1999 PBTI Accomplishments Report

Like other environmental departments around the world, the U.S. Environmental Protection Agency (EPA) has learned, little by little over time, that the impacts of PBT contamination have not been, and could not have been, entirely addressed by single-medium approaches or by a singularly domestic approach. Addressing PBT contamination requires a perspective that cuts across environmental media and geographic boundaries. Therefore, EPA continues to stay the course announced in its November 1998 draft PBT Strategy: that of taking an increasingly holistic and integrated approach to addressing PBT contamination.

The objective of EPA's PBT effort will be accomplished using all of the tools available to the Agency -- regulatory, compliance, enforcement, research, voluntary actions, and international negotiations. The effort also stresses a preventive approach, but recognizes that in some situations, treatment and remediation will also be required.

EPA's commitment to addressing PBT contamination brings about a dual obligation: (1) to account for the many significant areas of Agency activity that are being integrated or need to be integrated, and (2) to clarify how this process of increasing integration produces better results. In numerous instances, EPA began integrating certain PBT activities several years ago. The increasingly larger scale on which this is being attempted presents a constant challenge to the Agency.

This Report summarizes, for 1999, the Agency's PBT commitment by looking at accomplishments in Science, Policy, and Actions. This report does not attempt to capture each and every accomplishment made by the Agency and its Regions with regard to PBT pollutants. Rather, it is our hope that the accomplishments that follow demonstrate that the PBT Initiative is making great strides in further integrating the Agency's efforts -- a new way of doing business.

Science

   Much of the US EPA's work is to continually evaluate emerging scientific data on changes in the environment, and analyze their implications for existing EPA policies and actions. These data show that the extent and longevity of PBT pollutants, with their corresponding impact on human and wildlife populations, makes this contamination a global environmental problem of continuing urgency.
   In 1999, Agency efforts to better integrate its PBT work were demonstrated in several areas of scientific activity. This section identifies activities throughout the Agency that promote scientific research, the development of tools to identify, detect, monitor and measure PBTs as well as opportunities to foster the exchange of emerging scientific information as it relates to PBTs.

Selecting Additional Priority PBTs. In 1999, the Agency developed an integrated approach for selecting priority PBTs for purposes of the Waste Minimization National Plan and the PBT Initiative overall. The approach reflects consistent use of scientific information and PBT evaluation criteria by all of the EPA's program offices. The results of these integrated efforts will be made public in 2000.

Mercury Research Strategy. Lead by the Office of Research and Development (ORD), EPA drafted a strategy to help guide its mercury research program for the coming five years (2000 - 2004). The Mercury Research Strategy targets four areas for attention: human health effects and exposure; ecological health effects and exposure; atmospheric, terrestrial, and aquatic transport, transformation, and fate; and risk management for combustion and non-combustion sources. The draft Mercury Research Strategy was submitted for peer review in early 2000 and is targeted for publication in the Summer of 2000. A multi-year implementation plan is scheduled for delivery in early 2001.

Risk Characterization of and Risk Communication on Environmental Change and Subsistence Foods in Alaska. Over the past few years, EPA's Office of Radiation and Indoor Air and EPA Region 10 have funded the Traditional Knowledge and Radionuclides Project, aimed at sharing Native knowledge on environmental change in Alaska. The range of contaminants began with radionuclides but broadened, at the native peoples' request, to include PBTs. During this project, EPA became receptive to an alternative way of understanding and communicating about risk. In 1999, regional meetings and meetings with western scientists were held to share Native knowledge on environmental change and to review science knowledge and priorities. These efforts resulted in a Progress Report that tells of significant changes going on in the dynamics of the Alaskan food chain. (http://shiva.iser.uaa.alaska.edu/knowledge/).

PBTI integration efforts resulted in additional funding from EPA Region 10 to the Alaskan Sea Otter and Sea Lion Commission (representing about 50 Tribes) to develop a PBT screening tool for subsistence foods. Specifically, the program is directed at developing methods for identifying abnormalities in subsistence food species and the contaminants within these species, the tissues consumed by Native populations, methods of food preparation, and those human subpopulations at greatest risk. The program will result in a resource guide to be used by the Tribes for measuring contaminants in Native foods. EPA will diffuse this knowledge on Alaskan PBT-related issues to other Tribal nations.

Monitoring/Modeling. At the close of 1999, PBTI integration efforts resulted in the Agency recognizing the need to take a more integrated approach to monitoring and modeling for PBTs. EPA foresees work in 2000 that will integrate science, policy, and activity concerns on PBT monitoring and modeling needs.

ACS PBT Symposium. PBTI integration efforts led to the Agency's instrumental role in putting together a 3-day American Chemical Society (ACS) symposium on PBTs. The purpose of this March 1999 symposium was to exchange state-of-the-art information on PBT identification research and monitoring. Symposium proceedings will be published in June 2000 by the ACS Division of Environmental Chemistry.

PBTs in Sediment Paper Developed. Work was done in 1999 to advance a "Status and Needs" paper on the use of bioaccumulation data to assess sediment quality. The paper will be available in Spring 2000.

Policy

This section identifies policies, strategies or procedures intended to guide the Agency's thinking about how PBTs should be viewed and encourages the integration of PBTs throughout new and existing programs. These efforts have been consistently Agency-wide in their undertaking.

Preventing the Introduction of New PBT Chemicals. One of the first steps the Agency took under the PBT Initiative was to exercise its authority under the Toxic Substances Control Act (TSCA) to prevent additional PBTs from entering commerce. In November 1999, EPA issued a policy statement under TSCA establishing a category for new persistent, bioaccumulative, and toxic (PBT) substances. This policy statement defined a PBT and stated that EPA will require additional testing and review of chemical substances that fall under this definition. Action taken under this policy is reported under "Actions," page 6.

The Agency also took the first steps to establish a similar policy under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) that will strengthen EPA's screening policies for pesticides submitted for registration. Screening efforts for pesticides will continue in 2000.

Setting Agency PBT Priorities. In 1999, EPA advanced work on its PBT Strategy and corresponding PBT Initiative. The Agency made a consistent effort in 1999 to tackle some of the challenging issues raised in public comment. To do so, the Agency worked across programs on priority-setting and milestones, via the EPA Office Directors' Multimedia and Pollution Prevention (M2P2) Forum, representing about 15 Agency national program offices plus Agency Regions. The M2P2 Forum's efforts will be expressed, sometime in 2000, in the revised PBT Strategy, draft national action plans, the revised mercury Action Plan, and a 5-year PBT Initiative internal planning document. EPA's Office of Solid Waste will also publish a revised multi-media list of PBT chemicals beyond those addressed in National Action Plans to encourage voluntary reductions in PBT chemical releases.

Interim PBT Goal. While the PBTI has a long-term goal of virtually eliminating PBT pollutant releases into the environment, in 1999, the Agency recognized internally that working with certain populations on contaminated food concerns is an important interim goal. The importance of this arises from the fact that even if all PBT releases ceased worldwide today, existing PBT contamination and the continuing global distribution of these contaminants would present subsistence food concerns for some time to come.

Revising the Draft Mercury Action Plan. Based on public comments received on the draft Mercury Action Plan, the Agency spent much of 1999 prioritizing its activities on mercury. This effort will be reflected in the revised Mercury Action Plan to be released in 2000.

Drafting National Action Plans. As indicated in the PBT Strategy, EPA is committed to developing national action plans for 12 priority PBTs. These substances were adopted from the Canada/US Binational Toxics Strategy.

In 1999, the Agency began work on all action plans with active participation from both industry and environmental groups. Dioxin work focused on wrapping up the Agency Dioxin Reassessment. Agency-wide PBTI chemical-specific workgroups worked on these action plans in close coordination with the parallel chemical-specific workgroups supporting U.S. and Canadian implementation of the Canada-U.S. Binational Toxics Strategy (BNS), which focuses on the same pollutants.

The preliminary stakeholder review of the initial alkyl-lead, octachlorostyrene, pesticides (aldrin/ dieldrin, DDT, mirex, toxaphene, hexachlorobenzene, and chlordane) and PCB draft plans provided valuable comments, and the Agency will again use preliminary stakeholder review in 2000 for the remaining draft action plans. The Agency plans to release all draft action plans for full public comment in 2000.

Cross-Cutting Issues from Action Plans. At the very close of 1999, EPA preliminarily flagged several issues that the Agency could consider on a cross-cutting basis, rather than action plan by action plan. These areas are: (1) looking at the collective monitoring needs for multiple PBTs, (2)communicating with subpopulations that are concerned about or need to be informed about contaminated subsistence foods, and (3) focusing on "place-based" actions. Monitoring will be discussed further below.

Aligning PBT Monitoring and Measurement Programs. As a result of PBTI integration efforts, the Agency took note at the end of 1999 of the wide perception among federal, state, and international agencies and organizations that a network of monitoring efforts on PBTs is needed, and that no single organization or agency has the funds to pay for these efforts. As a matter of policy, EPA foresees further exploration in 2000 of how the Agency might work with other governmental entities on connecting and leveraging efforts to move towards accomplishing what is needed in PBT monitoring.

Actions

This section highlights the major 1999 activities the Agency implemented to address PBTs and to reduce their production, use, and releases nationwide.

Given EPA's mission, the Agency's work tends to fall into certain categories -- activities focused on a single chemical or cluster of chemicals (chemical-based), activities focused on a geographic area (place-based), and activities focused on an industrial or commercial sector (sector-based) -- reflecting the Agency's focus on contaminants and its relationships with the public. Accordingly, this Report breaks out this discussion of actions in these three categories. Monitoring actions are addressed lastly in a separate category, since they affect and support the other three categories of work.

Chemical-Based Actions

Lower PBT Reporting Thresholds Finalized under the Toxics Release Inventory (TRI). On October 29, 1999 EPA published a final rule which added seven chemicals and two chemical compound categories to the list of chemicals subject to reporting under section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA) and section 6607 of the Pollution Prevention Act of 1990 (PPA). Additionally, TRI reporting thresholds were lowered for 18 PBT chemicals and chemical categories. The rule also included a special, lower, reporting threshold of 0.1 grams for dioxin and dioxin-like compounds, and modified certain reporting exemptions and requirements for the chemicals newly subject to the lower reporting thresholds. This rule will give the public more information about PBT releases in their communities.

Reviewing Chemical Pre-manufacturing Notices under the new TSCA PBT Policy. As of November 1999, the Agency began screening the pre-manufacturing data on new chemicals that industry submits to EPA for evidence of PBT chemical characteristics. This additional level of screening -- conducted pursuant to EPA's new Toxic Substances Control Act (TSCA) Policy Statement reported on page 5 -- resulted in EPA identifying 36 new chemicals as potential PBTs, and issuing consent orders on 13 of these substances. Permissible control actions range from banning production to prohibiting certain uses and releases, pending the development of further data.

Developing a Publicly-Available PBT Screening Tool. Since 1997, EPA has been working on a screening tool that companies could use to evaluate the PBT characteristics of chemicals they are considering making or using for one purpose or another. This amounts to EPA publicly sharing its tools for analyzing chemical properties based on chemical structure, so industry can choose chemicals at the chemical and process design stage that are more benign for the environment. During 1999, EPA beta-tested this "PBT Profiler" tool with several corporations and received very positive feedback. At the close of 1999, EPA put the beta version of the PBT Profiler on the Internet, where it can be viewed at www.epa.gov/ .

Rewarding Lower-Risk Chemical Alternatives to PBTs. In 1999, EPA presented a Presidential Green Chemistry Challenge Award to Dow AgroSciences LLC for a new natural insect control product. This award recognizes outstanding chemical technologies that incorporate more environmentally-friendly principles into chemical design, manufacture, and use. Called Spinosad, Dow's product does not leach, volatilize, bioaccumulate, or persist in the environment.

Rewarding PBT Emissions Reductions. EPA's Office of Solid Waste (OSW) and the National Pollution Prevention Roundtable (NPPR) entered into a partnership to distribute the MVP2 /PBT Cup Awards. The MVP2/PBT Cup Awards go to companies that reduce PBT releases through innovative means. Awards are judged on five broad criteria, including: innovation, measurable results, transferability, commitment, and optimization of available project resources.

Reducing Mercury Emissions in Municipal and Medical Waste. Municipal Waste Combustion (MWC) and Medical Waste Incineration (MWI) account for approximately 30% of the nation's mercury emissions into the air. In 1999, EPA established Maximum Achievable Control Technology (MACT) standards for MWC and MWI which, when fully implemented, will reduce mercury emissions by approximately 90% and will result in more than a 95% reduction in dioxin/furan emissions.

Re-evaluating RCRA Land Disposal Restrictions (LDR) for Mercury-Bearing Hazardous Wastes. Existing LDR treatment standards applicable to mercury-bearing wastes require recovery and recycling of mercury or incineration, depending on the waste stream. On May 28, 1999, EPA published an Advance Notice of Proposed Rulemaking (ANPRM) to mark the beginning of EPA's comprehensive reevaluation of these treatment standards, and to note associated issues, options, and data needs. EPA is evaluating: (1) the impacts of reducing the number of waste types to be incinerated; (2) the environmental advantages of allowing direct treatment for disposal where secondary production exceeds demand; (3) whether thermal recovery is being required for wastes where this treatment is inappropriate; (4) mercury retorting emissions; and, (5) incentives for reducing the mercury in hazardous waste. The ANPRM comment period ended in August 1999. In 2000, EPA anticipates reviewing public comment and examining treatability studies conducted by EPA and the U.S. Department of Energy.

Collecting, Labeling, and Legislating on Mercury-in-Products. Under the PBTI, EPA awarded a 1999 grant to the Northeast Solid Waste Management Officials Association (NEWMOA) to report on state efforts to collect mercury-containing products for disposal (to prevent unintentional releases), to launch or implement mercury-labeling programs, and to draft mercury-in-products legislation. EPA Region I also worked on developing case studies at federal facilities for identifying mercury containing-products.

Minimizing Open Barrel Burning to Reduce Dioxin Emissions. According to recent EPA studies, burning household trash in backyard barrels is a significant source of dioxin/furan emissions. EPA , through the PBTI, awarded a 1999 grant to the Western Lake Superior Sanitary District to work collaboratively on a regional basis to help communities reduce garbage burning and implement a campaign to reduce the practice. Upon completion, the information can be shared nationwide; Agency surveys indicate an estimated 20 million people in rural areas burn trash in their backyards. Under another EPA grant, the Oregon Department of Environmental Quality is developing and delivering to schools a curriculum on alternatives to open burning.

Collecting Pesticides through State Clean Sweep Programs. Nearly half of the states operate "Clean Sweep" programs to help farmers and, in some cases, citizens and businesses, dispose of waste pesticides. In addition, many local governments conduct household hazardous waste collection programs to facilitate the disposal of unwanted chemicals, including pesticides. Some of the PBT chemicals removed through Clean Sweep programs include pesticides like aldrin, dieldrin, DDT, and chlordane and products containing mercury.

In 1999, EPA provided incremental funding to four existing Clean Sweep programs for pilot projects to facilitate the collection of data on the quantities of specific pesticides, including Level 1 pesticides, collected. Using this information, EPA is currently preparing a report on the status and success of Clean Sweep programs nationwide and will promote these programs by publicizing their success and providing information on the many different ways to start, operate, and fund them.

Phasing Out DDT in Mexico. Transboundary air deposition of DDT in the United States and Canada coming in from Mexico has been an issue the three countries have been working to address for several years. 1999 was a milestone year, for this was when Mexico stopped using DDT altogether, reserving only the limited right to use DDT in severe malaria control emergencies. The efforts of the three countries, through the North American Commission on Environmental Cooperation, appear to be now evolving towards developing sustainable malaria control practices for Mexico.

Reducing PBT Waste Generation. EPA awarded several 1999 grants to research and promote PBT waste generation reductions. North Carolina, for example, is focusing on the identification of PBT generators and training state hazardous waste program staff on PBT reduction techniques and OSW's Waste Minimization Prioritization Tool (WMPT).

Sector-Based Actions

Partnering with Hospitals. On June 24, 1998, the American Hospital Association (AHA) -- a national organization that represents and serves nearly 5,000 hospitals, health care networks, and their patients and communities - and the EPA, in consultation with Healthcare Without Harm, a group representing 80 non-governmental organizations, reached a landmark agreement with the goal of virtually eliminating mercury-containing waste from hospital waste streams by the year 2005. In 1999, EPA launched a formal program founded on this agreement and facilitated by the PBTI called Hospitals for a Healthy Environment (H2E). In March 1999, the H2E program received Vice President Gore's Hammer Award for excellence in government innovation. This partnership expects to complete the drafting of educational material by June 2000 and begin implementing educational courses on waste reduction later in the year.

Air Data Collection/Analysis at Electric Utilities. In 1999, EPA began collecting information to better understand mercury emissions from coal-fired, electric power plants. This collection effort includes data from coal sampling as well as stack tests. EPA intends to complete the information collection by mid-2000, and will begin analysis to determine the amount and species of mercury emissions from these plants.

Phasing Down PCBs in Great Lakes Utilities. In 1999, representatives of EPA Region 5, and EPA's Office of Enforcement and Compliance Assurance met with the region's major utilities to discuss the PCB Phasedown Program. The Phasedown Program, currently a pilot project with utilities in Region 5, is designed to encourage the reduction of PCBs by providing an incentive for facilities to commit to removing their remaining PCB equipment. Incentives include public recognition and consideration of the PCB removal efforts during settlement of enforcement actions. As this program is being finalized, utilities in the region continue to make efforts to phasedown PCB transformers and capacitors.

Partnering with Industrial Boilers. EPA issued a grant under the PBTI to the Delta Institute to develop a partnership with the Council of Industrial Boiler Owners and then work with one or several of the industries represented to develop ways to increase energy efficiency and reduce toxic chemical use and discharge. This effort is being done in collaboration with the Department of Energy. The critical substances of concern that are targeted with this project include mercury, cadmium, PCBs, dioxins/furans and hexachlorobenzene.

Partnering with Steel Facilities. In 1998, under the Binational Toxics Strategy (BNS), three Indiana steel facilities -- Bethlehem Steel Burns Harbor, Ispat Inland Inc. Indiana Harbor Works, and U.S. Steel Gary Works -- signed a Memorandum of Understanding (MOU) with EPA to reduce the use of mercury at their facilities through pollution prevention. The PBTI was instrumental in implementing this MOU. In 1999, as a part of this agreement, the companies developed an inventory of mercury sources and are now working on a mercury reduction strategy. The expectation is that lessons learned here can be shared with others in the industry.

Working with the Chlor-alkali Sector. In 1998, the Agency received a commitment from the Chlor-alkali sector of the chemical industry to reduce mercury use by 50 percent by 2005.

On August 31, 1999, EPA's Region 5 met with representatives of industry, government and academia to plan a Mercury Emissions Study at the Olin Chlor-alkali Facility in Augusta, Georgia. The results will be used to identify methods for reducing mercury emissions at other chlor-alkali facilities, as well.

Significant Reductions Achieved Through Compliance/Enforcement Efforts. Continuing Federal compliance/enforcement efforts for major regulations addressing PBTs along with on-going support to States has yielded PBT reductions through increased compliance and deterrence of violations. Case settlements and Supplemental Environmental Projects (SEPs) in 1999 have also resulted in additional reductions of: 129 million pounds of PCB waste; 573 million pounds of soil contaminated with dioxin/lead/arsenic; and 4 million pounds of polycyclic aromatic hydrocarbons (PAH's).

Awarding Grants to Assist Health Care Facilities. Through an EPA Environmental Justice for Pollution Prevention grant the St. Clair County Health Department will promote pollution prevention in health care facilities in the East St. Louis area and surrounding communities, with an emphasis on eliminating mercury-containing products and waste streams. The St. Clair County Health Department will establish a model facility, disseminate information to promote mercury reduction, assist facilities with mercury reductions and pollution prevention practices, develop case studies of successful programs at healthcare facilities, and encourage the development of pollution prevention and waste minimization plans.

Many states, including New Hampshire, Massachusetts, Vermont and California, have also been focusing on reducing mercury and other toxics in hospital waste streams with EPA funding. Specific activities conducted under these grants include on-site assessments of participating hospitals; developing and implementing training curricula, checklists, case studies, and outreach materials for hospital staff.

Place-Based Actions

Mixing Zone Guidance for the Great Lakes. On, September 24, 1999, EPA Administrator Carol Browner proposed to phase-out the discharges of "bioaccumulative chemicals of concern" (BCCs, another term for PBTs) into "mixing zones"(areas of the Great Lakes where discharges of toxic chemicals are allowed to mix with receiving waters and dilute.) This proposal would prohibit new discharges of BCCs, including mercury, PCBs, dioxin, chlordane, DDT and mirex, into mixing zones in the Great Lakes Basin and would phase out the use of existing mixing zones for BCCs in the Great Lakes Basin over 10 years.

Indiana, Michigan, Minnesota, and Wisconsin have already eliminated mixing zones for PBTs in the Great Lakes Basin. This announcement ensures that mixing zones for BCCs in the Great Lakes Basin are also prohibited in Illinois, New York, Ohio and Pennsylvania. EPA anticipates that the proposal will reduce mercury from direct water discharges (like outfall pipes) into the Great Lakes by up to 90 percent.

Monitoring

Assisting in the Development of Surveys. EPA contributes funds to Health and Human Services (HHS) to develop National Health and Nutrition Examination Surveys (NHANES) to analyze the U.S. population for various PBTs. Recently EPA succeeded in having mercury added to the NHANES parameter list.

Monitoring Fetal Cord Blood. 1999 was the first year of a three year testing program in which the PBTI, through the Office of International Activities has funded the National Institutes of Health (NIH) to monitor PBTs in fetal cord blood of Alaskan native groups.

Conducting a Fish Tissue Survey. In 1999, EPA also began a three-year National Study of Chemical Residues in Fish with funding from the PBTI. The study, organized and managed by the Office of Water, will provide information on fish tissue levels of toxic bioaccumulative contaminants in lakes throughout the U.S. The Agency consulted with states, tribes, other Federal agencies and the PBTI Plenary Group to design the survey and to select the PBT chemicals for which to test. By providing for collection of samples through grants, this study will also enhance state and tribal data monitoring capabilities. EPA will make data available to states, tribes, and Agency programs to help them evaluate, prioritize, and target pollution prevention, abatement, remediation and control efforts. The data will highlight specific PBTs that need to be addressed and the locations of contamination problems.

Supporting Monitoring Efforts in Maine.  In 1999, EPA's Office of Enforcement and Compliance Assurance funded a grant under the PBTI to the Maine Department of Environmental Protection to reduce PBTs in the state. This project involves: multimedia data collection and analysis in partnership with the University of Maine to benchmark monitoring efforts; sector-based analysis of mercury sources; targeted on-site multimedia compliance and pollution-prevention efforts based on information collected; and appropriate enforcement responses to bring entities into compliance when assistance efforts are inappropriate.

Florida Everglades Long-Range Transport. An additional mercury monitoring advance is being made through OIA and ORD collaboration in the Florida Everglades, where OIA's contribution of mercury speciation equipment and trace metal analysis will determine what amount of mercury may be coming from abroad rather than from local sources. Aircraft flight monitoring, utilizing NOAA aircraft, augmented by ground sampling, will provide the first real data to identify amount and direction of sources of long-range transport of mercury in South Florida. At present there is controversy about whether local sources predominate, or whether large amounts of mercury may be carried via trade winds from Africa and Europe. Some estimate that up to 70% may come from abroad.

Barrow, Alaska Long-Range Transport. In September 1999, with funding from the PBTI, EPA's Office of International Activities (OIA) and Office of Research and Development (ORD) began to test the first speciated mercury analytical equipment at the NOAA/ORD Point Barrow, Alaska atmospheric mercury monitoring station. Speciated mercury analysis will enable EPA and its partners, National Oceanic and Atmospheric Administration (NOAA), Department of Energy (DOE), and Canada, to better understand the unique behavior and transport of atmospheric mercury under Arctic conditions. EPA will obtain data which will help determine potential for long-range transport of mercury at that location from, for example, Asia or Russia.

Great Lakes Long-Range Transport. Also in 1999, an important international monitoring dimension was added to a newly selected "master" mercury monitoring site in the Ohio River Valley within Region 5. This will be a dedicated long-term site dedicated to better understanding the effect of coal combustion on mercury deposition. OIA's contribution of speciation equipment and the data it provides will, through modeling, lessen the uncertainty about local, regional and global impacts. Long-range transport between the U.S. and Canada in particular will be evaluated. Also, the speciation measurements will help determine effectiveness of various mercury control technologies being tested nearby at a coal-fired facility.

Developing a NARAP for Environmental Monitoring and Assessment. Pursuant to a Commission on Environmental Cooperation (CEC) council resolution in June 1999, a North American Regional Action Plan (NARAP) on environmental monitoring and assessment for priority chemicals is being developed. EPA's interest in the NARAP's progress stems from the fact that it will likely focus on identifying a network of index sites, with an emphasis on atmospheric deposition, fate, transport and effects in receiving ecosystems, and addressing the human health dimension of exposure to chemicals.