EPA Region 10 Mercury Strategy Framework - Environmental ...

EPA 910-R-08-003 | December 2008EPA Region 10Mercury Strategy FrameworkOffice of Water and Office of Environmental AssessmentUnited States Environmental Protection Agency, Region 10

EPA Region 10Mercury Strategy FrameworkContentsIntroduction ...................................................................................................................... 1Goal and Objectives ......................................................................................................... 3Mercury Strategy Activities ............................................................................................ 41. Provide Monitoring Support ........................................................................... 42. Assess Factors Controlling Mercury Methylation.......................................... 53. Conduct Mercury Deposition Modeling ......................................................... 74. Identify / Inventory Mercury Sources ............................................................. 85. Facilitate Mercury Collection and Disposal Programs ................................. 96. Address Unregulated Atmospheric Sources in Region 10............................ 107. Implement a Tribal Outreach Strategy ......................................................... 128. Establish a Technical Exchange Forum ....................................................... 13Implementation Plan for each activity (to be appended when complete)Photo Credits:Cover:Page 3:Page 4:Page 5:Page 6:© 2008 Theodore Graywww.periodictable.comLeigh Woodruff, USEPAMike Abbott, Idaho National LaboratoryMatthew LaCroix, USEPAMatthew LaCroix, USEPAPage 8: Idaho State Historical Society. 81-49-1.Delamar mine, Owyhee, Mines. Circa 1900.Page 9:Page 10Page 11:Page 12:Kathy Parker, USEPA; Yakima HeraldRepublic, 5-18-07Van Housman, USEPALeigh Woodruff, USEPAMike Abbott, Idaho National Laboratory

EPA Region 10Mercury Strategy FrameworkIntroductionMercury is a metal that is found in the environment inseveral forms, all of which are toxic. It enters theenvironment as a result of natural processes (e.g. volcaniceruptions) and human activities such as combustion of fossilfuels; especially coal, and mining.Mercury is also very mobile in the environment, and can beconverted to other forms. Of particular concern is mercury’sconversion by bacteria to methyl mercury, which is highlytoxic and can be concentrated (bioaccumulated) inindividual organisms. Methyl mercury can also biomagnifyup the food chain, and reach high concentrations in toppredators. As a result, the most widespread humanexposure to mercury is through the consumption ofcontaminated fish.In 2006, EPA published the National Mercury Roadmapwhich lays out EPA’s national strategy for addressingmercury problems. It identified six major areas of focus tocharacterize and control mercury sources and to provideoutreach and education for the public.In 2007, EPA Region 10 established a Strategic Plan for theRegion to guide our work from 2007 - 2011. Included inthe plan’s Strategic Endeavors was a goal to addressmercury problems which have become more widelyrecognized within the Region. In order to achieve this goal,Region 10 established a Regional Mercury Workgroupwhich was tasked with developing a regional mercurystrategy (Strategy).Over a one year period the multi-program workgroupdeveloped a draft strategy bearing in mind that fewadditional resources would be available. Drafts of thestrategy were reviewed within EPA both in Region 10 andnationally, and external comments were sought on twooccasions. A number of external entities provided inputwhich improved the draft Strategy, including the U.S.Geological Survey, National Parks Service, Idaho NationalLaboratory, Shoshone-Bannock Tribe, Nez Perce Tribe, Pt.Gamble S’Klallam Tribe, and the States of Alaska, Oregon,Nevada and Washington.The purpose of the Strategy is to reduce human exposure tomercury. Although we acknowledge the ecological impactsof mercury, they are not the immediate driver of theStrategy. We expect that efforts to characterize mercurysources, fate and transport processes, and ultimately toreduce mercury levels, will be beneficial to minimizingecological impacts as well as reducing human health risk.As the Strategy is implemented and updated over time, weexpect that more information and direction regardingecological impacts will be incorporated.While Region 10 is currently involved in many ongoingactivities to address mercury contamination, the major focusof this Strategy is to identify areas where new or greaterEPA emphasis will increase our understanding and controlof mercury problems in the Region.The Strategy identifies eight key activities for Regionalfocus, with preliminary suggestions for specific work.More detailed workplans for each of these activities will bedeveloped by the appropriate programs, and will becomeadditions to this document. Available resources will be alimiting factor in implementing all activities. At present, nonew funds or other resources are available for Strategyimplementation.Implementation of this Strategy is expected to begin in theJanuary of 2009. In general the intent is that this version ofthe Strategy will provide direction for the next 2-3 years. Itis expected that our knowledge of issues will advancesignificantly during this timeframe such that additionalwork and refinements to the Strategy will be needed overtime. The Strategy is expected to be revised in the future toaccommodate new information.As noted above, the Strategy was developed with invaluableinput from many individuals across the Northwest andAlaska. The input we received helped set the direction andspecific role for EPA in the activities. We invite theparticipation of our sister federal agencies, state partners,and tribal governments and others to join together with EPAto achieve the ambitious outcomes that we have framed inthis Strategy. Without collaboration in this effort, EPAalone will not succeed.Mercury Strategy Framework - Page 1

EPA Region 10Mercury Strategy FrameworkGoal and ObjectivesGoal: Reduce human exposure to mercuryConsumption of contaminated fish is by far the most widespread source of human exposure to mercury. By reducingmercury levels in fish, we address the most significant human exposure, and also likely reduce the impacts to other aquaticand terrestrial receptors such as aquatic birds, mammals, and insect-eating songbirds. A less widespread but serious threatto human health is the continued occurrence of localized spills of elemental mercury in schools and homes. Additionaleffort is needed to raise awareness of elemental mercury risks, due to their public health significance and cost of cleanup.Objectives:• Characterize mercury levels in fish, water and sedimentin Region 10.Determining current mercury levels in fish across theregion is a key first step to defining the extent of theproblem and current exposure, and enabling states andtribes to establish health advisories, where needed. Inaddition, assessing the extent of mercury in water andsediment will assist in further defining the sources ofmercury, and helping better understand how mercury istransported and chemically transformed in theenvironment.• Conduct public education/outreach.Region 10 will support state, tribal and national efforts toheighten awareness of mercury issues, such as via healthadvisories and pollution prevention efforts. Whereappropriate, Region 10 will take the lead in publiceducation/outreach efforts.• Characterize local mercury sources that impactRegion 10.Region 10 will continue to support efforts to characterizesources in and near R10 which impact regionalwaterbodies. Efforts toward this work are underway, forexample, with the Columbia River Toxics Reductioneffort and the south Idaho atmospheric source attributionRegional Applied Research Endeavor (RARE) project.Additional work is needed to better characterize themagnitude and extent of atmospheric deposition,particularly from regional sources, and to map otherknown sources of mercury (Mining, RCRA andCERCLA sites, NPDES outfalls, air emissions, and nonpointsources) in relation to fish tissue levels.• Investigate key mercury fate and transport mechanisms.Region 10 will support efforts to better understand howmercury is transported and chemically transformed in theenvironment. In particular, characterizing key factorsdriving mercury’s conversion to methyl mercury, andinvestigating the transport of deposited mercury withinwatersheds, are two areas of immediate focus. The fateand transport of mercury may also be influenced byglobal climate change, but evaluating climate influencesis beyond this initial phase of the Strategy.• Take actions to control Regional sources of mercury.Region 10 will assist states and tribes in their efforts tocontrol regional sources of mercury under existingauthorities including the Clean Air Act, Clean Water Act,CERCLA, RCRA, and assist in developing nonregulatoryapproaches where appropriate.Mercury Strategy Framework - Page 3

EPA Region 10Mercury Strategy FrameworkMercury Strategy ActivitiesSpecific activities that Region 10 will undertake over the next two years are listed below. More detailed description ofactions under each Activity, and of EPA’s role, will be included in workplans which are anticipated to be developed byJanuary 2009, and appended to this Strategy.1. Provide Monitoring SupportMercury contamination affects multiple media. As a result,mercury monitoring of fish, air, water, and sediment isneeded to characterize the current extent of contamination,assess sources, and understand environmental fate andtransport processes.Monitoring is currently being conducted by various stateand federal agencies, and to a lesser extent tribes, nongovernmentorganizations (NGOs) and universityresearchers.An opportunity exists for Region 10 to participate in theplanning process, and work with this group to identify ameans to incorporate Regional monitoring efforts in thenational plan and database.Current examples of monitoring support include fish tissuestudies in the mid-Columbia River, Southwest Oregon, FortHall Reservation, and Puget Sound, an Idaho screeningproject, and a human biomonitoring project in Alaska.Region 10 has also supported air monitoring studies inSouth Idaho via RARE funds and the EPA Las VegasSuperfund Technical Support Center.EPA role:A number of external commenters on early versions of thisStrategy suggested that EPA provide a greater role insupporting monitoring projects, such as fish tissuemonitoring, air monitoring, evaluating methylation factors,and human biomonitoring.On a larger scale, a national interagency workgroup (USGS,EPA, NOAA, FWS, NPS) is in the process of developing anational mercury monitoring network for sediment, water,air, and fish. Congressional funding has been sought, butnot secured to date. Nonetheless, the workgroup isproceeding to develop a location-specific monitoring plan.• Solicit additional funding to:– conduct characterization and sourceidentification studies,– evaluate historical sources and trends, e.g. viasediment coring,– verify atmospheric model predictions via airmonitoring downwind of mercury sources,– continue Regional air monitoring to evaluatetrends over time.• In collaboration with USGS, provide guidelines tostates, tribes, and others for conducting methylationmonitoring studies.• Develop capacity for methyl mercury analysis atEPA’s Regional Lab.• Assist in local and national sampling design(logistical support, technical assistance, etc.) andcoordination with Region 10 states and tribes.• Collaborate with states, tribes and CDC in supportof human biomonitoring.• Provide additional equipment (e.g. Ohio Lumexmercury vapor analyzer) to loan to states and tribesfor fish, air and soil screening.Mercury Strategy Framework - Page 4

EPA Region 102. Assess Factors ControllingMercury MethylationMercury is usually released into the environment in aninorganic form, which is generally considered to have lowtoxicity if ingested. Approximately ninety percent of themercury found in fish tissue is methyl mercury, which istoxic when ingested. For mercury to be assimilated into thefood chain, it must first be converted into the organic methylform, generally through the action of sulfate reducingbacteria (SRB).USGS is the leader in research on methylation in the EasternUnited States (US), where it was noted that some waters haddisproportionately high fish tissue mercury relative to theirproximity to known mercury sources. After 15 years ofintensive study, factors responsible for these highconcentrations are well enough understood in the East thatthey can be predicted from data on the pH, sulfate levelsand dissolved organic carbon characteristic of thewaterbody.Conditions in the West differ substantially enough from theEast that research done to date on mercury methylation cannot be reliably applied to predict methylmercury abundanceand distributions in Region 10.For example:Mercury Strategy Framework• There are a considerable number of reservoirs in theWest – drying and rewetting of sediment has beendemonstrated to increase methylation rates, resulting inmethylmercury concentration spikes in water, sedimentand food webs.• Sulfate levels are a major factor influencing mercurymethylation. Low sulfate abundance in the East cansometimes limit methylation, and in general there aregreater amounts of sulfate in soils of the West. Howeverthe role sulfate plays in methylation in Region 10 isunclear and more data is needed in order to informresource managers.• Waters in the West generally have higher pH than Easternwaters and low pH tends to accelerate methylation• Selenium has a complex, multi-modal affect on mercury.At the right levels, selenium can effectively “tie up”mercury and render it unavailable for methylation. Onthe other hand, selenium itself is toxic at elevated levelsso attributing toxicological effects to a single co-factorcan be difficult where both selenium and mercury vary inspace. In general, low levels of native selenium in theEast have not stimulated much research in the past.However, the generally much higher levels in the Westwarrant more attention.• Conditions in Alaska may be substantially different thanin the rest of the Region and the U.S., given the abundantwetlands and extreme northern latitudes. In addition,some parts of Alaska contain many metal deposits,including mercury mines, therefore geologic sources mayplay an important role in the occurrence and distributionof mercury in local ecosystems.Understanding methylation factors that are important in theRegion will provide more information on alternative meansto reduce fish tissue levels in waters where the primarysources of mercury input are not immediately controllable,such as global mercury deposition or historic mining.Region 10 efforts to evaluate methylation will need to becoordinated closely with activities by other agencies. USGSis beginning to conduct research in the West under theirown initiative, although their limited budget has slowed thepace of this work. In addition, as mentioned above underthe Monitoring Support activity, several Federal agenciesare proceeding to develop a national monitoring planhoping that funds will be available in the future.Mercury Strategy Framework - Page 5

EPA Region 10Mercury Strategy FrameworkEPA role:To continue to communicate and collaborate onmethylation issues by supporting, leveraging andbuilding upon existing USGS efforts.Examples of the power of maintaining a frameworkfor communication with USGS and other agenciesdoing methyl mercury research include:• Participation in EPA’s Columbia River ToxicsWorkgroup helped USGS gain support within theiragency to win funding for a major sampling projectin the Columbia River.• USGS collaborated with EPA’s National Lakes FishTissue Study (http://www.epa.gov/waterscience/fish/study/) last year, analyzing fish tissue formercury. However, they could only participate intwo states due to time constraints.Additional activities could include:• Investigate adding methylmercury analysis to theRegion 10 Laboratory to allow more local study ofmethylation potential.• Work collaboratively with USGS to develop a“Methylation Evaluation Guide” that could be usedby states, tribes, and other federal agencies andentities to assist in characterizing methylationpotential of waterbodies throughout the West.• Assist Region 10 states and tribes in designing andconducting watershed-specific methylation studies,and/or work collaboratively with USGS and otherEPA Regions on larger scale methylation pilotstudies in the West (e.g. multi-region RAREproposals; link to national monitoring work, etc.)Mercury Strategy Framework - Page 6

EPA Region 103. Conduct Mercury Deposition ModelingAtmospheric deposition of mercury may be the largestsource of mercury for many watersheds throughoutRegion 10. Understanding the relative contribution ofmercury from the atmosphere, and what the mainatmospheric sources are is important when trying tocontrol mercury in water and fish.Deposition from global sources may be very significant, butbeyond our ability to control. On the other hand, largeemitters in Region 10 may have a very significant effect onlocal deposition, and consequently on concentrations inlocal water and fish.Nationally, the EPA Office of Water has developed amercury deposition model (REMSAD) and a GIS tool(Aggregator) to summarize atmospheric mercury depositionwithin watersheds to help determine the relativecontribution of global vs. regional sources. These tools willsoon be available for states, tribes, and EPA Regions. Theirpurpose is to apportion atmospheric sources of mercury at awatershed scale, primarily for purposes of developingmercury Total Maximum Daily Loads (TMDLs).Mercury Strategy FrameworkEPA role:To use these or more refined models to evaluate sitespecific mercury deposition issues, and provideassistance to states and tribes in using these tools.Different levels of effort ranging from ~ 0.05 to 0.5FTE are described below.1. Basic level of effort: Transfer ArcGIS Aggregatorsource apportionment technology to EPA Region10, including training of GIS staff. Assist states andtribes in using results for TMDLs and air controlstrategies.2. More extensive effort: Above, plus transferREMSAD Hg modeling system to EPA Region 10,and train modeling staff.• Region 10 modeling staff will work with theREMSAD contractor to transfer modelingsystem to EPA computers. These modelingsystems are highly complex and requiresignificant effort to install and operate.• Adjust emissions inputs as needed based on:(a) mitigation scenarios and/or(b) new emissions information and re-runREMSAD.• Pass on new REMSAD results to GIS staff forprocessing with Aggregator tool.3. Highest level of effort: Same level of effort asabove, plus perform additional modeling at a finerhorizontal resolution. Pass on new REMSADresults to GIS staff for processing with Aggregatortool and compare results to coarser resolutionresults.REMSAD model of mercury deposition in Washington, Idaho and Oregon.Mercury Strategy Framework - Page 7

EPA Region 104. Identify / Inventory Mercury SourcesThe relative contribution of Regional sources of mercuryremains unknown. It is crucial to know the magnitude ofdifferent sources and their impact on specific locations inorder to make sure that our work focuses on efforts thathave a high likelihood of success in reducing mercurycontamination.Some EPA programs have or collect information on mercurythat can be used to evaluate potential sources. Theseprograms include: RCRA, CERCLA, NPDES, Air, Miningand TRI. This information is currently scattered among thevarious programs and their separate databases, which makesit difficult to compare potential sources.For example:• Individual project managers in RCRA and Superfundknow whether their specific cleanup projects includemercury as an important contaminant of concern, but wedo not have any way to know the cumulative impact ofsuch sites compared to other sources and pathways suchas air emissions and deposition, sediment erosion andrunoff, or direct discharges to water.• Mercury may be discharged in wastewater from mining,municipal treatment plants, and other facilities underNPDES permits. Although some dischargers monitor formercury, many do not. Even those that do monitor mayhave high detection limits, which do not yield usefuldata.• TRI reports and Air program databases provideinformation on mercury emissions and can be used toidentify sources.Collecting and collating this information from diverseRegional sources will highlight the extent of our knowledgeand of our data gaps related to the relative contribution ofRegional-scale mercury sources.Mercury Strategy FrameworkEPA role:• Solicit and compile information from the Superfundand RCRA programs to describe the scope ofmercury cleanup work in the Region.• The NPDES permits and/or compliance units willprovide information on concentrations of mercuryin permitted outfalls.• TRI data will be reviewed to provide information ofmercury releases to air, land, and water.• EPA’s mining team is beginning an effort tocollaborate with federal land management agencies(USFS and BLM) and Region 10 states and tribesto inventory and prioritize abandoned mines in eachstate or reservation.• All of this information would be compiled into onerepository.GIS layers for fish tissue data will be needed tocompare to potential sources. This may be done inhouseeither by Office of Environmental Assessmentor Office of Research and Development, or under anEPA contract. It may also be supported at the state ortribal level by grant or contract funding; Idaho isalready contemplating a similar project.These are all expected to be relatively straightforwardtasks that would not require a significant investment interms of FTE.Another important part of this work is to conduct statisticalanalysis of existing fish tissue data from waters downstreamof potential sources to determine whether mercuryconcentrations in fish are elevated. Locations where there islittle or no fish tissue data downstream of known sourceareas would also be identified in order to target future fishtissue monitoring.Mercury Strategy Framework - Page 8

EPA Region 105. Facilitate Mercury Collection andDisposal ProgramsInformation available to the general public on properdisposal of mercury and mercury-containing productsvaries across the Region 10 states and tribes. In someareas, citizens can learn how to turn in elemental mercuryor have it collected by a contractor. In others, there maybe almost no information available. There may beinformation on recycling everyday items like compactfluorescent light bulbs, but not other products.Each year, the emergency response unit in Region 10’sOffice of Environmental Cleanup responds to one or moreelemental mercury releases, often in schools or households.These cleanups usually cost EPA between $10,000 and$60,000 to complete. One recent example cost more than$300,000. That spill also resulted in serious healthproblems for a young man. The source of mercury in theseevents may be unknown, or from stored mercury in a schoollab, old shed, barn or garage. Given that these eventscontinue to occur with some frequency, it seems reasonableto assume that there is much more elemental mercury justwaiting to be “discovered.” People may even know it isthere, but not be able to figure out how to properly disposeof it.There appears to be a real need to establish local disposaland awareness programs so the public at large has an easyway to responsibly dispose of excess mercury and mercurycontainingproducts. Greater awareness will result inavoiding costly cleanup efforts by EPA and others.Mercury Strategy FrameworkEPA role:EPA will work with states, tribes, and otherjurisdictions to assess existing and needed disposaland awareness programs.• Where disposal options are scarce, we willinvestigate what it would take to develop or supportnew programs.• Where public awareness is low, we will investigateoptions to communicate correct procedures to thepublic. Based on the frequency with whichcleanups have been associated with schools andgold miners, it may be particularly important tocommunicate with those interest groups.Region 10 will work with others who have completedpieces of the communication component. Our rolewill be to investigate and document those effortsbefore determining what new work is needed. Forexample, some educational materials for schools mayalready exist (Region 7 has already developed anextensive amount of information targeted towardsschools). In addition, the Washington Department ofEcology and Department of Health have alreadybegun working with gold miners to collect mercury.Mercury Strategy Framework - Page 9

EPA Region 106. Address Unregulated Atmospheric Sourcesin Region 10While there are fewer large sources of atmosphericmercury emissions in the Northwest than on the EastCoast, several large sources exist and could have asignificant local impact. Mercury emissions from most ofthese facilities are currently unregulated, and strategiesare needed to address these sources.For a variety of reasons, the most significant atmosphericsources of mercury in Region 10 are currently unregulated.The largest emitters in Region 10 include Ash GroveCement in Durkee, Oregon (approx. 2,500 lbs/year),Monsanto’s P4 plant in Soda Springs, Idaho (approx. 900lbs/year), TransAlta Power Plant in Centralia, Washington(approx. 530 lbs/year), Potlatch in Lewiston, Idaho(approx. 500 lbs/year), and the PGE Power Plant inBoardman, Oregon (approx. 120 lbs/year). With theexception of the newly adopted Oregon rules for the PGEBoardman plant, none of these facilities have applicable airregulations to control mercury, such as National EmissionStandards for Hazardous Air Pollutants (NESHAP). Somesources simply do not yet have federal or state standards;for others, federal standards have been vacated as a result ofcourt challenges.Mercury Strategy FrameworkThe Clean Air Mercury Rule (CAMR), which regulatedemissions from coal fired power utilities, has been vacatedby the DC Circuit Court and is being appealed by EPA.Until the appeal is resolved, there will be no effectivefederal regulations for mercury from coal-fired powerplants.Other federal air rules such as the Boiler MACT (MaximumAchievable Control Technology) have also been vacatedand the timeframe for re-establishing such rules is unclear.The Boiler MACT rules controlled emissions by requiringfacilities to install the best control technology for eachindustry that uses boilers. Because the Boiler MACT wasvacated, a large number of potential sources of mercury areleft unregulated, the largest in Region 10 being Ash Grove,P4 and Potlatch. EPA is also considering the developmentof a MACT for the cement industry which will addressmercury emissions from existing facilities.Mercury Strategy Framework - Page 10

EPA Region 10Mercury Strategy FrameworkThe lack of federal rules addressing mercury emissions fromatmospheric sources is unfortunate, but it is also unclearwhether the previous rules would have fully addressed theimpact that atmospheric sources have on surface waters.Despite the lack of federal rules, the Oregon Department ofEnvironmental Quality has worked with Ash Grove and anadvisory committee comprising industry, local residents,academia, and scientists to craft a “mutual agreement andorder” to reduce mercury emissions from the cement plant.Ash Grove agreed to install controls and committed toreducing emissions by 85 percent, including provisions formonetary penalties for noncompliance.Since there are a number of other unregulated facilities withsignificant emissions which do not have control agreements,it is clear that alternative approaches are needed to begincontrolling these sources.EPA role:• Work with states, tribes, and individual companiesto develop voluntary agreements to reduce mercuryemissions by taking advantage of the various P2,and waste partnerships, such as ResourceConservation Challenge and the NationalPartnership for Environmental Priorities (NPEP)Program.• Assist states and local agencies by giving guidanceon developing case-by-case MACT for boilers• Support States as they respond to the effects of theCAMR vacature. Region 10 States were at variousstages of implementing CAMR; the eventualoutcome of the vacature and subsequent appealcould affect their rules. Permitting of new coalfiredelectric utility steam generating units will alsobe impacted.• Assist states and tribes in evaluating mercurydeposition from known atmospheric sourcesutilizing EPA’s REMSAD model as described inActivity 3 on page 7.Mercury Strategy Framework - Page 11

EPA Region 107. Implement a Tribal Outreach StrategyWith few exceptions, consumption of contaminated fish isthe single greatest source of human exposure to mercury.Northwest tribes are recognized as having high fishconsumption rates, and as a result are a potential highlyexposed population.All Region 10 states and some tribes (Shoshone-Bannock,Duck Valley) have issued fish advisories. However, manytribes have not issued advisories. We know of no instanceof a comprehensive outreach strategy to tribal residents andothers who fish for subsistence purposes. In addition, webelieve that these advisories may not be a very efficientmeans to educate tribes as to the potential for mercuryexposure from the fish they eat. EPA has a Tribal trustMercury Strategy Frameworkresponsibility, as well as a responsibility to ensure thepublic is well informed as to the health risks associated withconsumption of mercury-contaminated fish.Some Northwest tribes reside in and/or have treaty-reservedrights in areas close to major mercury emitters or mercurydeposition areas. For these reasons, Region 10 initiateddetailed briefings for the Duck Valley and Shoshone-Bannock Tribes in Idaho. EPA was concerned thatparticularly sensitive subpopulations (women, children,infants) could be exposed without adequate information onthe risks of fish consumption.This activity will develop a more comprehensive outreachstrategy for affected Region 10 tribes.EPA role:EPA will be the catalyst to bring together affected tribesfrom Region 10 to develop a comprehensive outreachstrategy regarding mercury contamination and healtheffects associated with mercury–contaminated fishconsumption. For example, the strategy could involvethree major tasks, as follows:1. Develop generic outreach materials on mercury andfish consumption. The materials will be madeavailable for distribution within impactedreservations, tribal lands, and treaty-reserved rightsareas. These outreach materials will be developedjointly by a tribal/EPA team. They will be sharedwith individual tribes as part of the consultationeffort.2. Invite the governing councils of each affected tribeto meet, consult and discuss the issue and theregional strategy.3. Develop and implement an outreach strategy witheach tribal government that is specific for theirtribe. For example, generic outreach materialscould be “personalized” with the tribal logo andEPA logo. The detailed strategies would outline thetypes of outreach to be conducted, and thedevelopment of reservation-specific materials tosupport the outreach.Should a situation arise where a Tribe elects not to workcooperatively with EPA in providing outreach to thepublic, EPA will then consider whether the issue isserious enough to conduct the outreach without thetribe’s involvement. In this case, EPA will continue toinform the tribe of its activities.Mercury Strategy Framework - Page 12

EPA Region 108. Establish a Technical Exchange ForumMuch work related to mercury is underway by manyparties and there is always a lag time before informationgets disseminated. This technical information ranges fromrecent research results to practical application of newmonitoring techniques.A forum to discuss and disseminate technical information onmercury will help to more effectively coordinate,collaborate, and communicate among West Coast federalpartners, states, and tribes.Mercury Strategy FrameworkEPA role:EPA will act as a coordinator or convener of (monthlyor bi-monthly) calls. We may also explore thepossibility of reviving this in partnership with USGSand other western EPA Regions (the previousroundtable was national in scope and lacked a WestCoast focus). We may also explore the option ofexchanging information online via a ListServerinstead of, or in addition to, regular conference calls.Although states currently participate in the QuicksilverCaucus, the Caucus is just for states and tends to have apolicy focus. Idaho participates in the Great Basin mercuryworkgroup, but the other three states and most of the tribesdo not have similar opportunities.A Mercury Roundtable was once coordinated by USGS andEPA, and may be resurrected as a workable model.Participants said that it was well organized, focused, andextremely useful. Presentations were sent out in advanceand calls focused on technical topics such as results fromnew work and plans for upcoming work. Policy aspectswere limited to interactions among media and implicationsfor cross-program communication.A forum is needed for West Coast-specific technical aspectsof the mercury problem, which can be very different fromEast Coast issues. For example, we have less data, overseastrans-Pacific transport issues, mountains that influencetransport, different ecosystems, and the fact that methylationmay play a more important role here.Mercury Strategy Framework - Page 13