanout Campaign (SC3). For information, see:
            www.epa.gov/epaoswer/osw/conserve/clusters/schools/index.htm.

       16.  EPA. National Partnership for Environmental Priorities (NPEP) Program, The Mercury Challenge. For information, see:
            www.epa.gov/epaoswer/hazwaste/minimize/mercchall.htm.


       III. Managing Commodity-Grade Mercury Supplies
       1.   Lawrence, Bruce, 2002. Bethlehem Apparatus Company,  Inc. World Mercury Market(s) From the Supply Side. Presentation at
            conference: Breaking the Mercury Cycle, Boston, MA, May 1-3, 2002. Accessible at:
            www.newmoa.org/Newmoa/htdocs/prevention/mercury/breakingcycle/toc.cfm.

       2.   Maxson, PA., 2004 Mercury Flows Report: Mercury Flows in Europe and the World, The Impact of Decommissioned Chlor-
            alkali Plants. European Commission. Accessible at:
            http://europa.eu.int/comm/environment/chemicals/mercury/pdf/report.pdf.

       3.   Maxson, 2004.

       4.   The Chlorine Institute, Inc.,  2006.

       5.   69 Federal Register 23733, 4/30/04.

       6.   Quicksilver Caucus, 2003. Mercury Stewardship Storage of Mercury, October 2003. Accessible at:
            www.ecos.org/files/721_file_QSC_STOR_Oct_03.pdf

       7.   EPA, 2005f. Economic and Environmental Analysis of Technologies to Treat Mercury and Dispose in a Waste Containment
            Facility. See: www.epa.gov/ORD/NRMRL/pubs/600r05157/600r05157.pdf.

       8.   EPA. Mercury Laws and Regulations. For information on how mercury is regulated under RCRA, see:
            www.epa.gov/epaoswer/hazwaste/mercury/reg_stand.htm.


       IV. Communicating to the Public About Mercury Exposure Risks
       1.   Figure 1: The Mercury Cycle. Adapted from EPA, 1997. Mercury Study Report to Congress. EPA-452/R97-003, December 1997.
            Accessible  at: www.epa.gov/ttn/oarpg/t3/reports/volumel.pdf.

       2.   EPA and FDA, 2004. What You Need to Know About Mercury in Fish and Shellfish. EPA-823-F-04-009. Accessible at:
            www.epa.gov/waterscience/fishadvice/advice.html.

       3.   EPA, 2005c.

       4.   "EPA Releases 12th Annual National Listing of Fish Advisories." Press release. August 24, 2004.

       5.   EPA, 2002a. Task Force on Ritualistic Uses of Mercury Report, Dec. 2002. EPA-540-R01-005. Accessible at:
            www.epa.gov/superfund/action/community/mercury.pdf.

       6.   EPA. Mercury Web site. For information, see: www.epa.gov/mercury/.

       7.   Minnesota Pollution Control Agency. Mercury-Free Zone Program. For information, see:
            www.pca.state.mn.us/programs/mercury-free/.


       V. Addressing  International Mercury Sources
       1.   Figure 5: Where are Man-Made Mercury Emissions Originating? Source of figure: Pacyna, ]., S. Wilson, F. Steenhuisen and E.
            Pacyna. 2005. Spatially Distributed Inventories of Global Anthropogenic  Emissions of Mercury to the Atmosphere. Accessible at:
            (www.amap.no/Resources/HgEmissions/). Original figure presented courtesy of AMAP, Arctic Monitoring and Assessment
            Programme, Oslo, Norway.

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                                                                                                      Endnotes - 83
2.   EPA, 2005a.

3.   Figure 6: Man-Made Air Emissions of Mercury: Distribution by Region in 1990 and 2000. Source: Pacyna, J. and J. Munthe,
     2004. Summary of research projects on mercury conducted by researchers in Norway and Sweden. Presentation at Workshop on
     Mercury, Brussels, March 29-30, 2004. Accessible at: www.ivl.se/nytt/konferenser/mercury/pacyna.pdf.

4.   UNEP, 2002. United Nations Environment Programme. Global Mercury Assessment. Accessible at:
     www.chem.unep.ch/mercury/Report/GMA-report-TOC.htm.

5.   EPA estimate based on UNEP 2002.

6.   EIA, 2004. Energy Information Administration. International Energy Outlook 2004 (annual report). Report #DOE/EIA-
     0484(2004), April, 2004. Accessible at: www.eia.doe.gov/oiaf/ieo/.

7.   UNEP, 2002.

8.   Veiga, M. and R. Baker,  2004. Protocols for Environmental and Health Assessment of Mercury Released by Artisanal and Small-
     scale Gold Miners, Report to the Global Mercury Project: Removal to Barriers of Introduction to Cleaner Artisanal Gold Mining
     and Extraction Technologies, GEF/UNDP/UNIDO, Vienna, Austria, 170. Accessible at:
     www.unites.uqam.ca/gmf/intranet/gmp/files/doc/gmp/Protocols_for_Environmental% 20_Assessment_2005_08_ll.pdf.

9.   Veiga, M.M. and ].]. Hinton, 2002. Abandoned Artisanal Gold Mines in the Brazilian Amazon: A Legacy of Mercury Pollution.
     Natural Resources Forum, February, 2002.

10.   UNEP, 2002.

11.   This estimate is based on communication with The Chlorine Institute and review of the following two pamphlets: The Chlorine
     Institute, Inc., 2004b. Pamphlet 10, North American Chlor-Alkali Industry Plants and Production Data Report 2003, Updated
     June, 2004. The Chlorine Institute, Inc., 2004c. Pamphlet 16, Chlor-Alkali Plants Outside North America, Updated October
     2004.

12.   Source of 2,000 estimate is Lawrence, 2002. Source of 3,400 estimate is Maxson, 2004.

13.   Figure 7: Global Mercury Consumption, 2000. Source: Maxson, 2004.

14.   Environment Canada and EPA, 2005. Great Lakes Binational Toxics Strategy: Assessment of Level 1 Substances, Summary
     Report. Accessible at: http://binational.net/bns/2005/iindex.html.

15.   Conference of New England Governors/Eastern Canadian Premiers, 2003. Report to the New England Governors and Eastern
     Canadian Premiers on Mercury Projects, August 2003. Accessible at:
     http://cap-cpma.ca/images/pdf/eng/2003reportmercury.pdf.

16.   CEC. Commission for Environmental Cooperation. North American Regional Action Plan on Mercury. Accessible at:
     www.cec.org/programs_projects/pollutants_health/smoc/mercl34.cfm?varlan=english.

17.   UNECE, 1998. United Nations Economic Commission for Europe. Convention on Long-Range  Transboundary Air Pollution.
     Protocol on Heavy Metals. Accessible at: www.unece.org/env/lrtap/hm_hl.htm.

18.   UNEP Mercury Programme. For information, see: www.chem.unep.ch/mercury/default.htm.

19.   UNEP, 2005. Results of the Governing Council's discussions on chemicals management, including mercury programme, at its
     23rd session in February, 2005. Accessible at: www.chem.unep.ch/mercury/GC23-results.htm.

20.   UNEP Mercury Programme Partnerships. For information, see: www.chem.unep.ch/mercury/partnerships/default.htm.

21.   UNIDO. United Nations Industrial Development Organization. Global Mercury Project. For information, see:
     www.unido .org/en/doc/45 71.

22.   AMAP. Arctic Monitoring and Assessment Programme. For information, see: www.amap.no/.

23.   UNEP. Basel Convention. For information,  see: www.basel.int/index.html.


VI.  Conducting  Mercury  Research and Monitoring
1.   EPA, 2000. Mercury Research Strategy. EPA-600-R-00-073. Accessible at:
     http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=20853.

2.   EPA, 2003a. Mercury Research Multi-Year Plan. Accessible at: www.epa.gov/osp/myp/mercury.pdf.

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84 -  EPA's Roadmap for Mercury
        3.   EPA. Science To Achieve Results (STAR) Program. For information, see:
            http://cfpub.epa. gov/ncer_abstracts/index.cfm/fuseaction/recipients.display/rfa_id/109.
            http://cfpub.epa.gov/ncer_abstracts/index.cfm/fuseaction/re search. display/rpt/abs/rfa_id/2.

        4.   USGS. The Mercury Roundtable. For information, see: http://minerals.usgs.gov/mercury/roundtable.html.

        5.   EPA, 2003d. Performance and Cost of Mercury and Multipollutant Emission Control Technology Applications on Electric
            Utility Boilers; EPA/600/R-03/110; October, 2003.

            Srivastava, R.K., J.E. Staudt, and W. Jozewicz, 2004. Preliminary Estimates of Performance and Cost of Mercury Emission
            Control Technology Applications on Electric Utility Boilers: An Update. Prepared for presentation at The Combined Power
            Plant Air Pollutant Control Mega Symposium, Washington, DC, August 30-September 2, 2004.

        6.   EPA, 2005a.

        7.   EPA, 2005a.

        8.   www.epa.gov/mercury.

        9.   Revision of December 2000 Regulatory Finding on the Emissions of Hazardous Air Pollutants From Electric Utility Steam
            Generating Units and the Removal of Coal- and Oil-Fired Electric Utility Steam Generating Units from the Section 112(c) List"
            (The Section 112(n) Revision Rule) (70 FR 15994 (Mar. 29, 2005) and "Standards of Performance for New and Existing Station-
            ary Sources:  Electric Utility Steam Generating Units" ("The Clean Air  Mercury Rule" or "CAMR")  (70 FR 28606 (May  18, 2005).

        10.  Landis, M.S., R.K. Stevens, F. Shaedlich, and E.M. Presbo, 2002. Development and Characterization of an Annular Denuder
            Methodology for the Measurement of Divalent Inorganic Reactive Mercury in Ambient Air. Environmental Science Technology
            26: 3000-3009.

        11.  Bullock, R. and Brehme, K. 2002. "Atmospheric Mercury Simulation Using the CMAQ Model: Formulation, Description, and
            Analysis of Wet Deposition Results", Atmos. Envi., 36, pg. 2135-2146.

        12.  EPA, 2003d.

            Srivastava, R.K., J.E. Staudt, and W. Jozewicz, 2004.

        13.  EPA, 2005e. Control of Mercury Emissions from Coal-Fired Electric Utility Boilers: an Update, 02/18/05. Accessible at:
            www.epa.gov/ttn/atw/utility/ord_whtpaper_hgcontroltech_oar-2002-0056-6141.pdf.

        14.  Kosson, D.S., H.A. van der Sloot, F. Sanchez, F. and A.C. Garrabrants, 2002. An Integrated Framework for Evaluating Leaching
            in Waste Management and Utilization of Secondary Materials. Environmental Engineering Science 19(3): 159-204.

            Thorneloe, S.,  2003. Presentation to EPA Science Advisory Board,  Environmental Engineering Committee, Washington, D.C.,
            June 17, 2003.

            Potential for Cross-media Transfers from Management of Mercury-enriched Coal Combustion Residues. Feb. 18,  2005. Available
            throughwww.regulations.gov at EPA-HQ-OAR-2002-0056/6139.

        15.  EPA. Mercury  Continuous Emission Monitors. For information, see: www.epa.gov/etv/verifications/vcenterl-ll.html.

        16.  Wang, Q., D. Kim, D. Dionysiou, G. Sorial and D. Timberlake, 2004.  "Sources and Remediation for Mercury Contamination in
            Aquatic Sediments—A Literature Review," Environmental Pollution 131 (2004) 323-336.

            Kim, D., Q. Wang, G. Sorial, D. Dionysiou and D. Timberlake, 2004.  "A Model Approach for Evaluating Effects of Remedial
            Actions on Mercury Speciation and Transport in a Lake System," Science of the Total Environment 327 (2004) 1-15.

        17.  Randall, P.M.,  Chattopadhyay, S., and Ickes, JA, 2004. Influence of pH and Oxidation-Reduction (Eh) Potential on the
            Dissolution of Mercury-Containing Mine Wastes from the Sulfur Bank Mercury Mine, Minerals & Metallurgical  Processing
            Journal 21:93-98, May 2004.

        18.  Randall, P.M, L. Brown,  L. Deschaine, J. Dimarzio, G. Kaiser, and J. Vierow, 2004. Application of the Analytic Hierarchy
            Process to Compare Alternatives for the Long-Term Management of Surplus Mercury, Journal of Environmental Management
            71(l):35-43. Accessible at: http://dx.doi.Org/10.1016/j.jenvrmn.2004.01.004.

            Porter, S., et al., 2004. Toxic Metals in the Environment: Thermodynamic Considerations for  Possible Immobilization Strategies
            for Pb, Cd, As, and Hg, Critical Reviews in Environmental Science and Technology, 34:395-604.

            EPA, 2002b. Preliminary Analysis of Alternatives for the Long Term Management of Excess Mercury. EPA/600/R-03/048.
            Accessible at: www.epa.gov/ORD/NRMRL/Pubs/600R03048/600R03048.html.

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                                                                                                       Endnotes - 85
19.   Discussions of the fish sample data gathered by Region 8 will be included in the Human Health and Ecological Risk Assessment
     for the Cheyenne River Basin Site.

20.   MDN. Mercury Deposition Monitoring Network. NADR National Air Deposition Monitoring Program. For information see:
     http://nadp.sws.uiuc.edu/mdn/.

21.   FDA. U.S. Food and Drug Administration. Mercury in Fish: FDA Monitoring Program. For information, see:
     www.cfsan.fda.gov/  frf/seamehg2.html.

22.   EPA. National Fish Tissue Study. For information, see: www.epa.gov/waterscience/fishstudy/.

23.   EPA, 2005c.

24.   Mahaffey, K.R., 2005. Exposures to Mercury in the Americas. In: Pirrone, N. and K.R. Mahaffey, Dynamics of Mercury Pollution
     on Regional and Global Scales. Springer-Verlag, New York.

25.   CDC. National Health and Nutrition Examination Survey, (NHANES). For information, see:
     www.cdc.gov/nchs/about/major/nhanes/growthcharts/charts.htm.

26.   CDC, 2003. Mercury, PP. 17-19 in Second National Report on Human Exposure to Environmental Chemicals, January 2003.
     Accessible at: www.cdc.gov/exposurereport/2nd/.

27.   CDC, 2004. Blood Mercury Levels in Young Children and Childbearing-Aged Women-United States, 1999-2002. Morbidity
     and Mortality Weekly Report, November 5, 2004/53(43): 1018-1020. Accessible at:
     www.cdc.gov/mmwr/preview/mmwrhtml/mm5343a5.htm.

28.   NHANES 2005-2006 Ethics Review Board Protocol. CDC, National Center for Health Statistics, Division of Health and
     Nutrition Examination Survey.

29.   EPA, 2003b. America's Children and the Environment: Measures of Contaminants, Body Burden, and Illness. EPA 240-R-03-
     001, February 2003. Accessible  at: www.epa.gov/envirohealth/children/.

30.   EPA, 2003c. Draft Report on the Environment. Accessible at: www.epa.gov/indicators/roe/html/roeTOC.htm.

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