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February 16, 2010
By Electronic Mail and Submission to www.regulations.gov
U.S. Environmental Protection Agency
Air and Radiation Docket and Information Center
Mail Code 2822T
1200 Pennsylvania Ave., NW
Washington, DC 20460
Attn: Docket ID No. EPA-HQ-OAR-2006-0735
E-mail: a-and-r-Docket@epa.gov
Re: EPA-HQ-OAR-2006-0735
Comments on EPA's Proposed Rule Concerning Revisions to Lead Ambient Air Monitoring Requirements (“Proposed Rule”), 74 Fed. Reg. 69,050 (to be codified at 40 C.F.R. pt. 58)
I submit these comments as a citizen of the State of Missouri, the number one lead mining state in the nation and home to North America's largest primary lead smelter, several secondary smelters, and a 300-year history of lead production. I support Environmental Protection Agency's proposed rule revisions concerning ambient air monitoring requirements for the toxic metal lead because it will help ensure that all communities that face the risk of unhealthy levels of airborne lead pollution are adequately protected. The Clean Air Act requires the EPA to set National Ambient Air Quality Standards (NAAQS) at levels that protect public health with an adequate margin of safety (CAA § 109(b)(1)). Sufficient monitoring for compliance with the NAAQS is essential to achieve the goal of protecting sensitive subpopulations, like children and pregnant women, with an adequate margin of safety.
I support EPA's proposed 0.5 tons per year threshold for monitoring. In its final rule on the lead NAAQS, EPA determined that an ambient standard of 0.15 µg/m3 of lead is required to protect public health with an adequate margin of safety. Only through adequate monitoring to identify areas of noncompliance and actions to ensure compliance will the NAAQS serve its intended purpose of protecting sensitive populations sufficiently. EPA's proposed monitoring threshold of 0.5 tons per year will provide the information necessary to assess compliance with the ambient standard and to identify violations of the standard and is supported by the technical analysis. The one ton per year standard is insufficient to assure adequate protections and is an arbitrary level set more by considerations of convenience than contamination. Due to the elevated levels measured in the air and soils downwind of major lead emitting facilities, it is crucial that these areas be closely monitored so that unsafe levels of lead can be detected and measures taken to reduce the health threat to neighboring communities. There is no safe level of lead exposure for children, and the NAAQS is one of the few health-based standards that can help protect them from this toxin.
Because healthy air is important for all human and environmental health, I further urge EPA to attach specific conditions to the issuance of waivers of the source-oriented monitoring requirements for lead and to provide more guidance to states concerning the kinds of sources that are expected to contribute to exceedances of the lead air standard. The conditions for obtaining waivers should be sufficiently strict to limit their use and states should be advised how to conduct an adequate monitoring program so that their states demonstrably meet the standards for healthy air. For example, site-specific data rather than generic, unreliable emissions estimates should be used to evaluate the impact of a source's emissions on ambient air lead concentrations.
I support expansion of the lead monitoring network because the existing monitoring network for lead is insufficient. Few of the current sources emitting more than one ton of lead per year have adequate downwind monitoring. The expansion of the lead monitoring network contained in the proposed rule will provide crucial data on the concentration of lead in ambient air so as to protect vulnerable populations. Monitoring downwind of facilities that emit between 0.5 and 1 tons per year of lead is necessary to provide sufficient information about airborne lead levels near these facilities in order to adequately enforce the NAAQS and to protect health with an adequate margin of safety. The addition of 161 additional source-oriented monitors, for a total of 272, will significantly expand public health protections for communities near large industrial sources. Otherwise, those downwind communities will not receive NAAQS protections.
EPA's proposal to rely on the NCore network for non-source-oriented lead NAAQS monitoring should be supplemented with additional monitors sited specifically to measure ambient lead levels in urban areas. Because the NCore monitoring locations are not chosen on the basis of potential lead exposure, the network is unlikely to adequately characterize historic lead contamination that can be resuspended in urban areas.
Thank you for the opportunity to comment.
Yours truly,
[name, address]
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