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November 20, 1998

EPA Releases Draft Strategy for Persistent, Bioaccumulative, and Toxic Pollutants (PBTs)

On Monday, November 16 EPA released its draft Multimedia Strategy for Priority PBT Pollutants and corresponding draft EPA Action Plan for Mercury. The strategy will focus on so-called "priority" PBTs, which are toxic, long-lasting chemicals that can build up in the food chain to levels of concern for humans and wildlife. These pollutants travel long distances, transfer effectively among air, water, and land, and persist over multiple generations. The priority PBTs include: aldrin/dieldrin, benzo-(a)pyrene, chlordane, DDT, hexachlorobenzene, alkyl-lead, mercury, mirex, octachlorostyrene, polychlorinated biphenyls (PCBs), dioxins and furans, and toxaphene.

EPA has developed this draft national strategy as part of its commitments under the 1997 Canada-U.S. Binational Toxics Strategy, the North American Agreement on Environmental Cooperation, and the Administration’s Clean Water Action Plan. The purpose of the strategy is to combat the remaining challenges in addressing priority PBTs. The draft has been designed with the intent of unifying currently separate regulatory activities in order to prevent unintended transfers between different environmental media (air, water, or land). A primary function of the strategy will be to establish and implement national action plans which will be appended to the strategy as they are developed. The release of the draft strategy was accompanied by the first draft national action plan for mercury.

The Agency specified several near-term actions which are expected to result from the draft strategy. These include: 1) preventing the introduction of new PBTs into commerce that may pose an unreasonable risk to human health and the environment; 2) encouraging voluntary reductions of priority PBTs in hazardous waste; 3) giving the public information on mercury emissions from utilities; 4) increasing the public’s right-to-know about local sources of PBT emissions through the Toxic Release Inventory (TRI) program; and 5) evaluating fish in U.S. water bodies for PBT contamination.

AMSA’s Mercury Working Group to Review Draft Strategy and Mercury Action Plan

AMSA’s Mercury Working Group plans to review the draft documents for any anticipated issues and concerns for POTWs. Comments are due to EPA by February 16, 1999. The Working Group has been tracking related developments in order to assess and respond to anticipated future effluent limitations for mercury. The Working Group is currently compiling low level mercury data solicited from the membership to identify the range of mercury concentrations from POTWs and collecting information characterizing the sources of influent mercury at POTWs (See upcoming September/November Regulatory Update). Copies of the draft PBT strategy and mercury action plan can be downloaded from the EPA Home Page at http://www.epa.gov/pbt/. Please call Mark Hoeke (link to mhoeke@amsa-cleanwater.org), AMSA at 202/833-9106 for more information.

AMSA Urges EPA to Modify Upcoming POTW MACT Standards

This week AMSA forwarded copies of an issue paper on the use of WATER8 to predict hazardous air pollutant (HAP) emissions from POTWs, and a report supporting the use of direct source test methodology for inclusion in the anticipated draft maximum available control technology (MACT) standards for POTWs to EPA’s Office of Air & Radiation. The AMSA letter recommends that EPA allow the use of Toxchem+ and BASTE estimation models and allow direct source testing in the standard as a final determinant as to whether a POTW is a major source of HAPs. The proposed MACT is expected to be published in the Federal Register before the end of the year.